IPWG: BPM and Tariff redlines for FAC-002-4 revision (20230808)

1.  FAC-002-4 R6 states: Each PC shall maintain a publicly available definition of qualified change for the purposes of facility interconnection.

Spreading the Qualified Change definition across multiple 100-plus page documents may meet the definition of publicly available, but is not user friendly.   No clear guidance on whether the definition Is located.   TPs, TOs, GOs and DPs need to know where the definition is located. MISO is recommended to:

ü  Provide a Compliance FAQ that precisely describes the location of the definition.

ü  Provide a summary document listing the definition on the PSC web page.

1.  The NERC staff and SDT developed an Implementation Guidance document with the balloting of FAC-002-4.  This document illustrated different types of categories of Qualified Changes and how threshold can be established for triggering the need to assess the Qualified Change.  This document was considered in the approval of this standard by NERC staff and FERC.    The MISO definition has little resemblance to the Implementation Guidance document, both in categories and thresholds.    Why did MISO not follow this guidance?

1. Qualified Change definition will be used by both PC and TP in assessing the reliability of the BES under FAC-002-4 R1.  The PC and TP will be required to have FAC-002-4 R1 evidence of assessing every Qualified Change against the subparts of R1.   The assessment may range from an in-depth study or passing professional judgment of no reliability impact.   Nonetheless evidence is needed for each Qualified Change.

 It is unclear whether the Qualified Change is a process to categorize every minute change as a Qualified Change or is the input to the process the qualified change.

Some examples:

Attachment X - Qualified Change shall mean a planned modification to an Existing Generating Facility that is undergoing evaluation for a Generating Facility Qualified Change or Generating Facility Replacement, and has a material adverse impact on the Transmission System.

It is ambiguous whether the Qualified Change is the planned modification or modification after evaluation against unknown adverse impact criteria.

BPM 015 - The following criteria will be used to determine whether the change to an Existing Generating Facility is a substantive change and/or Qualified Change:  An increase in short circuit current that degrades transmission system reliability.  

It is ambiguous whether the Qualified Change is the change in short circuit current or after evaluation against unknown transmission system reliability degradation criteria.  The change in short circuit will be a tremendous compliance burden.  Every change of one amp will be a Qualified Change or have evidence that it is not.   The small changes may be assessed with professional judgment, but must be documented for FAC-002-4 R1 compliance evidence.    MISO needs to establish thresholds of change for Qualified Change.

Peg Abbadini on behalf of Glencoe Light & Power

There is inconsistency between the proposed Attachment X GIP redlines and the proposed BPM-015 language to incorporate Qualified Change.  The Attachment X definition of  Generating Facility Qualified Change includes any modification to an Existing Generation Facility regardless of the impact of the change to the transmission system.  The Attachment X definition of Qualified Change includes any modification of an Existing Generating Facility AND has a material adverse impact on the Transmission System.  The two definitions are inconsistent with one another.

To further complicate matters, section 6.7 of the BPM refers to a Generating Facility Change as any change to an Existing Generartor Facility and further classifies that a change that results in a material adverse impact to the transmision system shall submit a request for Qualified Change evaluation.  It is difficult where in the process a change is considered a Qualified Change.  It is possible that a Qualified Change request and subsequent evaluation determines no material adverse impact to the transmission system.  By definition in Attachment X, the change is no longer "Qualfied" because it has not material adverse impact.

WEC Energy Group recommends maintaining the current definition of Generating Facility Modification, redefining Qualified Change as a Generating Facility Modification that has a material adverse impact on the transmission system, and re-writing section 6.7 of the BPM to maintain consistency with those defintions.

FAC-002-4 R6 states: Each PC shall maintain a publicly available definition of qualified change for the purposes of facility interconnection.

Spreading the Qualified Change definition across multiple 100-plus page documents may meet the definition of publicly available, but is not user friendly.   No clear guidance on whether the definition Is located.   TPs, TOs, GOs and DPs need to know where the definition is located. MISO is recommended to:

• Provide a Compliance FAQ that precisely describes the location of the definition.
• Provide a summary document listing the definition on the PSC web page.

1. Qualified Change definition will be used by both PC and TP in assessing the reliability of the BES under FAC-002-4 R1.  The PC and TP will be required to have FAC-002-4 R1 evidence of assessing every Qualified Change against the subparts of R1.   The assessment may range from  an in-depth study or passing professional judgment of no reliability impact.   Nonetheless evidence is needed for each Qualified Change.

 It is unclear whether the Qualified Change  is a process to categorize every minute change as a Qualified Change or is the input to the process the qualified change.

Some examples:

Attachment X  Qualified Change shall mean a planned modification to an Existing Generating Facility that is undergoing evaluation for a Generating Facility Qualified Change or Generating Facility Replacement, and has a material adverse impact on the Transmission System

It is ambiguous whether the Qualified Change is the planned modification or modification after evaluation against unknown adverse impact criteria.

BPM 015  The following criteria will be used to determine whether the change to an Existing Generating Facility is a substantive change and/or Qualified Change:  An increase in short circuit current that degrades transmission system reliability.  

It is ambiguous whether the Qualified Change is the change in short circuit current or after evaluation against unknown transmission system reliability degradation criteria.  The change in short circuit will be a tremendous compliance burden.  Every change of one amp will be a Qualified Change or have evidence that it is not.   The small changes may be assessed with professional judgment, but must be documented for FAC-002-4 R1 compliance evidence.    MISO needs to establish thresholds of change for Qualified Change.