Kenneth Wilson WECC Staff Slides: Branden 1-3 Michelle 4- 15 Richard 16-18 Branden 19-28 Richard 29-30 Bulk Electric System (BES) Definition Update May 14-15, 2013 RS Meeting, Salt Lake City

Overview “Core” BES Definition FERC Order BES Definition Processes Definitional Exclusion Reporting Process Rules of Procedure Exception Process Local Distribution Process De-registration Process Staff Points of Contact Further emphasize the difference between the core definition inclusions and exclusions and the Rules of Procedure exception process

BES Core Definition

BES Definition – Base “… all Transmission Elements operated at 100 kV or higher and Real and Reactive Power resources connected at 100 kV or higher. This does not include facilities used in the local distribution of electric energy.”

BES Definition – Definitional Inclusions and Exclusions The BES Definition provides specific criteria for “definitional” inclusions and exclusions I1 – I5, E1 – E4 These do not need to be submitted through the Rules of Procedure (RoP) Exception Process Element changes to the BES are reported to the Regions for review

Definitional Inclusions I1 - Transformers with the primary terminal and at least one secondary terminal operated at 100 kV or higher unless excluded under Exclusion E1 or E3. I2 - Generating resource(s) with gross individual nameplate rating greater than 20 MVA or gross plant/facility aggregate nameplate rating greater than 75 MVA including the generator terminals through the high-side of the step-up transformer(s) connected at a voltage of 100 kV or above. I3 - Blackstart Resources identified in the Transmission Operator’s restoration plan. I1 – clarifies transformers; previous discussion of whether it was just one winding or both that had to be above 100 kV I2 – Generation consistent with SCRC. Also includes step-up transformers that connect the generator to at 100 kV I3 – Blackstart resources

Definitional Inclusions (cont.) I4 - Dispersed power producing resources with aggregate capacity greater than 75 MVA (gross aggregate nameplate rating) utilizing a system designed primarily for aggregating capacity, connected at a common point at a voltage of 100 kV or above. I5 –Static or dynamic devices (excluding generators) dedicated to supplying or absorbing Reactive Power that are connected at 100 kV or higher, or through a dedicated transformer with a high-side voltage of 100 kV or higher, or through a transformer that is designated in Inclusion I1. I4 – meant to capture renewable resources, i.e. wind farms I5 – reactive resources

Definitional Exclusions E1 - Radial systems: A group of contiguous transmission Elements that emanates from a single point of connection of 100 kV or higher and: Only serves Load. or, b) Only includes generation resources, not identified in Inclusion I3, with an aggregate capacity less than or equal to 75 MVA (gross nameplate rating). or, c) Where the radial system serves Load and includes generation resources, not identified in Inclusion I3, with an aggregate capacity of non-retail generation less than or equal to 75 MVA (gross nameplate rating). Note – A normally open switching device between radial systems, as depicted on prints or one-line diagrams for example, does not affect this exclusion. Radials serving only load have always been excluded There was discussion about what “serving only load” really meant – many radials have de minimus generation, such as roof-top solars that the SDT believed were not intended to negate the exclusion. Therefore, they allowed for up to 75 MVA of generation Historic discussion of whether a N.O. switch meant a line was not radial. Argument that it adds reliability, and should not be penalized.

Definitional Exclusions (cont.) E2 - A generating unit or multiple generating units on the customer’s side of the retail meter that serve all or part of the retail Load with electric energy if: (i) the net capacity provided to the BES does not exceed 75 MVA, and (ii) standby, back-up, and maintenance power services are provided to the generating unit or multiple generating units or to the retail Load by a Balancing Authority, or provided pursuant to a binding obligation with a Generator Owner or Generator Operator, or under terms approved by the applicable regulatory authority. Retail generation is excluded – this is consistent with the SCRC

