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Transmission Planner Seminar

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Presentation on theme: "Transmission Planner Seminar"— Presentation transcript:

1 Transmission Planner Seminar
November 2, 2017 Portland, OR Introduction comments and distancing myself from “silliness” of previous presentations. Western Electricity Coordinating Council

2 Transmission Planner Seminar
Phil O’Donnell Manager, Operation and Planning Jay Loock Sr Auditor, Michael Dalebout Manager of Registration Introduction comments and distancing myself from “silliness” of previous presentations. Western Electricity Coordinating Council

3 Transmission Planner Seminar
WECC Antitrust Policy Link to WECC Antitrust Policy CFR Introduction BREAK TP Standards Review TP Implementation Plan Question & Answer LUNCH WECC conducts registration under the jurisdiction of NERC, so we have worked closely with NERC on all the solutions we have considered. This has been done by telephone, and face-to-face over months and months. What we came up with is rational, reasonable, and friendly. So, what is the fine line for us in registration to get this right? - Solutions can easily be considered either too complex or too simple – and possibly both depending on the critic. – Recognizing traditional community behaviors versus legally obligated behaviors – Do we or HAVE WE addressed the most important question: What problem(s) was it that we were trying to solve? Western Electricity Coordinating Council

4 Transmission Planner Seminar: Antitrust Statement
Attendees are reminded that all WECC meetings, including this one, are conducted in accordance with the WECC Antitrust Policy and the NERC Antitrust Compliance Guidelines. The WECC Antitrust Policy requires compliance with all applicable antitrust laws and the avoidance of any conduct that unreasonably restrains competition. It is the responsibility of every WECC employee and all participants at WECC-hosted events to be familiar with this policy and to comply with it. If you believe actions are being taken during this meeting in conflict with this policy, or if you have any questions about the policy, please contact me or WECC legal counsel immediately. A copy of the policy has been provided with this meeting’s agenda for your reference. Attendees are reminded that all WECC meetings, including this one, are conducted in accordance with the WECC Antitrust Policy and the NERC Antitrust Compliance Guidelines. The WECC Antitrust Policy requires compliance with all applicable antitrust laws and the avoidance of any conduct that unreasonably restrains competition. If you believe actions are being taken during this meeting in conflict with this policy, or if you have any questions about the policy, please contact me or WECC legal counsel immediately. A copy of the policy has been provided with this meeting’s agenda for your reference. Western Electricity Coordinating Council

5 Transmission Planner Seminar: CFR Introduction
What is a CFR? CFR is short for Coordinated Functional Registration (CFR). Western Electricity Coordinating Council

6 Transmission Planner Seminar: CFR Introduction
Although that’s pretty clear, if you don’t communicate with other people like this, it might take a second for simplify this in your head. If not, let me lend you my analysis, a CFR allows two entities to divvy up responsibilities between then for the same reliability function. Western Electricity Coordinating Council

7 Transmission Planner Seminar: CFR Introduction
In addition to registering as an entity responsible for all functions that it performs itself, multiple entities may each register using a CFR for one or more Reliability Standard(s) and/or for one or more Requirements/sub-Requirements within particular Reliability Standard(s) applicable to a specific function. What is important for a CFR is the underlying agreement between the entities. This is a way of the entities TELLING the regional entity how they are dividing up the work. Like any report, it can be helpful to the parties as a detailed record of what their agreement is but the success of the CFR is based on communications and clear lines of delineation. If one of the parties is asked about any standard in the CFR – any party including WECC should be able to easily say – Party X is responsible according to the CFR. And really that should be understood throughout the organization to be reliable and current. Western Electricity Coordinating Council

8 Transmission Planner Seminar: CFR Introduction
Why enter into a CFR? A CFR can simplify the audit process for affiliated parties by identifying just one party to be accountable for individual Reliability Standards. This approach may reduce the oversight burden for both parties depending on the arrangement. An example might be two transmission planners reaching an agreement on which one performs specific modeling scenarios to avoid the duplication of efforts. So what are the rules and regulations of how to do a CFR? Well if you take out the description of what a CFR is, you have about one page of requirements in the ROP. There are no other requirement layers on top of this – these are the rules for filing a CFR. Western Electricity Coordinating Council

