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pdfUNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
North American Electric Reliability
Corporation
)
Docket No. _________
)
PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF PROPOSED RELIABILITY STANDARD FAC-008-5 – FACILITY
RATINGS
Lauren A. Perotti
Senior Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
lauren.perotti@nerc.net
Counsel for the North American Electric
Reliability Corporation
February 19, 2021
TABLE OF CONTENTS
NOTICES AND COMMUNICATIONS ............................................................................. 3
BACKGROUND .................................................................................................................. 3
Regulatory Framework .................................................................................................... 3
NERC Reliability Standards Development Procedure .................................................... 4
The Standards Efficiency Review and Order No. 873 ..................................................... 5
Project 2018-03 Standards Efficiency Review Retirements ............................................ 6
JUSTIFCATION FOR APPROVAL ................................................................................... 7
EFFECTIVE DATE ........................................................................................................... 11
CONCLUSION .................................................................................................................. 11
i
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Proposed Reliability Standard FAC-008-5
Clean
Redline to Last Approved (FAC-008-3)
Implementation Plan
Order No. 672 Criteria
Analysis of Violation Risk Factors and Violation Severity Levels
Summary of Development and Complete Record of Development
Standard Drafting Team Roster, Project 2018-03 Standards Efficiency Review
Retirements
ii
UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
North American Electric Reliability
Corporation
)
Docket No. ________
)
PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF PROPOSED RELIABILITY STANDARD FAC-008-5 – FACILITY
RATINGS
Pursuant to Section 215(d)(1) of the Federal Power Act (“FPA”)1 and Section 39.52 of the
Federal Energy Regulatory Commission’s (“FERC” or “Commission”) regulations, the North
American Electric Reliability Corporation (“NERC”)3 hereby submits for Commission approval
proposed Reliability Standard FAC-008-5 (Facility Ratings).
Proposed Reliability Standard FAC-008-5 reflects the retirement of Requirement R7 of the
currently effective standard. This proposal was recommended following the first phase of work
under the NERC Standards Efficiency Review. This initiative, which began in 2017, reviewed the
body of NERC Reliability Standards to identify those Reliability Standards and requirements that
were administrative in nature, duplicative to other standards, or provided no benefit to reliability.
As explained more fully herein, currently effective Reliability Standard FAC-008-3 Requirement
R7 is redundant to those in other Reliability Standards and is not needed for reliability. Other
Reliability Standard provisions help ensure that the entities that have the responsibility to plan and
1
16 U.S.C. § 824o.
18 C.F.R. § 39.5.
3
The Commission certified NERC as the electric reliability organization (“ERO”) in accordance with Section
215 of the FPA on July 20, 2006. N. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062 (2006), order on reh’g &
compliance, 117 FERC ¶ 61,126 (2006), aff’d sub nom. Alcoa, Inc. v. FERC, 564 F.3d 1342 (D.C. Cir. 2009).
2
1
operate the Bulk Power System have the data they need for operations and planning. In its Order
No. 873 remanding a previously proposed version of the FAC-008 Reliability Standard, the
Commission agreed that the retirement of Requirement R7 from the standard would not result in a
reliability gap.4
NERC requests that the Commission approve proposed Reliability Standard FAC-008-5,
as shown in Exhibit A, as just, reasonable, not unduly discriminatory or preferential, and in the
public interest. NERC also requests that the Commission approve: (i) the associated Violation Risk
Factors (“VRFs”) and Violation Severity Levels (“VSLs”) (Exhibit D), which are generally
unchanged from the currently effective version of the standard; (ii) the retirement of currently
effective Reliability Standard FAC-008-3; and (iii) the proposed implementation plan (Exhibit B).
As required by Section 39.5(a)5 of the Commission’s regulations, this petition presents the
technical basis and purpose of the proposed Reliability Standard, a demonstration that the proposed
standard meets the criteria identified by the Commission in Order No. 6726 (Exhibit C), and a
summary of the standard development history (Exhibit E). The NERC Board of Trustees adopted
the proposed Reliability Standard on February 4, 2021.
This petition is organized as follows: Section I of the petition provides the individuals to
whom notices and communications related to the filing should be provided. Section II provides
relevant background regarding: (i) the regulatory structure governing the Reliability Standards
approval process; (ii) the Standards Efficiency Review and the Commission’s Order No. 873
4
Electric Reliability Organization Proposal to Retire Requirements in Reliability Standards under the NERC
Standards Efficiency Review, Order No. 873, 172 FERC ¶ 61,225 at P 38 (2020) [hereinafter Order No. 873].
5
18 C.F.R. § 39.5(a).
6
The Commission specified in Order No. 672 certain general factors it would consider when assessing whether
a particular Reliability Standard is just and reasonable. Rules Concerning Certification of the Electric Reliability
Organization; and Procedures for the Establishment, Approval, and Enforcement of Electric Reliability Standards,
Order No. 672, 114 FERC ¶ 61,104, at P 262, 321-37 (“Order No. 672”), order on reh’g, Order No. 672-A, 114 FERC
¶ 61,328 (2006).
2
regarding previous NERC proposals originating from this initiative; and (iii) information on the
development of proposed Reliability Standard FAC-008-5. Section III of the petition provides an
overview and justification for proposed Reliability Standard FAC-008-5. Section IV of the petition
provides a summary of the proposed implementation plan.
NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the following:
Lauren A. Perotti
Senior Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
lauren.perotti@nerc.net
Howard Gugel
Vice President and Director of Engineering and Standards
North American Electric Reliability Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
(404) 446-2560
(404) 446-2595 – facsimile
howard.gugel@nerc.net
BACKGROUND
Regulatory Framework
By enacting the Energy Policy Act of 2005,7 Congress entrusted the Commission with the
duties of approving and enforcing rules to ensure the reliability of the Bulk-Power System
(“BPS”), and with the duties of certifying an ERO that would be charged with developing and
enforcing mandatory Reliability Standards, subject to Commission approval. Section 215(b)(1)8
of the FPA states that all users, owners, and operators of the BPS in the United States will be
subject to Commission-approved Reliability Standards. Section 215(d)(5)9 of the FPA authorizes
the Commission to order the ERO to submit a new or modified Reliability Standard. Section
7
8
9
16 U.S.C. § 824o.
Id. § 824o(b)(1).
Id. § 824o(d)(5).
3
39.5(a)10 of the Commission’s regulations requires the ERO to file with the Commission for its
approval each new Reliability Standard that the ERO proposes should become mandatory and
enforceable in the United States, and each modification to a Reliability Standard that the ERO
proposes should be made effective.
The Commission is vested with the regulatory responsibility to approve Reliability
Standards that protect the reliability of the BPS and to ensure that Reliability Standards are just,
reasonable, not unduly discriminatory or preferential, and in the public interest. Pursuant to
Section 215(d)(2) of the FPA11 and Section 39.5(c)12 of the Commission’s regulations, the
Commission will give due weight to the technical expertise of the ERO with respect to the content
of a Reliability Standard.
NERC Reliability Standards Development Procedure
Proposed Reliability Standard FAC-008-5 was developed in an open and fair manner and
in accordance with the Commission-approved Reliability Standard development process. NERC
develops Reliability Standards in accordance with Section 300 (Reliability Standards
Development) of its Rules of Procedure and the NERC Standard Processes Manual.13
In its order certifying NERC as the Commission’s ERO, the Commission found that
NERC’s rules provide for reasonable notice and opportunity for public comment, due process,
openness, and a balance of interests in developing Reliability Standards,14 and thus satisfy several
of the Commission’s criteria for approving Reliability Standards.15 The development process is
10
18 C.F.R. § 39.5(a).
16 U.S.C. § 824o(d)(2).
12
18 C.F.R. § 39.5(c)(1).
13
The NERC Rules of Procedure, including Appendix 3A, NERC Standard Processes Manual, are available at
http://www.nerc.com/AboutNERC/Pages/Rules-of-Procedure.aspx.
14
N. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062 at P 250 (2006).
15
Order No. 672 at PP 268, 270.
11
4
open to any person or entity with a legitimate interest in the reliability of the BPS. NERC considers
the comments of all stakeholders. Stakeholders must approve, and the NERC Board of Trustees
must adopt, a new or revised Reliability Standard before NERC submits the Reliability Standard
to the Commission for approval.
The Standards Efficiency Review and Order No. 873
After a decade of developing and implementing mandatory Reliability Standards in the
United States, NERC launched the Standards Efficiency Review in 2017. This comprehensive,
multi-year review project comprised a key element of NERC’s plan to achieve its long-term
strategic goal of establishing risk-based controls to minimize BPS reliability risk while also driving
operational efficiencies and effectiveness.16
For the first phase of work, review teams consisting of industry experts in Real-time
operations, long-term planning, and operations planning performed a comprehensive review of the
operations and planning Reliability Standards. The purpose of this review was to identify
Reliability Standard requirements that provide little or no benefit to reliability and should be
retired. NERC then initiated the standard development process to consider the retirement
recommendations resulting from the phase one work.
In June 2019, following the conclusion of the standard development process, NERC
submitted a series of standard retirement proposals to the Commission.17 Among the proposals,
16
See ERO Enterprise Long-Term Strategy (Dec. 2019), available on NERC’s website at
https://www.nerc.com/AboutNERC/Pages/Strategic-Documents.aspx.
17
See Petition of NERC for Approval of Revised and Retired Reliability Standards under the NERC Standards
Efficiency Review, Docket No. RM19-17-000 (June 7, 2019) (proposals relating to retirements in the FAC, INT, MOD,
and PRC Reliability Standards families) and Petition of NERC for Approval of Reliability Standards IRO-002-7, TOP001-5, and VAR-001-6, Docket No. RM19-16-000 (June 7, 2019). NERC subsequently withdrew its VAR-001-6
proposal. See Notice of Withdrawal of NERC for Proposed Reliability Standard VAR-001-6, Docket No. RM19-16000 (May 14, 2020).
5
NERC submitted for Commission approval proposed Reliability Standard FAC-008-4, in which
NERC proposed to retire Requirements R7 and R8 of currently effective Reliability Standard FAC008-3.
In September 2020, the Commission issued Order No. 873 regarding NERC’s retirement
proposals.18 In this order, the Commission remanded proposed Reliability Standard FAC-008-4 to
NERC for further consideration, citing concerns with the proposed retirement of Requirement R8
of the currently effective standard.19 The Commission approved: (i) the retirement of four
Reliability Standards in their entirety (FAC-013-2, INT-004-3.1, INT-010.2.1, and MOD-020-0);
and (ii) five modified Reliability Standards in which individual requirements were proposed for
retirement (INT-006-5, INT-009-3, PRC-004-6, IRO-002-7, and TOP-001-5).20 The Commission
declined to take action on NERC’s proposal regarding the MOD A Reliability Standards, pending
further action in a separate proceeding involving the successor North American Energy Standards
Board (“NAESB”) business practice standards.21
Project 2018-03 Standards Efficiency Review Retirements
Following the issuance of Order No. 873, NERC recalled the Project 2018-03 Standards
Efficiency Review Retirements drafting team (roster included as Exhibit F) to consider further
steps regarding the remanded FAC-008 Reliability Standard. The standard drafting team
determined to develop a new version of the Reliability Standard, proposed Reliability Standard
18
See Order No. 873 at PP 1-5 (summary).
Id. at PP 37-40.
20
Id. at P 26.
21
Id. at P 4. The MOD A Reliability Standards proposed for retirement were: MOD-001-1a (Available
Transmission System Capability), MOD-004-1 (Capacity Benefit Margin), MOD-008-1 (Transmission Reliability
Margin Calculation Methodology), MOD-028-2 (Area Interchange Methodology), MOD-029-2a (Rated System Path
Methodology), and MOD-030-3 (Flowgate Methodology).
19
6
FAC-008-5, in which only Requirement R7 of the currently effective standard would be proposed
for retirement.
The proposed standard was posted for formal comment and ballot from November 30, 2020
through January 13, 2021, and for final ballot from January 19, 2021 through January 28, 2021.
The proposed standard achieved 95.96% approval with 91.04% quorum. The NERC Board of
Trustees adopted the proposed standard on February 4, 2020. A summary of the development
history and the complete record of development is attached to this petition as Exhibit E.
JUSTIFCATION FOR APPROVAL
In this petition, NERC submits for Commission approval proposed Reliability Standard
FAC-008-5 – Facility Ratings, in which Requirement R7 of the currently effective standard is
proposed for retirement. As discussed below, Requirement R7 is not necessary for reliability. As
shown in the redline included in Exhibit A, NERC has struck the requirement in its entirety and
replaced the text with the word “Reserved.” Corresponding revisions have also been made to the
VRFs, VSLs, and measures.
The proposed Reliability Standard continues to meet the Commission’s criteria for
approval in Order No. 672 and is just, reasonable, not unduly discriminatory, and in the public
interest. NERC respectfully requests that the Commission approve the proposed Reliability
Standard, to become effective in accordance with the proposed implementation plan discussed in
Section IV.
Currently Effective Reliability Standard FAC-008-3
Reliability Standard FAC-008-3 – Facility Ratings was approved by the Commission in
2011.22 The standard was developed in response to Commission directives from Order No. 693 to
22
Order Approving Reliability Standard, 137 FERC ¶ 61,123 (2011).
7
modify the FAC-008 standard to require entities to: (i) document underlying assumptions and
methods used to determine normal and emergency facility ratings; (ii) develop facility ratings
consistent with industry standards developed through an open, transparent, and validated process;
and (iii) for each facility, identify the limiting component and, for critical facilities, the resulting
increase in rating if that component is no longer limiting.23 In 2013, the Commission approved the
retirement of Requirements R4 and R5 following NERC’s “paragraph 81” initiative.24
In 2019, NERC proposed Reliability Standard FAC-008-4, in which NERC proposed to
retire Requirements R7 and R8 of the standard. As previously noted, the Commission remanded
proposed Reliability Standard FAC-008-4 in Order No. 873 due to concerns with the proposed
retirement of Requirement R8.
Justification for Approval for Proposed Reliability Standard FAC-008-5
The purpose of proposed Reliability Standard FAC-008-5, which remains unchanged from
the currently effective version of the standard, is to “to ensure that Facility Ratings used in the
reliable planning and operation of the Bulk Electric System (BES) are determined based on
technically sound principles. A Facility Rating is essential for the determination of System
Operating Limits.”
In proposed Reliability Standard FAC-008-5 NERC proposes to retire Requirement R7 of
the currently effective standard because this requirement is redundant to those in other Reliability
Standards and is therefore not needed for reliability.
Reliability Standard FAC-008-3 Requirement R7 requires Generator Owners and
23
Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, 118 FERC ¶ 61,218 at PP 739,
742, 756 (2007).
24
Electric Reliability Organization Proposal to Retire Requirements in Reliability Standards, Order No. 788,
145 FERC ¶ 61,147 at P 17 (2013). In proposed Reliability Standard FAC-008-5, NERC has struck the text of these
requirements and replaced them with the word “Reserved.”
8
Transmission Owners to provide certain information to requesting Reliability Coordinator(s),
Planning Coordinator(s), Transmission Planner(s), Transmission Owner(s), and Transmission
Operator(s) regarding their Facilities, as follows:
R7.
Each Generator Owner shall provide Facility Ratings (for its solely
and jointly owned Facilities that are existing Facilities, new
Facilities, modifications to existing Facilities and re-ratings of
existing Facilities) to its associated Reliability Coordinator(s),
Planning Coordinator(s), Transmission Planner(s), Transmission
Owner(s) and Transmission Operator(s) as scheduled by such
requesting entities.
In the years since Reliability Standard FAC-008-3 was developed, NERC has developed
other Reliability Standards that render the data provision obligations of Requirement R7
redundant. Specifically, Reliability Standards MOD-032-1, IRO-010-2, and TOP-003-3 contain
provisions to help ensure that the entities that have the responsibility to plan and operate the Bulk
Power System have the data they need from Generator Owners and Transmission Owners for
operations and planning.
Requirement R1 of Reliability Standard MOD-032-1 – Data for Power System Modeling
and Analysis requires the Planning Coordinator and Transmission Planner to develop modeling
data requirements and reporting procedures including the data listed in Attachment 1 to the
standard. This data would include information on power capabilities and Facility Ratings.25
Requirement R2 requires the Generator Owner and Transmission Owner to provide the requested
information.
Requirement R1 of Reliability Standard IRO-010-2 – Reliability Coordinator Data
Specification and Collection requires the Reliability Coordinator to maintain a documented
specification for the data necessary to perform its Operational Planning Analyses, Real-time
25
See Reliability Standard MOD-032-1 Attachment 1, steady-state column, Items 3, 3(f), 4(c) and 6(g).
9
monitoring, and Real-time Assessments. This data necessarily includes Facility Ratings as inputs
to System Operating Limit monitoring. Requirement R3 requires the Transmission Owner and
Generator Owner to provide requested data. Similarly, Requirement R1 of Reliability Standard
TOP-003-3 – Operational Reliability Data requires the Transmission Operator to maintain a
documented data specification (Requirement R1) and for the Transmission Owner and Generator
Owner to provide the requested data (Requirement R5).
While the provision of Facility Ratings data to Transmission Owners is not specified by
these standards listed above, such provision is not necessary as Transmission Owners have a more
limited role that does not involve the planning and operation of the Bulk Power System. In Order
No. 873, the Commission noted the previous history of the requirement, which did not include
Transmission Owners as receiving entities, and stated:
Regarding Reliability Standard FAC-008-3, Requirement R7, we
are persuaded that retiring Requirement R7 will not result in a
reliability gap because Requirement R7 is redundant or otherwise
provides little or no reliability benefit. We agree with NERC that,
unlike transmission operators and transmission planners that need
and will continue to receive facility ratings information under other
Reliability Standards, transmission owners do not need to exchange
facility ratings because they have a more limited functional role that
does not involve planning and operating the Bulk-Power System.26
As Reliability Standard FAC-008-3 Requirement R7 is now redundant to other more robust
Reliability Standards and is no longer needed for reliability, NERC proposes to retire this
requirement in proposed Reliability Standard FAC-008-5. The retirement of this Requirement
would not have an adverse impact on reliability and is in the public interest.
26
Order No. 873 at P 38.
10
EFFECTIVE DATE
NERC respectfully requests that the Commission approve the implementation plan
attached to this petition as Exhibit B. The proposed implementation plan provides that proposed
Reliability Standard FAC-008-5 would become effective on the first day of the first calendar
quarter that is three months after applicable regulatory approval. The currently effective version
of the standard would be retired immediately prior to the effective date of the revised Reliability
Standard. This implementation timeline reflects consideration that entities may need time to update
their internal systems and documentation to reflect the new Reliability Standard version number.
CONCLUSION
For the reasons set forth above, NERC respectfully requests that the Commission approve:
•
Proposed Reliability Standard FAC-008-5 (Facility Ratings) and the associated
elements, as shown in Exhibit A;
•
the retirement of currently effective Reliability Standard FAC-008-3; and
•
The implementation plan included in Exhibit B.
Respectfully submitted,
/s/ Lauren A. Perotti
Lauren A. Perotti
Senior Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
lauren.perotti@nerc.net
Counsel for the North American Electric
Reliability Corporation
February 19, 2021
11
Exhibit A-1
Proposed Reliability Standard FAC-008-5
Clean
RELIABILITY | RESILIENCE | SECURITY
FAC-008-5 – Facility Ratings
A. Introduction
1.
Title:
Facility Ratings
2.
Number:
FAC-008-5
3.
Purpose:
To ensure that Facility Ratings used in the reliable planning and
operation of the Bulk Electric System (BES) are determined based
on technically sound principles. A Facility Rating is essential for the
determination of System Operating Limits.
4.
Applicability:
4.1. Transmission Owner
4.2. Generator Owner
5.
Effective Date:
See Implementation Plan.
Page 1 of 13
FAC-008-5 – Facility Ratings
B. Requirements and Measures
R1. Each Generator Owner shall have documentation for determining the Facility Ratings
of its solely and jointly owned generator Facility(ies) up to the low side terminals of
the main step up transformer if the Generator Owner does not own the main step up
transformer and the high side terminals of the main step up transformer if the
Generator Owner owns the main step up transformer. [Violation Risk Factor: Lower]
[Time Horizon: Long-term Planning]
1.1. The documentation shall contain assumptions used to rate the generator and at
least one of the following:
x
Design or construction information such as design criteria, ratings provided
by equipment manufacturers, equipment drawings and/or specifications,
engineering analyses, method(s) consistent with industry standards (e.g.
ANSI and IEEE), or an established engineering practice that has been verified
by testing or engineering analysis.
x
Operational information such as commissioning test results, performance
testing or historical performance records, any of which may be
supplemented by engineering analyses.
1.2. The documentation shall be consistent with the principle that the Facility Ratings
do not exceed the most limiting applicable Equipment Rating of the individual
equipment that comprises that Facility.
M1. Each Generator Owner shall have documentation that shows how its Facility Ratings
were determined as identified in Requirement 1.
R2. Each Generator Owner shall have a documented methodology for determining Facility
Ratings (Facility Ratings methodology) of its solely and jointly owned equipment
connected between the location specified in R1 and the point of interconnection with
the Transmission Owner that contains all of the following. [Violation Risk Factor:
Medium] [Time Horizon: Long-term Planning]
2.1. The methodology used to establish the Ratings of the equipment that comprises
the Facility(ies) shall be consistent with at least one of the following:
x
Ratings provided by equipment manufacturers or obtained from equipment
manufacturer specifications such as nameplate rating.
x
One or more industry standards developed through an open process such as
Institute of Electrical and Electronic Engineers (IEEE) or International Council
on Large Electric Systems (CIGRE).
x
A practice that has been verified by testing, performance history or
engineering analysis.
Page 2 of 13
FAC-008-5 – Facility Ratings
2.2. The underlying assumptions, design criteria, and methods used to determine the
Equipment Ratings identified in Requirement R2, Part 2.1 including identification
of how each of the following were considered:
2.2.1. Equipment Rating standard(s) used in development of this methodology.
2.2.2. Ratings provided by equipment manufacturers or obtained from
equipment manufacturer specifications.
2.2.3. Ambient conditions (for particular or average conditions or as they vary
in real-time).
2.2.4. Operating limitations. 1
2.3. A statement that a Facility Rating shall respect the most limiting applicable
Equipment Rating of the individual equipment that comprises that Facility.
2.4. The process by which the Rating of equipment that comprises a Facility is
determined.
2.4.1. The scope of equipment addressed shall include, but not be limited to,
conductors, transformers, relay protective devices, terminal equipment,
and series and shunt compensation devices.
2.4.2. The scope of Ratings addressed shall include, as a minimum, both Normal
and Emergency Ratings.
M2. Each Generator Owner shall have a documented Facility Ratings methodology that
includes all of the items identified in Requirement 2, Parts 2.1 through 2.4.
R3. Each Transmission Owner shall have a documented methodology for determining
Facility Ratings (Facility Ratings methodology) of its solely and jointly owned Facilities
(except for those generating unit Facilities addressed in R1 and R2) that contains all of
the following: [Violation Risk Factor: Medium] [ Time Horizon: Long-term Planning]
3.1. The methodology used to establish the Ratings of the equipment that comprises
the Facility shall be consistent with at least one of the following:
1
x
Ratings provided by equipment manufacturers or obtained from equipment
manufacturer specifications such as nameplate rating.
x
One or more industry standards developed through an open process such as
Institute of Electrical and Electronics Engineers (IEEE) or International Council
on Large Electric Systems (CIGRE).
x
A practice that has been verified by testing, performance history or
engineering analysis.
Such as temporary de-ratings of impaired equipment in accordance with good utility practice.
Page 3 of 13
FAC-008-5 – Facility Ratings
3.2. The underlying assumptions, design criteria, and methods used to determine the
Equipment Ratings identified in Requirement R3, Part 3.1 including identification
of how each of the following were considered:
3.2.1. Equipment Rating standard(s) used in development of this methodology.
3.2.2. Ratings provided by equipment manufacturers or obtained from
equipment manufacturer specifications.
3.2.3. Ambient conditions (for particular or average conditions or as they vary
in real-time).
3.2.4. Operating limitations. 2
3.3. A statement that a Facility Rating shall respect the most limiting applicable
Equipment Rating of the individual equipment that comprises that Facility.
3.4. The process by which the Rating of equipment that comprises a Facility is
determined.
3.4.1. The scope of equipment addressed shall include, but not be limited to,
transmission conductors, transformers, relay protective devices, terminal
equipment, and series and shunt compensation devices.
3.4.2. The scope of Ratings addressed shall include, as a minimum, both Normal
and Emergency Ratings.
M3. Each Transmission Owner shall have a documented Facility Ratings methodology that
includes all of the items identified in Requirement 3, Parts 3.1 through 3.4.
R4. Reserved.
M4. Reserved.
R5. Reserved.
M5. Reserved.
R6. Each Transmission Owner and Generator Owner shall have Facility Ratings for its
solely and jointly owned Facilities that are consistent with the associated Facility
Ratings methodology or documentation for determining its Facility Ratings. [Violation
Risk Factor: Medium] [Time Horizon: Operations Planning]
M6. Each Transmission Owner and Generator Owner shall have evidence to show that its
Facility Ratings are consistent with the documentation for determining its Facility
Ratings as specified in Requirement R1 or consistent with its Facility Ratings
methodology as specified in Requirements R2 and R3 (Requirement R6).
R7. Reserved.
M7. Reserved.
2
Such as temporary de-ratings of impaired equipment in accordance with good utility practice.
Page 4 of 13
FAC-008-5 – Facility Ratings
R8.
Each Transmission Owner (and each Generator Owner subject to Requirement R2)
shall provide requested information as specified below (for its solely and jointly
owned Facilities that are existing Facilities, new Facilities, modifications to existing
Facilities and re-ratings of existing Facilities) to its associated Reliability
Coordinator(s), Planning Coordinator(s), Transmission Planner(s), Transmission
Owner(s) and Transmission Operator(s): [Violation Risk Factor: Medium] [Time
Horizon: Operations Planning]
8.1.
As scheduled by the requesting entities:
8.2.
8.1.1.
Facility Ratings
8.1.2.
Identity of the most limiting equipment of the Facilities
Within 30 calendar days (or a later date if specified by the requester), for any
requested Facility with a Thermal Rating that limits the use of Facilities under
the requester’s authority by causing any of the following: 1) An
Interconnection Reliability Operating Limit, 2) A limitation of Total Transfer
Capability, 3) An impediment to generator deliverability, or 4) An impediment
to service to a major load center:
8.2.1.
Identity of the existing next most limiting equipment of the Facility
8.2.2.
The Thermal Rating for the next most limiting equipment identified
in Requirement R8, Part 8.2.1.
M8. Each Transmission Owner (and Generator Owner subject to Requirement R2) shall
have evidence, such as a copy of a dated electronic note, or other comparable
evidence to show that it provided its Facility Ratings and identity of limiting equipment
to its associated Reliability Coordinator(s), Planning Coordinator(s), Transmission
Planner(s), Transmission Owner(s) and Transmission Operator(s) in accordance with
Requirement R8.
C. Compliance
1.
Compliance Monitoring Process
1.1. Compliance Enforcement Authority: “Compliance Enforcement Authority”
means NERC or the Regional Entity, or any entity as otherwise designated by an
Applicable Governmental Authority, in their respective roles of monitoring
and/or enforcing compliance with mandatory and enforceable Reliability
Standards in their respective jurisdictions.
1.2. Compliance Monitoring and Enforcement Processes:
x
Self-Certifications
x
Spot Checking
x
Compliance Audits
x
Self-Reporting
Page 5 of 13
FAC-008-5 – Facility Ratings
x
Compliance Violation Investigations
x
Complaints
1.3. Evidence Retention: The following evidence retention period(s) identify the
period of time an entity is required to retain specific evidence to demonstrate
compliance. For instances where the evidence retention period specified below
is shorter than the time since the last audit, the Compliance Enforcement
Authority may ask an entity to provide other evidence to show that it was
compliant for the full-time period since the last audit.
The applicable entity shall keep data or evidence to show compliance as
identified below unless directed by its Compliance Enforcement Authority to
retain specific evidence for a longer period of time as part of an investigation.
x
The Generator Owner shall keep its current documentation (for R1) and any
modifications to the documentation that were in force since last compliance
audit period for Measure M1 and Measure M6.
x
The Generator Owner shall keep its current, in force Facility Ratings
methodology (for R2) and any modifications to the methodology that were in
force since last compliance audit period for Measure M2 and Measure M6.
x
The Transmission Owner shall keep its current, in force Facility Ratings
methodology (for R3) and any modifications to the methodology that were in
force since the last compliance audit for Measure M3 and Measure M6.
x
The Transmission Owner and Generator Owner shall keep its current, in force
Facility Ratings and any changes to those ratings for three calendar years for
Measure M6.
x
The Transmission Owner (and Generator Owner that is subject to
Requirement R2) shall keep evidence for Measure M8 for three calendar
years.
x
If a Generator Owner or Transmission Owner is found non-compliant, it shall
keep information related to the non-compliance until found compliant.
x
The Compliance Enforcement Authority shall keep the last audit and all
subsequent compliance records.
1.4. Compliance Monitoring and Enforcement Program: As defined in the NERC
Rules of Procedure, “Compliance Monitoring and Enforcement Program” refers
to the identification of the processes that will be used to evaluate data or
information for the purpose of assessing performance or outcomes with the
associated Reliability Standard.
Page 6 of 13
2.1.
2.2.1
2.2.2
2.2.3
2.2.4
x
x
x
x
The Generator Owner
failed to include in its
Facility Rating
methodology one of the
following Parts of
Requirement R2:
R2.
x
N/A
Lower VSL
R1.
R#
Violation Severity Levels
FAC-008-5 – Facility Ratings
x
x
x
2.2.4
2.2.3
2.2.2
2.2.1
2.1.
2.2.1
2.2.2
2.2.3
2.2.4
x
x
x
x
x
The Generator Owner failed
to include in its Facility
Rating Methodology, three
of the following Parts of
Requirement R2:
OR
x
x
The Generator Owner’s
Facility Rating methodology
did not address all the
components of
Requirement R2, Part 2.4.
The Generator Owner failed
to include in its Facility
Rating methodology two of
the following Parts of
Requirement R2:
2.1
The Generator Owner’s
Facility Rating
documentation did not
address Requirement R1,
Part 1.2.
High VSL
The Generator Owner’s
Facility Rating
documentation did not
address Requirement R1,
Part 1.1.
Moderate VSL
Violation Severity Levels
2.1
2.2.1
2.2.2
2.2.3
2.2.4
x
x
x
x
x
Page 7 of 13
The Generator Owner failed to
include in its Facility Rating
Methodology four or more of
the following Parts of
Requirement R2:
OR
The Generator Owner’s Facility
Rating methodology failed to
recognize a facility's rating
based on the most limiting
component rating as required
in Requirement R2, Part 2.3
The Generator Owner failed to
provide documentation for
determining its Facility Ratings.
Severe VSL
R5.
Reserved.
R4.
Reserved.
R3.
R#
3.1
3.2.1
3.2.2
3.2.3
3.2.4
x
x
x
x
x
The Transmission Owner
failed to include in its
Facility Rating
methodology one of the
following Parts of
Requirement R3:
Lower VSL
FAC-008-5 – Facility Ratings
x
x
x
x
3.2.4
3.2.3
3.2.2
3.2.1
3.4.2
3.1
3.2.1
3.2.2
3.2.3
3.2.4
x
x
x
x
x
The Transmission Owner
failed to include in its
Facility Rating methodology
three of the following Parts
of Requirement R3:
OR
x
3.4.1
x
x
3.1
The Transmission Owner’s
Facility Rating methodology
did not address either of
the following Parts of
Requirement R3:
High VSL
The Transmission Owner
failed to include in its
Facility Rating methodology
two of the following Parts
of Requirement R3:
Moderate VSL
Violation Severity Levels
x
x
x
x
x
3.2.4
3.2.3
3.2.2
3.2.1
3.1
Page 8 of 13
The Transmission Owner failed
to include in its Facility Rating
methodology four or more of
the following Parts of
Requirement R3:
OR
The Transmission Owner’s
Facility Rating methodology
failed to recognize a Facility's
rating based on the most
limiting component rating as
required in Requirement R3,
Part 3.3
Severe VSL
R8.
R7.
Reserved.
R6.
R#
The responsible entity
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
15 calendar days but less
than or equal to 25
calendar days. (R8, Part 8.1)
OR
The responsible entity
provided less than 95%, but
OR
The responsible entity
provided less than 100%,
The responsible entity
failed to establish Facility
Ratings consistent with the
associated Facility Ratings
methodology or
documentation for
determining the Facility
Ratings for more than 5% or
more, but less than up to
(and including) 10% of its
solely owned and jointly
owned Facilities. (R6)
Moderate VSL
The responsible entity
provided less than 90%, but
OR
The responsible entity
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
25 calendar days but less
than or equal to 35
calendar days. (R8, Part 8.1)
The responsible entity
failed to establish Facility
Ratings consistent with the
associated Facility Ratings
methodology or
documentation for
determining the Facility
Ratings for more than 10%
up to (and including) 15% of
its solely owned and jointly
owned Facilities. (R6)
High VSL
Violation Severity Levels
The responsible entity
provided its Facility
Ratings to all of the
requesting entities but
missed meeting the
schedules by up to and
including 15 calendar
days. (R8, Part 8.1)
The responsible entity
failed to establish Facility
Ratings consistent with
the associated Facility
Ratings methodology or
documentation for
determining the Facility
Ratings for 5% or less of
its solely owned and
jointly owned Facilities.
(R6)
Lower VSL
FAC-008-5 – Facility Ratings
Page 9 of 13
The responsible entity provided
less than 85% of the required
Rating information to all of the
OR
The responsible entity provided
its Facility Ratings to all of the
requesting entities but missed
meeting the schedules by more
than 35 calendar days. (R8, Part
8.1)
The responsible entity failed to
establish Facility Ratings
consistent with the associated
Facility Ratings methodology or
documentation for determining
the Facility Ratings for more
than15% of its solely owned
and jointly owned Facilities.
(R6)
Severe VSL
The responsible entity provided
less than 85 % of the required
Rating information to the
requesting entity. (R8, Part 8.2)
OR
The responsible entity failed to
provide its Rating information
to the requesting entity. (R8,
Part 8.1)
OR
The responsible entity
provided the required
Rating information to the
requesting entity, but did so
more than 25 calendar days
but less than or equal to 35
calendar days late. (R8, Part
8.2)
OR
The responsible entity
provided less than 90%, but
no less than or equal to
85% of the required Rating
information to the
requesting entity. (R8, Part
8.2)
OR
The responsible entity
provided the required
Rating information to the
requesting entity, but did so
more 15 calendar days but
less than or equal to 25
calendar days late. (R8, Part
8.2)
OR
The responsible entity
provided less than 95%, but
not less than or equal to
90% of the required Rating
information to the
requesting entity. (R8, Part
8.2)
OR
The responsible entity
provided the required
Rating information to the
requesting entity, but the
information was provided
up to and including 15
calendar days late. (R8,
Part 8.2)
OR
The responsible entity
provided less than 100%,
but not less than or equal
to 95% of the required
Rating information to the
requesting entity. (R8,
Part 8.2)
None.
OR
Page 10 of 13
The responsible entity provided
the required Rating information
to the requesting entity, but did
so more than 35 calendar days
late. (R8, Part 8.2)
OR
requesting entities. (R8, Part
8.1)
not less than or equal to
85% of the required Rating
information to all of the
requesting entities. (R8,
Part 8.1)
not less than or equal to
90% of the required Rating
information to all of the
requesting entities. (R8,
Part 8.1)
but not less than or equal
to 95% of the required
Rating information to all
of the requesting entities.
(R8, Part 8.1)
Severe VSL
High VSL
Moderate VSL
Violation Severity Levels
Lower VSL
D. Regional Variances
R#
FAC-008-5 – Facility Ratings
None.
E. Associated Documents
FAC-008-5 – Facility Ratings
Page 11 of 13
FAC-008-5 – Facility Ratings
Version History
Version
Date
Action
Change Tracking
1
Feb 7, 2006
Approved by Board of Trustees
New
1
Mar 16, 2007
Approved by FERC
New
2
May 12, 2010
Approved by Board of Trustees
Complete Revision,
merging FAC_008-1
and FAC-009-1 under
Project 2009-06 and
address directives
from Order 693
3
May 24, 2011
Addition of Requirement R8
Project 2009-06
Expansion to address
third directive from
Order 693
3
May 24, 2011
Adopted by NERC Board of Trustees
3
November 17, FERC Order issued approving FAC-008-3
2011
3
May 17, 2012
FERC Order issued directing the VRF for
Requirement R2 be changed from
“Lower” to “Medium”
3
February 7,
2013
R4 and R5 and associated elements
approved by NERC Board of Trustees for
retirement as part of the Paragraph 81
project (Project 2013-02) pending
applicable regulatory approval.
3
November 21, R4 and R5 and associated elements
2013
approved by FERC for retirement as
part of the Paragraph 81 project
(Project 2013-02)
4
May 9, 2020
R7 and R8 and associated elements
adopted by NERC Board of Trustees for
retirement as part of Project 2018-03
Standards Efficiency Review
Retirements.
4
September
17, 2020
Remanded by FERC (Order No. 873).
Withdrawn
5
February 4,
2021
Adopted by NERC Board of Trustees
Requirement R8 and
associated elements
restored in response
Page 12 of 13
FAC-008-5 – Facility Ratings
Version
Date
Action
Change Tracking
to FERC Order No.
873.
Page 13 of 13
Exhibit A-2
Redline to Last Approved (FAC-008-3)
RELIABILITY | RESILIENCE | SECURITY
FAC‐008‐3 5 – Facility Ratings
A. Introduction
1.
Title:
Facility Ratings
2.
Number:
FAC‐008‐35
3.
Purpose:
To ensure that Facility Ratings used in the reliable planning and
operation of the Bulk Electric System (BES) are determined based
on technically sound principles. A Facility Rating is essential for the
determination of System Operating Limits.
4.
Applicability:
4.1. Transmission Owner
4.2. Generator Owner
5.
Effective Date: See Implementation Plan.The first day of the first calendar quarter
that is twelve months beyond the date approved by applicable regulatory authorities,
or in those jurisdictions where regulatory approval is not required, the first day of the
first calendar quarter twelve months following BOT adoptionSee Implementation Plan.
Page 1 of 16
FAC‐008‐3 5 – Facility Ratings
B. Requirements and Measures
R1. Each Generator Owner shall have documentation for determining the Facility Ratings
of its solely and jointly owned generator Facility(ies) up to the low side terminals of
the main step up transformer if the Generator Owner does not own the main step up
transformer and the high side terminals of the main step up transformer if the
Generator Owner owns the main step up transformer. [Violation Risk Factor: Lower]
[Time Horizon: Long‐term Planning]
1.1 The documentation shall contain assumptions used to rate the generator and at
least one of the following:
Design or construction information such as design criteria, ratings provided
by equipment manufacturers, equipment drawings and/or specifications,
engineering analyses, method(s) consistent with industry standards (e.g.
ANSI and IEEE), or an established engineering practice that has been verified
by testing or engineering analysis.
Operational information such as commissioning test results, performance
testing or historical performance records, any of which may be
supplemented by engineering analyses.
1.2 The documentation shall be consistent with the principle that the Facility Ratings
do not exceed the most limiting applicable Equipment Rating of the individual
equipment that comprises that Facility.
M1. Each Generator Owner shall have documentation that shows how its Facility Ratings
were determined as identified in Requirement 1.
R2. Each Generator Owner shall have a documented methodology for determining Facility
Ratings (Facility Ratings methodology) of its solely and jointly owned equipment
connected between the location specified in R1 and the point of interconnection with
the Transmission Owner that contains all of the following. [Violation Risk Factor:
Medium] [Time Horizon: Long‐term Planning]
2.1 The methodology used to establish the Ratings of the equipment that comprises
the Facility(ies) shall be consistent with at least one of the following:
Ratings provided by equipment manufacturers or obtained from equipment
manufacturer specifications such as nameplate rating.
One or more industry standards developed through an open process such as
Institute of Electrical and Electronic Engineers (IEEE) or International Council
on Large Electric Systems (CIGRE).
A practice that has been verified by testing, performance history or
engineering analysis.
Page 2 of 16
FAC‐008‐3 5 – Facility Ratings
2.2
The underlying assumptions, design criteria, and methods used to determine
the Equipment Ratings identified in Requirement R2, Part 2.1 including
identification of how each of the following were considered:
2.2.1 Equipment Rating standard(s) used in development of this
methodology.
2.2.2 Ratings provided by equipment manufacturers or obtained from
equipment manufacturer specifications.
2.2.3 Ambient conditions (for particular or average conditions or as they
vary in real‐time).
2.2.4 Operating limitations.1
2.3
A statement that a Facility Rating shall respect the most limiting applicable
Equipment Rating of the individual equipment that comprises that Facility.
2.4
The process by which the Rating of equipment that comprises a Facility is
determined.
2.4.1 The scope of equipment addressed shall include, but not be limited
to, conductors, transformers, relay protective devices, terminal
equipment, and series and shunt compensation devices.
2.4.2 The scope of Ratings addressed shall include, as a minimum, both
Normal and Emergency Ratings.
M2. Each Generator Owner shall have a documented Facility Ratings methodology that
includes all of the items identified in Requirement 2, Parts 2.1 through 2.4.
R3. Each Transmission Owner shall have a documented methodology for determining
Facility Ratings (Facility Ratings methodology) of its solely and jointly owned Facilities
(except for those generating unit Facilities addressed in R1 and R2) that contains all of
the following: [Violation Risk Factor: Medium] [ Time Horizon: Long‐term Planning]
3.1
1
The methodology used to establish the Ratings of the equipment that
comprises the Facility shall be consistent with at least one of the following:
Ratings provided by equipment manufacturers or obtained from equipment
manufacturer specifications such as nameplate rating.
One or more industry standards developed through an open process such as
Institute of Electrical and Electronics Engineers (IEEE) or International Council
on Large Electric Systems (CIGRE).
A practice that has been verified by testing, performance history or
engineering analysis.
Such as temporary de‐ratings of impaired equipment in accordance with good utility practice.
Page 3 of 16
FAC‐008‐3 5 – Facility Ratings
3.2 The underlying assumptions, design criteria, and methods used to determine the
Equipment Ratings identified in Requirement R3, Part 3.1 including identification
of how each of the following were considered:
3.2.1 Equipment Rating standard(s) used in development of this
methodology.
3.2.2 Ratings provided by equipment manufacturers or obtained from
equipment manufacturer specifications.
3.2.3 Ambient conditions (for particular or average conditions or as they
vary in real‐time).
3.2.4 Operating limitations.2
3.3 A statement that a Facility Rating shall respect the most limiting applicable
Equipment Rating of the individual equipment that comprises that Facility.
3.4 The process by which the Rating of equipment that comprises a Facility is
determined.
3.4.1 The scope of equipment addressed shall include, but not be limited
to, transmission conductors, transformers, relay protective devices,
terminal equipment, and series and shunt compensation devices.
3.4.2 The scope of Ratings addressed shall include, as a minimum, both
Normal and Emergency Ratings.
M3. Each Transmission Owner shall have a documented Facility Ratings methodology that
includes all of the items identified in Requirement 3, Parts 3.1 through 3.4.
R4. Reserved.Each Transmission Owner shall make its Facility Ratings methodology and
each Generator Owner shall each make its documentation for determining its Facility
Ratings and its Facility Ratings methodology available for inspection and technical
review by those Reliability Coordinators, Transmission Operators, Transmission
Planners and Planning Coordinators that have responsibility for the area in which the
associated Facilities are located, within 21 calendar days of receipt of a request.
[Violation Risk Factor: Lower] [Time Horizon: Operations Planning] (Retirement
approved by FERC effective January 21, 2014.)
M4. Reserved. Each Transmission Owner shall have evidence, such as a copy of a dated
electronic note, or other comparable evidence to show that it made its Facility Ratings
methodology available for inspection within 21 calendar days of a request in
accordance with Requirement 4. The Generator Owner shall have evidence, such as a
copy of a dated electronic note, or other comparable evidence to show that it made
its documentation for determining its Facility Ratings or its Facility Ratings
methodology available for inspection within 21 calendar days of a request in
2
Such as temporary de-ratings of impaired equipment in accordance with good utility practice.
Page 4 of 16
FAC‐008‐3 5 – Facility Ratings
accordance with Requirement R4. (Retirement approved by NERC BOT pending
applicable regulatory approval.).
R5. Reserved. If a Reliability Coordinator, Transmission Operator, Transmission Planner or
Planning Coordinator provides documented comments on its technical review of a
Transmission Owner’s Facility Ratings methodology or Generator Owner’s
documentation for determining its Facility Ratings and its Facility Rating methodology,
the Transmission Owner or Generator Owner shall provide a response to that
commenting entity within 45 calendar days of receipt of those comments. The
response shall indicate whether a change will be made to the Facility Ratings
methodology and, if no change will be made to that Facility Ratings methodology, the
reason why. [Violation Risk Factor: Lower] [Time Horizon: Operations Planning]
(Retirement approved by FERC effective January 21, 2014.)
M5. Reserved.If the Reliability Coordinator, Transmission Operator, Transmission Planner
or Planning Coordinator provides documented comments on its technical review of a
Transmission Owner’s or Generator Owner’s Facility Ratings methodology or a
Generator Owner’s documentation for determining its Facility Ratings, the
Transmission Owner or Generator Owner shall have evidence, (such as a copy of a
dated electronic or hard copy note, or other comparable evidence from the
Transmission Owner or Generator Owner addressed to the commenter that includes
the response to the comment,) that it provided a response to that commenting entity
in accordance with Requirement R5. (Retirement approved by NERC BOT pending
applicable regulatory approval.)
R6. Each Transmission Owner and Generator Owner shall have Facility Ratings for its solely
and jointly owned Facilities that are consistent with the associated Facility Ratings
methodology or documentation for determining its Facility Ratings. [Violation Risk
Factor: Medium] [Time Horizon: Operations Planning]
M6. Each Transmission Owner and Generator Owner shall have evidence to show that its
Facility Ratings are consistent with the documentation for determining its Facility
Ratings as specified in Requirement R1 or consistent with its Facility Ratings
methodology as specified in Requirements R2 and R3 (Requirement R6).