Definitional Exclusions (cont.) E3 - Local networks (LN): A group of contiguous transmission Elements operated at or above 100 kV but less than 300 kV that distribute power to Load rather than transfer bulk power across the interconnected system. LN’s emanate from multiple points of connection at 100 kV or higher to improve the level of service to retail customer Load and not to accommodate bulk power transfer across the interconnected system. The LN is characterized by all of the following: a) Limits on connected generation: The LN and its underlying Elements do not include generation resources identified in Inclusion I3 and do not have an aggregate capacity of non-retail generation greater than 75 MVA (gross nameplate rating) ; b) Power flows only into the LN and the LN does not transfer energy originating outside the LN for delivery through the LN; and c) Not part of a Flowgate or transfer path: The LN does not contain a monitored Facility of a permanent Flowgate in the Eastern Interconnection, a major transfer path within the Western Interconnection, or a comparable monitored Facility in the ERCOT or Quebec Interconnections, and is not a monitored Facility included in an Interconnection Reliability Operating Limit (IROL). E4 – Reactive Power devices owned and operated by the retail customer solely for its own use. Local Networks are meant to be low-impact systems; power flows in, not out or through. Also not part of a major transfer path. E4 is for retail reactive power.

FERC Order Michelle

BES Definition - History Approved by NERC Board of Trustees on 1/19/12 FERC proposed to approve definition and revisions to the Rules of Procedure in its 6/22/12 Notice of Proposed Rulemaking FERC approval 12/20/12 (Order 773) FERC final approval 4/18/13 (Order 773-A)

Effective Dates Definition effective July 1, 2013 Compliance for newly added facilities July 1, 2015

FERC Order Changes Local Distribution E1 and E3 do not apply to generation tie lines (NERC will Modify Definition) 100 kV minimum on local networks removed (NERC will Modify Definition) FERC can designate elements as part of the BES on its own Registered Entities must notify its Regional Entity of elements that changed BES status per application of the new BES definition (per section 501 of RoP) Discuss the need for FERC to address local distribution in the order

Definitional Inclusion/Exclusions Reporting Process

BES Definition Guidance Document Provides guidance on application Revisions related to FERC order and comments received expected in April NERC Informational webinar after release of document WECC recommends that entities begin reviewing their systems for conformance to the new BES definition, but where there are grey areas they should wait until the revised Guidance Document to evaluate those elements

Notification of Self-Determination Required by paragraph 317 of FERC Order 773 and Section 501 of the NERC Rules of Procedure Notification through “NERC BES Notification and Exception System” available July 1, 2013 Submission by asset owner (GO/TO) More detailed info at 5/30 webinar P110 of the rehearing order talked about notification in “Good Faith” Good Faith is proper application of the definition Will discuss further on 5/30 webinar

Definitional Exclusion/Inclusion Reporting Process Data Required List of element(s) that are included/exclude per the definition System Map If required two years of flow data into network WECC registration staff notifies entities of concurrence/non-concurrence of elements Need to mention that until the entity receives the results of our review they are assuming the risk that WECC may not agree with their conclusions. WECC anticipates on processing notifications on a first come, first served basis with the exception of upcoming audits – entities with audits may take precedence over others Even though WECC may accept notification in March, we have no obligation to turn them around, but will work hard to turn around as quickly as possible

Rules of Procedure Exception Process

Rules of Procedure Exception Process “ Elements may be included or excluded on a case-by-case basis through the Rules of Procedure exception process.” Exceptions requests will only be considered after Compliance staff determines the network/element is in the BES per the definition After an entity has gone through the definitional inclusions and exclusions they can go through the Rules of Procedure Exception Process

Ongoing RoP Exception Process Activities (a) Exclusion Exception An entity may request and obtain Approval from NERC for an Exclusion Exception on the grounds that the Element(s) for which the Exception Request is filed is included within the BES based on application of the BES Definition but is not necessary for the Reliable Operation of the interconnected bulk-power transmission system as evidenced by Required Information provided pursuant to Detailed Information to Support an Exception Request (Section III.B of the Exception Request Form).

Ongoing RoP Exception Process Activities (b) Inclusion Exception An entity may request and obtain Approval from NERC for an Inclusion Exception on the grounds that the Element(s) for which the Exception Request is filed is not included within the BES based on application of the BES Definition but is necessary for the Reliable Operation of the interconnected bulk-power transmission system as evidenced by Required Information provided pursuant to Detailed Information to Support an Exception Request (Section III.B of the Exception Request Form).