9 Transmission Planner Seminar: CFR Introduction
OK – that was the sales pitch. The Rules of Procedure govern the use of CFRs, not his presentation. Please always use the current NERC ROP as a reference Western Electricity Coordinating Council

10 Transmission Planner Seminar: CFR Introduction
The CFR submission must include a written agreement that governs itself and clearly specifies the entities’ respective compliance responsibilities. Each entity shall take full compliance responsibility for those Reliability Standards and/or Requirements/sub-Requirements it has registered for in the CFR. Neither NERC nor the Regional Entity shall be parties to any such agreement, nor shall NERC or the Regional Entity have responsibility for reviewing or approving any such agreement, other than to verify that the agreement provides for an allocation or assignment of responsibilities consistent with the CFR. Western Electricity Coordinating Council

11 Transmission Planner Seminar: CFR Introduction
Acceptance of a CFR means a review has determined that Section of the Rules of Procedure has been met. Neither NERC nor the Regional Entity have responsibility for reviewing or approving any such agreement, other than to verify that the agreement provides for a clear allocation or assignment of responsibilities consistent with the CFR. This means there are no gaps or overlaps: One and only one RC for each area. All BAs and TOPs under one and only one RC All facilities under one and only one TP, PA, and TOP. All load and generation under one and only one BA. Western Electricity Coordinating Council

12 Transmission Planner Seminar: CFR Introduction
Because the CFR is a reflection of an agreement between two parties, it may reflect a number of arrangements. Complete Agreement - This CFR is for an entire function and lists all the Standard Requirements for the reliability function. Partial Agreement – A CFR that covers only a subset of the Standards that are subject to a particular functional registration. Western Electricity Coordinating Council

13 Transmission Planner Seminar: CFR Introduction
Complete (full) Delegation – Responsibility for a requirement is performed by just one party in the agreement. Partial (shared) Delegation – Responsibility for a requirement is divided between the parties, notes may be required to support specifics. No Delegation - No responsibilities are delegated for performing the task. Same as not including in the agreement. Western Electricity Coordinating Council

14 Transmission Planner Seminar: CFR Introduction
NERC website here for CFR info: Western Electricity Coordinating Council

15 Transmission Planner Seminar: CFR Introduction
If your taking notes or wondering how you get a copy of this spreadsheet, this process is about to become much easier. NERC website here for CFR info: Western Electricity Coordinating Council

16 Transmission Planner Seminar: xRM Project
This process will soon be incorporated into the NERC xRM project. The xRM project will eventually provide a single location for NERC Compliance data for US Entities. This project is beginning with the CFR tool Testing is nearly complete and should be available before the end of the year. Western Electricity Coordinating Council

17 Transmission Planner Seminar: Implementations Plans
Questions may directed to WECC Support. WECC Support Phone: (801) Toll Free: (877) Will this effort be coordinated with the effort of the PCC GRT? This is not part of the PCC GRT effort. This is an effort performed by WECC, in its role as the Regional Entity for the Western Interconnection. WECC will provide relevant information to the PCC GRT that may help the PCC GRT’s efforts. The PC-GRT, once formed would be available to help entities with questions regarding the identification of their PC. There were an inadequate number of responses to the initial PC survey sufficient to provide an effective overview. The results of the Functional Mapping initiative will help identify potential gaps and the PC-GRT will be available to help provide input and suggest resolutions. . The use of the PC-GRT’s report by WECC or other entities is optional and its findings are not binding on WECC WECC is sensitive to the burden placed on industry resources and its commensurate value in terms of reliability . However, WECC’s primary duty as the Regional Entity is to comply with its obligations under the Delegations Agreement with NERC. Although there is not likely one perfect solution to resolving all reliability gaps, this effort will help WECC generate helpful information in identifying reliability gaps. We are open to input from industry on how to improve the process or to devise a mapping process that will help identify, and address reliability gaps. Western Electricity Coordinating Council