R7. Reserved.Each Generator Owner shall provide Facility Ratings (for its solely and jointly
owned Facilities that are existing Facilities, new Facilities, modifications to existing
Facilities and re‐ratings of existing Facilities) to its associated Reliability Coordinator(s),
Planning Coordinator(s), Transmission Planner(s), Transmission Owner(s) and
Transmission Operator(s) as scheduled by such requesting entities. [Violation Risk
Factor: Medium] [Time Horizon: Operations Planning]
M7. Reserved.Each Generator Owner shall have evidence, such as a copy of a dated
electronic note, or other comparable evidence to show that it provided its Facility
Ratings to its associated Reliability Coordinator(s), Planning Coordinator(s),
Transmission Planner(s), Transmission Owner(s) and Transmission Operator(s) in
accordance with Requirement R7.
Page 5 of 16
FAC‐008‐3 5 – Facility Ratings
R8. Each Transmission Owner (and each Generator Owner subject to Requirement R2)
shall provide requested information as specified below (for its solely and jointly
owned Facilities that are existing Facilities, new Facilities, modifications to existing
Facilities and re‐ratings of existing Facilities) to its associated Reliability Coordinator(s),
Planning Coordinator(s), Transmission Planner(s), Transmission Owner(s) and
Transmission Operator(s): [Violation Risk Factor: Medium] [Time Horizon: Operations
Planning]
8.1 As scheduled by the requesting entities:
3.4.3
Facility Ratings
3.4.4
Identity of the most limiting equipment of the Facilities
8.2 Within 30 calendar days (or a later date if specified by the requester), for any
requested Facility with a Thermal Rating that limits the use of Facilities under the
requester’s authority by causing any of the following: 1) An Interconnection
Reliability Operating Limit, 2) A limitation of Total Transfer Capability, 3) An
impediment to generator deliverability, or 4) An impediment to service to a
major load center:
8.2.1
Identity of the existing next most limiting equipment of the Facility
8.2.2
The Thermal Rating for the next most limiting equipment identified in
Requirement R8, Part 8.2.1.
M8. Each Transmission Owner (and Generator Owner subject to Requirement R2) shall
have evidence, such as a copy of a dated electronic note, or other comparable
evidence to show that it provided its Facility Ratings and identity of limiting
equipment to its associated Reliability Coordinator(s), Planning Coordinator(s),
Transmission Planner(s), Transmission Owner(s) and Transmission Operator(s) in
accordance with Requirement R8.
C. Compliance
1.
Compliance Monitoring Process
1.1. Compliance Enforcement Authority: “Compliance Enforcement Authority”
means NERC or the Regional Entity, or any entity as otherwise designated by an
Applicable Governmental Authority, in their respective roles of monitoring
and/or enforcing compliance with mandatory and enforceable Reliability
Standards in their respective jurisdictions.
1.2. Compliance Monitoring and Enforcement Processes:
Self‐Certifications
Spot Checking
Compliance Audits
Self‐Reporting
Page 6 of 16
FAC‐008‐3 5 – Facility Ratings
Compliance Violation Investigations
Complaints
1.3. Evidence Retention: The following evidence retention period(s) identify the
period of time an entity is required to retain specific evidence to demonstrate
compliance. For instances where the evidence retention period specified below
is shorter than the time since the last audit, the Compliance Enforcement
Authority may ask an entity to provide other evidence to show that it was
compliant for the full‐time period since the last audit.
The applicable entity shall keep data or evidence to show compliance as
identified below unless directed by its Compliance Enforcement Authority to
retain specific evidence for a longer period of time as part of an investigation.
The Generator Owner shall keep its current documentation (for R1) and any
modifications to the documentation that were in force since last compliance
audit period for Measure M1 and Measure M6.
The Generator Owner shall keep its current, in force Facility Ratings
methodology (for R2) and any modifications to the methodology that were in
force since last compliance audit period for Measure M2 and Measure M6.
The Transmission Owner shall keep its current, in force Facility Ratings
methodology (for R3) and any modifications to the methodology that were in
force since the last compliance audit for Measure M3 and Measure M6.
The Transmission Owner and Generator Owner shall keep its current, in force
Facility Ratings and any changes to those ratings for three calendar years for
Measure M6.
The Generator Owner and Transmission Owner shall each keep evidence for
Measure M4, and Measure M5, for three calendar years. (Retirement
approved by FERC effective January 21, 2014.)
The Generator Owner shall keep evidence for Measure M7 for three calendar
years.
The Transmission Owner (and Generator Owner that is subject to
Requirement R2) shall keep evidence for Measure M8 for three calendar
years.
If a Generator Owner or Transmission Owner is found non‐compliant, it shall
keep information related to the non‐compliance until found compliant.
The Compliance Enforcement Authority shall keep the last audit and all
subsequent compliance records.
Compliance Monitoring and Enforcement Program: As defined in the NERC
Rules of Procedure, “Compliance Monitoring and Enforcement Program” refers
Page 7 of 16
FAC‐008‐3 5 – Facility Ratings
to the identification of the processes that will be used to evaluate data or
information for the purpose of assessing performance or outcomes with the
associated Reliability Standard.
Page 8 of 16
FAC‐008‐3 5 – Facility Ratings
Violation Severity Levels
Violation Severity Levels
R#
Lower VSL
High VSL
Severe VSL
R1.
N/A
The Generator Owner’s
Facility Rating
documentation did not
address Requirement R1,
Part 1.1.
The Generator Owner’s
Facility Rating
documentation did not
address Requirement R1,
Part 1.2.
The Generator Owner failed
to provide documentation
for determining its Facility
Ratings.
R2.
The Generator Owner failed
to include in its Facility
Rating methodology one of
the following Parts of
Requirement R2:
The Generator Owner failed
to include in its Facility
Rating methodology two of
the following Parts of
Requirement R2:
The Generator Owner’s
Facility Rating methodology
did not address all the
components of
Requirement R2, Part 2.4.
2.1.
2.1
OR
2.2.1
2.2.1
2.2.2
2.2.2
2.2.3
2.2.3
2.2.4
2.2.4
The Generator Owner failed
to include in its Facility
Rating Methodology, three
of the following Parts of
Requirement R2:
The Generator Owner’s
Facility Rating methodology
failed to recognize a
facility's rating based on the
most limiting component
rating as required in
Requirement R2, Part 2.3
Moderate VSL
OR
The Generator Owner failed
to include in its Facility
Rating Methodology four or
more of the following Parts
of Requirement R2:
2.1.
2.2.1
2.1
2.2.2
2.2.1
2.2.3
2.2.2
2.2.4
2.2.3
Page 9 of 16
FAC‐008‐3 5 – Facility Ratings
Violation Severity Levels
R#
Lower VSL
Moderate VSL
High VSL
Severe VSL
R3.
The Transmission Owner
failed to include in its
Facility Rating methodology
one of the following Parts
of Requirement R3:
The Transmission Owner
failed to include in its
Facility Rating methodology
two of the following Parts
of Requirement R3:
The Transmission Owner’s
Facility Rating methodology
did not address either of
the following Parts of
Requirement R3:
3.1
3.1
3.4.1
3.2.1
3.2.1
3.4.2
3.2.2
3.2.2
OR
OR
3.2.3
3.2.3
3.2.4
3.2.4
The Transmission Owner
failed to include in its
Facility Rating methodology
three of the following Parts
of Requirement R3:
2.2.4
The Transmission Owner’s
Facility Rating methodology
failed to recognize a
Facility's rating based on
the most limiting
component rating as
required in Requirement
R3, Part 3.3
3.1
The Transmission Owner
failed to include in its
Facility Rating methodology
four or more of the
following Parts of
Requirement R3:
3.2.1
3.1
3.2.2
3.2.1
3.2.3
3.2.2
3.2.4
3.2.3
3.2.4
Page 10 of 16
FAC‐008‐3 5 – Facility Ratings
Violation Severity Levels
R#
Lower VSL
The responsible entity
made its Facility Ratings
Reserved.
methodology or Facility
Ratings documentation
(Retirement available within more than
21 calendar days but less
approved
than or equal to 31
by FERC
calendar days after a
effective
January 21, request.
2014.)
R4.
Moderate VSL
High VSL
Severe VSL
The responsible entity
made its Facility Ratings
methodology or Facility
Ratings documentation
available within more than
31 calendar days but less
than or equal to 41
calendar days after a
request.
The responsible entity
made its Facility Rating
methodology or Facility
Ratings documentation
available within more than
41 calendar days but less
than or equal to 51
calendar days after a
request.
The responsible entity
failed to make its Facility
Ratings methodology or
Facility Ratings
documentation available in
more than 51 calendar days
after a request. (R3)
The responsible entity
provided a response in
more than 60 calendar days
but less than or equal to 70
calendar days after a
request.
The responsible entity
provided a response in
more than 70 calendar days
but less than or equal to 80
calendar days after a
request.
The responsible entity
failed to provide a response
as required in more than 80
calendar days after the
comments were received.
(R5)
OR
OR
The responsible entity
provided a response within
45 calendar days, and the
response indicated that a
change will not be made to
the Facility Ratings
methodology or Facility
The responsible entity
provided a response within
45 calendar days, but the
response did not indicate
whether a change will be
made to the Facility Ratings
methodology or Facility
R5.
The responsible entity
provided a response in
Reserved.
(Retirement more than 45 calendar days
but less than or equal to 60
approved
calendar days after a
by FERC
request. (R5)
effective
January 21,
2014.)
Page 11 of 16
FAC‐008‐3 5 – Facility Ratings
Violation Severity Levels
R#
Lower VSL
High VSL
Ratings documentation but
did not indicate why no
change will be made. (R5)
Ratings documentation.
(R5)
Severe VSL
R6.
The responsible entity
failed to establish Facility
Ratings consistent with the
associated Facility Ratings
methodology or
documentation for
determining the Facility
Ratings for 5% or less of its
solely owned and jointly
owned Facilities. (R6)
The responsible entity
failed to establish Facility
Ratings consistent with the
associated Facility Ratings
methodology or
documentation for
determining the Facility
Ratings for more than 5% or
more, but less than up to
(and including) 10% of its
solely owned and jointly
owned Facilities. (R6)
The responsible entity
failed to establish Facility
Ratings consistent with the
associated Facility Ratings
methodology or
documentation for
determining the Facility
Ratings for more than 10%
up to (and including) 15% of
its solely owned and jointly
owned Facilities. (R6)
The responsible entity
failed to establish Facility
Ratings consistent with the
associated Facility Ratings
methodology or
documentation for
determining the Facility
Ratings for more than15%
of its solely owned and
jointly owned Facilities.
(R6)
R7.
The Generator Owner
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by up to and
including 15 calendar days.
The Generator Owner
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
15 calendar days but less
than or equal to 25
calendar days.
The Generator Owner
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
25 calendar days but less
than or equal to 35
calendar days.
The Generator Owner
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
35 calendar days.
Reserved.
Moderate VSL
OR
The Generator Owner failed
to provide its Facility
Page 12 of 16
FAC‐008‐3 5 – Facility Ratings
Violation Severity Levels
R#
Lower VSL
Moderate VSL
High VSL
Severe VSL
Ratings to the requesting
entities.
R8.
The responsible entity
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by up to and
including 15 calendar days.
(R8, Part 8.1)
OR
The responsible entity
provided less than 100%,
but not less than or equal
to 95% of the required
Rating information to all of
the requesting entities. (R8,
Part 8.1)
OR
The responsible entity
provided the required
Rating information to the
requesting entity, but the
information was provided
up to and including 15
The responsible entity
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
15 calendar days but less
than or equal to 25
calendar days. (R8, Part 8.1)
The responsible entity
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
25 calendar days but less
than or equal to 35
calendar days. (R8, Part 8.1)
The responsible entity
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
35 calendar days. (R8, Part
8.1)
OR
OR
The responsible entity
provided less than 95%, but
not less than or equal to
90% of the required Rating
information to all of the
requesting entities. (R8,
Part 8.1)
The responsible entity
provided less than 90%, but
not less than or equal to
85% of the required Rating
information to all of the
requesting entities. (R8,
Part 8.1)
The responsible entity
provided less than 85% of
the required Rating
information to all of the
requesting entities. (R8,
Part 8.1)
OR
OR
The responsible entity
provided the required
Rating information to the
requesting entity, but did
so more 15 calendar days
but less than or equal to 25
The responsible entity
provided the required
Rating information to the
requesting entity, but did
so more than 25 calendar
days but less than or equal
OR
OR
The responsible entity
provided the required
Rating information to the
requesting entity, but did
so more than 35 calendar
days late. (R8, Part 8.2)
OR
Page 13 of 16
FAC‐008‐3 5 – Facility Ratings
Violation Severity Levels
R#
Lower VSL
Moderate VSL
High VSL
Severe VSL
calendar days late. (R8, Part calendar days late. (R8, Part to 35 calendar days late.
(R8, Part 8.2)
8.2)
8.2)
OR
The responsible entity
provided less than 100%,
but not less than or equal
to 95% of the required
Rating information to the
requesting entity. (R8, Part
8.2)
The responsible entity
provided less than 85 % of
the required Rating
OR
OR
information to the
The responsible entity
The responsible entity
requesting entity. (R8, Part
provided less than 95%, but provided less than 90%, but 8.2)
no less than or equal to
not less than or equal to
OR
90% of the required Rating 85% of the required Rating
The responsible entity
information to the
information to the
requesting entity. (R8, Part requesting entity. (R8, Part failed to provide its Rating
8.2)
8.2)
information to the
requesting entity. (R8, Part
8.1)
D. Regional Variances
None.
E. Associated Documents
None.
Page 14 of 16
FAC‐008‐3 5 – Facility Ratings
Version History
Version
Date
Action
Change Tracking
1
Feb 7, 2006
Approved by Board of Trustees
New
1
Mar 16, 2007
Approved by FERC
New
2
May 12, 2010
Approved by Board of Trustees
Complete Revision,
merging FAC_008‐1
and FAC‐009‐1
under Project 2009‐
06 and address
directives from
Order 693
3
May 24, 2011
Addition of Requirement R8
Project 2009‐06
Expansion to
address third
directive from
Order 693
3
May 24, 2011
Adopted by NERC Board of Trustees
3
November 17,
2011
FERC Order issued approving FAC‐008‐
3
3
May 17, 2012
FERC Order issued directing the VRF
for Requirement R2 be changed from
“Lower” to “Medium”
3
February 7,
2013
R4 and R5 and associated elements
approved by NERC Board of Trustees
for retirement as part of the Paragraph
81 project (Project 2013‐02) pending
applicable regulatory approval.
3
November 21,
2013
R4 and R5 and associated elements
approved by FERC for retirement as
part of the Paragraph 81 project
(Project 2013‐02)
4
TBD May 9,
2020
R7 and R8 and associated elements
adopted by NERC Board of Trustees for
retirement as part of Project 2018-03
Standards Efficiency Review
Retirements.
Page 15 of 16
FAC‐008‐3 5 – Facility Ratings
4
September 17, Remanded by FERC (Order No. 873).
2020
Withdrawn
5
February 4,
2021
Requirement R8
and associated
elements restored
in response to FERC
Order No. 873.
Adopted by NERC Board of Trustees
Page 16 of 16
Exhibit B
Implementation Plan
RELIABILITY | RESILIENCE | SECURITY
Implementation Plan
Project 2018-03 Standards Efficiency Review Retirements
Reliability Standard FAC-008-5
Applicable Standard(s)
•
FAC-008-5 – Facility Ratings
Requested Retirement(s)
•
FAC-008-3 – Facility Ratings
Applicable Entities
•
Transmission Owner
•
Generator Owner
Background
In 2017, NERC initiated the Standards Efficiency Review (SER). The scope of this project was to use a
risk-based approach to identify potential efficiencies through retirement of Reliability Standard
requirements. Following the completion of the first phase of work, the SER Standard Drafting Team
(SDT) submitted a Standards Authorization Request (SAR) to the NERC Standards Committee, which
the Standards Committee accepted in August 2018.
Project 2018-03 Standards Efficiency Review Retirements was initiated to consider and implement
the recommendations for Reliability Standard retirements contained in the SAR.
Among other things, the SER SDT proposed retiring Requirements R7 and R8 in Reliability Standard
FAC-008-3 as redundant and not needed for reliability. Proposed Reliability Standard FAC-008-4
passed final ballot on May 2, 2019; was adopted by the Board of Trustees on May 9, 2019; and was
filed with the Federal Energy Regulatory Commission (FERC) on June 7, 2019 for approval.
On September 17, 2020, the Federal Regulatory Commission (FERC) issued Order No. 873. 1 With
respect to proposed Reliability Standard FAC-008-4, FERC determined that the retirement of
Requirement R7 would be appropriate, but rejected the retirement of Requirement R8, concluding
that “… Requirement R8 is needed to ensure that limiting and next limiting equipment is identified
and communicated” (P 40). FERC remanded proposed Reliability Standard FAC-008-4 to NERC for
further consideration.
1 Order No. 873, Electric Reliability Organization Proposal to Retire Requirements in Reliability Standards Under the NERC Standards
Efficiency Review, 172 FERC ¶ 61,225 (2020),
https://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Order%20on%20SER%20Retirements.pdf.
RELIABILITY | RESILIENCE | SECURITY
Following the FERC remand, NERC submitted a notice to the remaining applicable governmental
authorities requesting that FAC-008-4 be withdrawn in their respective jurisdictions.
Proposed Reliability Standard FAC-008-5 would retire Requirement R7 of currently effective
Reliability Standard FAC-008-3.
General Considerations
For Reliability Standard FAC-008-5– Facility Ratings, the standard will become effective on the first day
of the first calendar quarter that is three (3) months after applicable regulatory approval. This
implementation timeframe reflects consideration that entities may need time to update their internal
systems and documentation to reflect the new standard version numbers.
Effective Date
Reliability Standard FAC-008-5– Facility Ratings
Where approval by an applicable governmental authority is required, the standard shall become
effective on the first day of the first calendar quarter that is three (3) months after the effective date of
the applicable governmental authority’s order approving the standard, or as otherwise provided for by
the applicable governmental authority.
Where approval by an applicable governmental authority is not required, the standard shall become
effective on the first day of the first calendar quarter that is three (3) months after the date the
standard is adopted by the NERC Board of Trustees, or as otherwise provided for in that jurisdiction.
Retirement Date
Reliability Standard FAC-008-3 – Facility Ratings
Reliability Standard FAC-008-3 shall be retired immediately prior to the effective date of the revised
standard in the particular jurisdiction in which the revised standard is becoming effective.
Implementation Plan
Project 2018-03 Standards Efficiency Review Retirements | January 2021
2
Exhibit C
Order No. 672 Criteria
RELIABILITY | RESILIENCE | SECURITY
EXHIBIT C
Order No. 672 Criteria
In Order No. 672,1 the Commission identified a number of criteria it will use to analyze
Reliability Standards proposed for approval to ensure they are just, reasonable, not unduly
discriminatory or preferential, and in the public interest. The discussion below identifies these
factors and explains how proposed Reliability Standard FAC-008-5 continues to meet or exceed
the criteria.
1. Proposed Reliability Standards must be designed to achieve a specified reliability goal
and must contain a technically sound means to achieve that goal.2
Proposed Reliability Standard FAC-008-5 improves upon the currently effective version
by retiring a requirement (Requirement R7) that is redundant and provides little, if any, benefit to
reliability. Except for corresponding changes that are necessary to the Violation Risk Factors
(“VRFs”), Violation Severity Levels (“VSLs”), and measures, no other changes are proposed. As
such, the proposed Reliability Standard remains designed to achieve a specified reliability goal
and continues to provide a technically sound means to achieve that goal, consistent with the
Commission’s approval of the currently effective version of the standard.
2. Proposed Reliability Standards must be applicable only to users, owners and
operators of the bulk power system, and must be clear and unambiguous as to what
is required and who is required to comply.3
The proposed Reliability Standard is clear and unambiguous as to what is required and who
is required to comply, in accordance with Order No. 672. An individual requirement from the
1
Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the
Establishment, Approval, and Enforcement of Electric Reliability Standards, Order No. 672, 114 FERC ¶ 61,104,
order on reh’g, Order No. 672-A, 114 FERC ¶ 61,328 (2006).
2
Order No. 672 at PP 321, 324.
3
Order No. 672 at PP 322, 325.
1
currently effective version of the Reliability Standard is proposed for retirement. NERC does not
propose any changes to the applicability of the standard.
3. A proposed Reliability Standard must include clear and understandable
consequences and a range of penalties (monetary and/or non-monetary) for a
violation.4
The Violation Risk Factors (“VRFs”) and Violation Severity Levels (“VSLs”) for the
proposed Reliability Standard continue to comport with NERC and Commission guidelines related
to their assignment, as discussed further in Exhibit D. As noted therein, no changes are proposed
to the VRFs and VSLs from the currently effective version of the standard beyond those necessary
to reflect the retirement of Requirement R7.
4. A proposed Reliability Standard must identify clear and objective criterion or
measure for compliance, so that it can be enforced in a consistent and nonpreferential manner. 5
The proposed Reliability Standard contains measures that support each requirement by
clearly identifying what is required to demonstrate compliance. These measures help provide
clarity regarding the manner in which the requirements will be enforced and help ensure that the
requirements will be enforced in a clear, consistent, and non-preferential manner and without
prejudice to any party. No changes are proposed to the measures from the currently effective
versions of the standard beyond those necessary to reflect the retirement of Requirement R7.
4
Order No. 672 at P 326.
5
Order No. 672 at P 327.
2
5. Proposed Reliability Standards should achieve a reliability goal effectively and
efficiently — but do not necessarily have to reflect “best practices” without regard to
implementation cost or historical regional infrastructure design.6
The proposed Reliability Standard would achieve its reliability goals effectively and
efficiently in accordance with Order No. 672. The proposed Reliability Standard improves upon
the currently effective version by retiring Requirement R7, a requirement that is now redundant to
those in other Reliability Standards and is no longer needed for reliability, thereby improving the
efficiency of the standards.
6. Proposed Reliability Standards cannot be “lowest common denominator,” i.e., cannot
reflect a compromise that does not adequately protect Bulk-Power System reliability.
Proposed Reliability Standards can consider costs to implement for smaller entities,
but not at consequences of less than excellence in operating system reliability.7
The proposed Reliability Standard does not reflect a “lowest common denominator”
approach. The retirement of Requirement R7 in proposed Reliability Standard FAC-008-5 would
improve the effectiveness and efficiency of the standard and would not result in adverse impacts
to reliability.
7. Proposed Reliability Standards must be designed to apply throughout North America
to the maximum extent achievable with a single Reliability Standard while not
favoring one geographic area or regional model. It should take into account regional
variations in the organization and corporate structures of transmission owners and
operators, variations in generation fuel type and ownership patterns, and regional
variations in market design if these affect the proposed Reliability Standard.8
The proposed Reliability Standard continues to apply throughout North America and does
not favor one geographic area or regional model.
6
Order No. 672 at P 328.
7
Order No. 672 at P 329-30.
8
Order No. 672 at P 331.
3
8. Proposed Reliability Standards should cause no undue negative effect on competition
or restriction of the grid beyond any restriction necessary for reliability.9
The proposed Reliability Standard would have no undue negative impact on competition.
The proposed Reliability Standard would continue to require the same performance by each of the
applicable functional entities, minus Requirement R7 which is proposed for retirement. The
proposed Reliability Standard would not unreasonably restrict the available transmission
capability or limit use of the Bulk-Power System in a preferential manner.
9. The implementation time for the proposed Reliability Standard is reasonable.10
The proposed implementation period for the proposed Reliability Standard is just and
reasonable and allows entities sufficient time to update their internal documentation and other
processes.
10. The Reliability Standard was developed in an open and fair manner and in
accordance with the Commission-approved Reliability Standard development
process.11
The proposed Reliability Standard was developed in accordance with NERC’s
Commission-approved, ANSI-accredited processes for developing and approving Reliability
Standards. Exhibit E includes a summary of the development proceedings and details the
processes followed to develop the proposed Reliability Standard. These processes included, among
other things, comment and ballot periods. Additionally, all meetings of the drafting team were
properly noticed and open to the public. The initial and final ballots achieved a quorum and
exceeded the required ballot pool approval levels.
9
Order No. 672 at P 332.
10
Order No. 672 at P 333.
11
Order No. 672 at P 334.
4
11. NERC must explain any balancing of vital public interests in the development of
proposed Reliability Standards.12
NERC has identified no competing public interests regarding the request for approval of
the proposed Reliability Standard. No comments were received that indicated the proposed
Reliability Standard conflicts with other vital public interests.
12. Proposed Reliability Standards must consider any other appropriate factors.13
No other negative factors relevant to whether the proposed Reliability Standard is just and
reasonable were identified.
12
Order No. 672 at P 335.
13
Order No. 672 at P 323.
5
Exhibit D
Analysis of Violation Risk Factors and Violation Severity Levels
RELIABILITY | RESILIENCE | SECURITY
Violation Risk Factor and Violation Severity Level
Justifications
Project 2018-03 Standards Efficiency Review Retirements
This document provides the standard drafting team’s (SDT’s) justification for assignment of violation risk factors (VRFs) and violation severity
levels (VSLs) for each requirement in proposed Reliability Standard FAC-008-5. Each requirement is assigned a VRF and a VSL. These elements
support the determination of an initial value range for the Base Penalty Amount regarding violations of requirements in FERC-approved
Reliability Standards, as defined in the Electric Reliability Organizations (ERO) Sanction Guidelines. The SDT applied the following NERC criteria
and FERC Guidelines when developing the VRFs and VSLs for the requirements.
NERC Criteria for Violation Risk Factors
High Risk Requirement
A requirement that, if violated, could directly cause or contribute to Bulk Electric System instability, separation, or a cascading sequence of
failures, or could place the Bulk Electric System at an unacceptable risk of instability, separation, or cascading failures; or, a requirement in a
planning time frame that, if violated, could, under emergency, abnormal, or restorative conditions anticipated by the preparations, directly
cause or contribute to Bulk Electric System instability, separation, or a cascading sequence of failures, or could place the Bulk Electric System
at an unacceptable risk of instability, separation, or cascading failures, or could hinder restoration to a normal condition.
Medium Risk Requirement
A requirement that, if violated, could directly affect the electrical state or the capability of the Bulk Electric System, or the ability to effectively
monitor and control the Bulk Electric System. However, violation of a medium risk requirement is unlikely to lead to Bulk Electric System
instability, separation, or cascading failures; or, a requirement in a planning time frame that, if violated, could, under emergency, abnormal,
or restorative conditions anticipated by the preparations, directly and adversely affect the electrical state or capability of the Bulk Electric
System, or the ability to effectively monitor, control, or restore the Bulk Electric System. However, violation of a medium risk requirement is
unlikely, under emergency, abnormal, or restoration conditions anticipated by the preparations, to lead to Bulk Electric System instability,
separation, or cascading failures, nor to hinder restoration to a normal condition.
RELIABILITY | RESILIENCE | SECURITY
Lower Risk Requirement
A requirement that is administrative in nature and a requirement that, if violated, would not be expected to adversely affect the electrical
state or capability of the Bulk Electric System, or the ability to effectively monitor and control the Bulk Electric System; or, a requirement that
is administrative in nature and a requirement in a planning time frame that, if violated, would not, under the emergency, abnormal, or
restorative conditions anticipated by the preparations, be expected to adversely affect the electrical state or capability of the Bulk Electric
System, or the ability to effectively monitor, control, or restore the Bulk Electric System.
FERC Guidelines for Violation Risk Factors
Guideline (1) – Consistency with the Conclusions of the Final Blackout Report
FERC seeks to ensure that VRFs assigned to Requirements of Reliability Standards in these identified areas appropriately reflect their historical
critical impact on the reliability of the Bulk-Power System. In the VSL Order, FERC listed critical areas (from the Final Blackout Report) where
violations could severely affect the reliability of the Bulk-Power System:
•
Emergency operations
•
Vegetation management
•
Operator personnel training
•
Protection systems and their coordination
•
Operating tools and backup facilities
•
Reactive power and voltage control
•
System modeling and data exchange
•
Communication protocol and facilities
•
Requirements to determine equipment ratings
•
Synchronized data recorders
•
Clearer criteria for operationally critical facilities
•
Appropriate use of transmission loading relief.
VRF and VSL Justifications
Project 2018-03 Standards Efficiency Review Retirements | January 2021
2
Guideline (2) – Consistency within a Reliability Standard
FERC expects a rational connection between the sub-Requirement VRF assignments and the main Requirement VRF assignment.
Guideline (3) – Consistency among Reliability Standards
FERC expects the assignment of VRFs corresponding to Requirements that address similar reliability goals in different Reliability Standards
would be treated comparably.
Guideline (4) – Consistency with NERC’s Definition of the Violation Risk Factor Level
Guideline (4) was developed to evaluate whether the assignment of a particular VRF level conforms to NERC’s definition of that risk level.
Guideline (5) – Treatment of Requirements that Co-mingle More Than One Obligation
Where a single Requirement co-mingles a higher risk reliability objective and a lesser risk reliability objective, the VRF assignment for such
Requirements must not be watered down to reflect the lower risk level associated with the less important objective of the Reliability
Standard.
VRF and VSL Justifications
Project 2018-03 Standards Efficiency Review Retirements | January 2021
3
NERC Criteria for Violation Severity Levels
VSLs define the degree to which compliance with a requirement was not achieved. Each requirement must have at least one VSL. While it is
preferable to have four VSLs for each requirement, some requirements do not have multiple “degrees” of noncompliant performance and
may have only one, two, or three VSLs.
VSLs should be based on NERC’s overarching criteria shown in the table below:
Lower VSL
Moderate VSL
The performance or product
measured almost meets the full
intent of the requirement.
The performance or product
measured meets the majority of
the intent of the requirement.
High VSL
The performance or product
measured does not meet the
majority of the intent of the
requirement, but does meet
some of the intent.
Severe VSL
The performance or product
measured does not
substantively meet the intent of
the requirement.
FERC Order of Violation Severity Levels
The FERC VSL guidelines are presented below, followed by an analysis of whether the VSLs proposed for each requirement in the standard
meet the FERC Guidelines for assessing VSLs:
Guideline (1) – Violation Severity Level Assignments Should Not Have the Unintended Consequence of Lowering the Current
Level of Compliance
Compare the VSLs to any prior levels of non-compliance and avoid significant changes that may encourage a lower level of compliance than
was required when levels of non-compliance were used.
Guideline (2) – Violation Severity Level Assignments Should Ensure Uniformity and Consistency in the Determination of
Penalties
A violation of a “binary” type requirement must be a “Severe” VSL.
Do not use ambiguous terms such as “minor” and “significant” to describe noncompliant performance.
Guideline (3) – Violation Severity Level Assignment Should Be Consistent with the Corresponding Requirement
VSLs should not expand on what is required in the requirement.
VRF and VSL Justifications
Project 2018-03 Standards Efficiency Review Retirements | January 2021
4
Guideline (4) – Violation Severity Level Assignment Should Be Based on a Single Violation, Not on a Cumulative Number of
Violations
Unless otherwise stated in the requirement, each instance of non-compliance with a requirement is a separate violation. Section 4 of the
Sanction Guidelines states that assessing penalties on a per violation per day basis is the “default” for penalty calculations.
VRF Justification for FAC-008-5, Requirement R1
The VRF did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VRF Justification for FAC-008-5, Requirement R2
The VRF did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VRF Justification for FAC-008-5, Requirement R3
The VRF did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VRF Justification for FAC-008-5, Requirement R6
The VRF did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VRF Justification for FAC-008-5, Requirement R8
The VRF did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VSL Justification for FAC-008-5, Requirement R1
The VSL did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VSL Justification for FAC-008-5, Requirement R2
The VSL did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VSL Justification for FAC-008-5, Requirement R3
The VSL did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VSL Justification for FAC-008-5, Requirement R6
The VSL did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VSL Justification for FAC-008-5, Requirement R8
The VSL did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VRF and VSL Justifications
Project 2018-03 Standards Efficiency Review Retirements | January 2021
5
Exhibit E
Summary of Development History and Complete Record of Development
RELIABILITY | RESILIENCE | SECURITY
Summary of Development History
The following is a summary of the development record for proposed Reliability Standard
FAC-008-5.
I.
Overview of the Standard Drafting Team
When evaluating a proposed Reliability Standard, the Commission is expected to give “due
weight” to the technical expertise of the ERO.1 The technical expertise of the ERO is derived from
the standard drafting team (“SDT”) selected to lead each project in accordance with Section 4.3 of
the NERC Standard Processes Manual.2 For this project, the SDT consisted of industry experts, all
with a diverse set of experiences. A roster of the Project 2018-03 Standards Efficiency Review
Retirements SDT members is included in Exhibit F.
II.
Standard Development History
A. Standard Authorization Request Development
On August 22, 2018, the Standards Committee accepted the Standard Authoriation Request
(SAR) for Project 2018-03 Standards Efficiency Review and authorized posting the SAR for a 30day formal comment period. Project 2018-03 developed a series of standard and requirement
retirement proposals. In June 2019, NERC submitted these retirement proposals to the
Commission, including proposed Reliability Standard FAC-008-4. Following the issuance of
Order No. 873 remanding proposed FAC-008-4,3 NERC recalled the Project 2018-03 Standards
Efficiency Review Retirements drafting team to consider further steps regarding the FAC-008
Reliability Standard.
1
Section 215(d)(2) of the Federal Power Act; 16 U.S.C. § 824(d)(2) (2018).
The NERC Standard Processes Manual is available at
https://www.nerc.com/FilingsOrders/us/RuleOfProcedureDL/SPM_Clean_Mar2019.pdf.
3
Electric Reliability Organization Proposal to Retire Requirements in Reliability Standards under the NERC
Standards Efficiency Review, Order No. 873, 172 FERC ¶ 61,225 (2020).
2
1
B. First Posting - Comment Period, Initial Ballot, and Non-binding Poll
On November 19, 2020, the Standards Committee authorized initial posting of proposed
Reliability Standard FAC-008-5, the associated Implementation Plan and other associated
documents for a 45-day formal comment period from November 30, 2020 through January 13,
2021, with a parallel initial ballot and non-binding poll on the Violation Risk Factors (“VRFs”)
and Violation Severity Levels (“VSLs”) held during the last 10 days of the comment period from
January 4, 2021 through January 13, 2021. The initial ballot for proposed Reliability Standard
FAC-008-5 received 95.91 percent approval, reaching quorum at 89.93 percent of the ballot pool.
The non-binding poll for the associated VRFs and VSLs received 100 percent supportive opinions,
reaching quorum at 86.61 percent of the ballot pool. There were 45 sets of responses, including
comments from approximately 107 different individuals and approximately 81 companies,
representing all 10 industry segments.4
C. Final Ballot
Proposed Reliability Standard FAC-008-5 was posted for a 10-day final ballot period from
January 19, 2021 through January 28, 2021. The ballot for proposed Reliability Standard FAC008-5 and associated documents reached quorum at 91.04 percent of the ballot pool, receiving
affirmative support from 95.96 percent of the voters.
4
NERC, Consideration of Comments – FAC-008-5, Project 2018-03 Standards Efficiency Review
Retirements (Jan. 19, 2021),
https://www.nerc.com/pa/Stand/Project%20201803%20Standards%20Efficiency%20Review%20Require/201803_SER_FAC-008_Consideration_of_Comments_01192021.pdf.
2
D. Board of Trustees Adoption
The NERC Board of Trustees adopted proposed Reliability Standard FAC-008-5 on February
4, 2021.5
5
NERC, Board of Trustees Agenda Package, Agenda Item 7a. (Project 2018-03 Standards Efficiency
Review Retirements (FAC-008-5)) available at
https://www.nerc.com/gov/bot/Agenda%20highlights%20and%20Mintues%202013/Board_Open_Meeting_Agenda
-Feb-4-2021_PUBLIC_ONLY.pdf.
3
Complete Record of Development
4
Project 2018-03 Standards Efficiency Review Retirements
Related Files
Status
The 10-day final ballot for FAC-008-5 Facility Ratings concluded 8 p.m. Eastern, Thursday, January 28, 2021. The voting results can be accessed via the link below. The standard will be
submitted to the Board of Trustees for adoption and then filed with the appropriate regulatory authorities.
Project Scope
The Standard Authorization Request (SAR) drafting team evaluated NERC Reliability Standards using a risk-based approach to identify potential efficiencies through retirement or modification of
Reliability Standard Requirements. The drafting team identified potential candidate requirements that are not essential for reliability, could be simplified or consolidated, and could thereby reduce
regulatory obligations and/or compliance burden.
The Project 2018-03 standard drafting team (SDT) proposed retiring Requirement R7 and Requirement R8 of FAC-008-3. Proposed FAC-008-4 was approved by final ballot on May 2, 2019 and
adopted by the BOT on May 9, 2019. NERC subsequently filed a Petition with FERC on June 7, 2019 for approval of proposed Reliability Standard FAC-008-4. On September 17, 2020, FERC issued
an Order approving the retirement of 19 Reliability Standard requirements and remanded proposed FAC-008-4 for further consideration by NERC.
The Project 2018-3 SDT has been recalled to further consider the proposed retirements of Requirement R7 and Requirement R8 of FAC-008.
Standard(s) Affected: FAC-008-3
Standards Efficiency Review Retirements (SER-Retirements)
The SER-Retirements standards drafting team is comprised of a mix of team members with Real-time Operations, Long-term Planning, and Operations Planning expertise to evaluate FAC-008
Requirement R7 and Requirement R8 for retirement.
Draft
Actions
Dates
Results
Consideration of
Comments
Final Posting
FAC-008-5
(13) Clean | (14) Redline to Last Posted | (15) Redline
to Last Approved
Implementation Plan
(16) Clean | (17) Redline
Final Ballot
(20) Info
01/19/21 - 01/28/21
(21) Ballot Results
Vote
Supporting Materials
VRF/VSL Justifications
(18) Clean | (19) Redline
Initial Ballot and Nonbinding Poll
(1) FAC-008-4 (Redline)
Initial Posting
(2) FAC-008-5
(9) Updated Info
01/04/21 - 01/13/21
(11) Ballot Results
(12) Non-binding Poll
(10) Info
Results
Vote
(3) Implementation Plan
Supporting Materials
(4) Unofficial Comment Form
Join Ballot Pools
11/30/20 - 12/29/20
(Word)
(5) VRF/VSL Justifications
Comment Period
(6) Info
Submit Comments
11/30/20 - 01/13/21
(7)
Comments Received
(8) Consideration of
Comments
FAC-008-4 5 – Facility Ratings
A. Introduction
1.
Title:
Facility Ratings
2.
Number:
FAC-008-45
3.
Purpose:
To ensure that Facility Ratings used in the reliable planning and
operation of the Bulk Electric System (BES) are determined based
on technically sound principles. A Facility Rating is essential for the
determination of System Operating Limits.
4.
Applicability:
4.1. Transmission Owner
4.2. Generator Owner
5.
Effective Date:
See Implementation Plan.
Page 1 of 13
FAC-008-4 5 – Facility Ratings
B. Requirements and Measures
R1. Each Generator Owner shall have documentation for determining the Facility Ratings
of its solely and jointly owned generator Facility(ies) up to the low side terminals of
the main step up transformer if the Generator Owner does not own the main step up
transformer and the high side terminals of the main step up transformer if the
Generator Owner owns the main step up transformer. [Violation Risk Factor: Lower]
[Time Horizon: Long-term Planning]
1.1. The documentation shall contain assumptions used to rate the generator and at
least one of the following:
x
Design or construction information such as design criteria, ratings provided
by equipment manufacturers, equipment drawings and/or specifications,
engineering analyses, method(s) consistent with industry standards (e.g.
ANSI and IEEE), or an established engineering practice that has been verified
by testing or engineering analysis.
x
Operational information such as commissioning test results, performance
testing or historical performance records, any of which may be
supplemented by engineering analyses.
1.2. The documentation shall be consistent with the principle that the Facility Ratings
do not exceed the most limiting applicable Equipment Rating of the individual
equipment that comprises that Facility.
M1. Each Generator Owner shall have documentation that shows how its Facility Ratings
were determined as identified in Requirement 1.
R2. Each Generator Owner shall have a documented methodology for determining Facility
Ratings (Facility Ratings methodology) of its solely and jointly owned equipment
connected between the location specified in R1 and the point of interconnection with
the Transmission Owner that contains all of the following. [Violation Risk Factor:
Medium] [Time Horizon: Long-term Planning]
2.1. The methodology used to establish the Ratings of the equipment that comprises
the Facility(ies) shall be consistent with at least one of the following:
x
Ratings provided by equipment manufacturers or obtained from equipment
manufacturer specifications such as nameplate rating.
x
One or more industry standards developed through an open process such as
Institute of Electrical and Electronic Engineers (IEEE) or International Council
on Large Electric Systems (CIGRE).
x
A practice that has been verified by testing, performance history or
engineering analysis.
Page 2 of 13
FAC-008-4 5 – Facility Ratings
2.2. The underlying assumptions, design criteria, and methods used to determine the
Equipment Ratings identified in Requirement R2, Part 2.1 including identification
of how each of the following were considered:
2.2.1. Equipment Rating standard(s) used in development of this methodology.
2.2.2. Ratings provided by equipment manufacturers or obtained from
equipment manufacturer specifications.
2.2.3. Ambient conditions (for particular or average conditions or as they vary
in real-time).
2.2.4. Operating limitations. 1
2.3. A statement that a Facility Rating shall respect the most limiting applicable
Equipment Rating of the individual equipment that comprises that Facility.
2.4. The process by which the Rating of equipment that comprises a Facility is
determined.
2.4.1. The scope of equipment addressed shall include, but not be limited to,
conductors, transformers, relay protective devices, terminal equipment,
and series and shunt compensation devices.
2.4.2. The scope of Ratings addressed shall include, as a minimum, both Normal
and Emergency Ratings.
M2. Each Generator Owner shall have a documented Facility Ratings methodology that
includes all of the items identified in Requirement 2, Parts 2.1 through 2.4.
R3. Each Transmission Owner shall have a documented methodology for determining
Facility Ratings (Facility Ratings methodology) of its solely and jointly owned Facilities
(except for those generating unit Facilities addressed in R1 and R2) that contains all of
the following: [Violation Risk Factor: Medium] [ Time Horizon: Long-term Planning]
3.1. The methodology used to establish the Ratings of the equipment that comprises
the Facility shall be consistent with at least one of the following:
1
x
Ratings provided by equipment manufacturers or obtained from equipment
manufacturer specifications such as nameplate rating.
x
One or more industry standards developed through an open process such as
Institute of Electrical and Electronics Engineers (IEEE) or International Council
on Large Electric Systems (CIGRE).
x
A practice that has been verified by testing, performance history or
engineering analysis.
Such as temporary de-ratings of impaired equipment in accordance with good utility practice.
Page 3 of 13
FAC-008-4 5 – Facility Ratings
3.2. The underlying assumptions, design criteria, and methods used to determine the
Equipment Ratings identified in Requirement R3, Part 3.1 including identification
of how each of the following were considered:
3.2.1. Equipment Rating standard(s) used in development of this methodology.
3.2.2. Ratings provided by equipment manufacturers or obtained from
equipment manufacturer specifications.
3.2.3. Ambient conditions (for particular or average conditions or as they vary
in real-time).
3.2.4. Operating limitations. 2
3.3. A statement that a Facility Rating shall respect the most limiting applicable
Equipment Rating of the individual equipment that comprises that Facility.
3.4. The process by which the Rating of equipment that comprises a Facility is
determined.
3.4.1. The scope of equipment addressed shall include, but not be limited to,
transmission conductors, transformers, relay protective devices, terminal
equipment, and series and shunt compensation devices.
3.4.2. The scope of Ratings addressed shall include, as a minimum, both Normal
and Emergency Ratings.
M3. Each Transmission Owner shall have a documented Facility Ratings methodology that
includes all of the items identified in Requirement 3, Parts 3.1 through 3.4.
R4. Reserved.
M4. Reserved.
R5. Reserved.
M5. Reserved.
R6. Each Transmission Owner and Generator Owner shall have Facility Ratings for its
solely and jointly owned Facilities that are consistent with the associated Facility
Ratings methodology or documentation for determining its Facility Ratings. [Violation
Risk Factor: Medium] [Time Horizon: Operations Planning]
M6. Each Transmission Owner and Generator Owner shall have evidence to show that its
Facility Ratings are consistent with the documentation for determining its Facility
Ratings as specified in Requirement R1 or consistent with its Facility Ratings
methodology as specified in Requirements R2 and R3 (Requirement R6).
R7. Reserved.
M7. Reserved.
2
Such as temporary de-ratings of impaired equipment in accordance with good utility practice.
Page 4 of 13
FAC-008-4 5 – Facility Ratings
R8.
Reserved. Each Transmission Owner (and each Generator Owner subject to
Requirement R2) shall provide requested information as specified below (for its solely
and jointly owned Facilities that are existing Facilities, new Facilities, modifications to
existing Facilities and re-ratings of existing Facilities) to its associated Reliability
Coordinator(s), Planning Coordinator(s), Transmission Planner(s), Transmission
Owner(s) and Transmission Operator(s): [Violation Risk Factor: Medium] [Time
Horizon: Operations Planning]
8.1.
As scheduled by the requesting entities:
8.2.
8.1.1.
Facility Ratings
8.1.2.
Identity of the most limiting equipment of the Facilities
Within 30 calendar days (or a later date if specified by the requester), for any
requested Facility with a Thermal Rating that limits the use of Facilities under
the requester’s authority by causing any of the following: 1) An
Interconnection Reliability Operating Limit, 2) A limitation of Total Transfer
Capability, 3) An impediment to generator deliverability, or 4) An impediment
to service to a major load center:
8.2.1.
Identity of the existing next most limiting equipment of the Facility
8.2.2.
The Thermal Rating for the next most limiting equipment identified
in Requirement R8, Part 8.2.1.
M8. Reserved. Each Transmission Owner (and Generator Owner subject to Requirement
R2) shall have evidence, such as a copy of a dated electronic note, or other
comparable evidence to show that it provided its Facility Ratings and identity of
limiting equipment to its associated Reliability Coordinator(s), Planning Coordinator(s),
Transmission Planner(s), Transmission Owner(s) and Transmission Operator(s) in
accordance with Requirement R8.
