Filed with FERC: June 14, 2022
Background The NERC Inverter-based Resource Performance Task Force (IRPTF) undertook an effort to perform a comprehensive review of all NERC Reliability Standards to determine if there were any potential gaps or improvements based on the work and findings of the IRPTF. The IRPTF identified several issues as part of this effort and documented its findings and recommendations in a white paper. The “IRPTF Review of NERC Reliability Standards White Paper" was approved by the Operating Committee and the Planning Committee in March 2020. Among the findings noted in the white paper, the IRPTF identified issues with FAC-001-3 and FAC-002-2 that should be addressed.
Standard(s) Affected – FAC-001-3 and FAC-002-3
Purpose/Industry Need FAC-001-3 and FAC-002-3 imply that the term “materially modified" should be used to distinguish between facility changes that are required to be studied and those that need not be studied. While the existing standards do require coordination and cooperation between a Facility owner and the Transmission Planner or Planning Coordinator when a new or materially modified interconnection Facility is connected to their system, neither standard specifies what entity is responsible for determining what is considered to be a material modification. Further, the existing language is unclear about whether these requirements only apply when a different entity is proposing to interconnect to a Facility owner's Facility or if they also apply to the Facility owner's new or modified Facility.
Additionally, in FERC-jurisdictional areas, the term “Materially Modification" refers to a new generation project's impact on other generators in the interconnection queue. This has led to widespread confusion across the industry regarding the correct application of these terms related to the FERC Open Access Transmission Tariff (OATT) implementation and the NERC Reliability Standards requirements. The application of these terms is different between the FERC process and the NERC Reliability Standards (specifically FAC-001-3 and FAC-002-3). This project will modify FAC-001-3 and FAC-002-3 to clarify the use of “materially modifying", particularly as it relates to compliance with the standards.
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