18 Transmission Planner Seminar
Phil O’Donnell Manager, Operation and Planning Jay Loock Sr Auditor, Michael Dalebout Manager of Registration Introduction comments and distancing myself from “silliness” of previous presentations. Western Electricity Coordinating Council

19 Transmission Planner Seminar: Implementation Plans
Western Electricity Coordinating Council

20 Transmission Planning Implementation Plans
Michael Dalebout Manager of Registration Introduction comments and distancing myself from “silliness” of previous presentations. Western Electricity Coordinating Council

21 Transmission Planner Seminar: Implementation Plans
1.4 For all geographical or electrical areas of the Bulk Power System, the Registration process shall ensure that no areas are lacking any entities to perform the duties and tasks identified in and required by the Reliability Standards to the fullest extent practical, and there is no unnecessary duplication of such coverage or of required oversight of such coverage. In particular the process shall: Western Electricity Coordinating Council

22 Transmission Planner Seminar: Implementation Plans
2015 1.4 For all geographical or electrical areas of the Bulk Power System, the Registration process shall ensure that no areas are lacking any entities to perform the duties and tasks identified in and required by the Reliability Standards to the fullest extent practical, and there is no unnecessary duplication of such coverage or of required oversight of such coverage. In particular the process shall: Western Electricity Coordinating Council

23 Transmission Planner Seminar: Implementation Plans
The purpose of the Planning Coordinator function is to "coordinate, facilitate, integrate and evaluate (generally one year and beyond) transmission facility and service plans and resource plans within a Planning Coordinator area and coordinate those plans with adjoining Planning Coordinator areas.” At the time there were growing concerns that gaps in reliability could exist because there are entities that are neither registered for the Planning Coordinator function nor identified in another entity’s Planning Coordinator area. This concern was elevated following the final assessment of the September 8, 2011 “Southwest Outage” event. In consideration of this event, WECC acknowledged the potential gap and recognized there could be a reliability risk if Bulk Electric System (BES) Facilities do not fall under the purview of a Planning Coordinator, and subsequently a Transmission Planner. Western Electricity Coordinating Council

24 Transmission Planner Seminar: Implementation Plans
Rules of Procedure of the North American Electric Reliability Corporation Ensure that all areas are under the oversight of one and only one Reliability Coordinator. Ensure that all Balancing Authorities and Transmission Operator entities are under the responsibility of one and only one Reliability Coordinator. Ensure that all transmission Facilities of the Bulk Power System are the responsibility and under the control of one and only one Transmission Planner, Planning Authority, and Transmission Operator. Ensure that all Loads and generators are under the responsibility and control of one and only one Balancing Authority. 1.4 For all geographical or electrical areas of the Bulk Power System, the Registration process shall ensure that no areas are lacking any entities to perform the duties and tasks identified in and required by the Reliability Standards to the fullest extent practical, and there is no unnecessary duplication of such coverage or of required oversight of such coverage. In particular the process shall: Western Electricity Coordinating Council

25 Transmission Planner Seminar: Implementation Plans
Transmission Owner (TO) Transmission Operator (TOP) Transmission Planner (TP) Transmission Service Provider (TSP) Planning Authority (PA) Transmission Operator (TOP) Transmission Planner (TP) Western Electricity Coordinating Council

26 Transmission Planner Seminar: Implementation Plans
Transmission Owners unmapped to Transmission Planners and / or Transmission Operators must put together a Implementation Plan. I won’t cover this in detail again, however Western Electricity Coordinating Council

27 Transmission Planner Seminar: Implementation Plans
What is an Implementation Plan? Western Electricity Coordinating Council