C. Compliance
1.
Compliance Monitoring Process
1.1. Compliance Enforcement Authority: “Compliance Enforcement Authority”
means NERC or the Regional Entity, or any entity as otherwise designated by an
Applicable Governmental Authority, in their respective roles of monitoring
and/or enforcing compliance with mandatory and enforceable Reliability
Standards in their respective jurisdictions.
1.2. Compliance Monitoring and Enforcement Processes:
x
Self-Certifications
x
Spot Checking
x
Compliance Audits
Page 5 of 13
FAC-008-4 5 – Facility Ratings
x
Self-Reporting
x
Compliance Violation Investigations
x
Complaints
1.3. Evidence Retention: The following evidence retention period(s) identify the
period of time an entity is required to retain specific evidence to demonstrate
compliance. For instances where the evidence retention period specified below
is shorter than the time since the last audit, the Compliance Enforcement
Authority may ask an entity to provide other evidence to show that it was
compliant for the full-time period since the last audit.
The applicable entity shall keep data or evidence to show compliance as
identified below unless directed by its Compliance Enforcement Authority to
retain specific evidence for a longer period of time as part of an investigation.
x
The Generator Owner shall keep its current documentation (for R1) and any
modifications to the documentation that were in force since last compliance
audit period for Measure M1 and Measure M6.
x
The Generator Owner shall keep its current, in force Facility Ratings
methodology (for R2) and any modifications to the methodology that were in
force since last compliance audit period for Measure M2 and Measure M6.
x
The Transmission Owner shall keep its current, in force Facility Ratings
methodology (for R3) and any modifications to the methodology that were in
force since the last compliance audit for Measure M3 and Measure M6.
x
The Transmission Owner and Generator Owner shall keep its current, in force
Facility Ratings and any changes to those ratings for three calendar years for
Measure M6.
x
The Transmission Owner (and Generator Owner that is subject to
Requirement R2) shall keep evidence for Measure M8 for three calendar
years.
x
If a Generator Owner or Transmission Owner is found non-compliant, it shall
keep information related to the non-compliance until found compliant.
x
The Compliance Enforcement Authority shall keep the last audit and all
subsequent compliance records.
1.4. Compliance Monitoring and Enforcement Program: As defined in the NERC
Rules of Procedure, “Compliance Monitoring and Enforcement Program” refers
to the identification of the processes that will be used to evaluate data or
information for the purpose of assessing performance or outcomes with the
associated Reliability Standard.
Page 6 of 13
2.1.
2.2.1
2.2.2
2.2.3
2.2.4
x
x
x
x
The Generator Owner
failed to include in its
Facility Rating
methodology one of the
following Parts of
Requirement R2:
R2.
x
N/A
Lower VSL
R1.
R#
Violation Severity Levels
FAC-008-4 5 – Facility Ratings
x
x
x
2.2.4
2.2.3
2.2.2
2.2.1
2.1.
2.2.1
2.2.2
2.2.3
2.2.4
x
x
x
x
x
The Generator Owner failed
to include in its Facility
Rating Methodology, three
of the following Parts of
Requirement R2:
OR
x
x
The Generator Owner’s
Facility Rating methodology
did not address all the
components of
Requirement R2, Part 2.4.
The Generator Owner failed
to include in its Facility
Rating methodology two of
the following Parts of
Requirement R2:
2.1
The Generator Owner’s
Facility Rating
documentation did not
address Requirement R1,
Part 1.2.
High VSL
The Generator Owner’s
Facility Rating
documentation did not
address Requirement R1,
Part 1.1.
Moderate VSL
Violation Severity Levels
2.1
2.2.1
2.2.2
2.2.3
2.2.4
x
x
x
x
x
Page 7 of 13
The Generator Owner failed to
include in its Facility Rating
Methodology four or more of
the following Parts of
Requirement R2:
OR
The Generator Owner’s Facility
Rating methodology failed to
recognize a facility's rating
based on the most limiting
component rating as required
in Requirement R2, Part 2.3
The Generator Owner failed to
provide documentation for
determining its Facility Ratings.
Severe VSL
R5.
Reserved.
R4.
Reserved.
R3.
R#
3.1
3.2.1
3.2.2
3.2.3
3.2.4
x
x
x
x
x
The Transmission Owner
failed to include in its
Facility Rating
methodology one of the
following Parts of
Requirement R3:
Lower VSL
FAC-008-4 5 – Facility Ratings
x
x
x
x
3.2.4
3.2.3
3.2.2
3.2.1
3.4.2
3.1
3.2.1
3.2.2
3.2.3
3.2.4
x
x
x
x
x
The Transmission Owner
failed to include in its
Facility Rating methodology
three of the following Parts
of Requirement R3:
OR
x
3.4.1
x
x
3.1
The Transmission Owner’s
Facility Rating methodology
did not address either of
the following Parts of
Requirement R3:
High VSL
The Transmission Owner
failed to include in its
Facility Rating methodology
two of the following Parts
of Requirement R3:
Moderate VSL
Violation Severity Levels
x
x
x
x
x
3.2.4
3.2.3
3.2.2
3.2.1
3.1
Page 8 of 13
The Transmission Owner failed
to include in its Facility Rating
methodology four or more of
the following Parts of
Requirement R3:
OR
The Transmission Owner’s
Facility Rating methodology
failed to recognize a Facility's
rating based on the most
limiting component rating as
required in Requirement R3,
Part 3.3
Severe VSL
The responsible entity
failed to establish Facility
Ratings consistent with
the associated Facility
Ratings methodology or
documentation for
determining the Facility
Ratings for 5% or less of
its solely owned and
jointly owned Facilities.
(R6)
Lower VSL
OR
The responsible entity
provided less than 95%, but
The responsible entity
provided less than 100%,
The responsible entity
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
15 calendar days but less
than or equal to 25
calendar days. (R8, Part 8.1)
The responsible entity
failed to establish Facility
Ratings consistent with the
associated Facility Ratings
methodology or
documentation for
determining the Facility
Ratings for more than 5% or
more, but less than up to
(and including) 10% of its
solely owned and jointly
owned Facilities. (R6)
Moderate VSL
The responsible entity
provided less than 90%, but
OR
The responsible entity
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
25 calendar days but less
than or equal to 35
calendar days. (R8, Part 8.1)
The responsible entity
failed to establish Facility
Ratings consistent with the
associated Facility Ratings
methodology or
documentation for
determining the Facility
Ratings for more than 10%
up to (and including) 15% of
its solely owned and jointly
owned Facilities. (R6)
High VSL
Violation Severity Levels
OR
R8.
The responsible entity
Reserved. provided its Facility
Ratings to all of the
requesting entities but
missed meeting the
schedules by up to and
including 15 calendar
days. (R8, Part 8.1)
R7.
Reserved.
R6.
R#
FAC-008-4 5 – Facility Ratings
Page 9 of 13
The responsible entity provided
less than 85% of the required
Rating information to all of the
OR
The responsible entity provided
its Facility Ratings to all of the
requesting entities but missed
meeting the schedules by more
than 35 calendar days. (R8, Part
8.1)
The responsible entity failed to
establish Facility Ratings
consistent with the associated
Facility Ratings methodology or
documentation for determining
the Facility Ratings for more
than15% of its solely owned
and jointly owned Facilities.
(R6)
Severe VSL
Moderate VSL
not less than or equal to
90% of the required Rating
information to all of the
requesting entities. (R8,
Part 8.1)
OR
The responsible entity
provided the required
Rating information to the
requesting entity, but did so
more 15 calendar days but
less than or equal to 25
calendar days late. (R8, Part
8.2)
OR
The responsible entity
provided less than 95%, but
not less than or equal to
90% of the required Rating
information to the
requesting entity. (R8, Part
8.2)
but not less than or equal
to 95% of the required
Rating information to all
of the requesting entities.
(R8, Part 8.1)
OR
The responsible entity
provided the required
Rating information to the
requesting entity, but the
information was provided
up to and including 15
calendar days late. (R8,
Part 8.2)
OR
The responsible entity
provided less than 100%,
but not less than or equal
to 95% of the required
Rating information to the
requesting entity. (R8,
Part 8.2)
None.
The responsible entity
provided less than 90%, but
no less than or equal to
85% of the required Rating
information to the
requesting entity. (R8, Part
8.2)
OR
The responsible entity
provided the required
Rating information to the
requesting entity, but did so
more than 25 calendar days
but less than or equal to 35
calendar days late. (R8, Part
8.2)
OR
not less than or equal to
85% of the required Rating
information to all of the
requesting entities. (R8,
Part 8.1)
High VSL
Violation Severity Levels
Lower VSL
D. Regional Variances
R#
FAC-008-4 5 – Facility Ratings
Page 10 of 13
The responsible entity failed to
provide its Rating information
to the requesting entity. (R8,
Part 8.1)
OR
The responsible entity provided
less than 85 % of the required
Rating information to the
requesting entity. (R8, Part 8.2)
OR
The responsible entity provided
the required Rating information
to the requesting entity, but did
so more than 35 calendar days
late. (R8, Part 8.2)
OR
requesting entities. (R8, Part
8.1)
Severe VSL
None.
E. Associated Documents
FAC-008-4 5 – Facility Ratings
Page 11 of 13
FAC-008-4 5– Facility Ratings
Version History
Version
Date
Action
Change Tracking
1
Feb 7, 2006
Approved by Board of Trustees
New
1
Mar 16, 2007
Approved by FERC
New
2
May 12, 2010
Approved by Board of Trustees
Complete Revision,
merging FAC_008-1
and FAC-009-1 under
Project 2009-06 and
address directives
from Order 693
3
May 24, 2011
Addition of Requirement R8
Project 2009-06
Expansion to address
third directive from
Order 693
3
May 24, 2011
Adopted by NERC Board of Trustees
3
November 17, FERC Order issued approving FAC-008-3
2011
3
May 17, 2012
FERC Order issued directing the VRF for
Requirement R2 be changed from
“Lower” to “Medium”
3
February 7,
2013
R4 and R5 and associated elements
approved by NERC Board of Trustees for
retirement as part of the Paragraph 81
project (Project 2013-02) pending
applicable regulatory approval.
3
November 21, R4 and R5 and associated elements
2013
approved by FERC for retirement as
part of the Paragraph 81 project
(Project 2013-02)
4
TBDMay 9,
2020
R7 and R8 and associated elements
adopted by NERC Board of Trustees for
retirement as part of Project 2018-03
Standards Efficiency Review
Retirements.Adopted by NERC Board of
Trustees
R7 and R8 and
associated elements
approved by NERC
Board of Trustees for
retirement as part of
Project 2018-03
Standard Efficiency
Review Retirements
4
September
17, 2020
Remanded by FERC (Order No. 873).
Withdrawn
Page 12 of 13
FAC-008-4 5– Facility Ratings
Version
5
Date
TBD
Action
Adopted by NERC Board of Trustees
Change Tracking
Requirement R8 and
associated elements
restored in response
to FERC Order No.
873.
Page 13 of 13
FAC-008-5 – Facility Ratings
A. Introduction
1.
Title:
Facility Ratings
2.
Number:
FAC-008-5
3.
Purpose:
To ensure that Facility Ratings used in the reliable planning and
operation of the Bulk Electric System (BES) are determined based
on technically sound principles. A Facility Rating is essential for the
determination of System Operating Limits.
4.
Applicability:
4.1. Transmission Owner
4.2. Generator Owner
5.
Effective Date:
See Implementation Plan.
Page 1 of 13
FAC-008-5 – Facility Ratings
B. Requirements and Measures
R1. Each Generator Owner shall have documentation for determining the Facility Ratings
of its solely and jointly owned generator Facility(ies) up to the low side terminals of
the main step up transformer if the Generator Owner does not own the main step up
transformer and the high side terminals of the main step up transformer if the
Generator Owner owns the main step up transformer. [Violation Risk Factor: Lower]
[Time Horizon: Long-term Planning]
1.1. The documentation shall contain assumptions used to rate the generator and at
least one of the following:
x
Design or construction information such as design criteria, ratings provided
by equipment manufacturers, equipment drawings and/or specifications,
engineering analyses, method(s) consistent with industry standards (e.g.
ANSI and IEEE), or an established engineering practice that has been verified
by testing or engineering analysis.
x
Operational information such as commissioning test results, performance
testing or historical performance records, any of which may be
supplemented by engineering analyses.
1.2. The documentation shall be consistent with the principle that the Facility Ratings
do not exceed the most limiting applicable Equipment Rating of the individual
equipment that comprises that Facility.
M1. Each Generator Owner shall have documentation that shows how its Facility Ratings
were determined as identified in Requirement 1.
R2. Each Generator Owner shall have a documented methodology for determining Facility
Ratings (Facility Ratings methodology) of its solely and jointly owned equipment
connected between the location specified in R1 and the point of interconnection with
the Transmission Owner that contains all of the following. [Violation Risk Factor:
Medium] [Time Horizon: Long-term Planning]
2.1. The methodology used to establish the Ratings of the equipment that comprises
the Facility(ies) shall be consistent with at least one of the following:
x
Ratings provided by equipment manufacturers or obtained from equipment
manufacturer specifications such as nameplate rating.
x
One or more industry standards developed through an open process such as
Institute of Electrical and Electronic Engineers (IEEE) or International Council
on Large Electric Systems (CIGRE).
x
A practice that has been verified by testing, performance history or
engineering analysis.
Page 2 of 13
FAC-008-5 – Facility Ratings
2.2. The underlying assumptions, design criteria, and methods used to determine the
Equipment Ratings identified in Requirement R2, Part 2.1 including identification
of how each of the following were considered:
2.2.1. Equipment Rating standard(s) used in development of this methodology.
2.2.2. Ratings provided by equipment manufacturers or obtained from
equipment manufacturer specifications.
2.2.3. Ambient conditions (for particular or average conditions or as they vary
in real-time).
2.2.4. Operating limitations. 1
2.3. A statement that a Facility Rating shall respect the most limiting applicable
Equipment Rating of the individual equipment that comprises that Facility.
2.4. The process by which the Rating of equipment that comprises a Facility is
determined.
2.4.1. The scope of equipment addressed shall include, but not be limited to,
conductors, transformers, relay protective devices, terminal equipment,
and series and shunt compensation devices.
2.4.2. The scope of Ratings addressed shall include, as a minimum, both Normal
and Emergency Ratings.
M2. Each Generator Owner shall have a documented Facility Ratings methodology that
includes all of the items identified in Requirement 2, Parts 2.1 through 2.4.
R3. Each Transmission Owner shall have a documented methodology for determining
Facility Ratings (Facility Ratings methodology) of its solely and jointly owned Facilities
(except for those generating unit Facilities addressed in R1 and R2) that contains all of
the following: [Violation Risk Factor: Medium] [ Time Horizon: Long-term Planning]
3.1. The methodology used to establish the Ratings of the equipment that comprises
the Facility shall be consistent with at least one of the following:
1
x
Ratings provided by equipment manufacturers or obtained from equipment
manufacturer specifications such as nameplate rating.
x
One or more industry standards developed through an open process such as
Institute of Electrical and Electronics Engineers (IEEE) or International Council
on Large Electric Systems (CIGRE).
x
A practice that has been verified by testing, performance history or
engineering analysis.
Such as temporary de-ratings of impaired equipment in accordance with good utility practice.
Page 3 of 13
FAC-008-5 – Facility Ratings
3.2. The underlying assumptions, design criteria, and methods used to determine the
Equipment Ratings identified in Requirement R3, Part 3.1 including identification
of how each of the following were considered:
3.2.1. Equipment Rating standard(s) used in development of this methodology.
3.2.2. Ratings provided by equipment manufacturers or obtained from
equipment manufacturer specifications.
3.2.3. Ambient conditions (for particular or average conditions or as they vary
in real-time).
3.2.4. Operating limitations. 2
3.3. A statement that a Facility Rating shall respect the most limiting applicable
Equipment Rating of the individual equipment that comprises that Facility.
3.4. The process by which the Rating of equipment that comprises a Facility is
determined.
3.4.1. The scope of equipment addressed shall include, but not be limited to,
transmission conductors, transformers, relay protective devices, terminal
equipment, and series and shunt compensation devices.
3.4.2. The scope of Ratings addressed shall include, as a minimum, both Normal
and Emergency Ratings.
M3. Each Transmission Owner shall have a documented Facility Ratings methodology that
includes all of the items identified in Requirement 3, Parts 3.1 through 3.4.
R4. Reserved.
M4. Reserved.
R5. Reserved.
M5. Reserved.
R6. Each Transmission Owner and Generator Owner shall have Facility Ratings for its
solely and jointly owned Facilities that are consistent with the associated Facility
Ratings methodology or documentation for determining its Facility Ratings. [Violation
Risk Factor: Medium] [Time Horizon: Operations Planning]
M6. Each Transmission Owner and Generator Owner shall have evidence to show that its
Facility Ratings are consistent with the documentation for determining its Facility
Ratings as specified in Requirement R1 or consistent with its Facility Ratings
methodology as specified in Requirements R2 and R3 (Requirement R6).
R7. Reserved.
M7. Reserved.
2
Such as temporary de-ratings of impaired equipment in accordance with good utility practice.
Page 4 of 13
FAC-008-5 – Facility Ratings
R8.
Each Transmission Owner (and each Generator Owner subject to Requirement R2)
shall provide requested information as specified below (for its solely and jointly
owned Facilities that are existing Facilities, new Facilities, modifications to existing
Facilities and re-ratings of existing Facilities) to its associated Reliability
Coordinator(s), Planning Coordinator(s), Transmission Planner(s), Transmission
Owner(s) and Transmission Operator(s): [Violation Risk Factor: Medium] [Time
Horizon: Operations Planning]
8.1.
As scheduled by the requesting entities:
8.2.
8.1.1.
Facility Ratings
8.1.2.
Identity of the most limiting equipment of the Facilities
Within 30 calendar days (or a later date if specified by the requester), for any
requested Facility with a Thermal Rating that limits the use of Facilities under
the requester’s authority by causing any of the following: 1) An
Interconnection Reliability Operating Limit, 2) A limitation of Total Transfer
Capability, 3) An impediment to generator deliverability, or 4) An impediment
to service to a major load center:
8.2.1.
Identity of the existing next most limiting equipment of the Facility
8.2.2.
The Thermal Rating for the next most limiting equipment identified
in Requirement R8, Part 8.2.1.
M8. Each Transmission Owner (and Generator Owner subject to Requirement R2) shall
have evidence, such as a copy of a dated electronic note, or other comparable
evidence to show that it provided its Facility Ratings and identity of limiting equipment
to its associated Reliability Coordinator(s), Planning Coordinator(s), Transmission
Planner(s), Transmission Owner(s) and Transmission Operator(s) in accordance with
Requirement R8.
C. Compliance
1.
Compliance Monitoring Process
1.1. Compliance Enforcement Authority: “Compliance Enforcement Authority”
means NERC or the Regional Entity, or any entity as otherwise designated by an
Applicable Governmental Authority, in their respective roles of monitoring
and/or enforcing compliance with mandatory and enforceable Reliability
Standards in their respective jurisdictions.
1.2. Compliance Monitoring and Enforcement Processes:
x
Self-Certifications
x
Spot Checking
x
Compliance Audits
x
Self-Reporting
Page 5 of 13
FAC-008-5 – Facility Ratings
x
Compliance Violation Investigations
x
Complaints
1.3. Evidence Retention: The following evidence retention period(s) identify the
period of time an entity is required to retain specific evidence to demonstrate
compliance. For instances where the evidence retention period specified below
is shorter than the time since the last audit, the Compliance Enforcement
Authority may ask an entity to provide other evidence to show that it was
compliant for the full-time period since the last audit.
The applicable entity shall keep data or evidence to show compliance as
identified below unless directed by its Compliance Enforcement Authority to
retain specific evidence for a longer period of time as part of an investigation.
x
The Generator Owner shall keep its current documentation (for R1) and any
modifications to the documentation that were in force since last compliance
audit period for Measure M1 and Measure M6.
x
The Generator Owner shall keep its current, in force Facility Ratings
methodology (for R2) and any modifications to the methodology that were in
force since last compliance audit period for Measure M2 and Measure M6.
x
The Transmission Owner shall keep its current, in force Facility Ratings
methodology (for R3) and any modifications to the methodology that were in
force since the last compliance audit for Measure M3 and Measure M6.
x
The Transmission Owner and Generator Owner shall keep its current, in force
Facility Ratings and any changes to those ratings for three calendar years for
Measure M6.
x
The Transmission Owner (and Generator Owner that is subject to
Requirement R2) shall keep evidence for Measure M8 for three calendar
years.
x
If a Generator Owner or Transmission Owner is found non-compliant, it shall
keep information related to the non-compliance until found compliant.
x
The Compliance Enforcement Authority shall keep the last audit and all
subsequent compliance records.
1.4. Compliance Monitoring and Enforcement Program: As defined in the NERC
Rules of Procedure, “Compliance Monitoring and Enforcement Program” refers
to the identification of the processes that will be used to evaluate data or
information for the purpose of assessing performance or outcomes with the
associated Reliability Standard.
Page 6 of 13
2.1.
2.2.1
2.2.2
2.2.3
2.2.4
x
x
x
x
The Generator Owner
failed to include in its
Facility Rating
methodology one of the
following Parts of
Requirement R2:
R2.
x
N/A
Lower VSL
R1.
R#
Violation Severity Levels
FAC-008-5 – Facility Ratings
x
x
x
2.2.4
2.2.3
2.2.2
2.2.1
2.1.
2.2.1
2.2.2
2.2.3
2.2.4
x
x
x
x
x
The Generator Owner failed
to include in its Facility
Rating Methodology, three
of the following Parts of
Requirement R2:
OR
x
x
The Generator Owner’s
Facility Rating methodology
did not address all the
components of
Requirement R2, Part 2.4.
The Generator Owner failed
to include in its Facility
Rating methodology two of
the following Parts of
Requirement R2:
2.1
The Generator Owner’s
Facility Rating
documentation did not
address Requirement R1,
Part 1.2.
High VSL
The Generator Owner’s
Facility Rating
documentation did not
address Requirement R1,
Part 1.1.
Moderate VSL
Violation Severity Levels
2.1
2.2.1
2.2.2
2.2.3
2.2.4
x
x
x
x
x
Page 7 of 13
The Generator Owner failed to
include in its Facility Rating
Methodology four or more of
the following Parts of
Requirement R2:
OR
The Generator Owner’s Facility
Rating methodology failed to
recognize a facility's rating
based on the most limiting
component rating as required
in Requirement R2, Part 2.3
The Generator Owner failed to
provide documentation for
determining its Facility Ratings.
Severe VSL
R5.
Reserved.
R4.
Reserved.
R3.
R#
3.1
3.2.1
3.2.2
3.2.3
3.2.4
x
x
x
x
x
The Transmission Owner
failed to include in its
Facility Rating
methodology one of the
following Parts of
Requirement R3:
Lower VSL
FAC-008-5 – Facility Ratings
x
x
x
x
3.2.4
3.2.3
3.2.2
3.2.1
3.4.2
3.1
3.2.1
3.2.2
3.2.3
3.2.4
x
x
x
x
x
The Transmission Owner
failed to include in its
Facility Rating methodology
three of the following Parts
of Requirement R3:
OR
x
3.4.1
x
x
3.1
The Transmission Owner’s
Facility Rating methodology
did not address either of
the following Parts of
Requirement R3:
High VSL
The Transmission Owner
failed to include in its
Facility Rating methodology
two of the following Parts
of Requirement R3:
Moderate VSL
Violation Severity Levels
x
x
x
x
x
3.2.4
3.2.3
3.2.2
3.2.1
3.1
Page 8 of 13
The Transmission Owner failed
to include in its Facility Rating
methodology four or more of
the following Parts of
Requirement R3:
OR
The Transmission Owner’s
Facility Rating methodology
failed to recognize a Facility's
rating based on the most
limiting component rating as
required in Requirement R3,
Part 3.3
Severe VSL
R8.
R7.
Reserved.
R6.
R#
The responsible entity
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
15 calendar days but less
than or equal to 25
calendar days. (R8, Part 8.1)
OR
The responsible entity
provided less than 95%, but
OR
The responsible entity
provided less than 100%,
The responsible entity
failed to establish Facility
Ratings consistent with the
associated Facility Ratings
methodology or
documentation for
determining the Facility
Ratings for more than 5% or
more, but less than up to
(and including) 10% of its
solely owned and jointly
owned Facilities. (R6)
Moderate VSL
The responsible entity
provided less than 90%, but
OR
The responsible entity
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
25 calendar days but less
than or equal to 35
calendar days. (R8, Part 8.1)
The responsible entity
failed to establish Facility
Ratings consistent with the
associated Facility Ratings
methodology or
documentation for
determining the Facility
Ratings for more than 10%
up to (and including) 15% of
its solely owned and jointly
owned Facilities. (R6)
High VSL
Violation Severity Levels
The responsible entity
provided its Facility
Ratings to all of the
requesting entities but
missed meeting the
schedules by up to and
including 15 calendar
days. (R8, Part 8.1)
The responsible entity
failed to establish Facility
Ratings consistent with
the associated Facility
Ratings methodology or
documentation for
determining the Facility
Ratings for 5% or less of
its solely owned and
jointly owned Facilities.
(R6)
Lower VSL
FAC-008-5 – Facility Ratings
Page 9 of 13
The responsible entity provided
less than 85% of the required
Rating information to all of the
OR
The responsible entity provided
its Facility Ratings to all of the
requesting entities but missed
meeting the schedules by more
than 35 calendar days. (R8, Part
8.1)
The responsible entity failed to
establish Facility Ratings
consistent with the associated
Facility Ratings methodology or
documentation for determining
the Facility Ratings for more
than15% of its solely owned
and jointly owned Facilities.
(R6)
Severe VSL
The responsible entity provided
less than 85 % of the required
Rating information to the
requesting entity. (R8, Part 8.2)
OR
The responsible entity failed to
provide its Rating information
to the requesting entity. (R8,
Part 8.1)
OR
The responsible entity
provided the required
Rating information to the
requesting entity, but did so
more than 25 calendar days
but less than or equal to 35
calendar days late. (R8, Part
8.2)
OR
The responsible entity
provided less than 90%, but
no less than or equal to
85% of the required Rating
information to the
requesting entity. (R8, Part
8.2)
OR
The responsible entity
provided the required
Rating information to the
requesting entity, but did so
more 15 calendar days but
less than or equal to 25
calendar days late. (R8, Part
8.2)
OR
The responsible entity
provided less than 95%, but
not less than or equal to
90% of the required Rating
information to the
requesting entity. (R8, Part
8.2)
OR
The responsible entity
provided the required
Rating information to the
requesting entity, but the
information was provided
up to and including 15
calendar days late. (R8,
Part 8.2)
OR
The responsible entity
provided less than 100%,
but not less than or equal
to 95% of the required
Rating information to the
requesting entity. (R8,
Part 8.2)
None.
OR
Page 10 of 13
The responsible entity provided
the required Rating information
to the requesting entity, but did
so more than 35 calendar days
late. (R8, Part 8.2)
OR
requesting entities. (R8, Part
8.1)
not less than or equal to
85% of the required Rating
information to all of the
requesting entities. (R8,
Part 8.1)
not less than or equal to
90% of the required Rating
information to all of the
requesting entities. (R8,
Part 8.1)
but not less than or equal
to 95% of the required
Rating information to all
of the requesting entities.
(R8, Part 8.1)
Severe VSL
High VSL
Moderate VSL
Violation Severity Levels
Lower VSL
D. Regional Variances
R#
FAC-008-5 – Facility Ratings
None.
E. Associated Documents
FAC-008-5 – Facility Ratings
Page 11 of 13
FAC-008-5 – Facility Ratings
Version History
Version
Date
Action
Change Tracking
1
Feb 7, 2006
Approved by Board of Trustees
New
1
Mar 16, 2007
Approved by FERC
New
2
May 12, 2010
Approved by Board of Trustees
Complete Revision,
merging FAC_008-1
and FAC-009-1 under
Project 2009-06 and
address directives
from Order 693
3
May 24, 2011
Addition of Requirement R8
Project 2009-06
Expansion to address
third directive from
Order 693
3
May 24, 2011
Adopted by NERC Board of Trustees
3
November 17, FERC Order issued approving FAC-008-3
2011
3
May 17, 2012
FERC Order issued directing the VRF for
Requirement R2 be changed from
“Lower” to “Medium”
3
February 7,
2013
R4 and R5 and associated elements
approved by NERC Board of Trustees for
retirement as part of the Paragraph 81
project (Project 2013-02) pending
applicable regulatory approval.
3
November 21, R4 and R5 and associated elements
2013
approved by FERC for retirement as
part of the Paragraph 81 project
(Project 2013-02)
4
May 9, 2020
R7 and R8 and associated elements
adopted by NERC Board of Trustees for
retirement as part of Project 2018-03
Standards Efficiency Review
Retirements.
4
September
17, 2020
Remanded by FERC (Order No. 873).
Withdrawn
5
TBD
Adopted by NERC Board of Trustees
Requirement R8 and
associated elements
restored in response
Page 12 of 13
FAC-008-5 – Facility Ratings
Version
Date
Action
Change Tracking
to FERC Order No.
873.
Page 13 of 13
Implementation Plan
Project 2018-03 Standards Efficiency Review Retirements
Reliability Standard FAC-008-5
Applicable Standard(s)
x
FAC-008-5 – Facility Ratings
Requested Retirement(s)
x
FAC-008-3 – Facility Ratings
Applicable Entities
x
Transmission Owner
x
Generator Owner
Background
In 2017, NERC initiated the Standards Efficiency Review (SER). The scope of this project was to use a
risk-based approach to identify potential efficiencies through retirement of Reliability Standard
requirements. Following the completion of the first phase of work, the SER standard drafting team
(SDT) submitted a Standards Authorization Request (SAR) to the NERC Standards Committee, which
the Standards Committee accepted in August 2018.
Project 2018-03 Standards Efficiency Review Retirements was initiated to consider and implement
the recommendations for Reliability Standard retirements contained in the SAR.
Among other things, the SER SDT proposed retiring Requirements R7 and R8 in Reliability Standard
FAC-008-3 as redundant and not needed for reliability. Proposed Reliability Standard FAC-008-4
passed final ballot on May 2, 2019; was adopted by the Board of Trustees on May 9, 2019; and was
filed with the Federal Energy Regulatory Commission (FERC) on June 7, 2019 for approval.
On September 17, 2020, the Federal Regulatory Commission (FERC) issued Order No. 873. 1 With
respect to proposed Reliability Standard FAC-008-4, FERC determined that the retirement of
Requirement R7 would be appropriate, but rejected the retirement of Requirement R8, concluding
that “… Requirement R8 is needed to ensure that limiting and next limiting equipment is identified
and communicated” (P 40). FERC remanded proposed Reliability Standard FAC-008-4 to NERC for
further consideration.
1
Order No. 873, Electric Reliability Organization Proposal to Retire Requirements in Reliability Standards Under the NERC Standards
Efficiency Review, 172 FERC ¶ 61,225 (2020),
https://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Order%20on%20SER%20Retirements.pdf.
RELIABILITY | RESILIENCE | SECURITY
Following the FERC remand, NERC submitted a notice to the remaining applicable governmental
authorities requesting that FAC-008-4 be withdrawn in their respective jurisdictions.
Proposed Reliability Standard FAC-008-5 would retire Requirement R7 of currently effective
Reliability Standard FAC-008-3.
General Considerations
For Reliability Standard FAC-008-5– Facility Ratings, the standard will become effective on the first day
of the first calendar quarter that is three (3) months after applicable regulatory approval. This
implementation timeframe reflects consideration that entities may need time to update their internal
systems and documentation to reflect the new standard version numbers.
Effective Date
Reliability Standard FAC-008-5– Facility Ratings
Where approval by an applicable governmental authority is required, the standard shall become
effective on the first day of the first calendar quarter that is three (3) months after the effective date of
the applicable governmental authority’s order approving the standard, or as otherwise provided for by
the applicable governmental authority.
Where approval by an applicable governmental authority is not required, the standard shall become
effective on the first day of the first calendar quarter that is three (3) months after the date the
standard is adopted by the NERC Board of Trustees, or as otherwise provided for in that jurisdiction.
Retirement Date
Reliability Standard FAC-008-3 – Facility Ratings
Reliability Standard FAC-008-3 shall be retired immediately prior to the effective date of the revised
standard in the particular jurisdiction in which the revised standard is becoming effective.
Implementation Plan | Project 2018-03 Standards Efficiency Review Retirements
FAC-008-5 | November 2020
2
Unofficial Comment Form
Project 2018-03 Standards Efficiency Review Retirements
Do not use this form for submitting comments. Use the Standards Balloting and Commenting System
(SBS) to submit comments on FAC-008-5 – Facility Ratings by 8 p.m. Eastern, Wednesday, January 13,
2021.
m. Eastern, Thursday, August 20, 2015
Additional information is available on the project page. If you have questions, contact Standards
Developer, Laura Anderson (via email), or at 404-446-9671.
Background Information
In 2017, NERC initiated the Standards Efficiency Review (SER). The scope of this project was to use a riskbased approach to identify potential efficiencies through retirement of Reliability Standard Requirements.
Following the completion of the first phase of work, the SER standard drafting team (SDT) submitted a
SAR to the NERC Standards Committee, which the Standards Committee accepted in August 2018.
Project 2018-03 Standards Efficiency Review Retirements was initiated to consider and implement the
recommendations for Reliability Standard retirements contained in the SAR.
Among other things, the SER SDT proposed retiring Requirements R7 and R8 in Reliability Standard FAC008-3 as redundant and not needed for reliability. Proposed Reliability Standard FAC-008-4 passed final
ballot at 95.74 percent on May 2, 2019; was adopted by the Board of Trustees on May 9, 2019; and was
filed with the Federal Energy Regulatory Commission (FERC) on June 7, 2019 for approval.
On September 17, 2020, FERC issued Order No. 873. 1 With respect to proposed Reliability Standard FAC008-4, FERC determined that the retirement of Requirement R7 would be appropriate, but rejected the
retirement of Requirement R8, concluding that “… Requirement R8 is needed to ensure that limiting and
next limiting equipment is identified and communicated” (P 40). FERC remanded proposed Reliability
Standard FAC-008-4 to NERC for further consideration.
The SER SDT has met, considered the issues contained in FERC’s Order No. 873, and has developed
proposed Reliability Standard FAC-008-5, which would retain Requirement R8 and retire Requirement R7
of FAC-008-3.
1 Order No. 873, Electric Reliability Organization Proposal to Retire Requirements in Reliability Standards under the NERC Standards Efficiency
Review, 172 FERC ¶ 61,225 (2020), https://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Order%20on%20SER%20Retirements.pdf.
RELIABILITY | RESILIENCE | SECURITY
Questions
1. The SDT is proposing to retire Requirements R7 from FAC-008-3, as indicated in previously
proposed FAC-008-4, and retain Requirement R8. Do you agree with the SDT’s proposal to retire
Requirement R7? If you do not agree, please provide comments. Or, if you agree but have
comments or suggestions on the SDT’s proposal, please provide your explanation.
Yes
No
Comments:
2. Please provide any additional comments for the SDT to consider that have not already been
provided in the questions above.
Comments:
Unofficial Comment Form | Project 2018-03 Standards Efficiency Review Retirements
FAC-008-5 | November 2020 - January 2021
2
Violation Risk Factor and Violation Severity Level
Justifications
Project 2018-03 Standards Efficiency Review Retirements
This document provides the standard drafting team’s (SDT’s) justification for assignment of violation risk factors (VRFs) and violation severity
levels (VSLs) for each requirement in proposed Reliability Standard FAC-008-5. Each requirement is assigned a VRF and a VSL. These elements
support the determination of an initial value range for the Base Penalty Amount regarding violations of requirements in FERC-approved
Reliability Standards, as defined in the Electric Reliability Organizations (ERO) Sanction Guidelines. The SDT applied the following NERC criteria
and FERC Guidelines when developing the VRFs and VSLs for the requirements.
NERC Criteria for Violation Risk Factors
High Risk Requirement
A requirement that, if violated, could directly cause or contribute to Bulk Electric System instability, separation, or a cascading sequence of
failures, or could place the Bulk Electric System at an unacceptable risk of instability, separation, or cascading failures; or, a requirement in a
planning time frame that, if violated, could, under emergency, abnormal, or restorative conditions anticipated by the preparations, directly
cause or contribute to Bulk Electric System instability, separation, or a cascading sequence of failures, or could place the Bulk Electric System
at an unacceptable risk of instability, separation, or cascading failures, or could hinder restoration to a normal condition.
Medium Risk Requirement
A requirement that, if violated, could directly affect the electrical state or the capability of the Bulk Electric System, or the ability to effectively
monitor and control the Bulk Electric System. However, violation of a medium risk requirement is unlikely to lead to Bulk Electric System
instability, separation, or cascading failures; or, a requirement in a planning time frame that, if violated, could, under emergency, abnormal,
or restorative conditions anticipated by the preparations, directly and adversely affect the electrical state or capability of the Bulk Electric
System, or the ability to effectively monitor, control, or restore the Bulk Electric System. However, violation of a medium risk requirement is
unlikely, under emergency, abnormal, or restoration conditions anticipated by the preparations, to lead to Bulk Electric System instability,
separation, or cascading failures, nor to hinder restoration to a normal condition.
RELIABILITY | RESILIENCE | SECURITY
Lower Risk Requirement
A requirement that is administrative in nature and a requirement that, if violated, would not be expected to adversely affect the electrical
state or capability of the Bulk Electric System, or the ability to effectively monitor and control the Bulk Electric System; or, a requirement that
is administrative in nature and a requirement in a planning time frame that, if violated, would not, under the emergency, abnormal, or
restorative conditions anticipated by the preparations, be expected to adversely affect the electrical state or capability of the Bulk Electric
System, or the ability to effectively monitor, control, or restore the Bulk Electric System.
FERC Guidelines for Violation Risk Factors
Guideline (1) – Consistency with the Conclusions of the Final Blackout Report
FERC seeks to ensure that VRFs assigned to Requirements of Reliability Standards in these identified areas appropriately reflect their historical
critical impact on the reliability of the Bulk-Power System. In the VSL Order, FERC listed critical areas (from the Final Blackout Report) where
violations could severely affect the reliability of the Bulk-Power System:
•
Emergency operations
•
Vegetation management
•
Operator personnel training
•
Protection systems and their coordination
•
Operating tools and backup facilities
•
Reactive power and voltage control
•
System modeling and data exchange
•
Communication protocol and facilities
•
Requirements to determine equipment ratings
•
Synchronized data recorders
•
Clearer criteria for operationally critical facilities
•
Appropriate use of transmission loading relief.
VRF and VSL Justifications | Project 2018-03 Standards Efficiency Review Retirements
FAC-008-5 | November 2020
2
Guideline (2) – Consistency within a Reliability Standard
FERC expects a rational connection between the sub-Requirement VRF assignments and the main Requirement VRF assignment.
Guideline (3) – Consistency among Reliability Standards
FERC expects the assignment of VRFs corresponding to Requirements that address similar reliability goals in different Reliability Standards
would be treated comparably.
Guideline (4) – Consistency with NERC’s Definition of the Violation Risk Factor Level
Guideline (4) was developed to evaluate whether the assignment of a particular VRF level conforms to NERC’s definition of that risk level.
Guideline (5) – Treatment of Requirements that Co-mingle More Than One Obligation
Where a single Requirement co-mingles a higher risk reliability objective and a lesser risk reliability objective, the VRF assignment for such
Requirements must not be watered down to reflect the lower risk level associated with the less important objective of the Reliability
Standard.
VRF and VSL Justifications | Project 2018-03 Standards Efficiency Review Retirements
FAC-008-5 | November 2020
3
NERC Criteria for Violation Severity Levels
VSLs define the degree to which compliance with a requirement was not achieved. Each requirement must have at least one VSL. While it is
preferable to have four VSLs for each requirement, some requirements do not have multiple “degrees” of noncompliant performance and
may have only one, two, or three VSLs.
VSLs should be based on NERC’s overarching criteria shown in the table below:
Lower VSL
Moderate VSL
The performance or product
measured almost meets the full
intent of the requirement.
The performance or product
measured meets the majority of
the intent of the requirement.
High VSL
The performance or product
measured does not meet the
majority of the intent of the
requirement, but does meet
some of the intent.
Severe VSL
The performance or product
measured does not
substantively meet the intent of
the requirement.
FERC Order of Violation Severity Levels
The FERC VSL guidelines are presented below, followed by an analysis of whether the VSLs proposed for each requirement in the standard
meet the FERC Guidelines for assessing VSLs:
Guideline (1) – Violation Severity Level Assignments Should Not Have the Unintended Consequence of Lowering the Current
Level of Compliance
Compare the VSLs to any prior levels of non-compliance and avoid significant changes that may encourage a lower level of compliance than
was required when levels of non-compliance were used.
Guideline (2) – Violation Severity Level Assignments Should Ensure Uniformity and Consistency in the Determination of
Penalties
A violation of a “binary” type requirement must be a “Severe” VSL.
Do not use ambiguous terms such as “minor” and “significant” to describe noncompliant performance.
Guideline (3) – Violation Severity Level Assignment Should Be Consistent with the Corresponding Requirement
VSLs should not expand on what is required in the requirement.
VRF and VSL Justifications | Project 2018-03 Standards Efficiency Review Retirements
FAC-008-5 | November 2020
4
Guideline (4) – Violation Severity Level Assignment Should Be Based on a Single Violation, Not on a Cumulative Number of
Violations
Unless otherwise stated in the requirement, each instance of non-compliance with a requirement is a separate violation. Section 4 of the
Sanction Guidelines states that assessing penalties on a per violation per day basis is the “default” for penalty calculations.
VRF Justification for FAC-008-5, Requirement R1
The VRF did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VRF Justification for FAC-008-5, Requirement R2
The VRF did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VRF Justification for FAC-008-5, Requirement R3
The VRF did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VRF Justification for FAC-008-5, Requirement R6
The VRF did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VRF Justification for FAC-008-5, Requirement R8
The VRF did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VSL Justification for FAC-008-5, Requirement R1
The VSL did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VSL Justification for FAC-008-5, Requirement R2
The VSL did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VSL Justification for FAC-008-5, Requirement R3
The VSL did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VSL Justification for FAC-008-5, Requirement R6
The VSL did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VSL Justification for FAC-008-5, Requirement R8
The VSL did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VRF and VSL Justifications | Project 2018-03 Standards Efficiency Review Retirements
FAC-008-5 | November 2020
5
Standards Announcement
Project 2018-03 Standards Efficiency Review Retirements
Formal Comment Period Open through January 13, 2021
Ballot Pools Forming through December 29, 2020
Now Available
A 45-day comment period for FAC-008-5 – Facility Ratings is open through 8 p.m. Eastern, Wednesday,
January 13, 2021.
Commenting
Use the Standards Balloting and Commenting System (SBS) to submit comments. If you experience
issues using the SBS, contact Wendy Muller. An unofficial Word version of the comment form is posted
on the project page.
Ballot Pools
Ballot pools are being formed through 8 p.m. Eastern, Tuesday, December 29, 2020. Registered Ballot
Body members can join the ballot pools here.
•
Contact NERC IT support directly at https://support.nerc.net/ (Monday – Friday, 8 a.m. - 5 p.m.
Eastern) for problems regarding accessing the SBS due to a forgotten password, incorrect
credential error messages, or system lock-out.
•
Passwords expire every 6 months and must be reset.
•
The SBS is not supported for use on mobile devices.
•
Please be mindful of ballot and comment period closing dates. We ask to allow at least 48 hours
for NERC support staff to assist with inquiries. Therefore, it is recommended that users try logging
into their SBS accounts prior to the last day of a comment/ballot period.
Next Steps
The initial ballot for the standard and non-binding poll of the associated Violation Risk Factors and
Violation Severity Levels, will be conducted January 4-13, 2021.
For information on the Standards Development Process, refer to the Standard Processes Manual.
For more information or assistance, contact Standards Developer, Laura Anderson (via email) or at (404)
446-9671.
North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com
RELIABILITY | RESILIENCE | SECURITY
Comment Report
Project Name:
2018-03 Standards Efficiency Review Retirements | FAC-008-5
Comment Period Start Date:
11/30/2020
Comment Period End Date:
1/13/2021
Associated Ballots:
2018-03 Standards Efficiency Review Retirements FAC-008-5 IN 1 ST
There were 45 sets of responses, including comments from approximately 107 different people from approximately 81 companies
representing 10 of the Industry Segments as shown in the table on the following pages.
Questions
1. The SDT is proposing to retire Requirements R7 from FAC-008-3, as indicated in previously proposed FAC-008-4, and retain Requirement
R8. Do you agree with the SDT’s proposal to retire Requirement R7? If you do not agree, please provide comments. Or, if you agree but have
comments or suggestions on the SDT’s proposal, please provide your explanation.
2. If desired, please provide additional comments for the SDT to consider.
Organization
Name
MRO
Name
Dana Klem
Segment(s)
1,2,3,4,5,6
Region
MRO
Group
Name
MRO NSRF
Group Member
Name
Group
Group
Member
Member
Organization Segment(s)
Joseph
DePoorter
Madison Gas
& Electric
Larry Heckert
Alliant Energy 4
MRO
Michael
Brytowski
Great River
Energy
MRO
Jodi Jensen
Western Area 1,6
Power
Administration
MRO
Andy Crooks
SaskPower
Corporation
1
MRO
Bryan Sherrow
Kansas City
1
Board of
Public Utilities
MRO
Bobbi Welch
Omaha Public 1,3,5,6
Power District
MRO
Jeremy Voll
Basin Electric 1
Power
Cooperative
MRO
Bobbi Welch
Midcontinent
ISO
MRO
Douglas Webb
Kansas City
1,3,5,6
Power & Light
MRO
Fred Meyer
Algonquin
Power Co.
1
MRO
John Chang
Manitoba
Hydro
1,3,6
MRO
James Williams Southwest
Power Pool,
Inc.