Federal Power Act Section 215 of the FPA states: ‘‘(4) The term ‘reliable operation’ means operating the elements of the bulk-power system within equipment and electric system thermal, voltage, and stability limits so that instability, uncontrolled separation, or cascading failures of such system will not occur as a result of a sudden disturbance, including a cybersecurity incident, or unanticipated failure of system elements.”

RoP Exception Process Entity submits request Regional Entity accepts or rejects (submitting entity can appeal) If accepted, Regional Entity performs substantive review Regional Entity recommends approval or disapproval (if recommending disapproval, forward request to Technical Review Panel (TRP)) NERC makes final decision (submitting entity can appeal)

Eligible Submitter Scope of responsibility: Owner Regional Entity (RE) Planning Authority (PA) Reliability Coordinator (RC) Transmission Operator (TOP) Transmission Planner (TP) Balancing Authority (BA)

Initial Screening Complete screening either 60 days after initial receipt or 30 days after receiving owner’s response, whichever is later Assign unique identifier Review for whether: Submitting entity was eligible Required information was submitted Send notice to submitter Regional Entity Can accept or reject in whole or in part

Substantive Review Complete within six months of acceptance Regional Entity may request additional info Regional Entity develops recommendation If recommendation is for disapproval, engage a TRP Not involved in original review Regional Entity not bound by recommendation of TRP Submitting entity or owner can supplement the request at any time

Approval or Disapproval Complete 90 days after receiving Recommendation NERC develops team of three subject matter experts to review request NERC may request interviews with Regional Entity, submitting entity, or owner NERC President makes final decision

Ongoing RoP Exception Process Activities Registered entity training/outreach to come Submittal process Acceptable file formats Start dates Guidance on detailed information for Section III

Outreach and other important dates May 24, 9am MT, Application of Definition webinar May 30, 2pm MT, Notification of Self Determination webinar June 4-5, Compliance Users Group June 11, 2pm MT, Exception Process for TO/GOs webinar June 13, 2pm MT, Exception Process for TOP/BA/RC/PC webinar June 20, 3pm MT, Next Steps and Q&A webinar June 17-28, NERC webinars on BES Notification and Exception System July 1, 2013 BES Definition Effective Date

Detailed Information to Support an Exception Request A one-line breaker diagram identifying the Element(s) for which the exception is requested must be supplied with every request. The diagram(s) supplied should also show the Protection Systems at the interface points associated with the Elements for which the exception is being requested. The Detailed Information to Support an Exception Request provides a list of questions for Transmission Elements and Generation Resources that should be addressed (see http://www.nerc.com/docs/standards/sar/bes_criteria_third_posting_exception_request_form_20111107_clean.pdf)

Detailed Information to Support an Exception Request Entities are required to supply the data and studies needed to support their submittal. Studies should: Be based on an Interconnection-wide base case that is suitably complete and detailed to reflect the electrical characteristics and system topology; Clearly document all assumptions used; Address key performance measures of BES reliability through steady-state power flow; and, transient stability analysis as necessary to support the entity’s request, consistent with the methodologies described in the Transmission Planning (TPL) standard and commensurate with the scope of the request. Supporting statements for the submitted position from other entities are encouraged.

Local Distribution

Local Distribution Submit requests directly to FERC FERC will use the 7 Factor Test (Order 888) to determine applicability Once FERC issues a favorable decision the Local Distribution network is no longer part of the BES.

De-registration Process

De-registration Process Current Process Submit letter to compliancesupport@wecc.biz identifying reason for request (i.e. definitional exclusion, exception request etc.) Future Process Notification through “NERC BES Notification and Exception System” available July 1, 2013

WECC Staff Contacts Application of “Core” Definition and Definitional Exclusion Submittals, De-registration Process Richard Mabry: Email: rmabry@wecc.biz, Phone: 801.883.6847 Rules of Procedure Exception Process Kenneth Wilson: Email: ken@wecc.biz, Phone: 801.883.6886

Questions? Kenneth Wilson – ken@wecc.biz Richard Mabry – rmabry@wecc.biz