28 Transmission Planner Seminar: Implementations Plans
An Implementation Plan allows a soon-to-be-registered entity the opportunity to demonstrate a path to compliance. The purpose of submitting an Implementation Plan is to identify the controls and corrective actions that shall be taken by the entity to become compliant with all the standards required by its functional registration. The details of the plan should be commensurate with a mitigation plan. Western Electricity Coordinating Council

29 Transmission Planner Seminar: Implementations Plans
An Implementation Plan Must Include: Designated function Descriptive milestones Scheduled meetings or known events Proposed Completion Date Interim Risk Reduction Western Electricity Coordinating Council

30 Transmission Planner Seminar: Implementations Plans
Where can I find the Implementation Plan Templates? Western Electricity Coordinating Council

31 Transmission Planner Seminar: Implementations Plans
Western Electricity Coordinating Council

32 Transmission Planner Seminar: Implementations Plans
1 2 3 Western Electricity Coordinating Council

33 Transmission Planner Seminar: Implementations Plans
Western Electricity Coordinating Council

34 Transmission Planner Seminar: Implementations Plans
Western Electricity Coordinating Council

35 Transmission Planner Seminar: Implementations Plans
How do I submit a Implementation Plan? Western Electricity Coordinating Council

36 Transmission Planner Seminar: Implementations Plans
Implementation Plans should be attached to a WECC Registration Request Form when registering for the corresponding function. Western Electricity Coordinating Council

37 Transmission Planner Seminar: Implementations Plans
Western Electricity Coordinating Council

38 Transmission Planner Seminar: Implementations Plans
Who should submit the plan? WECC is asking that the entity which will ultimately perform the reliability functions to submit the Implementation Plan. Western Electricity Coordinating Council

39 Transmission Planner Seminar: Implementations Plans
When should the plan be submitted? If you are working on a CFR to determine the scope of your compliance obligation, we believe that in itself is part of the implementation plan. Thus, we encourage entities to submit plans as early as possible. The plan may be changed to accommodate unforeseen changes to the plan. Western Electricity Coordinating Council

40 Transmission Planner Seminar: Implementations Plans
Implementation Plans shall be reviewed by WECC Subject Matter Experts to determine if the timelines suggested are reasonable and appropriate. What it takes to win is simple, it's not easy. – Marv Levy Western Electricity Coordinating Council

41 Transmission Planner Seminar: Implementations Plans
WECC conducts registration under the jurisdiction of NERC, so we have worked closely with NERC on all the solutions we have considered. This has been done by telephone, and face-to-face over months and months. What we came up with is rational, reasonable, and friendly. NERC will send a modified registration letter that will reference the implementation plan on file with WECC & NERC. The entity will be added to the NERC Compliance Registry immediately. Western Electricity Coordinating Council

42 Transmission Planner Seminar: Implementations Plans
Questions may directed to WECC Support. WECC Support Phone: (801) Toll Free: (877) Will this effort be coordinated with the effort of the PCC GRT? This is not part of the PCC GRT effort. This is an effort performed by WECC, in its role as the Regional Entity for the Western Interconnection. WECC will provide relevant information to the PCC GRT that may help the PCC GRT’s efforts. The PC-GRT, once formed would be available to help entities with questions regarding the identification of their PC. There were an inadequate number of responses to the initial PC survey sufficient to provide an effective overview. The results of the Functional Mapping initiative will help identify potential gaps and the PC-GRT will be available to help provide input and suggest resolutions. . The use of the PC-GRT’s report by WECC or other entities is optional and its findings are not binding on WECC WECC is sensitive to the burden placed on industry resources and its commensurate value in terms of reliability . However, WECC’s primary duty as the Regional Entity is to comply with its obligations under the Delegations Agreement with NERC. Although there is not likely one perfect solution to resolving all reliability gaps, this effort will help WECC generate helpful information in identifying reliability gaps. We are open to input from industry on how to improve the process or to devise a mapping process that will help identify, and address reliability gaps. Western Electricity Coordinating Council


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