2
MRO
Jamie Monette
1
MRO
1,3,5
MRO
Minnesota
Power /
ALLETE
Jamison Cawley Nebraska
Public Power
3,4,5,6
1,3,5,6
2
Group
Member
Region
MRO
Sing Tay
Oklahoma
1,3,5,6
Gas & Electric
MRO
Terry Harbour
MidAmerican
Energy
MRO
1,3
Troy Brumfield
DTE Energy - Karie
Detroit Edison Barczak
Company
Duke Energy
FirstEnergy FirstEnergy
Corporation
Northeast
Power
Coordinating
Council
3
Kim Thomas 1,3,5,6
Mark Garza
Ruida Shu
American
1
Transmission
Company
DTE Energy Adrian Raducea DTE Energy - 5
- DTE
Detroit Edison
Company
Electric
1,2,3,4,5,6,7,8,9,10 NPCC
FE Voter
NPCC
Regional
Standards
Committee
RF
Daniel Herring
DTE Energy - 4
DTE Electric
RF
Karie Barczak
DTE Energy - 3
DTE Electric
RF
FRCC,RF,SERC,Texas Duke Energy Laura Lee
Duke Energy
RE
Dale Goodwine Duke Energy
4
MRO
1
SERC
5
SERC
Greg Cecil
Duke Energy
6
RF
Julie Severino
FirstEnergy FirstEnergy
Corporation
1
RF
Aaron
Ghodooshim
FirstEnergy FirstEnergy
Corporation
3
RF
Robert Loy
FirstEnergy FirstEnergy
Solutions
5
RF
Ann Carey
FirstEnergy FirstEnergy
Solutions
6
RF
Mark Garza
FirstEnergyFirstEnergy
4
RF
Guy V. Zito
Northeast
Power
Coordinating
Council
10
NPCC
Randy
MacDonald
New
Brunswick
Power
2
NPCC
Glen Smith
Entergy
Services
4
NPCC
Alan Adamson
New York
State
Reliability
Council
7
NPCC
David Burke
Orange &
Rockland
Utilities
3
NPCC
1
NPCC
Michele Tondalo UI
Helen Lainis
IESO
2
NPCC
David Kiguel
Independent
7
NPCC
Paul
Malozewski
Hydro One
3
Networks, Inc.
NPCC
Nick Kowalczyk Orange and
Rockland
1
NPCC
Joel Charlebois AESI Acumen
Engineered
Solutions
International
Inc.
5
NPCC
Mike Cooke
Ontario Power 4
Generation,
Inc.
NPCC
Salvatore
Spagnolo
New York
Power
Authority
1
NPCC
Shivaz Chopra
New York
Power
Authority
5
NPCC
Deidre Altobell
Con Ed Consolidated
Edison
4
NPCC
Dermot Smyth
Con Ed 1
Consolidated
Edison Co. of
New York
NPCC
Peter Yost
Con Ed 3
Consolidated
Edison Co. of
New York
NPCC
Cristhian Godoy Con Ed 6
Consolidated
Edison Co. of
New York
NPCC
Sean Bodkin
Dominion Dominion
Resources,
Inc.
6
NPCC
Nurul Abser
NB Power
Corporation
1
NPCC
Randy
MacDonald
NB Power
Corporation
2
NPCC
Michael
Ridolfino
Central
Hudson Gas
and Electric
1
NPCC
Vijay Puran
NYSPS
6
NPCC
ALAN
ADAMSON
New York
State
Reliability
Council
10
NPCC
Sean Cavote
PSEG - Public 1
Service
Electric and
Gas Co.
NPCC
Brian Robinson Utility
Services
5
NPCC
Quintin Lee
Eversource
Energy
1
NPCC
Jim Grant
NYISO
2
NPCC
John Pearson
ISONE
2
NPCC
John Hastings
National Grid
USA
1
NPCC
Michael Jones
National Grid
USA
1
NPCC
Nicolas Turcotte Hydro-Qu?bec 1
TransEnergie
NPCC
Chantal Mazza
NPCC
Hydro-Quebec 2
1. The SDT is proposing to retire Requirements R7 from FAC-008-3, as indicated in previously proposed FAC-008-4, and retain Requirement
R8. Do you agree with the SDT’s proposal to retire Requirement R7? If you do not agree, please provide comments. Or, if you agree but have
comments or suggestions on the SDT’s proposal, please provide your explanation.
Marty Hostler - Northern California Power Agency - 3,4,5,6
No
Answer
Document Name
Comment
Yes, R7 should be retired. R8 should also be retired. However, FERC did not agree to Retire R8 in their last ruling on this matter.
Consequently, I am balloting to retire what we can agree to retire.
Likes
0
Dislikes
0
Response
Dana Klem - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO NSRF
Yes
Answer
Document Name
Comment
The NSRF agrees with the SER Retirements.
Likes
0
Dislikes
0
Response
Michael Whitney - Northern California Power Agency - 3,4,5,6
Answer
Document Name
Comment
Yes
Yes, R7 should be retired. R8 should also be retired. However, FERC did not agree to Retire R8 in their last ruling on this matter. Consequently, I am
balloting to retire what we can agree to retire.
Likes
0
Dislikes
0
Response
Dennis Sismaet - Northern California Power Agency - 6
Yes
Answer
Document Name
Comment
Yes, R7 should be retired. R8 should also be retired. However, FERC did not agree to Retire R8 in their last ruling on this matter.
Consequently, I am balloting to retire what we can agree to retire
Likes
0
Dislikes
0
Response
Truong Le - Truong Le On Behalf of: Carol Chinn, Florida Municipal Power Agency, 6, 4, 5, 3; Chris Gowder, Florida Municipal Power Agency,
6, 4, 5, 3; Dale Ray, Florida Municipal Power Agency, 6, 4, 5, 3; Richard Montgomery, Florida Municipal Power Agency, 6, 4, 5, 3; - Truong Le
Yes
Answer
Document Name
Comment
Yes, R7 should be retired. R8 should also be retired. However, FERC did not agree to Retire R8 in their last ruling on this matter.
Likes
0
Dislikes
0
Response
Leonard Kula - Independent Electricity System Operator - 2
Answer
Document Name
Yes
Comment
N/A.
Likes
0
Dislikes
0
Response
Brandon Gleason - Electric Reliability Council of Texas, Inc. - 2
Yes
Answer
Document Name
Comment
None.
Likes
0
Dislikes
0
Response
Mark Gray - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Yes
Answer
Document Name
Comment
EEI supports the retirement of Requirement R7 and retention of Requirement R8.
Likes
0
Dislikes
0
Response
Daniel Gacek - Exelon - 1
Answer
Document Name
Comment
Yes
Exelon concurs with the EEI comment, supporting the retirement of Requirement R7 and the retention of Requirement R8.
Submitted on behalf of Exelon, Segments 1, 3, 5, 6
Likes
0
Dislikes
0
Response
W. Dwayne Preston - Austin Energy - 3
Yes
Answer
Document Name
Comment
Austin Energy agrees with the comments submitted by Platter River Power.
However, Austin Energy would like the SDT to consider providing clarification to the sub-requirement R8.2 where, when requested for the owner to
provide within 30-days, or other agreed upon timeframe, be clarified so that it is not an opening for expansion by auditors to request "cart blanc" the
next most limiting element for all facilities. Auditors are requesting the "next most limiting element" expanding the scope of the standard.
Likes
1
Dislikes
Platte River Power Authority, 5, Archie Tyson
0
Response
Jun Hua - Austin Energy - 4
Yes
Answer
Document Name
Comment
Austin Energy agrees with the comments submitted by Platter River Power.
However, Austin Energy would like the SDT to consider providing clarification to the sub-requirement R8.2 where, when requested for the owner to
provide within 30-days, or other agreed upon timeframe, be clarified so that it is not an opening for expansion by auditors to request "cart blanc" the
next most limiting element for all facilities. Auditors are requesting the "next most limiting element" expanding the scope of the standard.
Likes
1
Dislikes
Response
Platte River Power Authority, 5, Archie Tyson
0
Michael Dillard - Austin Energy - 5
Yes
Answer
Document Name
Comment
Austin Energy agrees with the comments submitted by Platter River Power.
However, Austin Energy would like the SDT to consider providing clarification to the sub-requirement R8.2 where, when requested for the owner to
provide within 30-days, or other agreed upon timeframe, be clarified so that it is not an opening for expansion by auditors to request "cart blanc" the
next most limiting element for all facilities. Auditors are requesting the "next most limiting element" expanding the scope of the standard.
Likes
1
Dislikes
Platte River Power Authority, 5, Archie Tyson
0
Response
Carl Pineault - Hydro-Qu?bec Production - 5
Yes
Answer
Document Name
Comment
No comments
Likes
0
Dislikes
0
Response
Larry Heckert - Alliant Energy Corporation Services, Inc. - 4
Yes
Answer
Document Name
Comment
No additional comments.
Likes
0
Dislikes
Response
0
Bobbi Welch - Midcontinent ISO, Inc. - 2
Yes
Answer
Document Name
Comment
MISO supports the retirement of Requirement R7 and the retention of Requirement R8.
Likes
0
Dislikes
0
Response
Colleen Campbell - AES - Indianapolis Power and Light Co. - 3
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Thomas Foltz - AEP - 5
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Kjersti Drott - Tri-State G and T Association, Inc. - 1
Answer
Document Name
Comment
Yes
Likes
0
Dislikes
0
Response
Daniela Atanasovski - APS - Arizona Public Service Co. - 1
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Karie Barczak - DTE Energy - Detroit Edison Company - 3, Group Name DTE Energy - DTE Electric
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Kim Thomas - Duke Energy - 1,3,5,6 - Texas RE,SERC,RF, Group Name Duke Energy
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
Response
0
Bruce Reimer - Manitoba Hydro - 1
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Jeremy Lorigan - Seminole Electric Cooperative, Inc. - 3
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Anton Vu - Los Angeles Department of Water and Power - 6
Answer
Document Name
Comment
Yes
Likes
0
Dislikes
0
Response
Richard Jackson - U.S. Bureau of Reclamation - 1
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Tammy Porter - Tammy Porter On Behalf of: Lee Maurer, Oncor Electric Delivery, 1; - Tammy Porter
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Tyson Archie - Platte River Power Authority - 5
Yes
Answer
Document Name
Comment
Likes
2
Dislikes
Platte River Power Authority, 1, Thompson Matt; Platte River Power Authority, 3, Kiess Wade
0
Response
Maryanne Darling-Reich - Black Hills Corporation - 1,3,5,6 - MRO,WECC
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Joe Tarantino - Joe Tarantino On Behalf of: Charles Norton, Sacramento Municipal Utility District, 3, 5, 6, 4, 1; Foung Mua, Sacramento
Municipal Utility District, 3, 5, 6, 4, 1; Kevin Smith, Balancing Authority of Northern California, 1; Nicole Goi, Sacramento Municipal Utility
District, 3, 5, 6, 4, 1; - Joe Tarantino
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Jenjira Knernschield - Old Dominion Electric Coop. - 3
Answer
Document Name
Comment
Yes
Likes
0
Dislikes
0
Response
David Jendras - Ameren - Ameren Services - 3
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Andrea Barclay - Georgia System Operations Corporation - 3,4
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Douglas Webb - Douglas Webb On Behalf of: Allen Klassen, Evergy, 6, 1, 3, 5; Derek Brown, Evergy, 6, 1, 3, 5; Marcus Moor, Evergy, 6, 1, 3, 5;
Thomas ROBBEN, Evergy, 6, 1, 3, 5; - Douglas Webb
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
Response
0
Dania Colon - Orlando Utilities Commission - 5
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Laura Nelson - IDACORP - Idaho Power Company - 1
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Maurice Paulk - Cleco Corporation - 3
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC Regional Standards Committee
Answer
Document Name
Comment
Yes
Likes
0
Dislikes
0
Response
Erin Green - Western Area Power Administration - 1,6
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Jennie Wike - Jennie Wike On Behalf of: Hien Ho, Tacoma Public Utilities (Tacoma, WA), 3, 1, 4, 5, 6; John Merrell, Tacoma Public Utilities
(Tacoma, WA), 3, 1, 4, 5, 6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 3, 1, 4, 5, 6; Terry Gifford, Tacoma Public Utilities
(Tacoma, WA), 3, 1, 4, 5, 6; - Jennie Wike
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Jennifer Bray - Arizona Electric Power Cooperative, Inc. - 1
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
Response
0
Paul Mehlhaff - Sunflower Electric Power Corporation - 1
Yes
Answer
Document Name
Comment
Likes
0
Dislikes
0
Response
Rachel Coyne - Texas Reliability Entity, Inc. - 10
Answer
Document Name
Comment
Texas RE recommends removing “subject to Requirement R2” in Requirement R8. It should be clear that all Generator Owners (GO) shall provide
Facility Ratings data when the Reliability Coordinators (RC), Planning Coordinators (PC), Transmission Planners (TP), Transmission Owners (TO), and
Transmission Operators (TOP) identify a need for the data. Since Requirement R2 is already applicable to a large majority of GOs, removing the
verbiage in Requirement R8, would eliminate the need for GOs to evaluate how a request for Facility Ratings data fits into the applicability specified
within Requirement R8.
Likes
0
Dislikes
0
Response
Andrew Gallo - Austin Energy - 6
Answer
Document Name
Comment
Austin Energy agrees with the comments submitted by Platter River Power.
Austin Energy would like the SDT to consider providing clarification to the sub-requirement R8.2 where, when requested for the owner to provide within
30-days, or other agreed upon timeframe, be clarified so it is not an opening for expansion by auditors to request "carte blanche" the next most limiting
element for all facilities. Auditors are requesting the "next most limiting element" expanding the scope of the standard.
Likes
Dislikes
0
0
Response
2. If desired, please provide additional comments for the SDT to consider.
Bobbi Welch - Midcontinent ISO, Inc. - 2
Answer
Document Name
Comment
None
Likes
0
Dislikes
0
Response
Jennie Wike - Jennie Wike On Behalf of: Hien Ho, Tacoma Public Utilities (Tacoma, WA), 3, 1, 4, 5, 6; John Merrell, Tacoma Public Utilities
(Tacoma, WA), 3, 1, 4, 5, 6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 3, 1, 4, 5, 6; Terry Gifford, Tacoma Public Utilities
(Tacoma, WA), 3, 1, 4, 5, 6; - Jennie Wike
Answer
Document Name
Comment
Tacoma Power supports the comments submitted by Platte River Power Authority with respect to modifying the language in FAC-008 R8 if retirement of
the Requirement is not feasible.
Likes
0
Dislikes
0
Response
Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC Regional Standards Committee
Answer
Document Name
Comment
We recommend that FAC-008 be prioritized for another revision (new project) to act on the potential revisions/corrections that were identified in Project
2017-03 FAC-008-3 Periodic Review.
Likes
Dislikes
0
0
Response
Larry Heckert - Alliant Energy Corporation Services, Inc. - 4
Answer
Document Name
Comment
No additional comments.
Likes
0
Dislikes
0
Response
Douglas Webb - Douglas Webb On Behalf of: Allen Klassen, Evergy, 6, 1, 3, 5; Derek Brown, Evergy, 6, 1, 3, 5; Marcus Moor, Evergy, 6, 1, 3, 5;
Thomas ROBBEN, Evergy, 6, 1, 3, 5; - Douglas Webb
Answer
Document Name
Comment
None.
Likes
0
Dislikes
0
Response
Joe Tarantino - Joe Tarantino On Behalf of: Charles Norton, Sacramento Municipal Utility District, 3, 5, 6, 4, 1; Foung Mua, Sacramento
Municipal Utility District, 3, 5, 6, 4, 1; Kevin Smith, Balancing Authority of Northern California, 1; Nicole Goi, Sacramento Municipal Utility
District, 3, 5, 6, 4, 1; - Joe Tarantino
Answer
Document Name
Comment
SMUD agrees with the comments submitted by Platter River Power.
However, SMUD would like the SDT to consider providing clarificaiton to the sub-requirement R8.2 where, when requested for the owner to
provide within 30-days, or other agreed upon timeframe, be clarified so that it is not an opening for expansion by auditors to request "cart blanc" the
next most limiting element for all facilities. Auditors are requesting the "next most limiting element" expanding the scope of the standard.
Likes
2
Dislikes
Austin Energy, 3, Preston W. Dwayne; Platte River Power Authority, 5, Archie Tyson
0
Response
Tyson Archie - Platte River Power Authority - 5
Answer
Document Name
Comment
Platte River agrees with the SDT’s recommendation to retire Requirement R7 from FAC-008-3 in response to FERC Oder No. 873. Platte River would
like R8 to be retired in its entirety as we believe sufficient technical justification was provided for its retirement by NERC in their June 7, 2019 petition. If
R8 cannot be retired in its entirety, we recommend revising R8 as detailed below.
Platte River recommends removing item 2) Total Transfer Capability (TTC) from Requirement 8.2, as TTC is primarily used for commercial operations
not reliability. As stated in NERC’s June 7, 2019 petition: “Real-time system operators are ambivalent of these commercial arrangements, as they must
maintain reliability of the BES according to SOLs and IROLs. If a scheduled interchange would violate SOLs or IROLs, the real-time operators must
disregard the scheduled interchange and operate the system to its actual reliability limits.” This observation is reinforced by NERC’s statement in the
2015 filing related to risk-based reliability proposing removal of the Interchange Authority from the compliance registry.
Additionally, Platte River agrees with NERC’s justification for the proposed retirement of the 56 MOD A Reliability Standards and their associated
requirements which includes the rationale that these standards are commercial in nature. If/when the MOD A reliability standards are retired,
determining TTC will no longer be required by any NERC reliability standard. Removing TTC at this time would be forward looking and beneficial as to
not have FAC-008-5 referencing an out of date term.
Platte River recommends removing or, at a minimum, defining 3) an impediment to generator deliverability. This term is not defined in the NERC
Glossary of Terms, and to date, ERO-endorsed guidance is not available for entities to reference for defining generator deliverability. Due to the
differences in size and complexity of registered entities and individual generating units, generator deliverability can vary widely. This creates
inconsistency and confusion for reporting entities as well as regional entity staff.
Platte River recommends removing item 4) An impediment to service to a major load center from Requirement 8.2. Major load center is not defined in
the NERC Glossary of Terms, and to date, ERO-endorsed guidance is not available for entities to reference for defining a major-load center. Due to the
differences in size and complexity of registered entities, a major load center can vary widely. This creates inconsistency and confusion for reporting
entities as well as regional entity staff.
Therefore, Platte River would like the SDT to consider the following proposed changes to Requirement R8, sub requirement 8.2.
Proposed changes to Requirement R8 of FAC-008-5:
R8: Each Transmission Owner (and each Generator Owner subject to Requirement R2) shall provide requested information as specified below (for its
solely and jointly owned Facilities that are existing Facilities, new Facilities, modifications to existing Facilities and re-ratings of existing Facilities) to its
associated Reliability Coordinator(s), Planning Coordinator(s), Transmission Planner(s), Transmission Owner(s) and Transmission Operator(s):
[Violation Risk Factor: Medium] [Time Horizon: Operations Planning]
8.1. As scheduled by the requesting entities:
8.1.1. Facility Ratings
8.1.2. Identity of the most limiting equipment of the Facilities
8.2. Within 30 calendar days (or a later date if specified by the requester), for any requested Facility with a Thermal Rating that limits the use of
Facilities under the requester’s authority by causing an Interconnection Reliability Operating Limit (IROL).
8.2.1. Identity of the existing next most limiting equipment of the Facility
8.2.2. The Thermal Rating for the next most limiting equipment identified in Requirement R8, Part 8.2.1.
In conclusion, Platte River believes the operation of the Bulk Electric System (BES) is rooted in determining and operating within SOL’s and
IROL’s. Requirement 8.1 addresses the sharing of SOL’s, and Platte River’s recommendation for Requirement 8.2 addresses the critical nature of
IROL’s. Requirement 8.2, as currently written, strays from these two well-known and widely used terms.
Likes
5
Dislikes
Tarantino Joe On Behalf of: Charles Norton, Sacramento Municipal Utility District, 3, 5, 6, 4, 1; Platte River
Power Authority, 1, Thompson Matt; Platte River Power Authority, 3, Kiess Wade; Austin Energy, 3,
Preston W. Dwayne; Wike Jennie On Behalf of: Hien Ho, Tacoma Public Utilities (Tacoma, WA), 3, 1, 4, 5,
6; John Merre
0
Response
Brandon Gleason - Electric Reliability Council of Texas, Inc. - 2
Answer
Document Name
Comment
None.
Likes
0
Dislikes
0
Response
Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Document Name
Comment
As in its previous NOPR response, BPA agrees with FERC’s assertion that Requirement R8’s direction to communicate with Transmission Owners is
not found in MOD-032, TOP-001, and/or IRO-010, therefore is a provision to be retained in FAC-008. BPA does, however, agree with the comments
submitted by Platte River Power Authority and recommends that Requirement R8 be revised to add clarity and reduce undue burden on reporting
entities.
Likes
0
Dislikes
0
Response
Leonard Kula - Independent Electricity System Operator - 2
Answer
Document Name
Comment
N/A.
Likes
0
Dislikes
0
Response
Tammy Porter - Tammy Porter On Behalf of: Lee Maurer, Oncor Electric Delivery, 1; - Tammy Porter
Answer
Document Name
Comment
N/A
Likes
0
Dislikes
0
Response
Richard Jackson - U.S. Bureau of Reclamation - 1
Answer
Document Name
Comment
Since R8 will not be retired despite industry support, Reclamation recommends the drafting team seek to simplify R8 as a means of addressing industry
opinion on its lack of value. Revising R8 could eliminate the difficulties of interpreting this requirement by narrowing the focus to address only the
portions described in FERC’s rationale for rejecting its retirement. Reclamation recommends the language of R8 be simplified to require TOs and GOs
subject to R2 to identify the most limiting Element and second most limiting Element for each solely or jointly owned Facility.
Likes
0
Dislikes
0
Response
Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer
Document Name
Comment
N/A
Likes
0
Dislikes
0
Response
Jeremy Lorigan - Seminole Electric Cooperative, Inc. - 3
Answer
Document Name
Comment
R8 limits the provision of information from the TO (and applicable GO) to ONLY “its associated RC, PC, TP, TO, and TOP” and does not have any
provision for adjacent RCs, PCs, TPs, TOs, or TOPs to request similar information. I would be inclined to include language that adjacent entities can
request this information which would be in-line with what FERC has issues in its NOPR on 11/19/2020 on “Managing Transmission Line Ratings.”
Also, I do disagree in part with the VSL’s for R8 in that there is no quantitative way to measure whether an entity only provide “85%” of the information
associated with a facility rating vs. “90%” and vs. “87%”. I agree with the quantitative measure on whether the entity provided it within the 30 calendar
days or within the agreed to time-frame.
Likes
Dislikes
0
0
Response
Rachel Coyne - Texas Reliability Entity, Inc. - 10
Answer
Document Name
Comment
Texas RE noticed an apparent redundancy in the Severe VSL language. The proposed Severe VSL language indicates that entities providing less than
85% of the information required under FAC-008-5, R8 Part 8.1 commit a “Severe” level violation. Correspondingly, the final proposed Severe VSL
category indicates that an entity’s complete failure to provide rating information required pursuant to FAC-008-5, R8 Part 8.1 also constitutes a “Severe”
level violation. From Texas RE’s perspective, because an entity has already committed a “Severe” violation when it submits less than 85% of the
information required under FAC-008-5, R8 Part 8.1, the additional language in the final section addressing a complete failure is wholly subsumed within
the 85% or less provision. As such, Texas RE recommends its removal.
Texas RE also noticed a space between 85 and % in the second to last sentence in the Severe VSL section.
Likes
0
Dislikes
0
Response
Kim Thomas - Duke Energy - 1,3,5,6 - Texas RE,SERC,RF, Group Name Duke Energy
Answer
Document Name
Comment
None.
Likes
0
Dislikes
0
Response
Dennis Sismaet - Northern California Power Agency - 6
Answer
Document Name
Comment
In the future the SDT or NERC should develop a formal definition of jointly owned facilities, since there appears to be conflicting interruptions being
enforced that may not have been vetted in accordance with the NERC Standards Processes Manual Standards Interruption process.
Additionally, the SAR was to modify V3 not V4. Thus the proposed Version should be Version 4 not Version 5. To my knowledge FERC did not
approve the prior proposed V4. See item section 39 at link Federal Register :: Electric Reliability Organization Proposal To Retire Requirements in
Reliability Standards Under the NERC Standards Efficiency Review
Likes
0
Dislikes
0
Response
Michael Whitney - Northern California Power Agency - 3,4,5,6
Answer
Document Name
Comment
In the future the SDT or NERC should develop a formal definition of jointly owned facilities, since there appears to be conflicting interruptions being
enforced that may not have been vetted in accordance with the NERC Standards Processes Manual Standards Interruption process.
Additionally, the SAR was to modify V3 not V4. Thus the proposed Version should be Version 4 not Version 5. To my knowledge FERC did not
approve the prior proposed V4. See item section 39 at link Federal Register :: Electric Reliability Organization Proposal To Retire Requirements in
Reliability Standards Under the NERC Standards Efficiency Review
Likes
0
Dislikes
0
Response
Marty Hostler - Northern California Power Agency - 3,4,5,6
Answer
Document Name
Comment
In the future the SDT or NERC should develop a formal definition of jointly owned facilities, since there appears to be conflicting interruptions being
enforced that may not have been vetted in accordance with the NERC Standards Processes Manual Standards Interruption process.
Additionally, the SAR was to modify V3 not V4. Thus the proposed Version should be V4. To my knowledge FERC did not approve the prior proposed
V4.
Likes
Dislikes
0
0
Response
Dana Klem - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO NSRF
Answer
Document Name
Comment
None
Likes
0
Dislikes
0
Response
Daniela Atanasovski - APS - Arizona Public Service Co. - 1
Answer
Document Name
Comment
None
Likes
0
Dislikes
Response
0
Project Name:
Consideration of Comments
2018‐03 Standards Efficiency Review Retirements | FAC‐008‐5
Comment Period Start Date: 11/30/2020
Comment Period End Date: 1/13/2021
Associated Ballot:
2018‐03 Standards Efficiency Review Retirements FAC‐008‐5 IN 1 ST
There were 45 sets of responses, including comments from approximately 107 different people from approximately 81
companies representing 10 of the Industry Segments as shown in the table on the following pages.
All comments submitted can be reviewed in their original format on the project page.
If you feel that your comment has been overlooked, please let us know immediately. Our goal is to give every comment serious consideration
in this process. If you feel there has been an error or omission, you can contact Senior Director of Engineering and Standards Howard Gugel
(via email) or at (404) 446‐9693.
Questions
1. The SDT is proposing to retire Requirements R7 from FAC‐008‐3, as indicated in previously proposed FAC‐008‐4, and retain
Requirement R8. Do you agree with the SDT’s proposal to retire Requirement R7? If you do not agree, please provide comments. Or, if
you agree but have comments or suggestions on the SDT’s proposal, please provide your explanation.
Summary Response:
Proposed Reliability Standard FAC‐008‐4, FERC Order No. 873, issued September 17, 2020, determined that the retirement of
Requirement R7 would be appropriate, but rejected the retirement of Requirement R8, concluding that “… Requirement R8 is needed to
ensure that limiting and next limiting equipment is identified and communicated” (P 40). The SDT discussed this and determined that
Requirement R8, Part 8.1 provides a more definitive regulatory obligation for Transmission Owners to provide Facility Rating information
for jointly‐owned Facilities to other Transmission Owners than does Requirement R6. The SDT further discussed that the development of
any additional justification for retiring Requirement R8 (in part or in its entirety), or modifications to FAC‐008 to better justify retiring
Requirement R8, may be better suited for a future Periodic Review team of FAC‐008 consider. Modifications to FAC‐008 would be outside
the scope of the Standard Authorization Request (SAR) this SDT is working under, which is strictly stated as retirements and references to
requirements being retired.
2. If desired, please provide additional comments for the SDT to consider.
Summary Response:
Proposed Reliability Standard FAC‐008‐4, FERC Order No. 873, issued September 17, 2020, determined that the retirement of
Requirement R7 would be appropriate, but rejected the retirement of Requirement R8, concluding that “… Requirement R8 is needed to
ensure that limiting and next limiting equipment is identified and communicated” (P 40). The SDT discussed this and determined that
Requirement R8, Part 8.1 provides a more definitive regulatory obligation for Transmission Owners to provide Facility Rating information
for jointly‐owned Facilities to other Transmission Owners than does Requirement R6. The SDT further discussed that the development of
any additional justification for retiring Requirement R8 (in part or in its entirety), or modifications to FAC‐008 to better justify retiring
Requirement R8, may be better suited for a future Periodic Review team of FAC‐008 consider. Modifications to FAC‐008 or its related
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
2
VSL’s would be outside the scope of the SAR this SDT is working under, which is strictly stated as retirements and references to
requirements being retired.
The retirement being proposed is a retirement to FAC‐008‐3. FAC‐008‐4 was remanded, but had gone through the development process
so a new version number needed to be created for this development. It is, however a retirement to R7 of FAC‐008‐3. Developing a
definition of jointly owned facilities may be better suited for the next Periodic Review team of FAC‐008 to consider. Modifications to FAC‐
008 would be outside the scope of the SAR this SDT is working under, which is strictly stated as retirements and references to
requirements being retired. Since the BOT approved FAC‐008‐4 to be submitted to FERC for consideration, this revision must necessarily
be FAC‐008‐5.
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
3
The Industry Segments are:
1 — Transmission Owners
2 — RTOs, ISOs
3 — Load‐serving Entities
4 — Transmission‐dependent Utilities
5 — Electric Generators
6 — Electricity Brokers, Aggregators, and Marketers
7 — Large Electricity End Users
8 — Small Electricity End Users
9 — Federal, State, Provincial Regulatory or other Government Entities
10 — Regional Reliability Organizations, Regional Entities
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
4
Organization
Name
MRO
Name
Segment(s)
Dana Klem 1,2,3,4,5,6
Region
MRO
Group
Name
Group Member
Name
MRO NSRF Joseph
DePoorter
Group
Group
Member
Member
Organization Segment(s)
Madison Gas 3,4,5,6
& Electric
MRO
Larry Heckert
Alliant Energy 4
MRO
Michael
Brytowski
Great River
Energy
MRO
Jodi Jensen
Western Area 1,6
Power
Administration
MRO
Andy Crooks
SaskPower
Corporation
1
MRO
Bryan Sherrow Kansas City
1
Board of
Public Utilities
MRO
Bobbi Welch
Omaha Public 1,3,5,6
Power District
MRO
Jeremy Voll
Basin Electric 1
Power
Cooperative
MRO
Bobbi Welch
Midcontinent 2
ISO
MRO
1,3,5,6
Douglas Webb Kansas City
1,3,5,6
Power & Light
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
Group
Member
Region
MRO
5
Organization
Name
Name
DTE Energy ‐ Karie
Detroit
Barczak
Edison
Company
Segment(s)
3
Region
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
Group
Name
Group Member
Name
Group
Group
Member
Member
Organization Segment(s)
Group
Member
Region
Fred Meyer
Algonquin
Power Co.
1
MRO
John Chang
Manitoba
Hydro
1,3,6
MRO
James Williams Southwest
Power Pool,
Inc.
2
MRO
Jamie Monette Minnesota
Power /
ALLETE
1
MRO
Jamison Cawley Nebraska
1,3,5
Public Power
MRO
Sing Tay
MRO
Oklahoma Gas 1,3,5,6
& Electric
Terry Harbour MidAmerican 1,3
Energy
MRO
Troy Brumfield American
1
Transmission
Company
MRO
DTE Energy ‐ Adrian Raducea DTE Energy ‐ 5
DTE Electric
Detroit Edison
Company
Daniel Herring DTE Energy ‐
DTE Electric
4
RF
RF
6
Organization
Name
Name
Segment(s)
Region
Group
Name
Group Member
Name
Karie Barczak
Duke Energy Kim Thomas 1,3,5,6
Northeast Ruida Shu
Power
Coordinating
Council
DTE Energy ‐
DTE Electric
3
FRCC,RF,SERC,Texas Duke Energy Laura Lee
Duke Energy 1
RE
Dale Goodwine Duke Energy 5
Greg Cecil
FirstEnergy ‐ Mark Garza 4
FirstEnergy
Corporation
Group
Group
Member
Member
Organization Segment(s)
1,2,3,4,5,6,7,8,9,10 NPCC
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
FE Voter
Duke Energy 6
Group
Member
Region
RF
SERC
SERC
RF
Julie Severino FirstEnergy ‐
FirstEnergy
Corporation
1
RF
Aaron
Ghodooshim
FirstEnergy ‐
FirstEnergy
Corporation
3
RF
Robert Loy
FirstEnergy ‐
FirstEnergy
Solutions
5
RF
Ann Carey
FirstEnergy ‐
FirstEnergy
Solutions
6
RF
Mark Garza
FirstEnergy‐
FirstEnergy
4
RF
NPCC
Guy V. Zito
Regional
Standards
Committee
Northeast
10
Power
Coordinating
Council
NPCC
7
Organization
Name
Name
Segment(s)
Region
Group
Name
Group Member
Name
Group
Group
Member
Member
Organization Segment(s)
Randy
MacDonald
New
Brunswick
Power
2
NPCC
Glen Smith
Entergy
Services
4
NPCC
Alan Adamson New York
State
Reliability
Council
7
NPCC
David Burke
Orange &
Rockland
Utilities
3
NPCC
Michele
Tondalo
UI
1
NPCC
Helen Lainis
IESO
2
NPCC
David Kiguel
Independent 7
NPCC
Paul
Malozewski
Hydro One
3
Networks, Inc.
NPCC
Nick Kowalczyk Orange and
Rockland
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
Group
Member
Region
1
NPCC
Joel Charlebois AESI ‐ Acumen 5
Engineered
Solutions
NPCC
8
Organization
Name
Name
Segment(s)
Region
Group
Name
Group Member
Name
Group
Group
Member
Member
Organization Segment(s)
Group
Member
Region
International
Inc.
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
Mike Cooke
Ontario Power 4
Generation,
Inc.
NPCC
Salvatore
Spagnolo
New York
Power
Authority
1
NPCC
Shivaz Chopra New York
Power
Authority
5
NPCC
Deidre Altobell Con Ed ‐
4
Consolidated
Edison
NPCC
Dermot Smyth Con Ed ‐
1
Consolidated
Edison Co. of
New York
NPCC
Peter Yost
Con Ed ‐
3
Consolidated
Edison Co. of
New York
NPCC
Cristhian
Godoy
Con Ed ‐
6
Consolidated
NPCC
9
Organization
Name
Name
Segment(s)
Region
Group
Name
Group Member
Name
Group
Group
Member
Member
Organization Segment(s)
Group
Member
Region
Edison Co. of
New York
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
Sean Bodkin
Dominion ‐
Dominion
Resources,
Inc.
6
NPCC
Nurul Abser
NB Power
Corporation
1
NPCC
Randy
MacDonald
NB Power
Corporation
2
NPCC
Michael
Ridolfino
Central
Hudson Gas
and Electric
1
NPCC
Vijay Puran
NYSPS
6
NPCC
ALAN
ADAMSON
New York
State
Reliability
Council
10
NPCC
Sean Cavote
PSEG ‐ Public 1
Service
Electric and
Gas Co.
NPCC
Brian Robinson Utility Services 5
NPCC
10
Organization
Name
Name
Segment(s)
Region
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
Group
Name
Group Member
Name
Group
Group
Member
Member
Organization Segment(s)
Group
Member
Region
Quintin Lee
Eversource
Energy
1
NPCC
Jim Grant
NYISO
2
NPCC
John Pearson
ISONE
2
NPCC
John Hastings National Grid 1
USA
NPCC
Michael Jones National Grid 1
USA
NPCC
Nicolas
Turcotte
Hydro‐Qu?bec 1
TransEnergie
NPCC
Chantal Mazza Hydro‐Quebec 2
NPCC
11
1. The SDT is proposing to retire Requirements R7 from FAC‐008‐3, as indicated in previously proposed FAC‐008‐4, and retain
Requirement R8. Do you agree with the SDT’s proposal to retire Requirement R7? If you do not agree, please provide comments. Or, if
you agree but have comments or suggestions on the SDT’s proposal, please provide your explanation.
Marty Hostler ‐ Northern California Power Agency ‐ 3,4,5,6
Answer
No
Document Name
Comment
Yes, R7 should be retired. R8 should also be retired. However, FERC did not agree to Retire R8 in their last ruling on this matter.
Consequently, I am balloting to retire what we can agree to retire.
Likes 0
Dislikes 0
Response
Thank you for your comment. With respect to proposed Reliability Standard FAC‐008‐4, FERC Order No. 873, issued September 17, 2020,
determined that the retirement of Requirement R7 would be appropriate, but rejected the retirement of Requirement R8, concluding
that “… Requirement R8 is needed to ensure that limiting and next limiting equipment is identified and communicated” (P 40). The SDT
discussed this and determined that Requirement R8, Part 8.1 provides a more definitive regulatory obligation for Transmission Owners to
provide Facility Rating information for jointly‐owned Facilities to other Transmission Owners than does Requirement R6. The SDT further
discussed that the development of any additional justification for retiring Requirement R8 (in part or in its entirety), or modifications to
FAC‐008 to better justify retiring Requirement R8, may be better suited for a future Periodic Review team of FAC‐008 consider.
Modifications to FAC‐008 would be outside the scope of the SAR this SDT is working under, which is strictly stated as retirements and
references to requirements being retired.
Dana Klem ‐ MRO ‐ 1,2,3,4,5,6 ‐ MRO, Group Name MRO NSRF
Answer
Yes
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
12
Document Name
Comment
The NSRF agrees with the SER Retirements.
Likes 0
Dislikes 0
Response
Thank you for your support.
Michael Whitney ‐ Northern California Power Agency ‐ 3,4,5,6
Answer
Yes
Document Name
Comment
Yes, R7 should be retired. R8 should also be retired. However, FERC did not agree to Retire R8 in their last ruling on this matter.
Consequently, I am balloting to retire what we can agree to retire.
Likes 0
Dislikes 0
Response
Thank you for your comment. With respect to proposed Reliability Standard FAC‐008‐4, FERC Order No. 873, issued September 17, 2020,
determined that the retirement of Requirement R7 would be appropriate, but rejected the retirement of Requirement R8, concluding
that “… Requirement R8 is needed to ensure that limiting and next limiting equipment is identified and communicated” (P 40). The SDT
discussed this and determined that Requirement R8, Part 8.1 provides a more definitive regulatory obligation for Transmission Owners to
provide Facility Rating information for jointly‐owned Facilities to other Transmission Owners than does Requirement R6. The SDT further
discussed that the development of any additional justification for retiring Requirement R8 (in part or in its entirety), or modifications to
FAC‐008 to better justify retiring Requirement R8, may be better suited for a future Periodic Review team of FAC‐008 consider.
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
13
Modifications to FAC‐008 would be outside the scope of the SAR this SDT is working under, which is strictly stated as retirements and
references to requirements being retired.
Dennis Sismaet ‐ Northern California Power Agency ‐ 6
Answer
Yes
Document Name
Comment
Yes, R7 should be retired. R8 should also be retired. However, FERC did not agree to Retire R8 in their last ruling on this matter.
Consequently, I am balloting to retire what we can agree to retire
Likes 0
Dislikes 0
Response
Thank you for your comment. With respect to proposed Reliability Standard FAC‐008‐4, FERC Order No. 873, issued September 17, 2020,
determined that the retirement of Requirement R7 would be appropriate, but rejected the retirement of Requirement R8, concluding
that “… Requirement R8 is needed to ensure that limiting and next limiting equipment is identified and communicated” (P 40). The SDT
discussed this and determined that Requirement R8, Part 8.1 provides a more definitive regulatory obligation for Transmission Owners to
provide Facility Rating information for jointly‐owned Facilities to other Transmission Owners than does Requirement R6. The SDT further
discussed that the development of any additional justification for retiring Requirement R8 (in part or in its entirety), or modifications to
FAC‐008 to better justify retiring Requirement R8, may be better suited for a future Periodic Review team of FAC‐008 consider.
Modifications to FAC‐008 would be outside the scope of the SAR this SDT is working under, which is strictly stated as retirements and
references to requirements being retired.
Truong Le ‐ Truong Le On Behalf of: Carol Chinn, Florida Municipal Power Agency, 6, 4, 5, 3; Chris Gowder, Florida Municipal Power
Agency, 6, 4, 5, 3; Dale Ray, Florida Municipal Power Agency, 6, 4, 5, 3; Richard Montgomery, Florida Municipal Power Agency, 6, 4, 5,
3; ‐ Truong Le
Answer
Yes
Document Name
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
14
Comment
Yes, R7 should be retired. R8 should also be retired. However, FERC did not agree to Retire R8 in their last ruling on this matter.
Likes 0
Dislikes 0
Response
Thank you for your comment. With respect to proposed Reliability Standard FAC‐008‐4, FERC Order No. 873, issued September 17, 2020,
determined that the retirement of Requirement R7 would be appropriate, but rejected the retirement of Requirement R8, concluding
that “… Requirement R8 is needed to ensure that limiting and next limiting equipment is identified and communicated” (P 40). The SDT
discussed this and determined that Requirement R8, Part 8.1 provides a more definitive regulatory obligation for Transmission Owners to
provide Facility Rating information for jointly‐owned Facilities to other Transmission Owners than does Requirement R6. The SDT further
discussed that the development of any additional justification for retiring Requirement R8 (in part or in its entirety), or modifications to
FAC‐008 to better justify retiring Requirement R8, may be better suited for a future Periodic Review team of FAC‐008 consider.
Modifications to FAC‐008 would be outside the scope of the SAR this SDT is working under, which is strictly stated as retirements and
references to requirements being retired.
Leonard Kula ‐ Independent Electricity System Operator ‐ 2
Answer
Yes
Document Name
Comment
N/A.
Likes 0
Dislikes 0
Response
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
15
Thank you for your support.
Brandon Gleason ‐ Electric Reliability Council of Texas, Inc. ‐ 2
Answer
Yes
Document Name
Comment
None.
Likes 0
Dislikes 0
Response
Thank you for your support.
Mark Gray ‐ Edison Electric Institute ‐ NA ‐ Not Applicable ‐ NA ‐ Not Applicable
Answer
Yes
Document Name
Comment
EEI supports the retirement of Requirement R7 and retention of Requirement R8.
Likes 0
Dislikes 0
Response
Thank you for your support.
Daniel Gacek ‐ Exelon ‐ 1
Answer
Yes
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
16
Document Name
Comment
Exelon concurs with the EEI comment, supporting the retirement of Requirement R7 and the retention of Requirement R8.
Submitted on behalf of Exelon, Segments 1, 3, 5, 6
Likes 0
Dislikes 0
Response
Thank you for your support.
W. Dwayne Preston ‐ Austin Energy ‐ 3
Answer
Yes
Document Name
Comment
Austin Energy agrees with the comments submitted by Platter River Power.
However, Austin Energy would like the SDT to consider providing clarification to the sub‐requirement R8.2 where, when requested for the
owner to provide within 30‐days, or other agreed upon timeframe, be clarified so that it is not an opening for expansion by auditors to
request "cart blanc" the next most limiting element for all facilities. Auditors are requesting the "next most limiting element" expanding
the scope of the standard.
Likes 1
Platte River Power Authority, 5, Archie Tyson
Dislikes 0
Response
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
17
Thank you for your comment. Please see response to comments submitted by Platte River Power Authority. Clarifications to FAC‐008
would be outside the scope of the SAR this SDT is working under, which is strictly stated as retirements and references to requirements
being retired. Clarification for Requirement Part R8.2 may be better suited for a future Periodic Review team of FAC‐008 to consider, or
through a formal Request for Interpretation (RFI) to be submitted to NERC.
Jun Hua ‐ Austin Energy ‐ 4
Answer
Yes
Document Name
Comment
Austin Energy agrees with the comments submitted by Platter River Power.
However, Austin Energy would like the SDT to consider providing clarification to the sub‐requirement R8.2 where, when requested for the
owner to provide within 30‐days, or other agreed upon timeframe, be clarified so that it is not an opening for expansion by auditors to
request "cart blanc" the next most limiting element for all facilities. Auditors are requesting the "next most limiting element" expanding
the scope of the standard.
Likes 1
Platte River Power Authority, 5, Archie Tyson
Dislikes 0
Response
Thank you for your comment. Please see response to comments submitted by Platte River Power Authority. Clarifications to FAC‐008
would be outside the scope of the SAR this SDT is working under, which is strictly stated as retirements and references to requirements
being retired. Clarification for Requirement Part R8.2 may be better suited for a future Periodic Review team of FAC‐008 to consider, or
through a formal Request for Interpretation (RFI) to be submitted to NERC.
Michael Dillard ‐ Austin Energy ‐ 5
Answer
Yes
Document Name
Comment
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
18
Austin Energy agrees with the comments submitted by Platter River Power.
However, Austin Energy would like the SDT to consider providing clarification to the sub‐requirement R8.2 where, when requested for the
owner to provide within 30‐days, or other agreed upon timeframe, be clarified so that it is not an opening for expansion by auditors to
request "cart blanc" the next most limiting element for all facilities. Auditors are requesting the "next most limiting element" expanding
the scope of the standard.
Likes 1
Platte River Power Authority, 5, Archie Tyson
Dislikes 0
Response
Thank you for your comment. Please see response to comments submitted by Platte River Power Authority. Clarifications to FAC‐008
would be outside the scope of the SAR this SDT is working under, which is strictly stated as retirements and references to requirements
being retired. Clarification for Requirement Part R8.2 may be better suited for a future Periodic Review team of FAC‐008 to consider, or
through a formal Request for Interpretation (RFI) to be submitted to NERC.
Carl Pineault ‐ Hydro‐Qu?bec Production ‐ 5
Answer
Yes
Document Name
Comment
No comments
Likes 0
Dislikes 0
Response
Thank you for your support.
Larry Heckert ‐ Alliant Energy Corporation Services, Inc. ‐ 4
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
19
Answer
Yes
Document Name
Comment
No additional comments.
Likes 0
Dislikes 0
Response
Thank you for your support.
Bobbi Welch ‐ Midcontinent ISO, Inc. ‐ 2
Answer
Yes
Document Name
Comment
MISO supports the retirement of Requirement R7 and the retention of Requirement R8.
