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SAR - Refine Applicability of NERC Standards
Related Files
Status:
The drafting team is considering comments received
from the posting of the draft SAR Version 1.
Purpose/Industry Need:
The existing reliability standards identify what functional entities are
to comply with the requirements of the standard.
There has been much concern in the industry about the
"reliability relevance" of many of the entities identified, especially
the DP, LSE, GO and GOP.
We believe that the definitions in the NERC Reliability Standards
Glossary are appropriate and that the Reliability Standards themselves
need to be more specific in terms of applicability.
As identified in the ERO application, excellent standards should
clearly identify who they are applicable to, and may include qualifying
information such as limitations on the applicability of the standard
based on electric facility characteristics, such as generators with a
nameplate rating of 20 MW or greater, or transmission facilities
energized at 200 kV or greater.
This SAR supports the action.
Each of these standards in the following list should be reviewed to
determine if the requirements really should apply to certain sizes of
entities.
For instance, perhaps a requirement should only apply to a
generating unit that is greater than 20 MVA nameplate rating.
Or, perhaps a requirement should only apply to a DP or LSE that
serves greater than 25 MW peak load.
Applicability should be more detailed within the standard
depending on what the requirements are, and we should move away from a
broad applicability by type of function.
This would be the best way to determine the reliability relevance
to the bulk power system.
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