PSC: BPM20 NERC FAC-002-4 Revision Proposal (20230809)

Transmission Owner feedback on BPM-020 NERC FAC-002-4 Revision Proposal

During the August 9, 2023, Planning Subcommittee (PSC) meeting, MISO proposed BPM20 language to define qualified change for transmission and electricity end-user facilities interconnection. Stakeholders were asked to provide feedback on the proposed language, and the Owners provide the comments below for MISO’s consideration..

MISO’s Proposed addition to BPM -020 Section 4.2.3 – All transmission voltage Projects with the following criteria must be reported to the [MTEP] Project Database:

Existing interconnections of transmission facilities or electricity end-user facilities seeking to make a qualified change on the transmission system as defined as: i) transmission system topology change; ii) protection configuration change that could impact contingency performance, short circuit, or dynamic performance; iii) change the electrical characteristics of a circuit.

In the related presentation to the PSC, MISO explained that “the project reporting guidelines defined in section 4.2.3 of BPM20 can be used as the “qualified change” required in the new FAC-002 R6 as these guidelines are applied to all projects evaluated in MTEP”.

The Owners have the following suggestions.

(1)   The Owners would like to see more definition of terms above, such as “electrical characteristics”.

(2)   The Owners would like to see detail about the facility cost minimums triggering a FAC-002 study.

(3)   The Owners believe the existing language, as shown below, sufficiently covers the projects needing to be reported to MISO. 

4.2.3 Project Reporting Guidelines (current language)

• Members who are Transmission Owner(s) are required to report projects developed in their local planning processes and that have an expected in-service date within the MTEP planning horizon. Projects with in-service dates beyond the MTEP planning horizon and up to 10 years from the current year may be submitted for MISO review and tentative inclusion in the MTEP. All transmission voltage Projects with the following criteria must be reported to the Project Database:
• All projects that represent a system topology change (i.e., constructing a new circuit, tapping an existing circuit, removing a circuit from the planning model, or retiring a circuit). All projects that include interconnecting new distribution service from new or existing transmission facilities must report distribution sub taps.
• All new circuit breaker additions to transmission facilities.
• All upgraded circuit breakers that result in changes to a breaker’s continuous current-carrying or interrupting capacity.
• All projects that change the electrical characteristics of a circuit (i.e., changes to shunt or series inductors, capacitors, conductor type or performance, switches, current transformers, or wave traps).
• All projects involving like-for-like replacements with direct costs of $1 million or more.
• All projects that change a circuit rating.
• Generator interconnection projects with signed Interconnection Agreements (provided by MISO planning staff) and Network Upgrades associated with conditionally confirmed transmission service requests (TDSP).
• Members are encouraged (but are not required) to report projects that consist of like-for-like replacements costing less than $1 million, or projects that improve Transmission System operational performance such as SCADA systems, communications, or relaying upgrades.

WEC Energy Group is concerned that the proposed BPM language fails to define Qualified Change for transmission and electricity end-user facility interconnections.  Additionally, the it appears "qualified change" includes any "change the electrical characteristics of a circuit."  We believe that this is overly broad and inappropriate.  For example, if a change is made to the distribution system, this could be viewed as a change in the electrical characteristics of the transmission circuit(s) connected to that distribution system.  We recommend that the BPM-020 inclusion of Qualified Change consider language similar to that within BPM-015, wherby a transmission interconnection or electric end-user interconnection change that has a material adverse impact on the transmission system is considered Qualified.

MRES does not believe the language for a FAC-002 qualified change  should be added to Section 4.2.3 as the there are MTEP reporting requirements that wouldn't necessarily apply to FAC-002. For example like for like projects over $ 1 M dollars are in Section 4.2.3 but this would be neither a new or modified Facility and therefore would not be applicable to FAC-002. Also, in this section there are references to SCADA or communications changes which are not related to new or modified Facility. In addition, the new proposed language is largely redundant to existing language such as topology change, protection change, or changing electrical characteristics.

MRES believes the FAC-002 language should be its own section. MRES has the following changes to the proposed language. 

ii) Inserted the word negatively as it would not make sense to perform a study for improvements such as if clearing time was improved for fault clearing or if a P5 contingency was eliminated by adding redundant equipment. 

iii) Strike this language as it is too vague and could bring in too many scenarios such as jumper replacements, CTs, wave trap, switches, etc. FAC-002 studies should not be necessary for changes like those.

FAC-002 Language

Existing interconnections of transmission facilities or electricity end-user facilities seeking to make a qualified change on the transmission system as defined as: i) transmission system topology change; ii) protection configuration change that could negatively impact contingency performance, short circuit, or dynamic performance; iii) change the electrical characteristics of a circuit.

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.

BPM 020 - Existing interconnections of transmission facilities or electricity end-user facilities seeking to make a qualified change on the transmission system as defined as: i) transmission system topology change; ii) protection configuration change that could impact contingency performance, short circuit, or dynamic performance; iii) change the electrical characteristics of a circuit

It is ambiguous whether the Qualified Change is the protection configuration change or modification after evaluation against unknown contingency performance, short circuit, or dynamic performance.

The change the electrical characteristics of a circuit will be a tremendous compliance burden.  Every rating of one amp, either up or down will be a Qualified Change.   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

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.

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.

A example:

BPM 020  Existing interconnections of transmission facilities or electricity end-user facilities seeking to make a qualified change on  the transmission system as defined as: i) transmission system topology change; ii) protection configuration change that could impact contingency performance, short circuit, or dynamic performance; iii) change the electrical characteristics of a circuit

It is ambiguous whether the Qualified Change is the protection configuration change or modification after evaluation against unknown contingency performance, short circuit, or dynamic performance.

The change the electrical characteristics of a circuit will be a tremendous compliance burden.  Every rating of one amp, either up or down will be a Qualified Change.   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.