Likes 0
Dislikes 0
Response
Thank you for your support.
Colleen Campbell ‐ AES ‐ Indianapolis Power and Light Co. ‐ 3
Answer
Yes
Document Name
Comment
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
20
Likes 0
Dislikes 0
Response
Thank you for your support.
Thomas Foltz ‐ AEP ‐ 5
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Kjersti Drott ‐ Tri‐State G and T Association, Inc. ‐ 1
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
21
Daniela Atanasovski ‐ APS ‐ Arizona Public Service Co. ‐ 1
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Karie Barczak ‐ DTE Energy ‐ Detroit Edison Company ‐ 3, Group Name DTE Energy ‐ DTE Electric
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Kim Thomas ‐ Duke Energy ‐ 1,3,5,6 ‐ Texas RE,SERC,RF, Group Name Duke Energy
Answer
Yes
Document Name
Comment
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
22
Likes 0
Dislikes 0
Response
Thank you for your support.
Bruce Reimer ‐ Manitoba Hydro ‐ 1
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Jeremy Lorigan ‐ Seminole Electric Cooperative, Inc. ‐ 3
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Mark Garza ‐ FirstEnergy ‐ FirstEnergy Corporation ‐ 4, Group Name FE Voter
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
23
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Anton Vu ‐ Los Angeles Department of Water and Power ‐ 6
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Richard Jackson ‐ U.S. Bureau of Reclamation ‐ 1
Answer
Yes
Document Name
Comment
Likes 0
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
24
Dislikes 0
Response
Thank you for your support.
Tammy Porter ‐ Tammy Porter On Behalf of: Lee Maurer, Oncor Electric Delivery, 1; ‐ Tammy Porter
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Cain Braveheart ‐ Bonneville Power Administration ‐ 1,3,5,6 ‐ WECC
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Tyson Archie ‐ Platte River Power Authority ‐ 5
Answer
Yes
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
25
Document Name
Comment
Likes 2
Platte River Power Authority, 1, Thompson Matt; Platte River Power Authority, 3, Kiess Wade
Dislikes 0
Response
Thank you for your support.
Maryanne Darling‐Reich ‐ Black Hills Corporation ‐ 1,3,5,6 ‐ MRO,WECC
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Joe Tarantino ‐ Joe Tarantino On Behalf of: Charles Norton, Sacramento Municipal Utility District, 3, 5, 6, 4, 1; Foung Mua, Sacramento
Municipal Utility District, 3, 5, 6, 4, 1; Kevin Smith, Balancing Authority of Northern California, 1; Nicole Goi, Sacramento Municipal
Utility District, 3, 5, 6, 4, 1; ‐ Joe Tarantino
Answer
Yes
Document Name
Comment
Likes 0
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
26
Dislikes 0
Response
Thank you for your support.
Jenjira Knernschield ‐ Old Dominion Electric Coop. ‐ 3
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
David Jendras ‐ Ameren ‐ Ameren Services ‐ 3
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Andrea Barclay ‐ Georgia System Operations Corporation ‐ 3,4
Answer
Yes
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
27
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Douglas Webb ‐ Douglas Webb On Behalf of: Allen Klassen, Evergy, 6, 1, 3, 5; Derek Brown, Evergy, 6, 1, 3, 5; Marcus Moor, Evergy, 6,
1, 3, 5; Thomas ROBBEN, Evergy, 6, 1, 3, 5; ‐ Douglas Webb
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Dania Colon ‐ Orlando Utilities Commission ‐ 5
Answer
Yes
Document Name
Comment
Likes 0
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
28
Dislikes 0
Response
Thank you for your support.
Laura Nelson ‐ IDACORP ‐ Idaho Power Company ‐ 1
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Maurice Paulk ‐ Cleco Corporation ‐ 3
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Ruida Shu ‐ Northeast Power Coordinating Council ‐ 1,2,3,4,5,6,7,8,9,10 ‐ NPCC, Group Name NPCC Regional Standards Committee
Answer
Yes
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
29
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Erin Green ‐ Western Area Power Administration ‐ 1,6
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Jennie Wike ‐ Jennie Wike On Behalf of: Hien Ho, Tacoma Public Utilities (Tacoma, WA), 3, 1, 4, 5, 6; John Merrell, Tacoma Public
Utilities (Tacoma, WA), 3, 1, 4, 5, 6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 3, 1, 4, 5, 6; Terry Gifford, Tacoma Public
Utilities (Tacoma, WA), 3, 1, 4, 5, 6; ‐ Jennie Wike
Answer
Yes
Document Name
Comment
Likes 0
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
30
Dislikes 0
Response
Thank you for your support.
Jennifer Bray ‐ Arizona Electric Power Cooperative, Inc. ‐ 1
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Paul Mehlhaff ‐ Sunflower Electric Power Corporation ‐ 1
Answer
Yes
Document Name
Comment
Likes 0
Dislikes 0
Response
Thank you for your support.
Rachel Coyne ‐ Texas Reliability Entity, Inc. ‐ 10
Answer
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
31
Document Name
Comment
Texas RE recommends removing “subject to Requirement R2” in Requirement R8. It should be clear that all Generator Owners (GO) shall
provide Facility Ratings data when the Reliability Coordinators (RC), Planning Coordinators (PC), Transmission Planners (TP), Transmission
Owners (TO), and Transmission Operators (TOP) identify a need for the data. Since Requirement R2 is already applicable to a large
majority of GOs, removing the verbiage in Requirement R8, would eliminate the need for GOs to evaluate how a request for Facility
Ratings data fits into the applicability specified within Requirement R8.
Likes 0
Dislikes 0
Response
Thank you for your comment. Modifications to FAC‐008 would be outside the scope of the SAR this SDT is working under, which is strictly
stated as retirements and references to requirements being retired. Modification for Requirement R8 may be better suited for a future
Periodic Review team of FAC‐008 to consider.
Andrew Gallo ‐ Austin Energy ‐ 6
Answer
Document Name
Comment
Austin Energy agrees with the comments submitted by Platter River Power.
Austin Energy would like the SDT to consider providing clarification to the sub‐requirement R8.2 where, when requested for the owner to
provide within 30‐days, or other agreed upon timeframe, be clarified so it is not an opening for expansion by auditors to request "carte
blanche" the next most limiting element for all facilities. Auditors are requesting the "next most limiting element" expanding the scope of
the standard.
Likes 0
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
32
Dislikes 0
Response
Thank you for your comment. Please see response to comments submitted by Platte River Power Authority. Clarifications to FAC‐008
would be outside the scope of the SAR this SDT is working under, which is strictly stated as retirements and references to requirements
being retired. Clarification for Requirement Part R8.2 may be better suited for a future Periodic Review team of FAC‐008 to consider, or
through a formal Request for Interpretation (RFI) to be submitted to NERC.
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
33
2. If desired, please provide additional comments for the SDT to consider.
Bobbi Welch ‐ Midcontinent ISO, Inc. ‐ 2
Answer
Document Name
Comment
None
Likes 0
Dislikes 0
Response
Jennie Wike ‐ Jennie Wike On Behalf of: Hien Ho, Tacoma Public Utilities (Tacoma, WA), 3, 1, 4, 5, 6; John Merrell, Tacoma Public
Utilities (Tacoma, WA), 3, 1, 4, 5, 6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 3, 1, 4, 5, 6; Terry Gifford, Tacoma Public
Utilities (Tacoma, WA), 3, 1, 4, 5, 6; ‐ Jennie Wike
Answer
Document Name
Comment
Tacoma Power supports the comments submitted by Platte River Power Authority with respect to modifying the language in FAC‐008 R8
if retirement of the Requirement is not feasible.
Likes 0
Dislikes 0
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
34
Response
Thank you for your comment. Please see responses to Platte River Power Authority. Modifications to FAC‐008 would be outside the scope
of the SAR this SDT is working under, which is strictly stated as retirements and references to requirements being retired. Modification for
Requirement R8 may be better suited for a future Periodic Review team of FAC‐008 to consider.
Ruida Shu ‐ Northeast Power Coordinating Council ‐ 1,2,3,4,5,6,7,8,9,10 ‐ NPCC, Group Name NPCC Regional Standards Committee
Answer
Document Name
Comment
We recommend that FAC‐008 be prioritized for another revision (new project) to act on the potential revisions/corrections that were
identified in Project 2017‐03 FAC‐008‐3 Periodic Review.
Likes 0
Dislikes 0
Response
Thank you for your comment.
Larry Heckert ‐ Alliant Energy Corporation Services, Inc. ‐ 4
Answer
Document Name
Comment
No additional comments.
Likes 0
Dislikes 0
Response
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
35
Douglas Webb ‐ Douglas Webb On Behalf of: Allen Klassen, Evergy, 6, 1, 3, 5; Derek Brown, Evergy, 6, 1, 3, 5; Marcus Moor, Evergy, 6,
1, 3, 5; Thomas ROBBEN, Evergy, 6, 1, 3, 5; ‐ Douglas Webb
Answer
Document Name
Comment
None.
Likes 0
Dislikes 0
Response
Joe Tarantino ‐ Joe Tarantino On Behalf of: Charles Norton, Sacramento Municipal Utility District, 3, 5, 6, 4, 1; Foung Mua, Sacramento
Municipal Utility District, 3, 5, 6, 4, 1; Kevin Smith, Balancing Authority of Northern California, 1; Nicole Goi, Sacramento Municipal
Utility District, 3, 5, 6, 4, 1; ‐ Joe Tarantino
Answer
Document Name
Comment
SMUD agrees with the comments submitted by Platter River Power.
However, SMUD would like the SDT to consider providing clarificaiton to the sub‐requirement R8.2 where, when requested for the owner
to provide within 30‐days, or other agreed upon timeframe, be clarified so that it is not an opening for expansion by auditors to request
"cart blanc" the next most limiting element for all facilities. Auditors are requesting the "next most limiting element" expanding the
scope of the standard.
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
36
Likes 2
Austin Energy, 3, Preston W. Dwayne; Platte River Power Authority, 5, Archie Tyson
Dislikes 0
Response
Thank you for your comment. Please see response to comments submitted by Platte River Power Authority. Clarifications to FAC‐008
would be outside the scope of the SAR this SDT is working under, which is strictly stated as retirements and references to requirements
being retired. Clarification for Requirement Part R8.2 may be better suited for a future Periodic Review team of FAC‐008 to consider, or
through a formal Request for Interpretation (RFI) to be submitted to NERC.
Tyson Archie ‐ Platte River Power Authority ‐ 5
Answer
Document Name
Comment
Platte River agrees with the SDT’s recommendation to retire Requirement R7 from FAC‐008‐3 in response to FERC Oder No. 873. Platte
River would like R8 to be retired in its entirety as we believe sufficient technical justification was provided for its retirement by NERC in
their June 7, 2019 petition. If R8 cannot be retired in its entirety, we recommend revising R8 as detailed below.
Platte River recommends removing item 2) Total Transfer Capability (TTC) from Requirement 8.2, as TTC is primarily used for commercial
operations not reliability. As stated in NERC’s June 7, 2019 petition: “Real‐time system operators are ambivalent of these commercial
arrangements, as they must maintain reliability of the BES according to SOLs and IROLs. If a scheduled interchange would violate SOLs or
IROLs, the real‐time operators must disregard the scheduled interchange and operate the system to its actual reliability limits.” This
observation is reinforced by NERC’s statement in the 2015 filing related to risk‐based reliability proposing removal of the Interchange
Authority from the compliance registry.
Additionally, Platte River agrees with NERC’s justification for the proposed retirement of the 56 MOD A Reliability Standards and their
associated requirements which includes the rationale that these standards are commercial in nature. If/when the MOD A reliability
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
37
standards are retired, determining TTC will no longer be required by any NERC reliability standard. Removing TTC at this time would be
forward looking and beneficial as to not have FAC‐008‐5 referencing an out of date term.
Platte River recommends removing or, at a minimum, defining 3) an impediment to generator deliverability. This term is not defined in
the NERC Glossary of Terms, and to date, ERO‐endorsed guidance is not available for entities to reference for defining generator
deliverability. Due to the differences in size and complexity of registered entities and individual generating units, generator deliverability
can vary widely. This creates inconsistency and confusion for reporting entities as well as regional entity staff.
Platte River recommends removing item 4) An impediment to service to a major load center from Requirement 8.2. Major load center is
not defined in the NERC Glossary of Terms, and to date, ERO‐endorsed guidance is not available for entities to reference for defining a
major‐load center. Due to the differences in size and complexity of registered entities, a major load center can vary widely. This creates
inconsistency and confusion for reporting entities as well as regional entity staff.
Therefore, Platte River would like the SDT to consider the following proposed changes to Requirement R8, sub requirement 8.2.
Proposed changes to Requirement R8 of FAC‐008‐5:
R8: Each Transmission Owner (and each Generator Owner subject to Requirement R2) shall provide requested information as specified
below (for its solely and jointly owned Facilities that are existing Facilities, new Facilities, modifications to existing Facilities and re‐ratings
of existing Facilities) to its associated Reliability Coordinator(s), Planning Coordinator(s), Transmission Planner(s), Transmission Owner(s)
and Transmission Operator(s): [Violation Risk Factor: Medium] [Time Horizon: Operations Planning]
8.1. As scheduled by the requesting entities:
8.1.1. Facility Ratings
8.1.2. Identity of the most limiting equipment of the Facilities
8.2. Within 30 calendar days (or a later date if specified by the requester), for any requested Facility with a Thermal Rating that limits the
use of Facilities under the requester’s authority by causing an Interconnection Reliability Operating Limit (IROL).
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
38
8.2.1. Identity of the existing next most limiting equipment of the Facility
8.2.2. The Thermal Rating for the next most limiting equipment identified in Requirement R8, Part 8.2.1.
In conclusion, Platte River believes the operation of the Bulk Electric System (BES) is rooted in determining and operating within SOL’s and
IROL’s. Requirement 8.1 addresses the sharing of SOL’s, and Platte River’s recommendation for Requirement 8.2 addresses the critical
nature of IROL’s. Requirement 8.2, as currently written, strays from these two well‐known and widely used terms.
Likes 5
Tarantino Joe On Behalf of: Charles Norton, Sacramento Municipal Utility District, 3, 5, 6, 4, 1;
Platte River Power Authority, 1, Thompson Matt; Platte River Power Authority, 3, Kiess Wade;
Austin Energy, 3, Preston W. Dwayne; Wike Jennie On Behalf of: Hien Ho, Tacoma Public Utilities
(Tacoma, WA), 3, 1, 4, 5, 6; John Merre
Dislikes 0
Response
Thank you for your comment. With respect to proposed Reliability Standard FAC‐008‐4, FERC Order No. 873, issued September 17, 2020,
determined that the retirement of Requirement R7 would be appropriate, but rejected the retirement of Requirement R8, concluding
that “… Requirement R8 is needed to ensure that limiting and next limiting equipment is identified and communicated” (P 40). The SDT
discussed this and determined that Requirement R8, Part 8.1 provides a more definitive regulatory obligation for Transmission Owners to
provide Facility Rating information for jointly‐owned Facilities to other Transmission Owners than does Requirement R6. The SDT further
discussed that the development of any additional justification for retiring Requirement R8 (in part or in its entirety), or modifications to
FAC‐008 to better justify retiring Requirement R8, may be better suited for a future Periodic Review team of FAC‐008 consider.
Modifications to FAC‐008 would be outside the scope of the SAR this SDT is working under, which is strictly stated as retirements and
references to requirements being retired.
Brandon Gleason ‐ Electric Reliability Council of Texas, Inc. ‐ 2
Answer
Document Name
Comment
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
39
None.
Likes 0
Dislikes 0
Response
Cain Braveheart ‐ Bonneville Power Administration ‐ 1,3,5,6 ‐ WECC
Answer
Document Name
Comment
As in its previous NOPR response, BPA agrees with FERC’s assertion that Requirement R8’s direction to communicate with Transmission
Owners is not found in MOD‐032, TOP‐001, and/or IRO‐010, therefore is a provision to be retained in FAC‐008. BPA does, however, agree
with the comments submitted by Platte River Power Authority and recommends that Requirement R8 be revised to add clarity and
reduce undue burden on reporting entities.
Likes 0
Dislikes 0
Response
Thank you for your comment. Please see responses to Platte River Power Authority. Modifications to FAC‐008 would be outside the scope
of the SAR this SDT is working under, which is strictly stated as retirements and references to requirements being retired. Modification for
Requirement R8 may be better suited for a future Periodic Review team of FAC‐008 to consider.
Leonard Kula ‐ Independent Electricity System Operator ‐ 2
Answer
Document Name
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
40
Comment
N/A.
Likes 0
Dislikes 0
Response
Tammy Porter ‐ Tammy Porter On Behalf of: Lee Maurer, Oncor Electric Delivery, 1; ‐ Tammy Porter
Answer
Document Name
Comment
N/A
Likes 0
Dislikes 0
Response
Richard Jackson ‐ U.S. Bureau of Reclamation ‐ 1
Answer
Document Name
Comment
Since R8 will not be retired despite industry support, Reclamation recommends the drafting team seek to simplify R8 as a means of
addressing industry opinion on its lack of value. Revising R8 could eliminate the difficulties of interpreting this requirement by narrowing
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
41
the focus to address only the portions described in FERC’s rationale for rejecting its retirement. Reclamation recommends the language of
R8 be simplified to require TOs and GOs subject to R2 to identify the most limiting Element and second most limiting Element for each
solely or jointly owned Facility.
Likes 0
Dislikes 0
Response
Thank you for your comment. Modifications to FAC‐008 would be outside the scope of the SAR this SDT is working under, which is strictly
stated as retirements and references to requirements being retired. Modification for Requirement R8 may be better suited for a future
Periodic Review team of FAC‐008 to consider.
Mark Garza ‐ FirstEnergy ‐ FirstEnergy Corporation ‐ 4, Group Name FE Voter
Answer
Document Name
Comment
N/A
Likes 0
Dislikes 0
Response
Jeremy Lorigan ‐ Seminole Electric Cooperative, Inc. ‐ 3
Answer
Document Name
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
42
Comment
R8 limits the provision of information from the TO (and applicable GO) to ONLY “its associated RC, PC, TP, TO, and TOP” and does not
have any provision for adjacent RCs, PCs, TPs, TOs, or TOPs to request similar information. I would be inclined to include language that
adjacent entities can request this information which would be in‐line with what FERC has issues in its NOPR on 11/19/2020 on “Managing
Transmission Line Ratings.”
Also, I do disagree in part with the VSL’s for R8 in that there is no quantitative way to measure whether an entity only provide “85%” of
the information associated with a facility rating vs. “90%” and vs. “87%”. I agree with the quantitative measure on whether the entity
provided it within the 30 calendar days or within the agreed to time‐frame.
Likes 0
Dislikes 0
Response
Thank you for your comment. With respect to proposed Reliability Standard FAC‐008‐4, FERC Order No. 873, issued September 17, 2020,
determined that the retirement of Requirement R7 would be appropriate, but rejected the retirement of Requirement R8, concluding
that “… Requirement R8 is needed to ensure that limiting and next limiting equipment is identified and communicated” (P 40). The SDT
discussed this and determined that Requirement R8, Part 8.1 provides a more definitive regulatory obligation for Transmission Owners to
provide Facility Rating information for jointly‐owned Facilities to other Transmission Owners than does Requirement R6. The SDT further
discussed that the development of any additional justification for retiring Requirement R8 (in part or in its entirety), or modifications to
FAC‐008 to better justify retiring Requirement R8, may be better suited for a future Periodic Review team of FAC‐008 consider.
Modifications to FAC‐008 or its related VSL’s would be outside the scope of the SAR this SDT is working under, which is strictly stated as
retirements and references to requirements being retired.
Rachel Coyne ‐ Texas Reliability Entity, Inc. ‐ 10
Answer
Document Name
Comment
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
43
Texas RE noticed an apparent redundancy in the Severe VSL language. The proposed Severe VSL language indicates that entities
providing less than 85% of the information required under FAC‐008‐5, R8 Part 8.1 commit a “Severe” level violation. Correspondingly, the
final proposed Severe VSL category indicates that an entity’s complete failure to provide rating information required pursuant to FAC‐
008‐5, R8 Part 8.1 also constitutes a “Severe” level violation. From Texas RE’s perspective, because an entity has already committed a
“Severe” violation when it submits less than 85% of the information required under FAC‐008‐5, R8 Part 8.1, the additional language in the
final section addressing a complete failure is wholly subsumed within the 85% or less provision. As such, Texas RE recommends its
removal.
Texas RE also noticed a space between 85 and % in the second to last sentence in the Severe VSL section.
Likes 0
Dislikes 0
Response
Thank you for your comment. With respect to proposed Reliability Standard FAC‐008‐4, FERC Order No. 873, issued September 17, 2020,
determined that the retirement of Requirement R7 would be appropriate, but rejected the retirement of Requirement R8, concluding
that “… Requirement R8 is needed to ensure that limiting and next limiting equipment is identified and communicated” (P 40). The SDT
discussed this and determined that Requirement R8, Part 8.1 provides a more definitive regulatory obligation for Transmission Owners to
provide Facility Rating information for jointly‐owned Facilities to other Transmission Owners than does Requirement R6. The SDT further
discussed that the development of any additional justification for retiring Requirement R8 (in part or in its entirety), or modifications to
FAC‐008 to better justify retiring Requirement R8, may be better suited for a future Periodic Review team of FAC‐008 consider.
Modifications to FAC‐008 or its related VSL’s would be outside the scope of the SAR this SDT is working under, which is strictly stated as
retirements and references to requirements being retired.
Kim Thomas ‐ Duke Energy ‐ 1,3,5,6 ‐ Texas RE,SERC,RF, Group Name Duke Energy
Answer
Document Name
Comment
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
44
None.
Likes 0
Dislikes 0
Response
Dennis Sismaet ‐ Northern California Power Agency ‐ 6
Answer
Document Name
Comment
In the future the SDT or NERC should develop a formal definition of jointly owned facilities, since there appears to be conflicting
interruptions being enforced that may not have been vetted in accordance with the NERC Standards Processes Manual Standards
Interruption process.
Additionally, the SAR was to modify V3 not V4. Thus the proposed Version should be Version 4 not Version 5. To my knowledge FERC did
not approve the prior proposed V4. See item section 39 at link Federal Register :: Electric Reliability Organization Proposal To Retire
Requirements in Reliability Standards Under the NERC Standards Efficiency Review
Likes 0
Dislikes 0
Response
Thank you for your comment. The retirement being proposed is a retirement to FAC‐008‐3. FAC‐008‐4 was remanded, but had gone
through the development process so a new version number needed to be created for this development. It is, however a retirement to R7
of FAC‐008‐3. Developing a definition of jointly owned facilities may be better suited for the next Periodic Review team of FAC‐008 to
consider. Modifications to FAC‐008 would be outside the scope of the SAR this SDT is working under, which is strictly stated as
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
45
retirements and references to requirements being retired. Since the BOT approved FAC‐008‐4 to be submitted to FERC for consideration,
this revision must necessarily be FAC‐008‐5.
Michael Whitney ‐ Northern California Power Agency ‐ 3,4,5,6
Answer
Document Name
Comment
In the future the SDT or NERC should develop a formal definition of jointly owned facilities, since there appears to be conflicting
interruptions being enforced that may not have been vetted in accordance with the NERC Standards Processes Manual Standards
Interruption process.
Additionally, the SAR was to modify V3 not V4. Thus the proposed Version should be Version 4 not Version 5. To my knowledge FERC did
not approve the prior proposed V4. See item section 39 at link Federal Register :: Electric Reliability Organization Proposal To Retire
Requirements in Reliability Standards Under the NERC Standards Efficiency Review
Likes 0
Dislikes 0
Response
Thank you for your comment. The retirement being proposed is a retirement to FAC‐008‐3. FAC‐008‐4 was remanded, but had gone
through the development process so a new version number needed to be created for this development. It is, however a retirement to R7
of FAC‐008‐3. Developing a definition of jointly owned facilities may be better suited for the next Periodic Review team of FAC‐008 to
consider. Modifications to FAC‐008 would be outside the scope of the SAR this SDT is working under, which is strictly stated as
retirements and references to requirements being retired. Since the BOT approved FAC‐008‐4 to be submitted to FERC for consideration,
this revision must necessarily be FAC‐008‐5.
Marty Hostler ‐ Northern California Power Agency ‐ 3,4,5,6
Answer
Document Name
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
46
Comment
In the future the SDT or NERC should develop a formal definition of jointly owned facilities, since there appears to be conflicting
interruptions being enforced that may not have been vetted in accordance with the NERC Standards Processes Manual Standards
Interruption process.
Additionally, the SAR was to modify V3 not V4. Thus the proposed Version should be V4. To my knowledge FERC did not approve the
prior proposed V4.
Likes 0
Dislikes 0
Response
Thank you for your comment. The retirement being proposed is a retirement to FAC‐008‐3. FAC‐008‐4 was remanded, but had gone
through the development process so a new version number needed to be created for this development. It is, however a retirement to R7
of FAC‐008‐3. Developing a definition of jointly owned facilities may be better suited for the next Periodic Review team of FAC‐008 to
consider. Modifications to FAC‐008 would be outside the scope of the SAR this SDT is working under, which is strictly stated as
retirements and references to requirements being retired. Since the BOT approved FAC‐008‐4 to be submitted to FERC for consideration,
this revision must necessarily be FAC‐008‐5.
Dana Klem ‐ MRO ‐ 1,2,3,4,5,6 ‐ MRO, Group Name MRO NSRF
Answer
Document Name
Comment
None
Likes 0
Dislikes 0
Response
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
47
Daniela Atanasovski ‐ APS ‐ Arizona Public Service Co. ‐ 1
Answer
Document Name
Comment
None
Likes 0
Dislikes 0
Response
End of Report
Consideration of Comments | Project 2018‐03 Standards Efficiency Retirements
January 19, 2021
48
Standards Announcement
REMINDER
Project 2018-03 Standards Efficiency Review Retirements
Initial Ballot and Non-ballot Poll Open through January 13, 2021
Now Available
The initial ballot and non-binding poll for Project 2018-03 Standards Efficiency Review Retirements
FAC-008-5 – Facility Ratings is open through 8 p.m. Eastern, Wednesday, January 13, 2021.
Balloting
Members of the ballot pools associated with this project can log in and submit votes by accessing the
Standards Balloting and Commenting System (SBS). Contact Wendy Muller regarding issues using the
SBS.
•
Contact NERC IT support directly at https://support.nerc.net/ (Monday – Friday, 8 a.m. - 5 p.m.
Eastern) for problems regarding accessing the SBS due to a forgotten password, incorrect
credential error messages, or system lock-out.
•
Passwords expire every 6 months and must be reset.
•
The SBS is not supported for use on mobile devices.
•
Please be mindful of ballot and comment period closing dates. We ask to allow at least 48
hours for NERC support staff to assist with inquiries. Therefore, it is recommended that users
try logging into their SBS accounts prior to the last day of a comment/ballot period.
Next Steps
The ballot results will be announced and posted on the project page. The drafting team will review all
responses received during the comment period and determine the next steps of the project.
For information on the Standards Development Process, refer to the Standard Processes Manual.
For more information or assistance, contact Standards Developer, Laura Anderson (via email) or at (404)
446-9671.
North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com
Standards Announcement
Project 2018-03 Standards Efficiency Review Retirements
Formal Comment Period Open through January 13, 2021
Ballot Pools Forming through December 29, 2020
Now Available
A 45-day comment period for FAC-008-5 – Facility Ratings is open through 8 p.m. Eastern, Wednesday,
January 13, 2021.
Commenting
Use the Standards Balloting and Commenting System (SBS) to submit comments. If you experience
issues using the SBS, contact Wendy Muller. An unofficial Word version of the comment form is posted
on the project page.
Ballot Pools
Ballot pools are being formed through 8 p.m. Eastern, Tuesday, December 29, 2020. Registered Ballot
Body members can join the ballot pools here.
•
Contact NERC IT support directly at https://support.nerc.net/ (Monday – Friday, 8 a.m. - 5 p.m.
Eastern) for problems regarding accessing the SBS due to a forgotten password, incorrect
credential error messages, or system lock-out.
•
Passwords expire every 6 months and must be reset.
•
The SBS is not supported for use on mobile devices.
•
Please be mindful of ballot and comment period closing dates. We ask to allow at least 48 hours
for NERC support staff to assist with inquiries. Therefore, it is recommended that users try logging
into their SBS accounts prior to the last day of a comment/ballot period.
Next Steps
The initial ballot for the standard and non-binding poll of the associated Violation Risk Factors and
Violation Severity Levels, will be conducted January 4-13, 2021.
For information on the Standards Development Process, refer to the Standard Processes Manual.
For more information or assistance, contact Standards Developer, Laura Anderson (via email) or at (404)
446-9671.
North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com
RELIABILITY | RESILIENCE | SECURITY
Index - NERC Balloting Tool
Page 1 of 16
NERC Balloting Tool (/)
Dashboard (/)
Users
Ballots
Comment Forms
Login (/Users/Login) / Register (/Users/Register)
BALLOT RESULTS
Comment: View Comment Results (/CommentResults/Index/209)
Ballot Name: 2018-03 Standards Efficiency Review Retirements FAC-008-5 IN 1 ST
Voting Start Date: 1/4/2021 12:01:00 AM
Voting End Date: 1/13/2021 8:00:00 PM
Ballot Type: ST
Ballot Activity: IN
Ballot Series: 1
Total # Votes: 241
Total Ballot Pool: 268
Quorum: 89.93
Quorum Established Date: 1/13/2021 2:27:59 PM
Weighted Segment Value: 95.91
Negative
Fraction
w/
Comment
Negative
Votes
w/o
Comment
Abstain
No
Vote
Ballot
Pool
Segment
Weight
Affirmative
Votes
Affirmative
Fraction
Negative
Votes w/
Comment
Segment:
1
69
1
59
0.952
3
0.048
0
2
5
Segment:
2
8
0.6
6
0.6
0
0
0
1
1
Segment:
3
62
1
53
0.981
1
0.019
0
1
7
Segment:
4
15
1
12
0.923
1
0.077
0
0
2
Segment:
5
68
1
57
0.95
3
0.05
0
0
8
Segment:
6
41
1
34
0.944
2
0.056
0
1
4
Segment:
7
0
0
0
0
0
0
0
0
0
Segment:
8
1
0.1
1
0.1
0
0
0
0
0
Segment:
9
0
0
0
0
0
0
0
0
0
Segment
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Page 2 of 16
Negative
Fraction
w/
Comment
Negative
Votes
w/o
Comment
Abstain
No
Vote
Ballot
Pool
Segment
Weight
Affirmative
Votes
Affirmative
Fraction
Negative
Votes w/
Comment
Segment:
10
4
0.4
4
0.4
0
0
0
0
0
Totals:
268
6.1
226
5.851
10
0.249
0
5
27
Segment
BALLOT POOL MEMBERS
Show All
Segment
entries
Organization
Search: Search
Voter
Designated
Proxy
Ballot
NERC
Memo
1
AEP - AEP Service
Corporation
Dennis Sauriol
Affirmative
N/A
1
Ameren - Ameren
Services
Tamara Evey
None
N/A
1
APS - Arizona Public
Service Co.
Daniela
Atanasovski
Affirmative
N/A
1
Arizona Electric Power
Cooperative, Inc.
Jennifer Bray
Affirmative
N/A
1
Associated Electric
Cooperative, Inc.
Mark Riley
Affirmative
N/A
1
Austin Energy
Thomas Standifur
Affirmative
N/A
1
Avista - Avista
Corporation
Mike Magruder
None
N/A
1
Balancing Authority of
Northern California
Kevin Smith
Negative
Comments
Submitted
1
Basin Electric Power
Cooperative
David Rudolph
Affirmative
N/A
Affirmative
N/A
1
BC Hydro and Power
Adrian Andreoiu
Authority
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
Joe Tarantino
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 3 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
1
Berkshire Hathaway
Energy - MidAmerican
Energy Co.
Terry Harbour
Affirmative
N/A
1
Bonneville Power
Administration
Kammy RogersHolliday
Affirmative
N/A
1
CenterPoint Energy
Houston Electric, LLC
Daniela Hammons
None
N/A
1
Cleco Corporation
John Lindsey
Affirmative
N/A
1
Dairyland Power
Cooperative
Renee Leidel
Affirmative
N/A
1
Dominion - Dominion
Virginia Power
Candace Marshall
None
N/A
1
Duke Energy
Laura Lee
Affirmative
N/A
1
Edison International Southern California
Edison Company
Jose Avendano
Mora
Affirmative
N/A
1
Entergy - Entergy
Services, Inc.
Oliver Burke
Affirmative
N/A
1
Evergy
Allen Klassen
Affirmative
N/A
1
Eversource Energy
Quintin Lee
Affirmative
N/A
1
Exelon
Daniel Gacek
Affirmative
N/A
1
FirstEnergy FirstEnergy Corporation
Julie Severino
Affirmative
N/A
1
Georgia Transmission
Corporation
Greg Davis
Affirmative
N/A
1
Great River Energy
Gordon Pietsch
Affirmative
N/A
1
Hydro One Networks,
Inc.
Payam
Farahbakhsh
Affirmative
N/A
1
Hydro-Qu?bec
TransEnergie
Nicolas Turcotte
Affirmative
N/A
1
IDACORP - Idaho Power
Company
Laura Nelson
Affirmative
N/A
1
Imperial Irrigation District
Jesus Sammy
Alcaraz
Affirmative
N/A
Douglas Webb
Denise Sanchez
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 4 of 16
Voter
1
International
Transmission Company
Holdings Corporation
Michael Moltane
1
JEA
1
Designated
Proxy
NERC
Memo
Abstain
N/A
Joe McClung
Negative
Third-Party
Comments
KAMO Electric
Cooperative
Micah Breedlove
Affirmative
N/A
1
Los Angeles Department
of Water and Power
faranak sarbaz
Affirmative
N/A
1
Lower Colorado River
Authority
James Baldwin
Affirmative
N/A
1
Manitoba Hydro
Bruce Reimer
Affirmative
N/A
1
MEAG Power
David Weekley
Scott Miller
Affirmative
N/A
1
Minnkota Power
Cooperative Inc.
Theresa Allard
Andy Fuhrman
Affirmative
N/A
1
Muscatine Power and
Water
Andy Kurriger
Affirmative
N/A
1
N.W. Electric Power
Cooperative, Inc.
Mark Ramsey
Affirmative
N/A
1
National Grid USA
Michael Jones
Affirmative
N/A
1
NB Power Corporation
Nurul Abser
Affirmative
N/A
1
Nebraska Public Power
District
Jamison Cawley
Abstain
N/A
1
New York Power
Authority
Salvatore
Spagnolo
Affirmative
N/A
1
NextEra Energy - Florida
Power and Light Co.
Mike ONeil
Affirmative
N/A
1
NiSource - Northern
Indiana Public Service
Co.
Steve Toosevich
Affirmative
N/A
1
OGE Energy Oklahoma Gas and
Electric Co.
Terri Pyle
Affirmative
N/A
Affirmative
N/A
1
Omaha Public Power
Doug Peterchuck
District
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Allie Gavin
Ballot
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 5 of 16
Voter
1
Oncor Electric Delivery
Lee Maurer
1
Orlando Utilities
Commission
1
Designated
Proxy
Tammy Porter
Ballot
NERC
Memo
Affirmative
N/A
Aaron Staley
Affirmative
N/A
OTP - Otter Tail Power
Company
Charles Wicklund
Affirmative
N/A
1
Pacific Gas and Electric
Company
Marco Rios
None
N/A
1
Platte River Power
Authority
Matt Thompson
Negative
Comments
Submitted
1
PPL Electric Utilities
Corporation
Preston Walker
Affirmative
N/A
1
PSEG - Public Service
Electric and Gas Co.
Randhir Singh
Affirmative
N/A
1
Public Utility District No.
1 of Chelan County
Ginette Lacasse
Affirmative
N/A
1
Public Utility District No.
1 of Snohomish County
Alyssia Rhoads
Affirmative
N/A
1
Salt River Project
Chris Hofmann
Affirmative
N/A
1
Santee Cooper
Chris Wagner
Affirmative
N/A
1
SaskPower
Wayne
Guttormson
Affirmative
N/A
1
Seattle City Light
Pawel Krupa
Affirmative
N/A
1
Seminole Electric
Cooperative, Inc.
Bret Galbraith
Affirmative
N/A
1
Southern Company Southern Company
Services, Inc.
Matt Carden
Affirmative
N/A
1
Sunflower Electric
Power Corporation
Paul Mehlhaff
Affirmative
N/A
1
Tacoma Public Utilities
(Tacoma, WA)
John Merrell
Affirmative
N/A
1
Tennessee Valley
Authority
Gabe Kurtz
Affirmative
N/A
1
Tri-State G and T
Kjersti Drott
Affirmative
N/A
Jennie Wike
Association,
Inc.
© 2021 - NERC Ver 4.3.0.0
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Name: ERODVSBSWB01
2/9/2021
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Segment
Organization
Page 6 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
1
U.S. Bureau of
Reclamation
Richard Jackson
Affirmative
N/A
1
Western Area Power
Administration
sean erickson
Affirmative
N/A
1
Xcel Energy, Inc.
Dean Schiro
Affirmative
N/A
2
California ISO
Jamie Johnson
Abstain
N/A
2
Electric Reliability
Council of Texas, Inc.
Brandon Gleason
Affirmative
N/A
2
Independent Electricity
System Operator
Leonard Kula
None
N/A
2
ISO New England, Inc.
Michael Puscas
Affirmative
N/A
2
Midcontinent ISO, Inc.
Bobbi Welch
Affirmative
N/A
2
New York Independent
System Operator
Gregory Campoli
Affirmative
N/A
2
PJM Interconnection,
L.L.C.
Tom Foster
Affirmative
N/A
2
Southwest Power Pool,
Inc. (RTO)
Charles Yeung
Affirmative
N/A
3
AEP
Kent Feliks
Affirmative
N/A
3
AES - Indianapolis
Power and Light Co.
Colleen Campbell
Affirmative
N/A
3
Ameren - Ameren
Services
David Jendras
Affirmative
N/A
3
APS - Arizona Public
Service Co.
Jessica Lopez
Affirmative
N/A
3
Austin Energy
W. Dwayne
Preston
Affirmative
N/A
3
Avista - Avista
Corporation
Scott Kinney
None
N/A
3
Basin Electric Power
Cooperative
Jeremy Voll
Affirmative
N/A
3
BC Hydro and Power
Authority
Hootan Jarollahi
Affirmative
N/A
Elizabeth Davis
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2/9/2021
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Segment
Organization
Page 7 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
3
Berkshire Hathaway
Energy - MidAmerican
Energy Co.
Darnez Gresham
Affirmative
N/A
3
Black Hills Corporation
Don Stahl
Affirmative
N/A
3
Bonneville Power
Administration
Ken Lanehome
Affirmative
N/A
3
Central Electric Power
Cooperative (Missouri)
Adam Weber
Affirmative
N/A
3
Cleco Corporation
Maurice Paulk
Affirmative
N/A
3
CMS Energy Consumers Energy
Company
Karl Blaszkowski
Affirmative
N/A
3
Colorado Springs
Utilities
Hillary Dobson
Affirmative
N/A
3
Dominion - Dominion
Resources, Inc.
Connie Lowe
Affirmative
N/A
3
DTE Energy - Detroit
Edison Company
Karie Barczak
Affirmative
N/A
3
Duke Energy
Lee Schuster
Affirmative
N/A
3
Edison International Southern California
Edison Company
Romel Aquino
Affirmative
N/A
3
Evergy
Marcus Moor
Affirmative
N/A
3
Eversource Energy
Christopher
McKinnon
Affirmative
N/A
3
Exelon
Kinte Whitehead
Affirmative
N/A
3
FirstEnergy FirstEnergy Corporation
Aaron
Ghodooshim
Affirmative
N/A
3
Florida Municipal Power
Agency
Dale Ray
Affirmative
N/A
3
Georgia System
Operations Corporation
Scott McGough
Affirmative
N/A
3
Great River Energy
Michael Brytowski
Affirmative
N/A
3
Imperial Irrigation District
Glen Allegranza
Affirmative
N/A
Douglas Webb
Truong Le
Denise Sanchez
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Index - NERC Balloting Tool
Segment
Organization
Page 8 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
3
JEA
Garry Baker
None
N/A
3
KAMO Electric
Cooperative
Tony Gott
Affirmative
N/A
3
Lakeland Electric
Patricia Boody
None
N/A
3
Lincoln Electric System
Jason Fortik
Affirmative
N/A
3
Los Angeles Department
of Water and Power
Tony Skourtas
Affirmative
N/A
3
M and A Electric Power
Cooperative
Stephen Pogue
Affirmative
N/A
3
Manitoba Hydro
Karim Abdel-Hadi
Affirmative
N/A
3
MEAG Power
Roger Brand
Affirmative
N/A
3
Muscatine Power and
Water
Seth Shoemaker
Affirmative
N/A
3
National Grid USA
Brian Shanahan
Affirmative
N/A
3
Nebraska Public Power
District
Tony Eddleman
Abstain
N/A
3
New York Power
Authority
David Rivera
Affirmative
N/A
3
NiSource - Northern
Indiana Public Service
Co.
Steven Taddeucci
Affirmative
N/A
3
Northeast Missouri
Electric Power
Cooperative
Skyler Wiegmann
None
N/A
3
NW Electric Power
Cooperative, Inc.
John Stickley
Affirmative
N/A
3
OGE Energy Oklahoma Gas and
Electric Co.
Donald Hargrove
Affirmative
N/A
3
OTP - Otter Tail Power
Company
Wendi Olson
Affirmative
N/A
3
Owensboro Municipal
Utilities
Thomas Lyons
Affirmative
N/A
3
Platte River Power
Wade Kiess
Negative
Comments
Submitted
Authority
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Scott Miller
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 9 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
3
Portland General
Electric Co.
Dan Zollner
None
N/A
3
PPL - Louisville Gas and
Electric Co.
James Frank
Affirmative
N/A
3
PSEG - Public Service
Electric and Gas Co.
maria pardo
Affirmative
N/A
3
Public Utility District No.
1 of Chelan County
Joyce Gundry
Affirmative
N/A
3
Puget Sound Energy,
Inc.
Tim Womack
None
N/A
3
Santee Cooper
James Poston
Affirmative
N/A
3
Seminole Electric
Cooperative, Inc.
Jeremy Lorigan
Affirmative
N/A
3
Sho-Me Power Electric
Cooperative
Jarrod Murdaugh
Affirmative
N/A
3
Snohomish County PUD
No. 1
Holly Chaney
Affirmative
N/A
3
Southern Company Alabama Power
Company
Joel Dembowski
Affirmative
N/A
3
Tacoma Public Utilities
(Tacoma, WA)
Marc Donaldson
Affirmative
N/A
3
TECO - Tampa Electric
Co.
Ronald Donahey
None
N/A
3
Tennessee Valley
Authority
Ian Grant
Affirmative
N/A
3
Tri-State G and T
Association, Inc.
Janelle Marriott
Gill
Affirmative
N/A
3
WEC Energy Group, Inc.
Thomas Breene
Affirmative
N/A
3
Xcel Energy, Inc.
Ray Jasicki
Affirmative
N/A
4
Alliant Energy
Corporation Services,
Inc.
Larry Heckert
Affirmative
N/A
4
Austin Energy
Jun Hua
Affirmative
N/A
Jennie Wike
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 10 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
4
City Utilities of
Springfield, Missouri
John Allen
Affirmative
N/A
4
CMS Energy Consumers Energy
Company
Aric Root
Affirmative
N/A
4
FirstEnergy FirstEnergy Corporation
Mark Garza
Affirmative
N/A
4
Florida Municipal Power
Agency
Carol Chinn
Affirmative
N/A
4
LaGen
Wayne Messina
None
N/A
4
MGE Energy - Madison
Gas and Electric Co.
Joseph DePoorter
Affirmative
N/A
4
Modesto Irrigation
District
Spencer Tacke
None
N/A
4
Public Utility District No.
1 of Snohomish County
John Martinsen
Affirmative
N/A
4
Public Utility District No.
2 of Grant County,
Washington
Karla Weaver
Affirmative
N/A
4
Sacramento Municipal
Utility District
Foung Mua
Negative
Comments
Submitted
4
Seattle City Light
Hao Li
Affirmative
N/A
4
Tacoma Public Utilities
(Tacoma, WA)
Hien Ho
Affirmative
N/A
4
WEC Energy Group, Inc.
Matthew Beilfuss
Affirmative
N/A
5
Acciona Energy North
America
George Brown
Affirmative
N/A
5
AEP
Thomas Foltz
Affirmative
N/A
5
Ameren - Ameren
Missouri
Sam Dwyer
Affirmative
N/A
5
APS - Arizona Public
Service Co.
Kelsi Rigby
Affirmative
N/A
5
Austin Energy
Michael Dillard
Affirmative
N/A
5
Avista - Avista
Glen Farmer
Affirmative
N/A
Truong Le
Joe Tarantino
Jennie Wike
Corporation
© 2021 - NERC Ver 4.3.0.0
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2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 11 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
5
Basin Electric Power
Cooperative
Colleen Peterson
Affirmative
N/A
5
BC Hydro and Power
Authority
Helen Hamilton
Harding
None
N/A
5
Berkshire Hathaway NV Energy
Kevin Salsbury
Affirmative
N/A
5
Black Hills Corporation
Derek Silbaugh
Affirmative
N/A
5
Boise-Kuna Irrigation
District - Lucky Peak
Power Plant Project
Mike Kukla
Affirmative
N/A
5
Bonneville Power
Administration
Scott Winner
Affirmative
N/A
5
Brazos Electric Power
Cooperative, Inc.
Shari Heino
None
N/A
5
Cleco Corporation
Stephanie
Huffman
None
N/A
5
CMS Energy Consumers Energy
Company
David Greyerbiehl
Affirmative
N/A
5
Colorado Springs
Utilities
Jeff Icke
None
N/A
5
Dairyland Power
Cooperative
Tommy Drea
Affirmative
N/A
5
Dominion - Dominion
Resources, Inc.
