- If a drafting team needs help in understanding tasks that comprise a function and/or in
determining which reliability model function entity is responsible
for a function/tasks, the drafting team's coordinator will send an
e-mail to the NERC staff assigned as the FMWG facilitator with a
request for clarification.
- The NERC staff assigned as the FMWG facilitator will convene a conference call/meeting of
available members of the FMWG to review the questions(s) and provide a clarification.
-
Each FMWG request for clarification and the associated response will be
posted on the NERC Functional Model Web page under a Frequently
Asked Questions Section.
The Functional
Model continues to confuse functions with organizations. What can be
done to fix this?
We reformatted the Functional Model document to distinguish between
functions, which are defined as tasks, and responsible entities, which are organizations that register with
NERC to perform the functions. Version 4 of the Functional Model
lists the tasks associated with each function separately from the
interrelationships among the responsible entities. The NERC
Reliability Standards will specify what responsible entities must do
or achieve to maintain electric system reliability.
We developed a Technical Discussion document that contains the
explanations, opinions, and discussions of the Functional Model
Working Group (FMWG) and contains examples of how functions can be
rolled up in an organization.
Is the Functional
Model a Reliability Standard?
The Model provides the foundation and framework for NERC’s
Reliability Standards, but is not a standard itself. In that regard,
it is similar to the Reliability Principles and Market Interface
Principles in NERC’s Reliability Standards Process Manual. The Model
defines the basic functions that must be performed to ensure that
the bulk electric systems are planned and operated reliably. The
Model also describes the interrelationship between the responsible
entities. However, the Model does not include compliance measures or
requirements.
A “Purpose” statement is in the Functional Model document that
further explains how the Model is used within NERC and by other
organizations that write standards and business practices, and a
“Guiding Principles” section to clearly explain the basis for the
Model.
How can the
Functional Model be revised?
The FMWG is responsible for
revisions to the Functional Model.
The FMWG reviews annually need to revise the Functional Model
based on input from NERC Standing Committees, Standards Drafting
Teams and the industry at large.
New version of the Functional Model is provided for public
review and comment, with final consideration and approval by the
standing committees.
Why doesn’t the
Functional Model mention the Regional Entities?
Because the Regional Entities are organizations, not functions. The
Regional Entities may perform some of the functions defined in the
Model. For instance, some Regional Entities perform the Reliability
Operations function (Reliability Coordinator), some the Planning
Reliability functions (Planning Coordinator), and all perform the
Compliance Enforcement (Compliance Enforcement Authority) function.
Does the Planning
Coordinator consider the Regional Council’s planning standards when
assessing the “plan?”
The Planning Coordinator assesses plans against NERC Reliability
Standards. The Planning Coordinator may also assess plans
against other industry reliability standards; however, NERC
compliance will be based on NERC Reliability Standards.
Why doesn’t the
Functional Model include the FERC-defined Transmission Provider from
Order 888?
For two reasons. First, many organizations are not
FERC-jurisdictional, and their provision of transmission services
may not align with FERC’s Transmission Provider. Second, FERC
defines the Transmission Provider as an organization, not a
function:
“The public utility (or its Designated Agent)
that owns, controls, or operates facilities used for the
transmission of electric energy in interstate commerce and provides
transmission service under the Tariff.” (from pro forma
tariff)
Thus, the FERC-defined Transmission Provider has actually “bundled”
several functions that can today be performed by separate
organizations. For instance, one can envision an organization that
owns transmission and a separate organization that operates the
transmission system. Both of these organizations could be within an
RTO that provides transmission service through its tariff.
It appears that
the revisions to the Functional Model are trying to align the Model
with the Commission’s proposed Standard Market Design and RTO
structures. Is that true?
No. The Functional Model is designed to accommodate any market
design, and does not assume any particular organization structure.
It’s designed for traditional vertically integrated utilities,
regional transmission organizations, independent system operators,
and so on.
Why are the
Transmission Owner and Transmission Operator separate functions?
Similarly, why are the Generator Owner and Generator Operator
separate functions?
Because these are separate, fundamental functions that comprise sets
of related tasks that can be performed by separate organizations.
For instance, some organizations, such as an RTO, provide the
Transmission Operations function for their members who are
individual Transmission Owners. However, other organizations have
bundled the Transmission Ownership and Transmission Operations
functions. Similarly, a Generator Owner can arrange for a Generator
Operator to operate its facilities.
Why is the
Interchange Authority’s role restricted to bilateral transactions?
Because the sole purpose of the Interchange Authority is to bring
the financial “deal” between Purchasing-Selling Entities across
Balancing Areas to physical implementation. Financial
transactions within markets are handled by the Market Operator and
do not need the services of the Interchange Authority.
Why does the model
include the Market Operator?
This function in the Functional Model recognizes that it provides
energy and capacity products in some markets. The Market Operator is
also an interconnection point between the NERC Functional Model and
models that other organizations may create as a framework for market
structures and business practices.
Is the “Generator
Operator” referred to in our standards strictly related to System
Operators or does it also includes power plant operators?
Due to the fact that a power plant operator operates
generator unit(s), should they receive the same training as that of
a system operator?
The NERC Functional Model
identifies entities with specific functions and tasks that support
the reliability of the Bulk Electric System. Several entities,
including the Generator Operator, are staffed with System Operators
in their respective control centers (i.e. Balancing Authority,
Transmission Operator, Generator Operator and Reliability
Coordinator).
This is concept supported by the NERC Glossary of
Terms with the following definitions:
“Generator Operator - The entity that operates
generating unit(s) and performs the functions of supplying energy
and Interconnected Operations Services.”
“System Operator - An individual at a control
center (Balancing Authority, Transmission Operator, Generator
Operator, Reliability Coordinator) whose responsibility it is to
monitor and control that electric system in real time.”
Power plant operators control and monitor
boilers, turbines, generators, and auxiliary equipment while the
System Operator (Generator Operator) monitors the status of the
generating facility and controls the real and reactive power (i.e.
AGC control signals) in a manner to support Interconnection
frequency the overall reliability of the Bulk Electric System.
The NERC Personnel Performance, Training and
Qualifications (PER) Standards are applicable to the Balancing
Authority, Transmission Operator and Reliability Coordinator
entities and contain specific requirements associated with the
training and qualification of System Operators responsible for the
execution of the tasks assigned to these entities (i.e. BA, TOP &
RC). The opinion of the FMWG is that the NERC PER Standards are not
applicable to the System Operators associated with the Generator
Operator entities and are therefore not applicable to power plant
operators.