Rachel Snead
None
N/A
5
DTE Energy - Detroit
Edison Company
Adrian Raducea
None
N/A
5
Duke Energy
Dale Goodwine
Affirmative
N/A
5
Edison International Southern California
Edison Company
Neil Shockey
Affirmative
N/A
5
Entergy
Jamie Prater
Affirmative
N/A
5
Evergy
Derek Brown
Affirmative
N/A
5
Exelon
Cynthia Lee
Affirmative
N/A
Douglas Webb
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 12 of 16
Voter
5
FirstEnergy FirstEnergy Corporation
Robert Loy
5
Florida Municipal Power
Agency
Chris Gowder
5
Great River Energy
5
Designated
Proxy
Ballot
NERC
Memo
Affirmative
N/A
Affirmative
N/A
Jacalynn Bentz
Affirmative
N/A
Herb Schrayshuen
Herb Schrayshuen
Affirmative
N/A
5
Hydro-Qu?bec
Production
Carl Pineault
Affirmative
N/A
5
Imperial Irrigation District
Tino Zaragoza
Affirmative
N/A
5
JEA
John Babik
Negative
Third-Party
Comments
5
Lincoln Electric System
Kayleigh
Wilkerson
Affirmative
N/A
5
Los Angeles Department
of Water and Power
Glenn Barry
Affirmative
N/A
5
Lower Colorado River
Authority
Teresa Cantwell
Affirmative
N/A
5
Manitoba Hydro
Yuguang Xiao
Affirmative
N/A
5
Massachusetts
Municipal Wholesale
Electric Company
Anthony Stevens
Affirmative
N/A
5
Muscatine Power and
Water
Neal Nelson
Affirmative
N/A
5
National Grid USA
Elizabeth Spivak
Affirmative
N/A
5
NB Power Corporation
Rob Vance
Affirmative
N/A
5
New York Power
Authority
Shivaz Chopra
Affirmative
N/A
5
NiSource - Northern
Indiana Public Service
Co.
Kathryn Tackett
Affirmative
N/A
5
NovaSource Power
Services
Bradley Collard
None
N/A
Affirmative
N/A
5
OGE Energy Patrick Wells
Oklahoma Gas and
Electric
Co.
© 2021 - NERC Ver 4.3.0.0
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Name: ERODVSBSWB01
Truong Le
Denise Sanchez
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 13 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
5
Oglethorpe Power
Corporation
Donna Johnson
Affirmative
N/A
5
Omaha Public Power
District
Mahmood Safi
Affirmative
N/A
5
Ontario Power
Generation Inc.
Constantin
Chitescu
Affirmative
N/A
5
Orlando Utilities
Commission
Dania Colon
Affirmative
N/A
5
OTP - Otter Tail Power
Company
Brett Jacobs
Affirmative
N/A
5
Pacific Gas and Electric
Company
Ed Hanson
Affirmative
N/A
5
Platte River Power
Authority
Tyson Archie
Negative
Comments
Submitted
5
Portland General
Electric Co.
Ryan Olson
None
N/A
5
PPL - Louisville Gas and
Electric Co.
JULIE
HOSTRANDER
Affirmative
N/A
5
PSEG - PSEG Fossil
LLC
Tim Kucey
Affirmative
N/A
5
Public Utility District No.
1 of Chelan County
Meaghan Connell
Affirmative
N/A
5
Public Utility District No.
1 of Snohomish County
Sam Nietfeld
Affirmative
N/A
5
Public Utility District No.
2 of Grant County,
Washington
Amy Jones
Affirmative
N/A
5
Sacramento Municipal
Utility District
Nicole Goi
Negative
Comments
Submitted
5
Salt River Project
Kevin Nielsen
Affirmative
N/A
5
Santee Cooper
Tommy Curtis
Affirmative
N/A
5
Seattle City Light
Faz Kasraie
Affirmative
N/A
5
Seminole Electric
Cooperative, Inc.
Mickey Bellard
Affirmative
N/A
Joe Tarantino
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 14 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
5
Southern Company Southern Company
Generation
James Howell
Affirmative
N/A
5
Talen Generation, LLC
Donald Lock
Affirmative
N/A
5
Tennessee Valley
Authority
M Lee Thomas
Affirmative
N/A
5
Tri-State G and T
Association, Inc.
Ryan Walter
Affirmative
N/A
5
U.S. Bureau of
Reclamation
Wendy Center
Affirmative
N/A
5
WEC Energy Group, Inc.
Janet OBrien
Affirmative
N/A
5
Xcel Energy, Inc.
Gerry Huitt
Affirmative
N/A
6
AEP
JT Kuehne
Affirmative
N/A
6
Ameren - Ameren
Services
Robert Quinlivan
Affirmative
N/A
6
APS - Arizona Public
Service Co.
Marcus Bortman
Affirmative
N/A
6
Associated Electric
Cooperative, Inc.
Brian Ackermann
None
N/A
6
Austin Energy
Andrew Gallo
Affirmative
N/A
6
Basin Electric Power
Cooperative
Jerry Horner
Affirmative
N/A
6
Black Hills Corporation
Eric Scherr
Affirmative
N/A
6
Bonneville Power
Administration
Andrew Meyers
Affirmative
N/A
6
Cleco Corporation
Robert Hirchak
Affirmative
N/A
6
Dominion - Dominion
Resources, Inc.
Sean Bodkin
None
N/A
6
Duke Energy
Greg Cecil
Affirmative
N/A
6
Evergy
Thomas ROBBEN
Affirmative
N/A
6
Exelon
Becky Webb
Affirmative
N/A
FirstEnergy Ann Carey
FirstEnergy Corporation
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
Affirmative
N/A
6
Douglas Webb
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 15 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
6
Florida Municipal Power
Agency
Richard
Montgomery
Truong Le
Affirmative
N/A
6
Imperial Irrigation District
Diana Torres
Denise Sanchez
Affirmative
N/A
6
Los Angeles Department
of Water and Power
Anton Vu
Affirmative
N/A
6
Manitoba Hydro
Blair Mukanik
Affirmative
N/A
6
Muscatine Power and
Water
Nick Burns
Affirmative
N/A
6
New York Power
Authority
Erick Barrios
Affirmative
N/A
6
NextEra Energy - Florida
Power and Light Co.
Justin Welty
None
N/A
6
NiSource - Northern
Indiana Public Service
Co.
Joe O'Brien
Affirmative
N/A
6
Northern California
Power Agency
Dennis Sismaet
Abstain
N/A
6
OGE Energy Oklahoma Gas and
Electric Co.
Sing Tay
Affirmative
N/A
6
Omaha Public Power
District
Joel Robles
Affirmative
N/A
6
Platte River Power
Authority
Sabrina Martz
Negative
Comments
Submitted
6
Portland General
Electric Co.
Daniel Mason
Affirmative
N/A
6
Powerex Corporation
Gordon DobsonMack
None
N/A
6
PPL - Louisville Gas and
Electric Co.
Linn Oelker
Affirmative
N/A
6
PSEG - PSEG Energy
Resources and Trade
LLC
Joseph Neglia
Affirmative
N/A
6
Public Utility District No.
1 of Chelan County
Glen Pruitt
Affirmative
N/A
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 16 of 16
Voter
6
Public Utility District No.
2 of Grant County,
Washington
LeRoy Patterson
6
Sacramento Municipal
Utility District
Charles Norton
6
Santee Cooper
6
Designated
Proxy
Ballot
NERC
Memo
Affirmative
N/A
Negative
Comments
Submitted
Marty Watson
Affirmative
N/A
Seattle City Light
Brian Belger
Affirmative
N/A
6
Snohomish County PUD
No. 1
John Liang
Affirmative
N/A
6
Southern Company Southern Company
Generation
Ron Carlsen
Affirmative
N/A
6
Tacoma Public Utilities
(Tacoma, WA)
Terry Gifford
Affirmative
N/A
6
Tennessee Valley
Authority
Marjorie Parsons
Affirmative
N/A
6
WEC Energy Group, Inc.
David Hathaway
Affirmative
N/A
6
Xcel Energy, Inc.
Carrie Dixon
Affirmative
N/A
8
David Kiguel
David Kiguel
Affirmative
N/A
10
New York State
Reliability Council
ALAN ADAMSON
Affirmative
N/A
10
Northeast Power
Coordinating Council
Guy V. Zito
Affirmative
N/A
10
ReliabilityFirst
Anthony Jablonski
Affirmative
N/A
10
Texas Reliability Entity,
Inc.
Rachel Coyne
Affirmative
N/A
Joe Tarantino
Jennie Wike
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Showing 1 to 268 of 268 entries
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Index - NERC Balloting Tool
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NERC Balloting Tool (/)
Dashboard (/)
Users
Ballots
Comment Forms
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BALLOT RESULTS
Ballot Name: 2018-03 Standards Efficiency Review Retirements FAC-008-5 Non-binding Poll IN 1 ST
Voting Start Date: 1/4/2021 12:01:00 AM
Voting End Date: 1/13/2021 8:00:00 PM
Ballot Type: ST
Ballot Activity: IN
Ballot Series: 1
Total # Votes: 220
Total Ballot Pool: 254
Quorum: 86.61
Quorum Established Date: 1/13/2021 2:58:41 PM
Weighted Segment Value: 100
Ballot
Pool
Segment
Weight
Affirmative
Votes
Affirmative
Fraction
Negative
Votes w/
Comment
Negative
Fraction
w/
Comment
Segment:
1
66
1
47
1
0
0
4
7
8
Segment:
2
8
0.5
5
0.5
0
0
0
2
1
Segment:
3
60
1
44
1
0
0
1
7
8
Segment:
4
14
1
11
1
0
0
1
0
2
Segment:
5
62
1
46
1
0
0
3
3
10
Segment:
6
39
1
27
1
0
0
1
6
5
Segment:
7
0
0
0
0
0
0
0
0
0
Segment:
8
1
0.1
1
0.1
0
0
0
0
0
Segment:
9
0
0
0
0
0
0
0
0
0
0
0
0
1
0
Segment
Segment: 4
0.3
3
0.3
© 2021
NERC
Ver
4.3.0.0
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10
Negative
Votes
w/o
Comment
Abstain
No
Vote
2/9/2021
Index - NERC Balloting Tool
Page 2 of 16
Segment
Ballot
Pool
Segment
Weight
Affirmative
Votes
Affirmative
Fraction
Negative
Votes w/
Comment
Totals:
254
5.9
184
5.9
0
Negative
Fraction
w/
Comment
Negative
Votes
w/o
Comment
Abstain
No
Vote
0
10
26
34
BALLOT POOL MEMBERS
Show All
Segment
entries
Organization
Search: Search
Voter
Designated
Proxy
Ballot
NERC
Memo
1
AEP - AEP Service
Corporation
Dennis Sauriol
Affirmative
N/A
1
Ameren - Ameren
Services
Tamara Evey
None
N/A
1
APS - Arizona Public
Service Co.
Daniela
Atanasovski
Affirmative
N/A
1
Arizona Electric Power
Cooperative, Inc.
Jennifer Bray
Affirmative
N/A
1
Associated Electric
Cooperative, Inc.
Mark Riley
Affirmative
N/A
1
Austin Energy
Thomas Standifur
Affirmative
N/A
1
Avista - Avista
Corporation
Mike Magruder
None
N/A
1
Balancing Authority of
Northern California
Kevin Smith
Negative
No Comment
Submitted
1
Basin Electric Power
Cooperative
David Rudolph
Affirmative
N/A
1
BC Hydro and Power
Authority
Adrian Andreoiu
Abstain
N/A
Affirmative
N/A
1
Berkshire Hathaway
Terry Harbour
Energy - MidAmerican
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
Energy Co.
Joe Tarantino
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 3 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
1
Bonneville Power
Administration
Kammy RogersHolliday
None
N/A
1
CenterPoint Energy
Houston Electric, LLC
Daniela Hammons
None
N/A
1
Cleco Corporation
John Lindsey
Affirmative
N/A
1
Dairyland Power
Cooperative
Renee Leidel
Affirmative
N/A
1
Dominion - Dominion
Virginia Power
Candace Marshall
None
N/A
1
Duke Energy
Laura Lee
Affirmative
N/A
1
Entergy - Entergy
Services, Inc.
Oliver Burke
Affirmative
N/A
1
Evergy
Allen Klassen
Affirmative
N/A
1
Eversource Energy
Quintin Lee
Affirmative
N/A
1
Exelon
Daniel Gacek
Affirmative
N/A
1
FirstEnergy - FirstEnergy
Corporation
Julie Severino
Affirmative
N/A
1
Georgia Transmission
Corporation
Greg Davis
Affirmative
N/A
1
Great River Energy
Gordon Pietsch
Affirmative
N/A
1
Hydro One Networks,
Inc.
Payam
Farahbakhsh
Affirmative
N/A
1
Hydro-Qu?bec
TransEnergie
Nicolas Turcotte
Affirmative
N/A
1
IDACORP - Idaho Power
Company
Laura Nelson
Affirmative
N/A
1
Imperial Irrigation District
Jesus Sammy
Alcaraz
Denise Sanchez
Affirmative
N/A
1
International
Transmission Company
Holdings Corporation
Michael Moltane
Allie Gavin
Abstain
N/A
1
JEA
Joe McClung
Negative
No Comment
Submitted
Douglas Webb
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 4 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
1
KAMO Electric
Cooperative
Micah Breedlove
Affirmative
N/A
1
Los Angeles Department
of Water and Power
faranak sarbaz
Affirmative
N/A
1
Lower Colorado River
Authority
James Baldwin
Affirmative
N/A
1
MEAG Power
David Weekley
Scott Miller
Affirmative
N/A
1
Minnkota Power
Cooperative Inc.
Theresa Allard
Andy Fuhrman
Affirmative
N/A
1
Muscatine Power and
Water
Andy Kurriger
Affirmative
N/A
1
N.W. Electric Power
Cooperative, Inc.
Mark Ramsey
Affirmative
N/A
1
National Grid USA
Michael Jones
Affirmative
N/A
1
NB Power Corporation
Nurul Abser
Affirmative
N/A
1
Nebraska Public Power
District
Jamison Cawley
Abstain
N/A
1
New York Power
Authority
Salvatore
Spagnolo
Affirmative
N/A
1
NextEra Energy - Florida
Power and Light Co.
Mike ONeil
Affirmative
N/A
1
NiSource - Northern
Indiana Public Service
Co.
Steve Toosevich
Affirmative
N/A
1
OGE Energy - Oklahoma
Gas and Electric Co.
Terri Pyle
Affirmative
N/A
1
Omaha Public Power
District
Doug Peterchuck
Affirmative
N/A
1
Oncor Electric Delivery
Lee Maurer
Affirmative
N/A
1
Orlando Utilities
Commission
Aaron Staley
None
N/A
1
OTP - Otter Tail Power
Company
Charles Wicklund
Affirmative
N/A
1
Pacific Gas and Electric
Marco Rios
None
N/A
Tammy Porter
Company
© 2021 - NERC Ver 4.3.0.0
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Index - NERC Balloting Tool
Segment
Organization
Page 5 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
1
Platte River Power
Authority
Matt Thompson
Abstain
N/A
1
PPL Electric Utilities
Corporation
Preston Walker
None
N/A
1
PSEG - Public Service
Electric and Gas Co.
Randhir Singh
Abstain
N/A
1
Public Utility District No.
1 of Chelan County
Ginette Lacasse
Affirmative
N/A
1
Public Utility District No.
1 of Snohomish County
Alyssia Rhoads
Affirmative
N/A
1
Salt River Project
Chris Hofmann
Affirmative
N/A
1
Santee Cooper
Chris Wagner
Affirmative
N/A
1
SaskPower
Wayne
Guttormson
Abstain
N/A
1
Seattle City Light
Pawel Krupa
Affirmative
N/A
1
Seminole Electric
Cooperative, Inc.
Bret Galbraith
Negative
No Comment
Submitted
1
Southern Company Southern Company
Services, Inc.
Matt Carden
Affirmative
N/A
1
Sunflower Electric Power
Corporation
Paul Mehlhaff
Affirmative
N/A
1
Tacoma Public Utilities
(Tacoma, WA)
John Merrell
Affirmative
N/A
1
Tennessee Valley
Authority
Gabe Kurtz
Abstain
N/A
1
Tri-State G and T
Association, Inc.
Kjersti Drott
Affirmative
N/A
1
U.S. Bureau of
Reclamation
Richard Jackson
Affirmative
N/A
1
Western Area Power
Administration
sean erickson
Negative
No Comment
Submitted
2
California ISO
Jamie Johnson
Abstain
N/A
2
Electric Reliability
Brandon Gleason
Affirmative
N/A
Jennie Wike
Council
of Texas,
Inc. ERODVSBSWB01
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Page 6 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
2
Independent Electricity
System Operator
Leonard Kula
None
N/A
2
ISO New England, Inc.
Michael Puscas
Affirmative
N/A
2
Midcontinent ISO, Inc.
Bobbi Welch
Affirmative
N/A
2
New York Independent
System Operator
Gregory Campoli
Abstain
N/A
2
PJM Interconnection,
L.L.C.
Tom Foster
Affirmative
N/A
2
Southwest Power Pool,
Inc. (RTO)
Charles Yeung
Affirmative
N/A
3
AEP
Kent Feliks
Affirmative
N/A
3
AES - Indianapolis
Power and Light Co.
Colleen Campbell
Affirmative
N/A
3
Ameren - Ameren
Services
David Jendras
Abstain
N/A
3
APS - Arizona Public
Service Co.
Jessica Lopez
Affirmative
N/A
3
Austin Energy
W. Dwayne
Preston
Affirmative
N/A
3
Avista - Avista
Corporation
Scott Kinney
None
N/A
3
Basin Electric Power
Cooperative
Jeremy Voll
Affirmative
N/A
3
BC Hydro and Power
Authority
Hootan Jarollahi
Abstain
N/A
3
Berkshire Hathaway
Energy - MidAmerican
Energy Co.
Darnez Gresham
Affirmative
N/A
3
Black Hills Corporation
Don Stahl
Affirmative
N/A
3
Bonneville Power
Administration
Ken Lanehome
Affirmative
N/A
3
Central Electric Power
Cooperative (Missouri)
Adam Weber
Affirmative
N/A
3
Cleco Corporation
Maurice Paulk
Affirmative
N/A
Elizabeth Davis
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 7 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
3
CMS Energy Consumers Energy
Company
Karl Blaszkowski
Affirmative
N/A
3
Colorado Springs
Utilities
Hillary Dobson
Affirmative
N/A
3
Dominion - Dominion
Resources, Inc.
Connie Lowe
Abstain
N/A
3
DTE Energy - Detroit
Edison Company
Karie Barczak
Affirmative
N/A
3
Duke Energy
Lee Schuster
Affirmative
N/A
3
Edison International Southern California
Edison Company
Romel Aquino
Affirmative
N/A
3
Evergy
Marcus Moor
Affirmative
N/A
3
Eversource Energy
Christopher
McKinnon
Affirmative
N/A
3
Exelon
Kinte Whitehead
Affirmative
N/A
3
FirstEnergy - FirstEnergy
Corporation
Aaron
Ghodooshim
Affirmative
N/A
3
Florida Municipal Power
Agency
Dale Ray
Affirmative
N/A
3
Georgia System
Operations Corporation
Scott McGough
Affirmative
N/A
3
Great River Energy
Michael Brytowski
Affirmative
N/A
3
Imperial Irrigation District
Glen Allegranza
Affirmative
N/A
3
JEA
Garry Baker
None
N/A
3
KAMO Electric
Cooperative
Tony Gott
Affirmative
N/A
3
Lakeland Electric
Patricia Boody
None
N/A
3
Lincoln Electric System
Jason Fortik
Affirmative
N/A
3
Los Angeles Department
of Water and Power
Tony Skourtas
Affirmative
N/A
Affirmative
N/A
3
M and A Electric Power
Stephen Pogue
Cooperative
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
Douglas Webb
Truong Le
Denise Sanchez
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 8 of 16
Voter
3
MEAG Power
Roger Brand
3
Muscatine Power and
Water
3
Designated
Proxy
NERC
Memo
Affirmative
N/A
Seth Shoemaker
Affirmative
N/A
National Grid USA
Brian Shanahan
Affirmative
N/A
3
Nebraska Public Power
District
Tony Eddleman
Abstain
N/A
3
New York Power
Authority
David Rivera
Affirmative
N/A
3
NiSource - Northern
Indiana Public Service
Co.
Steven Taddeucci
Affirmative
N/A
3
Northeast Missouri
Electric Power
Cooperative
Skyler Wiegmann
None
N/A
3
NW Electric Power
Cooperative, Inc.
John Stickley
Affirmative
N/A
3
OGE Energy - Oklahoma
Gas and Electric Co.
Donald Hargrove
Affirmative
N/A
3
OTP - Otter Tail Power
Company
Wendi Olson
Affirmative
N/A
3
Owensboro Municipal
Utilities
Thomas Lyons
Affirmative
N/A
3
Platte River Power
Authority
Wade Kiess
Abstain
N/A
3
Portland General Electric
Co.
Dan Zollner
None
N/A
3
PPL - Louisville Gas and
Electric Co.
James Frank
None
N/A
3
PSEG - Public Service
Electric and Gas Co.
maria pardo
Abstain
N/A
3
Public Utility District No.
1 of Chelan County
Joyce Gundry
Affirmative
N/A
3
Puget Sound Energy,
Inc.
Tim Womack
None
N/A
Affirmative
N/A
3
Santee Cooper
James Poston
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
Scott Miller
Ballot
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 9 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
3
Seminole Electric
Cooperative, Inc.
Jeremy Lorigan
Negative
No Comment
Submitted
3
Sho-Me Power Electric
Cooperative
Jarrod Murdaugh
Affirmative
N/A
3
Snohomish County PUD
No. 1
Holly Chaney
Affirmative
N/A
3
Southern Company Alabama Power
Company
Joel Dembowski
Affirmative
N/A
3
Tacoma Public Utilities
(Tacoma, WA)
Marc Donaldson
Affirmative
N/A
3
TECO - Tampa Electric
Co.
Ronald Donahey
None
N/A
3
Tennessee Valley
Authority
Ian Grant
Abstain
N/A
3
Tri-State G and T
Association, Inc.
Janelle Marriott
Gill
Affirmative
N/A
3
WEC Energy Group, Inc.
Thomas Breene
Affirmative
N/A
4
Alliant Energy
Corporation Services,
Inc.
Larry Heckert
Affirmative
N/A
4
Austin Energy
Jun Hua
Affirmative
N/A
4
City Utilities of
Springfield, Missouri
John Allen
Affirmative
N/A
4
CMS Energy Consumers Energy
Company
Aric Root
Affirmative
N/A
4
FirstEnergy - FirstEnergy
Corporation
Mark Garza
Affirmative
N/A
4
Florida Municipal Power
Agency
Carol Chinn
Affirmative
N/A
4
LaGen
Wayne Messina
None
N/A
4
Modesto Irrigation
District
Spencer Tacke
None
N/A
Affirmative
N/A
4
Public Utility District No.
John Martinsen
© 2021 - NERC Ver 4.3.0.0
Machine Name:
1 of Snohomish
CountyERODVSBSWB01
Jennie Wike
Truong Le
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 10 of 16
Voter
4
Public Utility District No.
2 of Grant County,
Washington
Karla Weaver
4
Sacramento Municipal
Utility District
Foung Mua
4
Seattle City Light
Hao Li
4
Tacoma Public Utilities
(Tacoma, WA)
Hien Ho
4
WEC Energy Group, Inc.
5
Designated
Proxy
Ballot
NERC
Memo
Affirmative
N/A
Negative
No Comment
Submitted
Affirmative
N/A
Affirmative
N/A
Matthew Beilfuss
Affirmative
N/A
Acciona Energy North
America
George Brown
Affirmative
N/A
5
AEP
Thomas Foltz
Affirmative
N/A
5
Ameren - Ameren
Missouri
Sam Dwyer
Abstain
N/A
5
APS - Arizona Public
Service Co.
Kelsi Rigby
Affirmative
N/A
5
Austin Energy
Michael Dillard
Affirmative
N/A
5
Avista - Avista
Corporation
Glen Farmer
Affirmative
N/A
5
Basin Electric Power
Cooperative
Colleen Peterson
Affirmative
N/A
5
BC Hydro and Power
Authority
Helen Hamilton
Harding
None
N/A
5
Berkshire Hathaway NV Energy
Kevin Salsbury
Affirmative
N/A
5
Boise-Kuna Irrigation
District - Lucky Peak
Power Plant Project
Mike Kukla
Affirmative
N/A
5
Bonneville Power
Administration
Scott Winner
Affirmative
N/A
5
Brazos Electric Power
Cooperative, Inc.
Shari Heino
None
N/A
5
Cleco Corporation
Stephanie
Huffman
None
N/A
Joe Tarantino
Jennie Wike
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 11 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
5
CMS Energy Consumers Energy
Company
David Greyerbiehl
Affirmative
N/A
5
Colorado Springs
Utilities
Jeff Icke
None
N/A
5
Dairyland Power
Cooperative
Tommy Drea
Affirmative
N/A
5
Dominion - Dominion
Resources, Inc.
Rachel Snead
None
N/A
5
DTE Energy - Detroit
Edison Company
Adrian Raducea
None
N/A
5
Duke Energy
Dale Goodwine
Affirmative
N/A
5
Edison International Southern California
Edison Company
Neil Shockey
Affirmative
N/A
5
Entergy
Jamie Prater
Affirmative
N/A
5
Evergy
Derek Brown
Affirmative
N/A
5
Exelon
Cynthia Lee
Affirmative
N/A
5
FirstEnergy - FirstEnergy
Corporation
Robert Loy
Affirmative
N/A
5
Florida Municipal Power
Agency
Chris Gowder
Affirmative
N/A
5
Great River Energy
Jacalynn Bentz
Affirmative
N/A
5
Herb Schrayshuen
Herb Schrayshuen
Affirmative
N/A
5
Hydro-Qu?bec
Production
Carl Pineault
Affirmative
N/A
5
Imperial Irrigation District
Tino Zaragoza
Affirmative
N/A
5
JEA
John Babik
Negative
No Comment
Submitted
5
Lincoln Electric System
Kayleigh
Wilkerson
Affirmative
N/A
5
Los Angeles Department
of Water and Power
Glenn Barry
Affirmative
N/A
Douglas Webb
Truong Le
Denise Sanchez
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 12 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
5
Lower Colorado River
Authority
Teresa Cantwell
Affirmative
N/A
5
Massachusetts Municipal
Wholesale Electric
Company
Anthony Stevens
Affirmative
N/A
5
Muscatine Power and
Water
Neal Nelson
Affirmative
N/A
5
NB Power Corporation
Rob Vance
Affirmative
N/A
5
New York Power
Authority
Shivaz Chopra
Affirmative
N/A
5
NiSource - Northern
Indiana Public Service
Co.
Kathryn Tackett
Affirmative
N/A
5
NovaSource Power
Services
Bradley Collard
None
N/A
5
Oglethorpe Power
Corporation
Donna Johnson
Affirmative
N/A
5
Omaha Public Power
District
Mahmood Safi
Affirmative
N/A
5
Ontario Power
Generation Inc.
Constantin
Chitescu
Affirmative
N/A
5
Orlando Utilities
Commission
Dania Colon
Affirmative
N/A
5
OTP - Otter Tail Power
Company
Brett Jacobs
Affirmative
N/A
5
Pacific Gas and Electric
Company
Ed Hanson
Affirmative
N/A
5
Platte River Power
Authority
Tyson Archie
Abstain
N/A
5
Portland General Electric
Co.
Ryan Olson
None
N/A
5
PPL - Louisville Gas and
Electric Co.
JULIE
HOSTRANDER
None
N/A
5
PSEG - PSEG Fossil
LLC
Tim Kucey
Abstain
N/A
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2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 13 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
5
Public Utility District No.
1 of Chelan County
Meaghan Connell
Affirmative
N/A
5
Public Utility District No.
1 of Snohomish County
Sam Nietfeld
Affirmative
N/A
5
Public Utility District No.
2 of Grant County,
Washington
Amy Jones
Affirmative
N/A
5
Sacramento Municipal
Utility District
Nicole Goi
Negative
No Comment
Submitted
5
Salt River Project
Kevin Nielsen
Affirmative
N/A
5
Santee Cooper
Tommy Curtis
Affirmative
N/A
5
Seattle City Light
Faz Kasraie
Affirmative
N/A
5
Seminole Electric
Cooperative, Inc.
Mickey Bellard
Negative
No Comment
Submitted
5
Southern Company Southern Company
Generation
James Howell
Affirmative
N/A
5
Tennessee Valley
Authority
M Lee Thomas
None
N/A
5
Tri-State G and T
Association, Inc.
Ryan Walter
Affirmative
N/A
5
U.S. Bureau of
Reclamation
Wendy Center
Affirmative
N/A
5
WEC Energy Group, Inc.
Janet OBrien
Affirmative
N/A
6
AEP
JT Kuehne
Affirmative
N/A
6
Ameren - Ameren
Services
Robert Quinlivan
Abstain
N/A
6
APS - Arizona Public
Service Co.
Marcus Bortman
Affirmative
N/A
6
Associated Electric
Cooperative, Inc.
Brian Ackermann
None
N/A
6
Austin Energy
Andrew Gallo
Affirmative
N/A
6
Basin Electric Power
Cooperative
Jerry Horner
Affirmative
N/A
Joe Tarantino
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 14 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
6
Black Hills Corporation
Eric Scherr
Affirmative
N/A
6
Bonneville Power
Administration
Andrew Meyers
Affirmative
N/A
6
Cleco Corporation
Robert Hirchak
Affirmative
N/A
6
Dominion - Dominion
Resources, Inc.
Sean Bodkin
None
N/A
6
Duke Energy
Greg Cecil
Affirmative
N/A
6
Evergy
Thomas ROBBEN
Affirmative
N/A
6
Exelon
Becky Webb
Affirmative
N/A
6
FirstEnergy - FirstEnergy
Corporation
Ann Carey
Affirmative
N/A
6
Florida Municipal Power
Agency
Richard
Montgomery
Truong Le
Affirmative
N/A
6
Imperial Irrigation District
Diana Torres
Denise Sanchez
Affirmative
N/A
6
Los Angeles Department
of Water and Power
Anton Vu
Affirmative
N/A
6
Muscatine Power and
Water
Nick Burns
Affirmative
N/A
6
New York Power
Authority
Erick Barrios
Affirmative
N/A
6
NextEra Energy - Florida
Power and Light Co.
Justin Welty
None
N/A
6
NiSource - Northern
Indiana Public Service
Co.
Joe O'Brien
Affirmative
N/A
6
Northern California
Power Agency
Dennis Sismaet
Abstain
N/A
6
OGE Energy - Oklahoma
Gas and Electric Co.
Sing Tay
Affirmative
N/A
6
Omaha Public Power
District
Joel Robles
Affirmative
N/A
6
Platte River Power
Authority
Sabrina Martz
Abstain
N/A
Douglas Webb
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2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 15 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
6
Portland General Electric
Co.
Daniel Mason
Affirmative
N/A
6
Powerex Corporation
Gordon DobsonMack
None
N/A
6
PPL - Louisville Gas and
Electric Co.
Linn Oelker
None
N/A
6
PSEG - PSEG Energy
Resources and Trade
LLC
Joseph Neglia
Abstain
N/A
6
Public Utility District No.
1 of Chelan County
Glen Pruitt
Affirmative
N/A
6
Public Utility District No.
2 of Grant County,
Washington
LeRoy Patterson
Affirmative
N/A
6
Sacramento Municipal
Utility District
Charles Norton
Negative
No Comment
Submitted
6
Santee Cooper
Marty Watson
Affirmative
N/A
6
Snohomish County PUD
No. 1
John Liang
Affirmative
N/A
6
Southern Company Southern Company
Generation
Ron Carlsen
Affirmative
N/A
6
Tacoma Public Utilities
(Tacoma, WA)
Terry Gifford
Affirmative
N/A
6
Tennessee Valley
Authority
Marjorie Parsons
Abstain
N/A
6
WEC Energy Group, Inc.
David Hathaway
Affirmative
N/A
6
Xcel Energy, Inc.
Carrie Dixon
Abstain
N/A
8
David Kiguel
David Kiguel
Affirmative
N/A
10
New York State
Reliability Council
ALAN ADAMSON
Affirmative
N/A
10
Northeast Power
Coordinating Council
Guy V. Zito
Affirmative
N/A
10
ReliabilityFirst
Anthony Jablonski
Affirmative
N/A
Joe Tarantino
Jennie Wike
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2/9/2021
Index - NERC Balloting Tool
Segment
10
Organization
Texas Reliability Entity,
Inc.
Page 16 of 16
Voter
Rachel Coyne
Designated
Proxy
Ballot
Abstain
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NERC
Memo
N/A
1
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Showing 1 to 254 of 254 entries
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
FAC-008-5 – Facility Ratings
A. Introduction
1.
Title:
Facility Ratings
2.
Number:
FAC-008-5
3.
Purpose:
To ensure that Facility Ratings used in the reliable planning and
operation of the Bulk Electric System (BES) are determined based
on technically sound principles. A Facility Rating is essential for the
determination of System Operating Limits.
4.
Applicability:
4.1. Transmission Owner
4.2. Generator Owner
5.
Effective Date:
See Implementation Plan.
Page 1 of 13
FAC-008-5 – Facility Ratings
B. Requirements and Measures
R1. Each Generator Owner shall have documentation for determining the Facility Ratings
of its solely and jointly owned generator Facility(ies) up to the low side terminals of
the main step up transformer if the Generator Owner does not own the main step up
transformer and the high side terminals of the main step up transformer if the
Generator Owner owns the main step up transformer. [Violation Risk Factor: Lower]
[Time Horizon: Long-term Planning]
1.1. The documentation shall contain assumptions used to rate the generator and at
least one of the following:
•
Design or construction information such as design criteria, ratings provided
by equipment manufacturers, equipment drawings and/or specifications,
engineering analyses, method(s) consistent with industry standards (e.g.
ANSI and IEEE), or an established engineering practice that has been verified
by testing or engineering analysis.
•
Operational information such as commissioning test results, performance
testing or historical performance records, any of which may be
supplemented by engineering analyses.
1.2. The documentation shall be consistent with the principle that the Facility Ratings
do not exceed the most limiting applicable Equipment Rating of the individual
equipment that comprises that Facility.
M1. Each Generator Owner shall have documentation that shows how its Facility Ratings
were determined as identified in Requirement 1.
R2. Each Generator Owner shall have a documented methodology for determining Facility
Ratings (Facility Ratings methodology) of its solely and jointly owned equipment
connected between the location specified in R1 and the point of interconnection with
the Transmission Owner that contains all of the following. [Violation Risk Factor:
Medium] [Time Horizon: Long-term Planning]
2.1. The methodology used to establish the Ratings of the equipment that comprises
the Facility(ies) shall be consistent with at least one of the following:
•
Ratings provided by equipment manufacturers or obtained from equipment
manufacturer specifications such as nameplate rating.
•
One or more industry standards developed through an open process such as
Institute of Electrical and Electronic Engineers (IEEE) or International Council
on Large Electric Systems (CIGRE).
•
A practice that has been verified by testing, performance history or
engineering analysis.
Page 2 of 13
FAC-008-5 – Facility Ratings
2.2. The underlying assumptions, design criteria, and methods used to determine the
Equipment Ratings identified in Requirement R2, Part 2.1 including identification
of how each of the following were considered:
2.2.1. Equipment Rating standard(s) used in development of this methodology.
2.2.2. Ratings provided by equipment manufacturers or obtained from
equipment manufacturer specifications.
2.2.3. Ambient conditions (for particular or average conditions or as they vary
in real-time).
2.2.4. Operating limitations.1
2.3. A statement that a Facility Rating shall respect the most limiting applicable
Equipment Rating of the individual equipment that comprises that Facility.
2.4. The process by which the Rating of equipment that comprises a Facility is
determined.
2.4.1. The scope of equipment addressed shall include, but not be limited to,
conductors, transformers, relay protective devices, terminal equipment,
and series and shunt compensation devices.
2.4.2. The scope of Ratings addressed shall include, as a minimum, both Normal
and Emergency Ratings.
M2. Each Generator Owner shall have a documented Facility Ratings methodology that
includes all of the items identified in Requirement 2, Parts 2.1 through 2.4.
R3. Each Transmission Owner shall have a documented methodology for determining
Facility Ratings (Facility Ratings methodology) of its solely and jointly owned Facilities
(except for those generating unit Facilities addressed in R1 and R2) that contains all of
the following: [Violation Risk Factor: Medium] [ Time Horizon: Long-term Planning]
3.1. The methodology used to establish the Ratings of the equipment that comprises
the Facility shall be consistent with at least one of the following:
1
•
Ratings provided by equipment manufacturers or obtained from equipment
manufacturer specifications such as nameplate rating.
•
One or more industry standards developed through an open process such as
Institute of Electrical and Electronics Engineers (IEEE) or International Council
on Large Electric Systems (CIGRE).
•
A practice that has been verified by testing, performance history or
engineering analysis.
Such as temporary de-ratings of impaired equipment in accordance with good utility practice.
Page 3 of 13
FAC-008-5 – Facility Ratings
3.2. The underlying assumptions, design criteria, and methods used to determine the
Equipment Ratings identified in Requirement R3, Part 3.1 including identification
of how each of the following were considered:
3.2.1. Equipment Rating standard(s) used in development of this methodology.
3.2.2. Ratings provided by equipment manufacturers or obtained from
equipment manufacturer specifications.
3.2.3. Ambient conditions (for particular or average conditions or as they vary
in real-time).
3.2.4. Operating limitations.2
3.3. A statement that a Facility Rating shall respect the most limiting applicable
Equipment Rating of the individual equipment that comprises that Facility.
3.4. The process by which the Rating of equipment that comprises a Facility is
determined.
3.4.1. The scope of equipment addressed shall include, but not be limited to,
transmission conductors, transformers, relay protective devices, terminal
equipment, and series and shunt compensation devices.
3.4.2. The scope of Ratings addressed shall include, as a minimum, both Normal
and Emergency Ratings.
M3. Each Transmission Owner shall have a documented Facility Ratings methodology that
includes all of the items identified in Requirement 3, Parts 3.1 through 3.4.
R4. Reserved.
M4. Reserved.
R5. Reserved.
M5. Reserved.
R6. Each Transmission Owner and Generator Owner shall have Facility Ratings for its
solely and jointly owned Facilities that are consistent with the associated Facility
Ratings methodology or documentation for determining its Facility Ratings. [Violation
Risk Factor: Medium] [Time Horizon: Operations Planning]
M6. Each Transmission Owner and Generator Owner shall have evidence to show that its
Facility Ratings are consistent with the documentation for determining its Facility
Ratings as specified in Requirement R1 or consistent with its Facility Ratings
methodology as specified in Requirements R2 and R3 (Requirement R6).
R7. Reserved.
M7. Reserved.
2
Such as temporary de-ratings of impaired equipment in accordance with good utility practice.
Page 4 of 13
FAC-008-5 – Facility Ratings
R8.
Each Transmission Owner (and each Generator Owner subject to Requirement R2)
shall provide requested information as specified below (for its solely and jointly
owned Facilities that are existing Facilities, new Facilities, modifications to existing
Facilities and re-ratings of existing Facilities) to its associated Reliability
Coordinator(s), Planning Coordinator(s), Transmission Planner(s), Transmission
Owner(s) and Transmission Operator(s): [Violation Risk Factor: Medium] [Time
Horizon: Operations Planning]
8.1.
As scheduled by the requesting entities:
8.2.
8.1.1.
Facility Ratings
8.1.2.
Identity of the most limiting equipment of the Facilities
Within 30 calendar days (or a later date if specified by the requester), for any
requested Facility with a Thermal Rating that limits the use of Facilities under
the requester’s authority by causing any of the following: 1) An
Interconnection Reliability Operating Limit, 2) A limitation of Total Transfer
Capability, 3) An impediment to generator deliverability, or 4) An impediment
to service to a major load center:
8.2.1.
Identity of the existing next most limiting equipment of the Facility
8.2.2.
The Thermal Rating for the next most limiting equipment identified
in Requirement R8, Part 8.2.1.
M8. Each Transmission Owner (and Generator Owner subject to Requirement R2) shall
have evidence, such as a copy of a dated electronic note, or other comparable
evidence to show that it provided its Facility Ratings and identity of limiting equipment
to its associated Reliability Coordinator(s), Planning Coordinator(s), Transmission
Planner(s), Transmission Owner(s) and Transmission Operator(s) in accordance with
Requirement R8.
C. Compliance
1.
Compliance Monitoring Process
1.1. Compliance Enforcement Authority: “Compliance Enforcement Authority”
means NERC or the Regional Entity, or any entity as otherwise designated by an
Applicable Governmental Authority, in their respective roles of monitoring
and/or enforcing compliance with mandatory and enforceable Reliability
Standards in their respective jurisdictions.
1.2. Compliance Monitoring and Enforcement Processes:
•
Self-Certifications
•
Spot Checking
•
Compliance Audits
•
Self-Reporting
Page 5 of 13
FAC-008-5 – Facility Ratings
•
Compliance Violation Investigations
•
Complaints
1.3. Evidence Retention: The following evidence retention period(s) identify the
period of time an entity is required to retain specific evidence to demonstrate
compliance. For instances where the evidence retention period specified below
is shorter than the time since the last audit, the Compliance Enforcement
Authority may ask an entity to provide other evidence to show that it was
compliant for the full-time period since the last audit.
The applicable entity shall keep data or evidence to show compliance as
identified below unless directed by its Compliance Enforcement Authority to
retain specific evidence for a longer period of time as part of an investigation.
•
The Generator Owner shall keep its current documentation (for R1) and any
modifications to the documentation that were in force since last compliance
audit period for Measure M1 and Measure M6.
•
The Generator Owner shall keep its current, in force Facility Ratings
methodology (for R2) and any modifications to the methodology that were in
force since last compliance audit period for Measure M2 and Measure M6.
•
The Transmission Owner shall keep its current, in force Facility Ratings
methodology (for R3) and any modifications to the methodology that were in
force since the last compliance audit for Measure M3 and Measure M6.
•
The Transmission Owner and Generator Owner shall keep its current, in force
Facility Ratings and any changes to those ratings for three calendar years for
Measure M6.
•
The Transmission Owner (and Generator Owner that is subject to
Requirement R2) shall keep evidence for Measure M8 for three calendar
years.
•
If a Generator Owner or Transmission Owner is found non-compliant, it shall
keep information related to the non-compliance until found compliant.
•
The Compliance Enforcement Authority shall keep the last audit and all
subsequent compliance records.
1.4. Compliance Monitoring and Enforcement Program: As defined in the NERC
Rules of Procedure, “Compliance Monitoring and Enforcement Program” refers
to the identification of the processes that will be used to evaluate data or
information for the purpose of assessing performance or outcomes with the
associated Reliability Standard.
Page 6 of 13
FAC-008-5 – Facility Ratings
Violation Severity Levels
Violation Severity Levels
R#
Lower VSL
Moderate VSL
High VSL
Severe VSL
R1.
N/A
The Generator Owner’s
Facility Rating
documentation did not
address Requirement R1,
Part 1.1.
The Generator Owner’s
Facility Rating
documentation did not
address Requirement R1,
Part 1.2.
The Generator Owner failed to
provide documentation for
determining its Facility Ratings.
R2.
The Generator Owner
failed to include in its
Facility Rating
methodology one of the
following Parts of
Requirement R2:
The Generator Owner failed
to include in its Facility
Rating methodology two of
the following Parts of
Requirement R2:
The Generator Owner’s
Facility Rating methodology
did not address all the
components of
Requirement R2, Part 2.4.
The Generator Owner’s Facility
Rating methodology failed to
recognize a facility's rating
based on the most limiting
component rating as required
in Requirement R2, Part 2.3
•
2.1.
•
2.2.1
•
2.2.2
•
2.2.3
•
2.2.4
•
2.1
OR
•
2.2.1
•
2.2.2
•
2.2.3
•
2.2.4
The Generator Owner failed
to include in its Facility
Rating Methodology, three
of the following Parts of
Requirement R2:
•
2.1.
•
2.2.1
•
2.2.2
•
2.2.3
•
2.2.4
OR
The Generator Owner failed to
include in its Facility Rating
Methodology four or more of
the following Parts of
Requirement R2:
•
2.1
•
2.2.1
•
2.2.2
•
2.2.3
•
2.2.4
Page 7 of 13
FAC-008-5 – Facility Ratings
Violation Severity Levels
R#
R3.
Lower VSL
The Transmission Owner
failed to include in its
Facility Rating
methodology one of the
following Parts of
Requirement R3:
•
3.1
•
3.2.1
•
3.2.2
•
3.2.3
•
3.2.4
Moderate VSL
High VSL
The Transmission Owner
failed to include in its
Facility Rating methodology
two of the following Parts
of Requirement R3:
The Transmission Owner’s
Facility Rating methodology
did not address either of
the following Parts of
Requirement R3:
•
3.1
•
3.4.1
•
3.2.1
•
3.4.2
•
3.2.2
OR
•
3.2.3
•
3.2.4
The Transmission Owner
failed to include in its
Facility Rating methodology
three of the following Parts
of Requirement R3:
•
3.1
•
3.2.1
•
3.2.2
•
3.2.3
•
3.2.4
Severe VSL
The Transmission Owner’s
Facility Rating methodology
failed to recognize a Facility's
rating based on the most
limiting component rating as
required in Requirement R3,
Part 3.3
OR
The Transmission Owner failed
to include in its Facility Rating
methodology four or more of
the following Parts of
Requirement R3:
•
3.1
•
3.2.1
•
3.2.2
•
3.2.3
•
3.2.4
R4.
Reserved.
R5.
Reserved.
Page 8 of 13
FAC-008-5 – Facility Ratings
Violation Severity Levels
R#
R6.
Lower VSL
Moderate VSL
High VSL
Severe VSL
The responsible entity
failed to establish Facility
Ratings consistent with
the associated Facility
Ratings methodology or
documentation for
determining the Facility
Ratings for 5% or less of
its solely owned and
jointly owned Facilities.
(R6)
The responsible entity
failed to establish Facility
Ratings consistent with the
associated Facility Ratings
methodology or
documentation for
determining the Facility
Ratings for more than 5% or
more, but less than up to
(and including) 10% of its
solely owned and jointly
owned Facilities. (R6)
The responsible entity
failed to establish Facility
Ratings consistent with the
associated Facility Ratings
methodology or
documentation for
determining the Facility
Ratings for more than 10%
up to (and including) 15% of
its solely owned and jointly
owned Facilities. (R6)
The responsible entity failed to
establish Facility Ratings
consistent with the associated
Facility Ratings methodology or
documentation for determining
the Facility Ratings for more
than15% of its solely owned
and jointly owned Facilities.
(R6)
The responsible entity
provided its Facility
Ratings to all of the
requesting entities but
missed meeting the
schedules by up to and
including 15 calendar
days. (R8, Part 8.1)
The responsible entity
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
15 calendar days but less
than or equal to 25
calendar days. (R8, Part 8.1)
The responsible entity
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
25 calendar days but less
than or equal to 35
calendar days. (R8, Part 8.1)
The responsible entity provided
its Facility Ratings to all of the
requesting entities but missed
meeting the schedules by more
than 35 calendar days. (R8, Part
8.1)
OR
OR
OR
The responsible entity
provided less than 100%,
The responsible entity
provided less than 95%, but
The responsible entity
provided less than 90%, but
R7.
Reserved.
R8.
OR
The responsible entity provided
less than 85% of the required
Rating information to all of the
Page 9 of 13
FAC-008-5 – Facility Ratings
Violation Severity Levels
R#
Lower VSL
Moderate VSL
High VSL
Severe VSL
but not less than or equal
to 95% of the required
Rating information to all
of the requesting entities.
(R8, Part 8.1)
not less than or equal to
90% of the required Rating
information to all of the
requesting entities. (R8,
Part 8.1)
not less than or equal to
85% of the required Rating
information to all of the
requesting entities. (R8,
Part 8.1)
OR
OR
OR
The responsible entity
provided the required
Rating information to the
requesting entity, but the
information was provided
up to and including 15
calendar days late. (R8,
Part 8.2)
The responsible entity
provided the required
Rating information to the
requesting entity, but did so
more 15 calendar days but
less than or equal to 25
calendar days late. (R8, Part
8.2)
The responsible entity
provided the required
Rating information to the
requesting entity, but did so
more than 25 calendar days
but less than or equal to 35
calendar days late. (R8, Part
8.2)
OR
OR
OR
OR
The responsible entity
provided less than 100%,
but not less than or equal
to 95% of the required
Rating information to the
requesting entity. (R8,
Part 8.2)
The responsible entity
provided less than 95%, but
not less than or equal to
90% of the required Rating
information to the
requesting entity. (R8, Part
8.2)
The responsible entity
provided less than 90%, but
no less than or equal to
85% of the required Rating
information to the
requesting entity. (R8, Part
8.2)
The responsible entity failed to
provide its Rating information
to the requesting entity. (R8,
Part 8.1)
requesting entities. (R8, Part
8.1)
OR
The responsible entity provided
the required Rating information
to the requesting entity, but did
so more than 35 calendar days
late. (R8, Part 8.2)
OR
The responsible entity provided
less than 85 % of the required
Rating information to the
requesting entity. (R8, Part 8.2)
D. Regional Variances
None.
Page 10 of 13
FAC-008-5 – Facility Ratings
E. Associated Documents
None.
Page 11 of 13
FAC-008-5 – Facility Ratings
Version History
Version
Date
Action
Change Tracking
1
Feb 7, 2006
Approved by Board of Trustees
New
1
Mar 16, 2007
Approved by FERC
New
2
May 12, 2010
Approved by Board of Trustees
Complete Revision,
merging FAC_008-1
and FAC-009-1 under
Project 2009-06 and
address directives
from Order 693
3
May 24, 2011
Addition of Requirement R8
Project 2009-06
Expansion to address
third directive from
Order 693
3
May 24, 2011
Adopted by NERC Board of Trustees
3
November 17, FERC Order issued approving FAC-008-3
2011
3
May 17, 2012
FERC Order issued directing the VRF for
Requirement R2 be changed from
“Lower” to “Medium”
3
February 7,
2013
R4 and R5 and associated elements
approved by NERC Board of Trustees for
retirement as part of the Paragraph 81
project (Project 2013-02) pending
applicable regulatory approval.
3
November 21, R4 and R5 and associated elements
2013
approved by FERC for retirement as
part of the Paragraph 81 project
(Project 2013-02)
4
May 9, 2020
R7 and R8 and associated elements
adopted by NERC Board of Trustees for
retirement as part of Project 2018-03
Standards Efficiency Review
Retirements.
4
September
17, 2020
Remanded by FERC (Order No. 873).
Withdrawn
5
February 4,
2021
Adopted by NERC Board of Trustees
Requirement R8 and
associated elements
restored in response
Page 12 of 13
FAC-008-5 – Facility Ratings
Version
Date
Action
Change Tracking
to FERC Order No.
873.
Page 13 of 13
FAC‐008‐5 – Facility Ratings
A. Introduction
1.
Title:
Facility Ratings
2.
Number:
FAC‐008‐5
3.
Purpose:
To ensure that Facility Ratings used in the reliable planning and
operation of the Bulk Electric System (BES) are determined based
on technically sound principles. A Facility Rating is essential for the
determination of System Operating Limits.
4.
Applicability:
4.1. Transmission Owner
4.2. Generator Owner
5.
Effective Date:
See Implementation Plan.
Page 1 of 13
FAC‐008‐5 – Facility Ratings
B. Requirements and Measures
R1. Each Generator Owner shall have documentation for determining the Facility Ratings
of its solely and jointly owned generator Facility(ies) up to the low side terminals of
the main step up transformer if the Generator Owner does not own the main step up
transformer and the high side terminals of the main step up transformer if the
Generator Owner owns the main step up transformer. [Violation Risk Factor: Lower]
[Time Horizon: Long‐term Planning]
1.1. The documentation shall contain assumptions used to rate the generator and at
least one of the following:
Design or construction information such as design criteria, ratings provided
by equipment manufacturers, equipment drawings and/or specifications,
engineering analyses, method(s) consistent with industry standards (e.g.
ANSI and IEEE), or an established engineering practice that has been verified
by testing or engineering analysis.
Operational information such as commissioning test results, performance
testing or historical performance records, any of which may be
supplemented by engineering analyses.
1.2. The documentation shall be consistent with the principle that the Facility Ratings
do not exceed the most limiting applicable Equipment Rating of the individual
equipment that comprises that Facility.
M1. Each Generator Owner shall have documentation that shows how its Facility Ratings
were determined as identified in Requirement 1.
R2. Each Generator Owner shall have a documented methodology for determining Facility
Ratings (Facility Ratings methodology) of its solely and jointly owned equipment
connected between the location specified in R1 and the point of interconnection with
the Transmission Owner that contains all of the following. [Violation Risk Factor:
Medium] [Time Horizon: Long‐term Planning]
2.1. The methodology used to establish the Ratings of the equipment that comprises
the Facility(ies) shall be consistent with at least one of the following:
Ratings provided by equipment manufacturers or obtained from equipment
manufacturer specifications such as nameplate rating.
One or more industry standards developed through an open process such as
Institute of Electrical and Electronic Engineers (IEEE) or International Council
on Large Electric Systems (CIGRE).
A practice that has been verified by testing, performance history or
engineering analysis.
Page 2 of 13
FAC‐008‐5 – Facility Ratings
2.2. The underlying assumptions, design criteria, and methods used to determine the
Equipment Ratings identified in Requirement R2, Part 2.1 including identification
of how each of the following were considered:
2.2.1. Equipment Rating standard(s) used in development of this methodology.
2.2.2. Ratings provided by equipment manufacturers or obtained from
equipment manufacturer specifications.
2.2.3. Ambient conditions (for particular or average conditions or as they vary
in real‐time).
2.2.4. Operating limitations.1
2.3. A statement that a Facility Rating shall respect the most limiting applicable
Equipment Rating of the individual equipment that comprises that Facility.
2.4. The process by which the Rating of equipment that comprises a Facility is
determined.
2.4.1. The scope of equipment addressed shall include, but not be limited to,
conductors, transformers, relay protective devices, terminal equipment,
and series and shunt compensation devices.
2.4.2. The scope of Ratings addressed shall include, as a minimum, both Normal
and Emergency Ratings.
M2. Each Generator Owner shall have a documented Facility Ratings methodology that
includes all of the items identified in Requirement 2, Parts 2.1 through 2.4.
R3. Each Transmission Owner shall have a documented methodology for determining
Facility Ratings (Facility Ratings methodology) of its solely and jointly owned Facilities
(except for those generating unit Facilities addressed in R1 and R2) that contains all of
the following: [Violation Risk Factor: Medium] [ Time Horizon: Long‐term Planning]
3.1. The methodology used to establish the Ratings of the equipment that comprises
the Facility shall be consistent with at least one of the following:
1
Ratings provided by equipment manufacturers or obtained from equipment
manufacturer specifications such as nameplate rating.
One or more industry standards developed through an open process such as
Institute of Electrical and Electronics Engineers (IEEE) or International Council
on Large Electric Systems (CIGRE).
A practice that has been verified by testing, performance history or
engineering analysis.
Such as temporary de‐ratings of impaired equipment in accordance with good utility practice.
Page 3 of 13
FAC‐008‐5 – Facility Ratings
3.2. The underlying assumptions, design criteria, and methods used to determine the
Equipment Ratings identified in Requirement R3, Part 3.1 including identification
of how each of the following were considered:
3.2.1. Equipment Rating standard(s) used in development of this methodology.
3.2.2. Ratings provided by equipment manufacturers or obtained from
equipment manufacturer specifications.
3.2.3. Ambient conditions (for particular or average conditions or as they vary
in real‐time).
3.2.4. Operating limitations.2
3.3. A statement that a Facility Rating shall respect the most limiting applicable
Equipment Rating of the individual equipment that comprises that Facility.
3.4. The process by which the Rating of equipment that comprises a Facility is
determined.
3.4.1. The scope of equipment addressed shall include, but not be limited to,
transmission conductors, transformers, relay protective devices, terminal
equipment, and series and shunt compensation devices.
3.4.2. The scope of Ratings addressed shall include, as a minimum, both Normal
and Emergency Ratings.
M3. Each Transmission Owner shall have a documented Facility Ratings methodology that
includes all of the items identified in Requirement 3, Parts 3.1 through 3.4.
R4. Reserved.
M4. Reserved.
R5. Reserved.
M5. Reserved.
R6. Each Transmission Owner and Generator Owner shall have Facility Ratings for its
solely and jointly owned Facilities that are consistent with the associated Facility
Ratings methodology or documentation for determining its Facility Ratings. [Violation
Risk Factor: Medium] [Time Horizon: Operations Planning]
M6. Each Transmission Owner and Generator Owner shall have evidence to show that its
Facility Ratings are consistent with the documentation for determining its Facility
Ratings as specified in Requirement R1 or consistent with its Facility Ratings
methodology as specified in Requirements R2 and R3 (Requirement R6).
R7. Reserved.
M7. Reserved.
2
Such as temporary de-ratings of impaired equipment in accordance with good utility practice.
Page 4 of 13
FAC‐008‐5 – Facility Ratings
R8.
Each Transmission Owner (and each Generator Owner subject to Requirement R2)
shall provide requested information as specified below (for its solely and jointly
owned Facilities that are existing Facilities, new Facilities, modifications to existing
Facilities and re‐ratings of existing Facilities) to its associated Reliability
Coordinator(s), Planning Coordinator(s), Transmission Planner(s), Transmission
Owner(s) and Transmission Operator(s): [Violation Risk Factor: Medium] [Time
Horizon: Operations Planning]
8.1.
As scheduled by the requesting entities:
8.2.
8.1.1.
Facility Ratings
8.1.2.
Identity of the most limiting equipment of the Facilities
Within 30 calendar days (or a later date if specified by the requester), for any
requested Facility with a Thermal Rating that limits the use of Facilities under
the requester’s authority by causing any of the following: 1) An
Interconnection Reliability Operating Limit, 2) A limitation of Total Transfer
Capability, 3) An impediment to generator deliverability, or 4) An impediment
to service to a major load center:
8.2.1.
Identity of the existing next most limiting equipment of the Facility
8.2.2.
The Thermal Rating for the next most limiting equipment identified
in Requirement R8, Part 8.2.1.
M8. Each Transmission Owner (and Generator Owner subject to Requirement R2) shall
have evidence, such as a copy of a dated electronic note, or other comparable
evidence to show that it provided its Facility Ratings and identity of limiting equipment
to its associated Reliability Coordinator(s), Planning Coordinator(s), Transmission
Planner(s), Transmission Owner(s) and Transmission Operator(s) in accordance with
Requirement R8.
C. Compliance
1.
Compliance Monitoring Process
1.1. Compliance Enforcement Authority: “Compliance Enforcement Authority”
means NERC or the Regional Entity, or any entity as otherwise designated by an
Applicable Governmental Authority, in their respective roles of monitoring
and/or enforcing compliance with mandatory and enforceable Reliability
Standards in their respective jurisdictions.
1.2. Compliance Monitoring and Enforcement Processes:
Self‐Certifications
Spot Checking
Compliance Audits
Self‐Reporting
Page 5 of 13
FAC‐008‐5 – Facility Ratings
Compliance Violation Investigations
Complaints
1.3. Evidence Retention: The following evidence retention period(s) identify the
period of time an entity is required to retain specific evidence to demonstrate
compliance. For instances where the evidence retention period specified below
is shorter than the time since the last audit, the Compliance Enforcement
Authority may ask an entity to provide other evidence to show that it was
compliant for the full‐time period since the last audit.
The applicable entity shall keep data or evidence to show compliance as
identified below unless directed by its Compliance Enforcement Authority to
retain specific evidence for a longer period of time as part of an investigation.
The Generator Owner shall keep its current documentation (for R1) and any
modifications to the documentation that were in force since last compliance
audit period for Measure M1 and Measure M6.
The Generator Owner shall keep its current, in force Facility Ratings
methodology (for R2) and any modifications to the methodology that were in
force since last compliance audit period for Measure M2 and Measure M6.
The Transmission Owner shall keep its current, in force Facility Ratings
methodology (for R3) and any modifications to the methodology that were in
force since the last compliance audit for Measure M3 and Measure M6.
The Transmission Owner and Generator Owner shall keep its current, in force
Facility Ratings and any changes to those ratings for three calendar years for
Measure M6.
The Transmission Owner (and Generator Owner that is subject to
Requirement R2) shall keep evidence for Measure M8 for three calendar
years.
If a Generator Owner or Transmission Owner is found non‐compliant, it shall
keep information related to the non‐compliance until found compliant.
The Compliance Enforcement Authority shall keep the last audit and all
subsequent compliance records.
1.4. Compliance Monitoring and Enforcement Program: As defined in the NERC
Rules of Procedure, “Compliance Monitoring and Enforcement Program” refers
to the identification of the processes that will be used to evaluate data or
information for the purpose of assessing performance or outcomes with the
associated Reliability Standard.
Page 6 of 13
FAC‐008‐5 – Facility Ratings
Violation Severity Levels
Violation Severity Levels
R#
Lower VSL
High VSL
Severe VSL
R1.
N/A
The Generator Owner’s
Facility Rating
documentation did not
address Requirement R1,
Part 1.1.
The Generator Owner’s
Facility Rating
documentation did not
address Requirement R1,
Part 1.2.
The Generator Owner failed to
provide documentation for
determining its Facility Ratings.
R2.
The Generator Owner
failed to include in its
Facility Rating
methodology one of the
following Parts of
Requirement R2:
The Generator Owner failed
to include in its Facility
Rating methodology two of
the following Parts of
Requirement R2:
The Generator Owner’s
Facility Rating methodology
did not address all the
components of
Requirement R2, Part 2.4.
2.1
OR
The Generator Owner’s Facility
Rating methodology failed to
recognize a facility's rating
based on the most limiting
component rating as required
in Requirement R2, Part 2.3
The Generator Owner failed
to include in its Facility
Rating Methodology, three
of the following Parts of
Requirement R2:
2.1.
2.2.1
2.2.1
2.2.2
2.2.2
2.2.3
2.2.3
2.2.4
2.2.4
Moderate VSL
2.1.
2.2.1
2.2.2
2.2.3
2.2.4
OR
The Generator Owner failed to
include in its Facility Rating
Methodology four or more of
the following Parts of
Requirement R2:
2.1
2.2.1
2.2.2
2.2.3
2.2.4
Page 7 of 13
FAC‐008‐5 – Facility Ratings
Violation Severity Levels
R#
R3.
Lower VSL
The Transmission Owner
failed to include in its
Facility Rating
methodology one of the
following Parts of
Requirement R3:
Moderate VSL
High VSL
The Transmission Owner
failed to include in its
Facility Rating methodology
two of the following Parts
of Requirement R3:
The Transmission Owner’s
Facility Rating methodology
did not address either of
the following Parts of
Requirement R3:
3.1
3.4.1
3.4.2
3.1
3.2.1
3.2.1
3.2.2
OR
3.2.2
3.2.3
3.2.3
3.2.4
3.2.4
The Transmission Owner
failed to include in its
Facility Rating methodology
three of the following Parts
of Requirement R3:
Severe VSL
The Transmission Owner’s
Facility Rating methodology
failed to recognize a Facility's
rating based on the most
limiting component rating as
required in Requirement R3,
Part 3.3
OR
The Transmission Owner failed
to include in its Facility Rating
methodology four or more of
the following Parts of
Requirement R3:
3.1
3.1
3.2.1
3.2.1
3.2.2
3.2.2
3.2.3
3.2.3
3.2.4
3.2.4
R4.
Reserved.
R5.
Reserved.
Page 8 of 13
FAC‐008‐5 – Facility Ratings
Violation Severity Levels
R#
Lower VSL
Moderate VSL
High VSL
Severe VSL
The responsible entity
failed to establish Facility
Ratings consistent with
the associated Facility
Ratings methodology or
documentation for
determining the Facility
Ratings for 5% or less of
its solely owned and
jointly owned Facilities.
(R6)
The responsible entity
failed to establish Facility
Ratings consistent with the
associated Facility Ratings
methodology or
documentation for
determining the Facility
Ratings for more than 5% or
more, but less than up to
(and including) 10% of its
solely owned and jointly
owned Facilities. (R6)
The responsible entity
failed to establish Facility
Ratings consistent with the
associated Facility Ratings
methodology or
documentation for
determining the Facility
Ratings for more than 10%
up to (and including) 15% of
its solely owned and jointly
owned Facilities. (R6)
The responsible entity failed to
establish Facility Ratings
consistent with the associated
Facility Ratings methodology or
documentation for determining
the Facility Ratings for more
than15% of its solely owned
and jointly owned Facilities.
(R6)
R7.
Reserved.
R8.
The responsible entity
provided its Facility
Ratings to all of the
requesting entities but
missed meeting the
schedules by up to and
including 15 calendar
days. (R8, Part 8.1)
The responsible entity
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
15 calendar days but less
than or equal to 25
calendar days. (R8, Part 8.1)
The responsible entity
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
25 calendar days but less
than or equal to 35
calendar days. (R8, Part 8.1)
The responsible entity provided
its Facility Ratings to all of the
requesting entities but missed
meeting the schedules by more
than 35 calendar days. (R8, Part
8.1)
OR
OR
OR
The responsible entity
provided less than 100%,
The responsible entity
The responsible entity
provided less than 95%, but provided less than 90%, but
R6.
OR
The responsible entity provided
less than 85% of the required
Rating information to all of the
Page 9 of 13
FAC‐008‐5 – Facility Ratings
Violation Severity Levels
R#
Lower VSL
Moderate VSL
High VSL
Severe VSL
but not less than or equal
to 95% of the required
Rating information to all
of the requesting entities.
(R8, Part 8.1)
not less than or equal to
90% of the required Rating
information to all of the
requesting entities. (R8,
Part 8.1)
not less than or equal to
85% of the required Rating
information to all of the
requesting entities. (R8,
Part 8.1)
OR
OR
OR
The responsible entity
provided the required
Rating information to the
requesting entity, but the
information was provided
up to and including 15
calendar days late. (R8,
Part 8.2)
The responsible entity
provided the required
Rating information to the
requesting entity, but did so
more 15 calendar days but
less than or equal to 25
calendar days late. (R8, Part
8.2)
The responsible entity
provided the required
Rating information to the
requesting entity, but did so
more than 25 calendar days
but less than or equal to 35
calendar days late. (R8, Part
8.2)
The responsible entity provided
less than 85 % of the required
Rating information to the
requesting entity. (R8, Part 8.2)
OR
OR
OR
OR
The responsible entity
provided less than 100%,
but not less than or equal
to 95% of the required
Rating information to the
requesting entity. (R8,
Part 8.2)
The responsible entity
provided less than 95%, but
not less than or equal to
90% of the required Rating
information to the
requesting entity. (R8, Part
8.2)
The responsible entity
provided less than 90%, but
no less than or equal to
85% of the required Rating
information to the
requesting entity. (R8, Part
8.2)
The responsible entity failed to
provide its Rating information
to the requesting entity. (R8,
Part 8.1)
requesting entities. (R8, Part
8.1)
OR
The responsible entity provided
the required Rating information
to the requesting entity, but did
so more than 35 calendar days
late. (R8, Part 8.2)
OR
D. Regional Variances
None.
Page 10 of 13
FAC‐008‐5 – Facility Ratings
E. Associated Documents
None.
Page 11 of 13
FAC‐008‐5 – Facility Ratings
Version History
Version
Date
Action
1
Feb 7, 2006
Approved by Board of Trustees
New
1
Mar 16, 2007
Approved by FERC
New
2
May 12, 2010 Approved by Board of Trustees
Complete Revision,
merging FAC_008‐1
and FAC‐009‐1 under
Project 2009‐06 and
address directives
from Order 693
3
May 24, 2011 Addition of Requirement R8
Project 2009‐06
Expansion to address
third directive from
Order 693
3
May 24, 2011 Adopted by NERC Board of Trustees
3
November 17, FERC Order issued approving FAC‐008‐3
2011
3
May 17, 2012 FERC Order issued directing the VRF for
Requirement R2 be changed from
“Lower” to “Medium”
3
February 7,
2013
3
November 21, R4 and R5 and associated elements
2013
approved by FERC for retirement as
part of the Paragraph 81 project
(Project 2013‐02)
4
May 9, 2020
R7 and R8 and associated elements
adopted by NERC Board of Trustees for
retirement as part of Project 2018-03
Standards Efficiency Review
Retirements.
4
September
17, 2020
Remanded by FERC (Order No. 873).
Withdrawn
5
TBDFebruary
4, 2021
Adopted by NERC Board of Trustees
Requirement R8 and
associated elements
restored in response
R4 and R5 and associated elements
approved by NERC Board of Trustees for
retirement as part of the Paragraph 81
project (Project 2013‐02) pending
applicable regulatory approval.
Change Tracking
Page 12 of 13
FAC‐008‐5 – Facility Ratings
Version
Date
Action
Change Tracking
to FERC Order No.
873.
Page 13 of 13
FAC-008-4 5 – Facility Ratings
A. Introduction
1.
Title:
Facility Ratings
2.
Number:
FAC-008-45
3.
Purpose:
To ensure that Facility Ratings used in the reliable planning and
operation of the Bulk Electric System (BES) are determined based
on technically sound principles. A Facility Rating is essential for the
determination of System Operating Limits.
4.
Applicability:
4.1. Transmission Owner
4.2. Generator Owner
5.
Effective Date:
See Implementation Plan.
Page 1 of 13
FAC-008-4 5 – Facility Ratings
B. Requirements and Measures
R1. Each Generator Owner shall have documentation for determining the Facility Ratings
of its solely and jointly owned generator Facility(ies) up to the low side terminals of
the main step up transformer if the Generator Owner does not own the main step up
transformer and the high side terminals of the main step up transformer if the
Generator Owner owns the main step up transformer. [Violation Risk Factor: Lower]
[Time Horizon: Long-term Planning]
1.1. The documentation shall contain assumptions used to rate the generator and at
least one of the following:
•
Design or construction information such as design criteria, ratings provided
by equipment manufacturers, equipment drawings and/or specifications,
engineering analyses, method(s) consistent with industry standards (e.g.
ANSI and IEEE), or an established engineering practice that has been verified
by testing or engineering analysis.
•
Operational information such as commissioning test results, performance
testing or historical performance records, any of which may be
supplemented by engineering analyses.
1.2. The documentation shall be consistent with the principle that the Facility Ratings
do not exceed the most limiting applicable Equipment Rating of the individual
equipment that comprises that Facility.
M1. Each Generator Owner shall have documentation that shows how its Facility Ratings
were determined as identified in Requirement 1.
R2. Each Generator Owner shall have a documented methodology for determining Facility
Ratings (Facility Ratings methodology) of its solely and jointly owned equipment
connected between the location specified in R1 and the point of interconnection with
the Transmission Owner that contains all of the following. [Violation Risk Factor:
Medium] [Time Horizon: Long-term Planning]
2.1. The methodology used to establish the Ratings of the equipment that comprises
the Facility(ies) shall be consistent with at least one of the following:
•
Ratings provided by equipment manufacturers or obtained from equipment
manufacturer specifications such as nameplate rating.
•
One or more industry standards developed through an open process such as
Institute of Electrical and Electronic Engineers (IEEE) or International Council
on Large Electric Systems (CIGRE).
•
A practice that has been verified by testing, performance history or
engineering analysis.
Page 2 of 13
FAC-008-4 5 – Facility Ratings
2.2. The underlying assumptions, design criteria, and methods used to determine the
Equipment Ratings identified in Requirement R2, Part 2.1 including identification
of how each of the following were considered:
2.2.1. Equipment Rating standard(s) used in development of this methodology.
2.2.2. Ratings provided by equipment manufacturers or obtained from
equipment manufacturer specifications.
2.2.3. Ambient conditions (for particular or average conditions or as they vary
in real-time).
2.2.4. Operating limitations.1
2.3. A statement that a Facility Rating shall respect the most limiting applicable
Equipment Rating of the individual equipment that comprises that Facility.
2.4. The process by which the Rating of equipment that comprises a Facility is
determined.
2.4.1. The scope of equipment addressed shall include, but not be limited to,
conductors, transformers, relay protective devices, terminal equipment,
and series and shunt compensation devices.
2.4.2. The scope of Ratings addressed shall include, as a minimum, both Normal
and Emergency Ratings.
M2. Each Generator Owner shall have a documented Facility Ratings methodology that
includes all of the items identified in Requirement 2, Parts 2.1 through 2.4.
R3. Each Transmission Owner shall have a documented methodology for determining
Facility Ratings (Facility Ratings methodology) of its solely and jointly owned Facilities
(except for those generating unit Facilities addressed in R1 and R2) that contains all of
the following: [Violation Risk Factor: Medium] [ Time Horizon: Long-term Planning]
3.1. The methodology used to establish the Ratings of the equipment that comprises
the Facility shall be consistent with at least one of the following:
1
•
Ratings provided by equipment manufacturers or obtained from equipment
manufacturer specifications such as nameplate rating.
•
One or more industry standards developed through an open process such as
Institute of Electrical and Electronics Engineers (IEEE) or International Council
on Large Electric Systems (CIGRE).
•
A practice that has been verified by testing, performance history or
engineering analysis.
Such as temporary de-ratings of impaired equipment in accordance with good utility practice.
Page 3 of 13
FAC-008-4 5 – Facility Ratings
3.2. The underlying assumptions, design criteria, and methods used to determine the
Equipment Ratings identified in Requirement R3, Part 3.1 including identification
of how each of the following were considered:
3.2.1. Equipment Rating standard(s) used in development of this methodology.
3.2.2. Ratings provided by equipment manufacturers or obtained from
equipment manufacturer specifications.
3.2.3. Ambient conditions (for particular or average conditions or as they vary
in real-time).
3.2.4. Operating limitations.2
3.3. A statement that a Facility Rating shall respect the most limiting applicable
Equipment Rating of the individual equipment that comprises that Facility.
3.4. The process by which the Rating of equipment that comprises a Facility is
determined.
3.4.1. The scope of equipment addressed shall include, but not be limited to,
transmission conductors, transformers, relay protective devices, terminal
equipment, and series and shunt compensation devices.
3.4.2. The scope of Ratings addressed shall include, as a minimum, both Normal
and Emergency Ratings.
M3. Each Transmission Owner shall have a documented Facility Ratings methodology that
includes all of the items identified in Requirement 3, Parts 3.1 through 3.4.
R4. Reserved.
M4. Reserved.
R5. Reserved.
M5. Reserved.
R6. Each Transmission Owner and Generator Owner shall have Facility Ratings for its
solely and jointly owned Facilities that are consistent with the associated Facility
Ratings methodology or documentation for determining its Facility Ratings. [Violation
Risk Factor: Medium] [Time Horizon: Operations Planning]
M6. Each Transmission Owner and Generator Owner shall have evidence to show that its
Facility Ratings are consistent with the documentation for determining its Facility
Ratings as specified in Requirement R1 or consistent with its Facility Ratings
methodology as specified in Requirements R2 and R3 (Requirement R6).
R7. Reserved.
M7. Reserved.
2
Such as temporary de-ratings of impaired equipment in accordance with good utility practice.
Page 4 of 13
FAC-008-4 5 – Facility Ratings
R8.
Reserved. Each Transmission Owner (and each Generator Owner subject to
Requirement R2) shall provide requested information as specified below (for its solely
and jointly owned Facilities that are existing Facilities, new Facilities, modifications to
existing Facilities and re-ratings of existing Facilities) to its associated Reliability
Coordinator(s), Planning Coordinator(s), Transmission Planner(s), Transmission
Owner(s) and Transmission Operator(s): [Violation Risk Factor: Medium] [Time
Horizon: Operations Planning]
8.1.
As scheduled by the requesting entities:
8.2.
8.1.1.
Facility Ratings
8.1.2.
Identity of the most limiting equipment of the Facilities
Within 30 calendar days (or a later date if specified by the requester), for any
requested Facility with a Thermal Rating that limits the use of Facilities under
the requester’s authority by causing any of the following: 1) An
Interconnection Reliability Operating Limit, 2) A limitation of Total Transfer
Capability, 3) An impediment to generator deliverability, or 4) An impediment
to service to a major load center:
8.2.1.
Identity of the existing next most limiting equipment of the Facility
8.2.2.
The Thermal Rating for the next most limiting equipment identified
in Requirement R8, Part 8.2.1.
M8. Reserved. Each Transmission Owner (and Generator Owner subject to Requirement
R2) shall have evidence, such as a copy of a dated electronic note, or other
comparable evidence to show that it provided its Facility Ratings and identity of
limiting equipment to its associated Reliability Coordinator(s), Planning Coordinator(s),
Transmission Planner(s), Transmission Owner(s) and Transmission Operator(s) in
accordance with Requirement R8.
C. Compliance
1.
Compliance Monitoring Process
1.1. Compliance Enforcement Authority: “Compliance Enforcement Authority”
means NERC or the Regional Entity, or any entity as otherwise designated by an
Applicable Governmental Authority, in their respective roles of monitoring
and/or enforcing compliance with mandatory and enforceable Reliability
Standards in their respective jurisdictions.
1.2. Compliance Monitoring and Enforcement Processes:
•
Self-Certifications
•
Spot Checking
•
Compliance Audits
Page 5 of 13
FAC-008-4 5 – Facility Ratings
•
Self-Reporting
•
Compliance Violation Investigations
•
Complaints
1.3. Evidence Retention: The following evidence retention period(s) identify the
period of time an entity is required to retain specific evidence to demonstrate
compliance. For instances where the evidence retention period specified below
is shorter than the time since the last audit, the Compliance Enforcement
Authority may ask an entity to provide other evidence to show that it was
compliant for the full-time period since the last audit.
The applicable entity shall keep data or evidence to show compliance as
identified below unless directed by its Compliance Enforcement Authority to
retain specific evidence for a longer period of time as part of an investigation.
•
The Generator Owner shall keep its current documentation (for R1) and any
modifications to the documentation that were in force since last compliance
audit period for Measure M1 and Measure M6.
•
The Generator Owner shall keep its current, in force Facility Ratings
methodology (for R2) and any modifications to the methodology that were in
force since last compliance audit period for Measure M2 and Measure M6.
•
The Transmission Owner shall keep its current, in force Facility Ratings
methodology (for R3) and any modifications to the methodology that were in
force since the last compliance audit for Measure M3 and Measure M6.
•
The Transmission Owner and Generator Owner shall keep its current, in force
Facility Ratings and any changes to those ratings for three calendar years for
Measure M6.
•
The Transmission Owner (and Generator Owner that is subject to
Requirement R2) shall keep evidence for Measure M8 for three calendar
years.
•
If a Generator Owner or Transmission Owner is found non-compliant, it shall
keep information related to the non-compliance until found compliant.
•
The Compliance Enforcement Authority shall keep the last audit and all
subsequent compliance records.
1.4. Compliance Monitoring and Enforcement Program: As defined in the NERC
Rules of Procedure, “Compliance Monitoring and Enforcement Program” refers
to the identification of the processes that will be used to evaluate data or
information for the purpose of assessing performance or outcomes with the
associated Reliability Standard.
Page 6 of 13
FAC-008-4 5 – Facility Ratings
Violation Severity Levels
Violation Severity Levels
R#
Lower VSL
Moderate VSL
High VSL
Severe VSL
R1.
N/A
The Generator Owner’s
Facility Rating
documentation did not
address Requirement R1,
Part 1.1.
The Generator Owner’s
Facility Rating
documentation did not
address Requirement R1,
Part 1.2.
The Generator Owner failed to
provide documentation for
determining its Facility Ratings.
R2.
The Generator Owner
failed to include in its
Facility Rating
methodology one of the
following Parts of
Requirement R2:
The Generator Owner failed
to include in its Facility
Rating methodology two of
the following Parts of
Requirement R2:
The Generator Owner’s
Facility Rating methodology
did not address all the
components of
Requirement R2, Part 2.4.
The Generator Owner’s Facility
Rating methodology failed to
recognize a facility's rating
based on the most limiting
component rating as required
in Requirement R2, Part 2.3
•
2.1.
•
2.2.1
•
2.2.2
•
2.2.3
•
2.2.4
•
2.1
OR
•
2.2.1
•
2.2.2
•
2.2.3
•
2.2.4
The Generator Owner failed
to include in its Facility
Rating Methodology, three
of the following Parts of
Requirement R2:
•
2.1.
•
2.2.1
•
2.2.2
•
2.2.3
•
2.2.4
OR
The Generator Owner failed to
include in its Facility Rating
Methodology four or more of
the following Parts of
Requirement R2:
•
2.1
•
2.2.1
•
2.2.2
•
2.2.3
•
2.2.4
Page 7 of 13
FAC-008-4 5 – Facility Ratings
Violation Severity Levels
R#
R3.
Lower VSL
The Transmission Owner
failed to include in its
Facility Rating
methodology one of the
following Parts of
Requirement R3:
•
3.1
•
3.2.1
•
3.2.2
•
3.2.3
•
3.2.4
Moderate VSL
High VSL
The Transmission Owner
failed to include in its
Facility Rating methodology
two of the following Parts
of Requirement R3:
The Transmission Owner’s
Facility Rating methodology
did not address either of
the following Parts of
Requirement R3:
•
3.1
•
3.4.1
•
3.2.1
•
3.4.2
•
3.2.2
OR
•
3.2.3
•
3.2.4
The Transmission Owner
failed to include in its
Facility Rating methodology
three of the following Parts
of Requirement R3:
•
3.1
•
3.2.1
•
3.2.2
•
3.2.3
•
3.2.4
Severe VSL
The Transmission Owner’s
Facility Rating methodology
failed to recognize a Facility's
rating based on the most
limiting component rating as
required in Requirement R3,
Part 3.3
OR
The Transmission Owner failed
to include in its Facility Rating
methodology four or more of
the following Parts of
Requirement R3:
•
3.1
•
3.2.1
•
3.2.2
•
3.2.3
•
3.2.4
R4.
Reserved.
R5.
Reserved.
Page 8 of 13
FAC-008-4 5 – Facility Ratings
Violation Severity Levels
R#
R6.
Lower VSL
Moderate VSL
High VSL
Severe VSL
The responsible entity
failed to establish Facility
Ratings consistent with
the associated Facility
Ratings methodology or
documentation for
determining the Facility
Ratings for 5% or less of
its solely owned and
jointly owned Facilities.
(R6)
The responsible entity
failed to establish Facility
Ratings consistent with the
associated Facility Ratings
methodology or
documentation for
determining the Facility
Ratings for more than 5% or
more, but less than up to
(and including) 10% of its
solely owned and jointly
owned Facilities. (R6)
The responsible entity
failed to establish Facility
Ratings consistent with the
associated Facility Ratings
methodology or
documentation for
determining the Facility
Ratings for more than 10%
up to (and including) 15% of
its solely owned and jointly
owned Facilities. (R6)
The responsible entity failed to
establish Facility Ratings
consistent with the associated
Facility Ratings methodology or
documentation for determining
the Facility Ratings for more
than15% of its solely owned
and jointly owned Facilities.
(R6)
The responsible entity
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
15 calendar days but less
than or equal to 25
calendar days. (R8, Part 8.1)
The responsible entity
provided its Facility Ratings
to all of the requesting
entities but missed meeting
the schedules by more than
25 calendar days but less
than or equal to 35
calendar days. (R8, Part 8.1)
The responsible entity provided
its Facility Ratings to all of the
requesting entities but missed
meeting the schedules by more
than 35 calendar days. (R8, Part
8.1)
OR
OR
OR
The responsible entity
provided less than 100%,
The responsible entity
provided less than 95%, but
The responsible entity
provided less than 90%, but
R7.
Reserved.
R8.
The responsible entity
Reserved. provided its Facility
Ratings to all of the
requesting entities but
missed meeting the
schedules by up to and
including 15 calendar
days. (R8, Part 8.1)
OR
The responsible entity provided
less than 85% of the required
Rating information to all of the
Page 9 of 13
FAC-008-4 5 – Facility Ratings
Violation Severity Levels
R#
Lower VSL
Moderate VSL
High VSL
Severe VSL
but not less than or equal
to 95% of the required
Rating information to all
of the requesting entities.
(R8, Part 8.1)
not less than or equal to
90% of the required Rating
information to all of the
requesting entities. (R8,
Part 8.1)
not less than or equal to
85% of the required Rating
information to all of the
requesting entities. (R8,
Part 8.1)
OR
OR
OR
The responsible entity
provided the required
Rating information to the
requesting entity, but the
information was provided
up to and including 15
calendar days late. (R8,
Part 8.2)
The responsible entity
provided the required
Rating information to the
requesting entity, but did so
more 15 calendar days but
less than or equal to 25
calendar days late. (R8, Part
8.2)
The responsible entity
provided the required
Rating information to the
requesting entity, but did so
more than 25 calendar days
but less than or equal to 35
calendar days late. (R8, Part
8.2)
OR
OR
OR
OR
The responsible entity
provided less than 100%,
but not less than or equal
to 95% of the required
Rating information to the
requesting entity. (R8,
Part 8.2)
The responsible entity
provided less than 95%, but
not less than or equal to
90% of the required Rating
information to the
requesting entity. (R8, Part
8.2)
The responsible entity
provided less than 90%, but
no less than or equal to
85% of the required Rating
information to the
requesting entity. (R8, Part
8.2)
The responsible entity failed to
provide its Rating information
to the requesting entity. (R8,
Part 8.1)
requesting entities. (R8, Part
8.1)
OR
The responsible entity provided
the required Rating information
to the requesting entity, but did
so more than 35 calendar days
late. (R8, Part 8.2)
OR
The responsible entity provided
less than 85 % of the required
Rating information to the
requesting entity. (R8, Part 8.2)
D. Regional Variances
None.
Page 10 of 13
FAC-008-4 5 – Facility Ratings
E. Associated Documents
None.
Page 11 of 13
FAC-008-4 5– Facility Ratings
Version History
Version
Date
Action
Change Tracking
1
Feb 7, 2006
Approved by Board of Trustees
New
1
Mar 16, 2007
Approved by FERC
New
2
May 12, 2010
Approved by Board of Trustees
Complete Revision,
merging FAC_008-1
and FAC-009-1 under
Project 2009-06 and
address directives
from Order 693
3
May 24, 2011
Addition of Requirement R8
Project 2009-06
Expansion to address
third directive from
Order 693
3
May 24, 2011
Adopted by NERC Board of Trustees
3
November 17, FERC Order issued approving FAC-008-3
2011
3
May 17, 2012
FERC Order issued directing the VRF for
Requirement R2 be changed from
“Lower” to “Medium”
3
February 7,
2013
R4 and R5 and associated elements
approved by NERC Board of Trustees for
retirement as part of the Paragraph 81
project (Project 2013-02) pending
applicable regulatory approval.
3
November 21, R4 and R5 and associated elements
2013
approved by FERC for retirement as
part of the Paragraph 81 project
(Project 2013-02)
4
TBDMay 9,
2020
R7 and R8 and associated elements
adopted by NERC Board of Trustees for
retirement as part of Project 2018-03
Standards Efficiency Review
Retirements.Adopted by NERC Board of
Trustees
R7 and R8 and
associated elements
approved by NERC
Board of Trustees for
retirement as part of
Project 2018-03
Standard Efficiency
Review Retirements
4
September
17, 2020
Remanded by FERC (Order No. 873).
Withdrawn
Page 12 of 13
FAC-008-4 5– Facility Ratings
Version
5
Date
February 4,
2021
Action
Adopted by NERC Board of Trustees
Change Tracking
Requirement R8 and
associated elements
restored in response
to FERC Order No.
873.
Page 13 of 13
Implementation Plan
Project 2018-03 Standards Efficiency Review Retirements
Reliability Standard FAC-008-5
Applicable Standard(s)
•
FAC-008-5 – Facility Ratings
Requested Retirement(s)
•
FAC-008-3 – Facility Ratings
Applicable Entities
•
Transmission Owner
•
Generator Owner
Background
In 2017, NERC initiated the Standards Efficiency Review (SER). The scope of this project was to use a
risk-based approach to identify potential efficiencies through retirement of Reliability Standard
requirements. Following the completion of the first phase of work, the SER Standard Drafting Team
(SDT) submitted a Standards Authorization Request (SAR) to the NERC Standards Committee, which
the Standards Committee accepted in August 2018.
Project 2018-03 Standards Efficiency Review Retirements was initiated to consider and implement
the recommendations for Reliability Standard retirements contained in the SAR.
Among other things, the SER SDT proposed retiring Requirements R7 and R8 in Reliability Standard
FAC-008-3 as redundant and not needed for reliability. Proposed Reliability Standard FAC-008-4
passed final ballot on May 2, 2019; was adopted by the Board of Trustees on May 9, 2019; and was
filed with the Federal Energy Regulatory Commission (FERC) on June 7, 2019 for approval.
On September 17, 2020, the Federal Regulatory Commission (FERC) issued Order No. 873. 1 With
respect to proposed Reliability Standard FAC-008-4, FERC determined that the retirement of
Requirement R7 would be appropriate, but rejected the retirement of Requirement R8, concluding
that “… Requirement R8 is needed to ensure that limiting and next limiting equipment is identified
and communicated” (P 40). FERC remanded proposed Reliability Standard FAC-008-4 to NERC for
further consideration.
1 Order No. 873, Electric Reliability Organization Proposal to Retire Requirements in Reliability Standards Under the NERC Standards
Efficiency Review, 172 FERC ¶ 61,225 (2020),
https://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Order%20on%20SER%20Retirements.pdf.
RELIABILITY | RESILIENCE | SECURITY
Following the FERC remand, NERC submitted a notice to the remaining applicable governmental
authorities requesting that FAC-008-4 be withdrawn in their respective jurisdictions.
Proposed Reliability Standard FAC-008-5 would retire Requirement R7 of currently effective
Reliability Standard FAC-008-3.
General Considerations
For Reliability Standard FAC-008-5– Facility Ratings, the standard will become effective on the first day
of the first calendar quarter that is three (3) months after applicable regulatory approval. This
implementation timeframe reflects consideration that entities may need time to update their internal
systems and documentation to reflect the new standard version numbers.
Effective Date
Reliability Standard FAC-008-5– Facility Ratings
Where approval by an applicable governmental authority is required, the standard shall become
effective on the first day of the first calendar quarter that is three (3) months after the effective date of
the applicable governmental authority’s order approving the standard, or as otherwise provided for by
the applicable governmental authority.
Where approval by an applicable governmental authority is not required, the standard shall become
effective on the first day of the first calendar quarter that is three (3) months after the date the
standard is adopted by the NERC Board of Trustees, or as otherwise provided for in that jurisdiction.
Retirement Date
Reliability Standard FAC-008-3 – Facility Ratings
Reliability Standard FAC-008-3 shall be retired immediately prior to the effective date of the revised
standard in the particular jurisdiction in which the revised standard is becoming effective.
Implementation Plan
Project 2018-03 Standards Efficiency Review Retirements | January 2021
2
Implementation Plan
Project 2018-03 Standards Efficiency Review Retirements
Reliability Standard FAC-008-5
Applicable Standard(s)
FAC‐008‐5 – Facility Ratings
Requested Retirement(s)
FAC‐008‐3 – Facility Ratings
Applicable Entities
Transmission Owner
Generator Owner
Background
In 2017, NERC initiated the Standards Efficiency Review (SER). The scope of this project was to use a
risk‐based approach to identify potential efficiencies through retirement of Reliability Standard
requirements. Following the completion of the first phase of work, the SER Standard Drafting Team
(SDT) submitted a Standards Authorization Request (SAR) to the NERC Standards Committee, which
the Standards Committee accepted in August 2018.
Project 2018‐03 Standards Efficiency Review Retirements was initiated to consider and implement
the recommendations for Reliability Standard retirements contained in the SAR.
Among other things, the SER SDT proposed retiring Requirements R7 and R8 in Reliability Standard
FAC‐008‐3 as redundant and not needed for reliability. Proposed Reliability Standard FAC‐008‐4
passed final ballot on May 2, 2019; was adopted by the Board of Trustees on May 9, 2019; and was
filed with the Federal Energy Regulatory Commission (FERC) on June 7, 2019 for approval.
On September 17, 2020, the Federal Regulatory Commission (FERC) issued Order No. 873.1 With
respect to proposed Reliability Standard FAC‐008‐4, FERC determined that the retirement of
Requirement R7 would be appropriate, but rejected the retirement of Requirement R8, concluding
that “… Requirement R8 is needed to ensure that limiting and next limiting equipment is identified
and communicated” (P 40). FERC remanded proposed Reliability Standard FAC‐008‐4 to NERC for
further consideration.
1 Order No. 873, Electric Reliability Organization Proposal to Retire Requirements in Reliability Standards Under the NERC Standards
Efficiency Review, 172 FERC ¶ 61,225 (2020),
https://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Order%20on%20SER%20Retirements.pdf.
RELIABILITY | RESILIENCE | SECURITY
Following the FERC remand, NERC submitted a notice to the remaining applicable governmental
authorities requesting that FAC‐008‐4 be withdrawn in their respective jurisdictions.
Proposed Reliability Standard FAC‐008‐5 would retire Requirement R7 of currently effective
Reliability Standard FAC‐008‐3.
General Considerations
For Reliability Standard FAC‐008‐5– Facility Ratings, the standard will become effective on the first day
of the first calendar quarter that is three (3) months after applicable regulatory approval. This
implementation timeframe reflects consideration that entities may need time to update their internal
systems and documentation to reflect the new standard version numbers.
Effective Date
Reliability Standard FAC‐008‐5– Facility Ratings
Where approval by an applicable governmental authority is required, the standard shall become
effective on the first day of the first calendar quarter that is three (3) months after the effective date of
the applicable governmental authority’s order approving the standard, or as otherwise provided for by
the applicable governmental authority.
Where approval by an applicable governmental authority is not required, the standard shall become
effective on the first day of the first calendar quarter that is three (3) months after the date the
standard is adopted by the NERC Board of Trustees, or as otherwise provided for in that jurisdiction.
Retirement Date
Reliability Standard FAC‐008‐3 – Facility Ratings
Reliability Standard FAC‐008‐3 shall be retired immediately prior to the effective date of the revised
standard in the particular jurisdiction in which the revised standard is becoming effective.
Implementation Plan
Project 2018‐03 Standards Efficiency Review Retirements | November 2020January 2021
2
Violation Risk Factor and Violation Severity Level
Justifications
Project 2018-03 Standards Efficiency Review Retirements
This document provides the standard drafting team’s (SDT’s) justification for assignment of violation risk factors (VRFs) and violation severity
levels (VSLs) for each requirement in proposed Reliability Standard FAC-008-5. Each requirement is assigned a VRF and a VSL. These elements
support the determination of an initial value range for the Base Penalty Amount regarding violations of requirements in FERC-approved
Reliability Standards, as defined in the Electric Reliability Organizations (ERO) Sanction Guidelines. The SDT applied the following NERC criteria
and FERC Guidelines when developing the VRFs and VSLs for the requirements.
NERC Criteria for Violation Risk Factors
High Risk Requirement
A requirement that, if violated, could directly cause or contribute to Bulk Electric System instability, separation, or a cascading sequence of
failures, or could place the Bulk Electric System at an unacceptable risk of instability, separation, or cascading failures; or, a requirement in a
planning time frame that, if violated, could, under emergency, abnormal, or restorative conditions anticipated by the preparations, directly
cause or contribute to Bulk Electric System instability, separation, or a cascading sequence of failures, or could place the Bulk Electric System
at an unacceptable risk of instability, separation, or cascading failures, or could hinder restoration to a normal condition.
Medium Risk Requirement
A requirement that, if violated, could directly affect the electrical state or the capability of the Bulk Electric System, or the ability to effectively
monitor and control the Bulk Electric System. However, violation of a medium risk requirement is unlikely to lead to Bulk Electric System
instability, separation, or cascading failures; or, a requirement in a planning time frame that, if violated, could, under emergency, abnormal,
or restorative conditions anticipated by the preparations, directly and adversely affect the electrical state or capability of the Bulk Electric
System, or the ability to effectively monitor, control, or restore the Bulk Electric System. However, violation of a medium risk requirement is
unlikely, under emergency, abnormal, or restoration conditions anticipated by the preparations, to lead to Bulk Electric System instability,
separation, or cascading failures, nor to hinder restoration to a normal condition.
RELIABILITY | RESILIENCE | SECURITY
Lower Risk Requirement
A requirement that is administrative in nature and a requirement that, if violated, would not be expected to adversely affect the electrical
state or capability of the Bulk Electric System, or the ability to effectively monitor and control the Bulk Electric System; or, a requirement that
is administrative in nature and a requirement in a planning time frame that, if violated, would not, under the emergency, abnormal, or
restorative conditions anticipated by the preparations, be expected to adversely affect the electrical state or capability of the Bulk Electric
System, or the ability to effectively monitor, control, or restore the Bulk Electric System.
FERC Guidelines for Violation Risk Factors
Guideline (1) – Consistency with the Conclusions of the Final Blackout Report
FERC seeks to ensure that VRFs assigned to Requirements of Reliability Standards in these identified areas appropriately reflect their historical
critical impact on the reliability of the Bulk-Power System. In the VSL Order, FERC listed critical areas (from the Final Blackout Report) where
violations could severely affect the reliability of the Bulk-Power System:
•
Emergency operations
•
Vegetation management
•
Operator personnel training
•
Protection systems and their coordination
•
Operating tools and backup facilities
•
Reactive power and voltage control
•
System modeling and data exchange
•
Communication protocol and facilities
•
Requirements to determine equipment ratings
•
Synchronized data recorders
•
Clearer criteria for operationally critical facilities
•
Appropriate use of transmission loading relief.
VRF and VSL Justifications
Project 2018-03 Standards Efficiency Review Retirements | January 2021
2
Guideline (2) – Consistency within a Reliability Standard
FERC expects a rational connection between the sub-Requirement VRF assignments and the main Requirement VRF assignment.
Guideline (3) – Consistency among Reliability Standards
FERC expects the assignment of VRFs corresponding to Requirements that address similar reliability goals in different Reliability Standards
would be treated comparably.
Guideline (4) – Consistency with NERC’s Definition of the Violation Risk Factor Level
Guideline (4) was developed to evaluate whether the assignment of a particular VRF level conforms to NERC’s definition of that risk level.
Guideline (5) – Treatment of Requirements that Co-mingle More Than One Obligation
Where a single Requirement co-mingles a higher risk reliability objective and a lesser risk reliability objective, the VRF assignment for such
Requirements must not be watered down to reflect the lower risk level associated with the less important objective of the Reliability
Standard.
VRF and VSL Justifications
Project 2018-03 Standards Efficiency Review Retirements | January 2021
3
NERC Criteria for Violation Severity Levels
VSLs define the degree to which compliance with a requirement was not achieved. Each requirement must have at least one VSL. While it is
preferable to have four VSLs for each requirement, some requirements do not have multiple “degrees” of noncompliant performance and
may have only one, two, or three VSLs.
VSLs should be based on NERC’s overarching criteria shown in the table below:
Lower VSL
Moderate VSL
The performance or product
measured almost meets the full
intent of the requirement.
The performance or product
measured meets the majority of
the intent of the requirement.
High VSL
The performance or product
measured does not meet the
majority of the intent of the
requirement, but does meet
some of the intent.
Severe VSL
The performance or product
measured does not
substantively meet the intent of
the requirement.
FERC Order of Violation Severity Levels
The FERC VSL guidelines are presented below, followed by an analysis of whether the VSLs proposed for each requirement in the standard
meet the FERC Guidelines for assessing VSLs:
Guideline (1) – Violation Severity Level Assignments Should Not Have the Unintended Consequence of Lowering the Current
Level of Compliance
Compare the VSLs to any prior levels of non-compliance and avoid significant changes that may encourage a lower level of compliance than
was required when levels of non-compliance were used.
Guideline (2) – Violation Severity Level Assignments Should Ensure Uniformity and Consistency in the Determination of
Penalties
A violation of a “binary” type requirement must be a “Severe” VSL.
Do not use ambiguous terms such as “minor” and “significant” to describe noncompliant performance.
Guideline (3) – Violation Severity Level Assignment Should Be Consistent with the Corresponding Requirement
VSLs should not expand on what is required in the requirement.
VRF and VSL Justifications
Project 2018-03 Standards Efficiency Review Retirements | January 2021
4
Guideline (4) – Violation Severity Level Assignment Should Be Based on a Single Violation, Not on a Cumulative Number of
Violations
Unless otherwise stated in the requirement, each instance of non-compliance with a requirement is a separate violation. Section 4 of the
Sanction Guidelines states that assessing penalties on a per violation per day basis is the “default” for penalty calculations.
VRF Justification for FAC-008-5, Requirement R1
The VRF did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VRF Justification for FAC-008-5, Requirement R2
The VRF did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VRF Justification for FAC-008-5, Requirement R3
The VRF did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VRF Justification for FAC-008-5, Requirement R6
The VRF did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VRF Justification for FAC-008-5, Requirement R8
The VRF did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VSL Justification for FAC-008-5, Requirement R1
The VSL did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VSL Justification for FAC-008-5, Requirement R2
The VSL did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VSL Justification for FAC-008-5, Requirement R3
The VSL did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VSL Justification for FAC-008-5, Requirement R6
The VSL did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VSL Justification for FAC-008-5, Requirement R8
The VSL did not change from the previously FERC approved FAC-008-3 Reliability Standard.
VRF and VSL Justifications
Project 2018-03 Standards Efficiency Review Retirements | January 2021
5
Violation Risk Factor and Violation Severity Level
Justifications
Project 2018-03 Standards Efficiency Review Retirements
This document provides the standard drafting team’s (SDT’s) justification for assignment of violation risk factors (VRFs) and violation severity
levels (VSLs) for each requirement in proposed Reliability Standard FAC‐008‐5. Each requirement is assigned a VRF and a VSL. These elements
support the determination of an initial value range for the Base Penalty Amount regarding violations of requirements in FERC‐approved
Reliability Standards, as defined in the Electric Reliability Organizations (ERO) Sanction Guidelines. The SDT applied the following NERC criteria
and FERC Guidelines when developing the VRFs and VSLs for the requirements.
NERC Criteria for Violation Risk Factors
High Risk Requirement
A requirement that, if violated, could directly cause or contribute to Bulk Electric System instability, separation, or a cascading sequence of
failures, or could place the Bulk Electric System at an unacceptable risk of instability, separation, or cascading failures; or, a requirement in a
planning time frame that, if violated, could, under emergency, abnormal, or restorative conditions anticipated by the preparations, directly
cause or contribute to Bulk Electric System instability, separation, or a cascading sequence of failures, or could place the Bulk Electric System
at an unacceptable risk of instability, separation, or cascading failures, or could hinder restoration to a normal condition.
Medium Risk Requirement
A requirement that, if violated, could directly affect the electrical state or the capability of the Bulk Electric System, or the ability to effectively
monitor and control the Bulk Electric System. However, violation of a medium risk requirement is unlikely to lead to Bulk Electric System
instability, separation, or cascading failures; or, a requirement in a planning time frame that, if violated, could, under emergency, abnormal,
or restorative conditions anticipated by the preparations, directly and adversely affect the electrical state or capability of the Bulk Electric
System, or the ability to effectively monitor, control, or restore the Bulk Electric System. However, violation of a medium risk requirement is
unlikely, under emergency, abnormal, or restoration conditions anticipated by the preparations, to lead to Bulk Electric System instability,
separation, or cascading failures, nor to hinder restoration to a normal condition.
RELIABILITY | RESILIENCE | SECURITY
Lower Risk Requirement
A requirement that is administrative in nature and a requirement that, if violated, would not be expected to adversely affect the electrical
state or capability of the Bulk Electric System, or the ability to effectively monitor and control the Bulk Electric System; or, a requirement that
is administrative in nature and a requirement in a planning time frame that, if violated, would not, under the emergency, abnormal, or
restorative conditions anticipated by the preparations, be expected to adversely affect the electrical state or capability of the Bulk Electric
System, or the ability to effectively monitor, control, or restore the Bulk Electric System.
FERC Guidelines for Violation Risk Factors
Guideline (1) – Consistency with the Conclusions of the Final Blackout Report
FERC seeks to ensure that VRFs assigned to Requirements of Reliability Standards in these identified areas appropriately reflect their historical
critical impact on the reliability of the Bulk‐Power System. In the VSL Order, FERC listed critical areas (from the Final Blackout Report) where
violations could severely affect the reliability of the Bulk‐Power System:
Emergency operations
Vegetation management
Operator personnel training
Protection systems and their coordination
Operating tools and backup facilities
Reactive power and voltage control
System modeling and data exchange
Communication protocol and facilities
Requirements to determine equipment ratings
Synchronized data recorders
Clearer criteria for operationally critical facilities
Appropriate use of transmission loading relief.
VRF and VSL Justifications
Project 2018‐03 Standards Efficiency Review Retirements | November 2020January 2021
2
Guideline (2) – Consistency within a Reliability Standard
FERC expects a rational connection between the sub‐Requirement VRF assignments and the main Requirement VRF assignment.
Guideline (3) – Consistency among Reliability Standards
FERC expects the assignment of VRFs corresponding to Requirements that address similar reliability goals in different Reliability Standards
would be treated comparably.
Guideline (4) – Consistency with NERC’s Definition of the Violation Risk Factor Level
Guideline (4) was developed to evaluate whether the assignment of a particular VRF level conforms to NERC’s definition of that risk level.
Guideline (5) – Treatment of Requirements that Co-mingle More Than One Obligation
Where a single Requirement co‐mingles a higher risk reliability objective and a lesser risk reliability objective, the VRF assignment for such
Requirements must not be watered down to reflect the lower risk level associated with the less important objective of the Reliability
Standard.
VRF and VSL Justifications
Project 2018‐03 Standards Efficiency Review Retirements | November 2020January 2021
3
NERC Criteria for Violation Severity Levels
VSLs define the degree to which compliance with a requirement was not achieved. Each requirement must have at least one VSL. While it is
preferable to have four VSLs for each requirement, some requirements do not have multiple “degrees” of noncompliant performance and
may have only one, two, or three VSLs.
VSLs should be based on NERC’s overarching criteria shown in the table below:
Lower VSL
The performance or product
measured almost meets the full
intent of the requirement.
Moderate VSL
High VSL
The performance or product
The performance or product
measured meets the majority of measured does not meet the
the intent of the requirement. majority of the intent of the
requirement, but does meet
some of the intent.
Severe VSL
The performance or product
measured does not
substantively meet the intent of
the requirement.
FERC Order of Violation Severity Levels
The FERC VSL guidelines are presented below, followed by an analysis of whether the VSLs proposed for each requirement in the standard
meet the FERC Guidelines for assessing VSLs:
Guideline (1) – Violation Severity Level Assignments Should Not Have the Unintended Consequence of Lowering the Current
Level of Compliance
Compare the VSLs to any prior levels of non‐compliance and avoid significant changes that may encourage a lower level of compliance than
was required when levels of non‐compliance were used.
Guideline (2) – Violation Severity Level Assignments Should Ensure Uniformity and Consistency in the Determination of
Penalties
A violation of a “binary” type requirement must be a “Severe” VSL.
Do not use ambiguous terms such as “minor” and “significant” to describe noncompliant performance.
Guideline (3) – Violation Severity Level Assignment Should Be Consistent with the Corresponding Requirement
VSLs should not expand on what is required in the requirement.
VRF and VSL Justifications
Project 2018‐03 Standards Efficiency Review Retirements | November 2020January 2021
4
Guideline (4) – Violation Severity Level Assignment Should Be Based on a Single Violation, Not on a Cumulative Number of
Violations
Unless otherwise stated in the requirement, each instance of non‐compliance with a requirement is a separate violation. Section 4 of the
Sanction Guidelines states that assessing penalties on a per violation per day basis is the “default” for penalty calculations.
VRF Justification for FAC‐008‐5, Requirement R1
The VRF did not change from the previously FERC approved FAC‐008‐3 Reliability Standard.
VRF Justification for FAC‐008‐5, Requirement R2
The VRF did not change from the previously FERC approved FAC‐008‐3 Reliability Standard.
VRF Justification for FAC‐008‐5, Requirement R3
The VRF did not change from the previously FERC approved FAC‐008‐3 Reliability Standard.
VRF Justification for FAC‐008‐5, Requirement R6
The VRF did not change from the previously FERC approved FAC‐008‐3 Reliability Standard.
VRF Justification for FAC‐008‐5, Requirement R8
The VRF did not change from the previously FERC approved FAC‐008‐3 Reliability Standard.
VSL Justification for FAC‐008‐5, Requirement R1
The VSL did not change from the previously FERC approved FAC‐008‐3 Reliability Standard.
VSL Justification for FAC‐008‐5, Requirement R2
The VSL did not change from the previously FERC approved FAC‐008‐3 Reliability Standard.
VSL Justification for FAC‐008‐5, Requirement R3
The VSL did not change from the previously FERC approved FAC‐008‐3 Reliability Standard.
VSL Justification for FAC‐008‐5, Requirement R6
The VSL did not change from the previously FERC approved FAC‐008‐3 Reliability Standard.
VSL Justification for FAC‐008‐5, Requirement R8
The VSL did not change from the previously FERC approved FAC‐008‐3 Reliability Standard.
VRF and VSL Justifications
Project 2018‐03 Standards Efficiency Review Retirements | November 2020January 2021
5
Standards Announcement
Project 2018-03 Standards Efficiency Review Retirements
Final Ballot Open through January 28, 2021
Now Available
The 10-day final ballot for Project 2018-03 Standards Efficiency Review Retirements FAC-008-5 – Facility
Ratings is open through 8 p.m. Eastern, Thursday, January 28, 2021.
Balloting
In the final ballot, votes are counted by exception. Votes from the previous ballot are automatically
carried over in the final ballot. Only members of the applicable ballot pools can cast a vote. Ballot pool
members who previously voted have the option to change their vote in the final ballot. Ballot pool
members who did not cast a vote during the previous ballot can vote in the final ballot.
Members of the ballot pool associated with this project can log in and submit votes by accessing the
Standards Balloting and Commenting System (SBS). Contact Wendy Muller regarding issues using the
SBS.
•
Contact NERC IT support directly at https://support.nerc.net/ (Monday – Friday, 8 a.m. - 5 p.m.
Eastern) for problems regarding accessing the SBS due to a forgotten password, incorrect
credential error messages, or system lock-out.
•
Passwords expire every 6 months and must be reset.
•
The SBS is not supported for use on mobile devices.
•
Please be mindful of ballot and comment period closing dates. We ask to allow at least 48
hours for NERC support staff to assist with inquiries. Therefore, it is recommended that users
try logging into their SBS accounts prior to the last day of a comment/ballot period.
Next Steps
The voting results will be posted and announced after the ballot closes. If approved, the standard will be
submitted to the Board of Trustees for adoption and then filed with the appropriate regulatory authorities.
For information on the Standards Development Process, refer to the Standard Processes Manual.
For more information or assistance, contact Standards Developer, Laura Anderson (via email) or at (404)
446-9671.
North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com
RELIABILITY | RESILIENCE | SECURITY
Index - NERC Balloting Tool
Page 1 of 16
NERC Balloting Tool (/)
Dashboard (/)
Users
Ballots
Comment Forms
Login (/Users/Login) / Register (/Users/Register)
BALLOT RESULTS
Ballot Name: 2018-03 Standards Efficiency Review Retirements FAC-008-5 FN 2 ST
Voting Start Date: 1/19/2021 11:02:33 AM
Voting End Date: 1/28/2021 8:00:00 PM
Ballot Type: ST
Ballot Activity: FN
Ballot Series: 2
Total # Votes: 244
Total Ballot Pool: 268
Quorum: 91.04
Quorum Established Date: 1/19/2021 11:39:36 AM
Weighted Segment Value: 95.96
Ballot
Pool
Segment
Weight
Affirmative
Votes
Affirmative
Fraction
Negative
Votes w/
Comment
Negative
Fraction
w/
Comment
Segment:
1
69
1
61
0.953
3
0.047
0
1
4
Segment:
2
8
0.6
6
0.6
0
0
0
1
1
Segment:
3
62
1
55
0.982
1
0.018
0
0
6
Segment:
4
15
1
12
0.923
1
0.077
0
0
2
Segment:
5
68
1
58
0.951
3
0.049
0
0
7
Segment:
6
41
1
34
0.944
2
0.056
0
1
4
Segment:
7
0
0
0
0
0
0
0
0
0
Segment:
8
1
0.1
1
0.1
0
0
0
0
0
Segment:
9
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Segment
Segment: 4
0.4
4
0.4
© 2021
NERC
Ver
4.3.0.0
Machine
Name:
ERODVSBSWB01
10
Negative
Votes
w/o
Comment
Abstain
No
Vote
2/9/2021
Index - NERC Balloting Tool
Page 2 of 16
Segment
Ballot
Pool
Segment
Weight
Affirmative
Votes
Affirmative
Fraction
Negative
Votes w/
Comment
Totals:
268
6.1
231
5.854
10
Negative
Fraction
w/
Comment
Negative
Votes
w/o
Comment
Abstain
No
Vote
0.246
0
3
24
BALLOT POOL MEMBERS
Show All
Segment
entries
Organization
Search: Search
Voter
Designated
Proxy
Ballot
NERC
Memo
1
AEP - AEP Service
Corporation
Dennis Sauriol
Affirmative
N/A
1
Ameren - Ameren
Services
Tamara Evey
None
N/A
1
APS - Arizona Public
Service Co.
Daniela
Atanasovski
Affirmative
N/A
1
Arizona Electric Power
Cooperative, Inc.
Jennifer Bray
Affirmative
N/A
1
Associated Electric
Cooperative, Inc.
Mark Riley
Affirmative
N/A
1
Austin Energy
Thomas Standifur
Affirmative
N/A
1
Avista - Avista
Corporation
Mike Magruder
None
N/A
1
Balancing Authority of
Northern California
Kevin Smith
Negative
N/A
1
Basin Electric Power
Cooperative
David Rudolph
Affirmative
N/A
1
BC Hydro and Power
Authority
Adrian Andreoiu
Affirmative
N/A
Affirmative
N/A
1
Berkshire Hathaway
Terry Harbour
Energy - MidAmerican
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
Energy Co.
Joe Tarantino
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 3 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
1
Bonneville Power
Administration
Kammy RogersHolliday
Affirmative
N/A
1
CenterPoint Energy
Houston Electric, LLC
Daniela Hammons
Affirmative
N/A
1
Cleco Corporation
John Lindsey
Affirmative
N/A
1
Dairyland Power
Cooperative
Renee Leidel
Affirmative
N/A
1
Dominion - Dominion
Virginia Power
Candace Marshall
None
N/A
1
Duke Energy
Laura Lee
Affirmative
N/A
1
Edison International Southern California
Edison Company
Jose Avendano
Mora
Affirmative
N/A
1
Entergy - Entergy
Services, Inc.
Oliver Burke
Affirmative
N/A
1
Evergy
Allen Klassen
Affirmative
N/A
1
Eversource Energy
Quintin Lee
Affirmative
N/A
1
Exelon
Daniel Gacek
Affirmative
N/A
1
FirstEnergy - FirstEnergy
Corporation
Julie Severino
Affirmative
N/A
1
Georgia Transmission
Corporation
Greg Davis
Affirmative
N/A
1
Great River Energy
Gordon Pietsch
Affirmative
N/A
1
Hydro One Networks, Inc.
Payam
Farahbakhsh
Affirmative
N/A
1
Hydro-Qu?bec
TransEnergie
Nicolas Turcotte
Affirmative
N/A
1
IDACORP - Idaho Power
Company
Laura Nelson
Affirmative
N/A
1
Imperial Irrigation District
Jesus Sammy
Alcaraz
Denise Sanchez
Affirmative
N/A
1
International
Transmission Company
Holdings Corporation
Michael Moltane
Allie Gavin
Abstain
N/A
Douglas Webb
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 4 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
1
JEA
Joe McClung
Negative
N/A
1
KAMO Electric
Cooperative
Micah Breedlove
Affirmative
N/A
1
Los Angeles Department
of Water and Power
faranak sarbaz
Affirmative
N/A
1
Lower Colorado River
Authority
James Baldwin
Affirmative
N/A
1
Manitoba Hydro
Bruce Reimer
Affirmative
N/A
1
MEAG Power
David Weekley
Scott Miller
Affirmative
N/A
1
Minnkota Power
Cooperative Inc.
Theresa Allard
Andy Fuhrman
Affirmative
N/A
1
Muscatine Power and
Water
Andy Kurriger
Affirmative
N/A
1
N.W. Electric Power
Cooperative, Inc.
Mark Ramsey
Affirmative
N/A
1
National Grid USA
Michael Jones
Affirmative
N/A
1
NB Power Corporation
Nurul Abser
Affirmative
N/A
1
Nebraska Public Power
District
Jamison Cawley
Affirmative
N/A
1
New York Power
Authority
Salvatore
Spagnolo
Affirmative
N/A
1
NextEra Energy - Florida
Power and Light Co.
Mike ONeil
Affirmative
N/A
1
NiSource - Northern
Indiana Public Service
Co.
Steve Toosevich
Affirmative
N/A
1
OGE Energy - Oklahoma
Gas and Electric Co.
Terri Pyle
Affirmative
N/A
1
Omaha Public Power
District
Doug Peterchuck
Affirmative
N/A
1
Oncor Electric Delivery
Lee Maurer
Affirmative
N/A
1
Orlando Utilities
Commission
Aaron Staley
Affirmative
N/A
Tammy Porter
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 5 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
1
OTP - Otter Tail Power
Company
Charles Wicklund
Affirmative
N/A
1
Pacific Gas and Electric
Company
Marco Rios
None
N/A
1
Platte River Power
Authority
Matt Thompson
Negative
N/A
1
PPL Electric Utilities
Corporation
Preston Walker
Affirmative
N/A
1
PSEG - Public Service
Electric and Gas Co.
Randhir Singh
Affirmative
N/A
1
Public Utility District No. 1
of Chelan County
Ginette Lacasse
Affirmative
N/A
1
Public Utility District No. 1
of Snohomish County
Alyssia Rhoads
Affirmative
N/A
1
Salt River Project
Chris Hofmann
Affirmative
N/A
1
Santee Cooper
Chris Wagner
Affirmative
N/A
1
SaskPower
Wayne
Guttormson
Affirmative
N/A
1
Seattle City Light
Michael Jang
Affirmative
N/A
1
Seminole Electric
Cooperative, Inc.
Bret Galbraith
Affirmative
N/A
1
Southern Company Southern Company
Services, Inc.
Matt Carden
Affirmative
N/A
1
Sunflower Electric Power
Corporation
Paul Mehlhaff
Affirmative
N/A
1
Tacoma Public Utilities
(Tacoma, WA)
John Merrell
Affirmative
N/A
1
Tennessee Valley
Authority
Gabe Kurtz
Affirmative
N/A
1
Tri-State G and T
Association, Inc.
Kjersti Drott
Affirmative
N/A
1
U.S. Bureau of
Reclamation
Richard Jackson
Affirmative
N/A
Jennie Wike
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 6 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
1
Western Area Power
Administration
sean erickson
Affirmative
N/A
1
Xcel Energy, Inc.
Dean Schiro
Affirmative
N/A
2
California ISO
Jamie Johnson
Abstain
N/A
2
Electric Reliability Council
of Texas, Inc.
Brandon Gleason
Affirmative
N/A
2
Independent Electricity
System Operator
Leonard Kula
None
N/A
2
ISO New England, Inc.
Michael Puscas
Affirmative
N/A
2
Midcontinent ISO, Inc.
Bobbi Welch
Affirmative
N/A
2
New York Independent
System Operator
Gregory Campoli
Affirmative
N/A
2
PJM Interconnection,
L.L.C.
Tom Foster
Affirmative
N/A
2
Southwest Power Pool,
Inc. (RTO)
Charles Yeung
Affirmative
N/A
3
AEP
Kent Feliks
Affirmative
N/A
3
AES - Indianapolis Power
and Light Co.
Colleen Campbell
Affirmative
N/A
3
Ameren - Ameren
Services
David Jendras
Affirmative
N/A
3
APS - Arizona Public
Service Co.
Jessica Lopez
Affirmative
N/A
3
Austin Energy
W. Dwayne
Preston
Affirmative
N/A
3
Avista - Avista
Corporation
Scott Kinney
Affirmative
N/A
3
Basin Electric Power
Cooperative
Jeremy Voll
Affirmative
N/A
3
BC Hydro and Power
Authority
Hootan Jarollahi
Affirmative
N/A
3
Berkshire Hathaway
Energy - MidAmerican
Energy Co.
Darnez Gresham
Affirmative
N/A
Elizabeth Davis
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 7 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
3
Black Hills Corporation
Don Stahl
Affirmative
N/A
3
Bonneville Power
Administration
Ken Lanehome
Affirmative
N/A
3
Central Electric Power
Cooperative (Missouri)
Adam Weber
Affirmative
N/A
3
Cleco Corporation
Maurice Paulk
Affirmative
N/A
3
CMS Energy Consumers Energy
Company
Karl Blaszkowski
Affirmative
N/A
3
Colorado Springs Utilities
Hillary Dobson
Affirmative
N/A
3
Dominion - Dominion
Resources, Inc.
Connie Lowe
Affirmative
N/A
3
DTE Energy - Detroit
Edison Company
Karie Barczak
Affirmative
N/A
3
Duke Energy
Lee Schuster
Affirmative
N/A
3
Edison International Southern California
Edison Company
Romel Aquino
Affirmative
N/A
3
Evergy
Marcus Moor
Affirmative
N/A
3
Eversource Energy
Christopher
McKinnon
Affirmative
N/A
3
Exelon
Kinte Whitehead
Affirmative
N/A
3
FirstEnergy - FirstEnergy
Corporation
Aaron
Ghodooshim
Affirmative
N/A
3
Florida Municipal Power
Agency
Dale Ray
Affirmative
N/A
3
Georgia System
Operations Corporation
Scott McGough
Affirmative
N/A
3
Great River Energy
Michael Brytowski
Affirmative
N/A
3
Imperial Irrigation District
Glen Allegranza
Affirmative
N/A
3
JEA
Garry Baker
None
N/A
3
KAMO Electric
Cooperative
Tony Gott
Affirmative
N/A
Douglas Webb
Truong Le
Denise Sanchez
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 8 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
3
Lakeland Electric
Patricia Boody
None
N/A
3
Lincoln Electric System
Jason Fortik
Affirmative
N/A
3
Los Angeles Department
of Water and Power
Tony Skourtas
Affirmative
N/A
3
M and A Electric Power
Cooperative
Stephen Pogue
Affirmative
N/A
3
Manitoba Hydro
Karim Abdel-Hadi
Affirmative
N/A
3
MEAG Power
Roger Brand
Affirmative
N/A
3
Muscatine Power and
Water
Seth Shoemaker
Affirmative
N/A
3
National Grid USA
Brian Shanahan
Affirmative
N/A
3
Nebraska Public Power
District
Tony Eddleman
Affirmative
N/A
3
New York Power
Authority
David Rivera
Affirmative
N/A
3
NiSource - Northern
Indiana Public Service
Co.
Steven Taddeucci
Affirmative
N/A
3
Northeast Missouri
Electric Power
Cooperative
Skyler Wiegmann
None
N/A
3
NW Electric Power
Cooperative, Inc.
John Stickley
Affirmative
N/A
3
OGE Energy - Oklahoma
Gas and Electric Co.
Donald Hargrove
Affirmative
N/A
3
OTP - Otter Tail Power
Company
Wendi Olson
Affirmative
N/A
3
Owensboro Municipal
Utilities
Thomas Lyons
Affirmative
N/A
3
Platte River Power
Authority
Wade Kiess
Negative
N/A
3
Portland General Electric
Co.
Dan Zollner
None
N/A
3
PPL - Louisville Gas and
James Frank
Affirmative
N/A
Scott Miller
Electric
Co.
© 2021 - NERC Ver 4.3.0.0
Machine
Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 9 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
3
PSEG - Public Service
Electric and Gas Co.
maria pardo
Affirmative
N/A
3
Public Utility District No. 1
of Chelan County
Joyce Gundry
Affirmative
N/A
3
Puget Sound Energy, Inc.
Tim Womack
None
N/A
3
Santee Cooper
James Poston
Affirmative
N/A
3
Seminole Electric
Cooperative, Inc.
Jeremy Lorigan
Affirmative
N/A
3
Sho-Me Power Electric
Cooperative
Jarrod Murdaugh
Affirmative
N/A
3
Snohomish County PUD
No. 1
Holly Chaney
Affirmative
N/A
3
Southern Company Alabama Power
Company
Joel Dembowski
Affirmative
N/A
3
Tacoma Public Utilities
(Tacoma, WA)
Marc Donaldson
Affirmative
N/A
3
TECO - Tampa Electric
Co.
Ronald Donahey
None
N/A
3
Tennessee Valley
Authority
Ian Grant
Affirmative
N/A
3
Tri-State G and T
Association, Inc.
Janelle Marriott
Gill
Affirmative
N/A
3
WEC Energy Group, Inc.
Thomas Breene
Affirmative
N/A
3
Xcel Energy, Inc.
Nicholas Friebel
Affirmative
N/A
4
Alliant Energy
Corporation Services, Inc.
Larry Heckert
Affirmative
N/A
4
Austin Energy
Jun Hua
Affirmative
N/A
4
City Utilities of
Springfield, Missouri
John Allen
Affirmative
N/A
4
CMS Energy Consumers Energy
Company
Aric Root
Affirmative
N/A
4
FirstEnergy - FirstEnergy
Mark Garza
Affirmative
N/A
Jennie Wike
Corporation
© 2021 - NERC Ver 4.3.0.0
Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 10 of 16
Voter
4
Florida Municipal Power
Agency
Carol Chinn
4
LaGen
4
Designated
Proxy
Truong Le
Ballot
NERC
Memo
Affirmative
N/A
Wayne Messina
None
N/A
MGE Energy - Madison
Gas and Electric Co.
Joseph DePoorter
Affirmative
N/A
4
Modesto Irrigation District
Spencer Tacke
None
N/A
4
Public Utility District No. 1
of Snohomish County
John Martinsen
Affirmative
N/A
4
Public Utility District No. 2
of Grant County,
Washington
Karla Weaver
Affirmative
N/A
4
Sacramento Municipal
Utility District
Foung Mua
Negative
N/A
4
Seattle City Light
Hao Li
Affirmative
N/A
4
Tacoma Public Utilities
(Tacoma, WA)
Hien Ho
Affirmative
N/A
4
WEC Energy Group, Inc.
Matthew Beilfuss
Affirmative
N/A
5
Acciona Energy North
America
George Brown
Affirmative
N/A
5
AEP
Thomas Foltz
Affirmative
N/A
5
Ameren - Ameren
Missouri
Sam Dwyer
Affirmative
N/A
5
APS - Arizona Public
Service Co.
Kelsi Rigby
Affirmative
N/A
5
Austin Energy
Michael Dillard
Affirmative
N/A
5
Avista - Avista
Corporation
Glen Farmer
Affirmative
N/A
5
Basin Electric Power
Cooperative
Colleen Peterson
Affirmative
N/A
5
BC Hydro and Power
Authority
Helen Hamilton
Harding
Affirmative
N/A
5
Berkshire Hathaway - NV
Energy
Kevin Salsbury
Affirmative
N/A
5 - NERC Ver 4.3.0.0
Black Machine
Hills Corporation
Derek Silbaugh
© 2021
Name: ERODVSBSWB01
Affirmative
N/A
Joe Tarantino
Jennie Wike
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 11 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
5
Boise-Kuna Irrigation
District - Lucky Peak
Power Plant Project
Mike Kukla
Affirmative
N/A
5
Bonneville Power
Administration
Scott Winner
Affirmative
N/A
5
Brazos Electric Power
Cooperative, Inc.
Shari Heino
None
N/A
5
Cleco Corporation
Stephanie
Huffman
None
N/A
5
CMS Energy Consumers Energy
Company
David Greyerbiehl
Affirmative
N/A
5
Colorado Springs Utilities
Jeff Icke
None
N/A
5
Dairyland Power
Cooperative
Tommy Drea
Affirmative
N/A
5
Dominion - Dominion
Resources, Inc.
Rachel Snead
None
N/A
5
DTE Energy - Detroit
Edison Company
Adrian Raducea
None
N/A
5
Duke Energy
Dale Goodwine
Affirmative
N/A
5
Edison International Southern California
Edison Company
Neil Shockey
Affirmative
N/A
5
Entergy
Jamie Prater
Affirmative
N/A
5
Evergy
Derek Brown
Affirmative
N/A
5
Exelon
Cynthia Lee
Affirmative
N/A
5
FirstEnergy - FirstEnergy
Corporation
Robert Loy
Affirmative
N/A
5
Florida Municipal Power
Agency
Chris Gowder
Affirmative
N/A
5
Great River Energy
Jacalynn Bentz
Affirmative
N/A
5
Herb Schrayshuen
Herb Schrayshuen
Affirmative
N/A
5
Hydro-Qu?bec Production
Carl Pineault
Affirmative
N/A
Affirmative
N/A
5 - NERC Ver 4.3.0.0
Imperial
Irrigation
District
Tino Zaragoza
© 2021
Machine
Name:
ERODVSBSWB01
Douglas Webb
Truong Le
Denise Sanchez
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 12 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
5
JEA
John Babik
Negative
N/A
5
Lincoln Electric System
Kayleigh
Wilkerson
Affirmative
N/A
5
Los Angeles Department
of Water and Power
Glenn Barry
Affirmative
N/A
5
Lower Colorado River
Authority
Teresa Cantwell
Affirmative
N/A
5
Manitoba Hydro
Yuguang Xiao
Affirmative
N/A
5
Massachusetts Municipal
Wholesale Electric
Company
Anthony Stevens
Affirmative
N/A
5
Muscatine Power and
Water
Neal Nelson
Affirmative
N/A
5
National Grid USA
Elizabeth Spivak
Affirmative
N/A
5
NB Power Corporation
Rob Vance
Affirmative
N/A
5
New York Power
Authority
Shivaz Chopra
Affirmative
N/A
5
NiSource - Northern
Indiana Public Service
Co.
Kathryn Tackett
Affirmative
N/A
5
NovaSource Power
Services
Bradley Collard
None
N/A
5
OGE Energy - Oklahoma
Gas and Electric Co.
Patrick Wells
Affirmative
N/A
5
Oglethorpe Power
Corporation
Donna Johnson
Affirmative
N/A
5
Omaha Public Power
District
Mahmood Safi
Affirmative
N/A
5
Ontario Power
Generation Inc.
Constantin
Chitescu
Affirmative
N/A
5
Orlando Utilities
Commission
Dania Colon
Affirmative
N/A
5
OTP - Otter Tail Power
Company
Brett Jacobs
Affirmative
N/A
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 13 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
5
Pacific Gas and Electric
Company
Ed Hanson
Affirmative
N/A
5
Platte River Power
Authority
Tyson Archie
Negative
N/A
5
Portland General Electric
Co.
Ryan Olson
None
N/A
5
PPL - Louisville Gas and
Electric Co.
JULIE
HOSTRANDER
Affirmative
N/A
5
PSEG - PSEG Fossil LLC
Tim Kucey
Affirmative
N/A
5
Public Utility District No. 1
of Chelan County
Meaghan Connell
Affirmative
N/A
5
Public Utility District No. 1
of Snohomish County
Sam Nietfeld
Affirmative
N/A
5
Public Utility District No. 2
of Grant County,
Washington
Amy Jones
Affirmative
N/A
5
Sacramento Municipal
Utility District
Nicole Goi
Negative
N/A
5
Salt River Project
Kevin Nielsen
Affirmative
N/A
5
Santee Cooper
Tommy Curtis
Affirmative
N/A
5
Seattle City Light
Faz Kasraie
Affirmative
N/A
5
Seminole Electric
Cooperative, Inc.
Mickey Bellard
Affirmative
N/A
5
Southern Company Southern Company
Generation
James Howell
Affirmative
N/A
5
Talen Generation, LLC
Donald Lock
Affirmative
N/A
5
Tennessee Valley
Authority
M Lee Thomas
Affirmative
N/A
5
Tri-State G and T
Association, Inc.
Ryan Walter
Affirmative
N/A
5
U.S. Bureau of
Reclamation
Wendy Center
Affirmative
N/A
5
WEC Energy Group, Inc.
Janet OBrien
Affirmative
N/A
Joe Tarantino
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 14 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
5
Xcel Energy, Inc.
Gerry Huitt
Affirmative
N/A
6
AEP
JT Kuehne
Affirmative
N/A
6
Ameren - Ameren
Services
Robert Quinlivan
Affirmative
N/A
6
APS - Arizona Public
Service Co.
Marcus Bortman
Affirmative
N/A
6
Associated Electric
Cooperative, Inc.
Brian Ackermann
None
N/A
6
Austin Energy
Tammy Cooper
Affirmative
N/A
6
Basin Electric Power
Cooperative
Jerry Horner
Affirmative
N/A
6
Black Hills Corporation
Brooke Voorhees
Affirmative
N/A
6
Bonneville Power
Administration
Andrew Meyers
Affirmative
N/A
6
Cleco Corporation
Robert Hirchak
Affirmative
N/A
6
Dominion - Dominion
Resources, Inc.
Sean Bodkin
None
N/A
6
Duke Energy
Greg Cecil
Affirmative
N/A
6
Evergy
Thomas ROBBEN
Affirmative
N/A
6
Exelon
Becky Webb
Affirmative
N/A
6
FirstEnergy - FirstEnergy
Corporation
Ann Carey
Affirmative
N/A
6
Florida Municipal Power
Agency
Richard
Montgomery
Truong Le
Affirmative
N/A
6
Imperial Irrigation District
Diana Torres
Denise Sanchez
Affirmative
N/A
6
Los Angeles Department
of Water and Power
Anton Vu
Affirmative
N/A
6
Manitoba Hydro
Blair Mukanik
Affirmative
N/A
6
Muscatine Power and
Water
Nick Burns
Affirmative
N/A
6
New York Power
Authority
Erick Barrios
Affirmative
N/A
Douglas Webb
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 15 of 16
Voter
Designated
Proxy
Ballot
NERC
Memo
6
NextEra Energy - Florida
Power and Light Co.
Justin Welty
None
N/A
6
NiSource - Northern
Indiana Public Service
Co.
Joe O'Brien
Affirmative
N/A
6
Northern California Power
Agency
Dennis Sismaet
Abstain
N/A
6
OGE Energy - Oklahoma
Gas and Electric Co.
Sing Tay
Affirmative
N/A
6
Omaha Public Power
District
Shonda McCain
Affirmative
N/A
6
Platte River Power
Authority
Sabrina Martz
Negative
N/A
6
Portland General Electric
Co.
Daniel Mason
Affirmative
N/A
6
Powerex Corporation
Gordon DobsonMack
None
N/A
6
PPL - Louisville Gas and
Electric Co.
Linn Oelker
Affirmative
N/A
6
PSEG - PSEG Energy
Resources and Trade
LLC
Joseph Neglia
Affirmative
N/A
6
Public Utility District No. 1
of Chelan County
Glen Pruitt
Affirmative
N/A
6
Public Utility District No. 2
of Grant County,
Washington
LeRoy Patterson
Affirmative
N/A
6
Sacramento Municipal
Utility District
Charles Norton
Negative
N/A
6
Santee Cooper
Marty Watson
Affirmative
N/A
6
Seattle City Light
Brian Belger
Affirmative
N/A
6
Snohomish County PUD
No. 1
John Liang
Affirmative
N/A
Affirmative
N/A
6
Southern Company Ron Carlsen
Southern Company
Generation
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
Joe Tarantino
2/9/2021
Index - NERC Balloting Tool
Segment
Organization
Page 16 of 16
Voter
6
Tacoma Public Utilities
(Tacoma, WA)
Terry Gifford
6
Tennessee Valley
Authority
6
Designated
Proxy
Jennie Wike
NERC
Memo
Ballot
Affirmative
N/A
Marjorie Parsons
Affirmative
N/A
WEC Energy Group, Inc.
David Hathaway
Affirmative
N/A
6
Xcel Energy, Inc.
Carrie Dixon
Affirmative
N/A
8
David Kiguel
David Kiguel
Affirmative
N/A
10
New York State Reliability
Council
ALAN ADAMSON
Affirmative
N/A
10
Northeast Power
Coordinating Council
Guy V. Zito
Affirmative
N/A
10
ReliabilityFirst
Anthony Jablonski
Affirmative
N/A
10
Texas Reliability Entity,
Inc.
Rachel Coyne
Affirmative
N/A
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Showing 1 to 268 of 268 entries
© 2021 - NERC Ver 4.3.0.0 Machine Name: ERODVSBSWB01
2/9/2021
Exhibit F
Standard Drafting Team Roster
RELIABILITY | RESILIENCE | SECURITY
Standard Drafting Team Roster
Project 2018-03 Standards Efficiency Review Retirements
Name
Entity
Chair
Charles Rogers
Consumers Energy
Vice Chair
Bob Staton
Public Service Company of Colorado (Xcel Energy)
Members
Karie Barczak
DTE Energy
Sandeep Borkar
ERCOT
Gerald Keenan
NWPP
Mario Kiresich
Southern California Edison
Thomas Leslie
Georgia Transmission Corp.
Michael Steckelberg
Great River Energy
Stephen Wendling
American Transmission Company
Jim Williams
SPP
Michael Brytowski
Great River Energy
Mark Pratt
Southern Company
Laura Anderson – Standards
Developer
North American Electric Reliability Corporation
Darrel Richardson – Principal
Technical Advisor
North American Electric Reliability Corporation
Scott Barfield – Senior Technical
Advisor
North American Electric Reliability Corporation
Al McMeekin – Senior Technical
Advisor
North American Electric Reliability Corporation
Lauren Perotti – Counsel
North American Electric Reliability Corporation
Wendy Muller – Specialist,
Standards Development
North American Electric Reliability Corporation
PMOS Liaisons
NERC Staff
| File Type | application/pdf |
| Author | bryants |
| File Modified | 2021-02-19 |
| File Created | 2021-02-19 |