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Ballot Results
Ballot Name: Projectd 2007-03 Recirculation TOP-003-2 April 2012_in
Ballot Period: 4/27/2012 - 5/6/2012
Ballot Type: Initial
Total # Votes: 296
Total Ballot Pool: 373
Quorum: 79.36 %  The Quorum has been reached
Weighted Segment Vote:

80.79 %

Ballot Results: The ballot has closed
Summary of Ballot Results
Segment Ballot
Pool
Segment
Weight
Affirmative Negative No
Vote
# Votes Fraction # Votes Fraction Negative Vote
without a Comment
Abstain
          
1 - Segment 1103 1 56 0.8 14 0.2 0528
2 - Segment 211 0.9 9 0.9 0 0 002
3 - Segment 382 1 56 0.862 9 0.138 0314
4 - Segment 427 1 15 0.682 7 0.318 005
5 - Segment 582 1 43 0.741 15 0.259 0816
6 - Segment 647 1 27 0.794 7 0.206 0310
7 - Segment 70 0 0 0 0 0 000
8 - Segment 88 0.5 4 0.4 1 0.1 012
9 - Segment 94 0.3 3 0.3 0 0 010
10 - Segment 109 0.7 5 0.5 2 0.2 020
Totals3737.42185.979551.42102377
Individual Ballot Pool Results
Segment Organization Member Ballot NERC Notes
     
1Ameren ServicesKirit Shah Affirmative
1American Electric PowerPaul B. Johnson Negative Comments are being submitted via electronic form by Thad Ness on behalf of American Electric Power.
1American Transmission Company, LLCAndrew Z Pusztai Affirmative Comments submitted.
1Arizona Public Service Co.Robert Smith Affirmative
1Associated Electric Cooperative, Inc.John Bussman Affirmative
1Avista Corp.Scott J Kinney Affirmative
1Balancing Authority of Northern CaliforniaKevin Smith Affirmative
1Baltimore Gas & Electric CompanyGregory S Miller Abstain
1BC Hydro and Power AuthorityPatricia Robertson Affirmative
1Beaches Energy ServicesJoseph S Stonecipher Negative
1Black Hills CorpEric Egge
1Bonneville Power AdministrationDonald S. Watkins Affirmative
1Brazos Electric Power Cooperative, Inc.Tony Kroskey Negative Additional clarification is necessary that warrants our negative vote. See the issues raised in the comments by ACES Power Marketing.
1CenterPoint Energy Houston ElectricDale Bodden
1Central Maine Power CompanyKevin L Howes
1City of Tacoma, Department of Public Utilities, Light Division, dba Tacoma PowerChang G Choi Affirmative If a Transmission Operator or a Balancing Authority is requesting data from another entity, they must demonstrate a reliability impact validating the need for the requested data.
1City of Vero BeachRandall McCamish
1Clark Public UtilitiesJack Stamper Affirmative
1Cleco Power LLCDanny McDaniel Affirmative
1Colorado Springs UtilitiesPaul Morland Abstain
1Consolidated Edison Co. of New YorkChristopher L de Graffenried Affirmative See NPCC group comments
1Dairyland Power Coop.Robert W. Roddy Abstain
1Dayton Power & Light Co.Hertzel Shamash
1Dominion Virginia PowerMichael S Crowley Affirmative
1Duke Energy CarolinaDouglas E. Hils Affirmative Comments submitted.
1East Kentucky Power Coop.George S. Carruba Negative The standard as proposed does not appear to comply with the stated intent of Project 2007-03, that being: “The industry needs clearer, unambiguous and enforceable standards in order to effectively operate the Bulk Electric System.” Not only are the changes to TOP-003 as vague—or ambiguous--if not more so than the previous TOP-003-1 standard, the requirements do not provide for any consistency between companies. For example, who between two parties determines, or in the case of an inability to reach agreement, who is responsible for arbitrating an agreement when two neighboring entities are attempting to establish a “mutually agreeable format”. Resolution could be problematic when required changes to a format between entities A and B would require format changes between entities A and C, A and D, and A and E, and would potentially require entity A to maintain several different format standards to meet the requirements for coordination between entities B, C, D, and E. Many items previously in TOP-003-1 appear to have been completely abandoned in lieu of much less prescriptive specifications in TOP-003-2. For example, clear provisions regarding timing of data availability listed in TOP-003-1 are not specified in any form in TOP-003-2 other than to require that entities needing to share data essentially “work it out amongst themselves”. The standard needs to better guide entities in regard to the type of data—at a minimum—they SHOULD be requesting and obtaining. Alternately, such format specifications should be left to the authority of the RC to coordinate among TO/BA entities for which they are responsible.
1Empire District Electric Co.Ralph F Meyer Affirmative
1Entergy Services, Inc.Edward J Davis Affirmative
1FirstEnergy Energy DeliveryRobert Martinko Affirmative FE appreciates the hard work of the standards drafting team. Please see additional comments and suggestions submitted through the formal comment period.
1Florida Keys Electric Cooperative Assoc.Dennis Minton
1Gainesville Regional UtilitiesLuther E. Fair
1Georgia Transmission CorporationHarold Taylor Affirmative
1Grand River Dam AuthorityJames M Stafford Abstain
1Great River EnergyGordon Pietsch Affirmative Great River Energy agrees with the comments of the MRO NSRF
1Hoosier Energy Rural Electric Cooperative, Inc.Bob Solomon
1Hydro One Networks, Inc.Ajay Garg Affirmative
1Hydro-Quebec TransEnergieBernard Pelletier Affirmative
1Idaho Power CompanyRonald D. Schellberg Affirmative
1Imperial Irrigation DistrictTino Zaragoza Affirmative
1International Transmission Company Holdings CorpMichael Moltane Affirmative
1JEATed Hobson Affirmative
1Kansas City Power & Light Co.Michael Gammon Negative Comments and concerns with the proposed standards have been expressed within the NERC comment form.
1Keys Energy ServicesStanley T Rzad
1Lake Worth UtilitiesWalt J Gill
1Lakeland ElectricLarry E Watt
1Lee County Electric CooperativeJohn W Delucca Affirmative
1Lincoln Electric SystemDoug Bantam
1Lone Star Transmission, LLCJulius Horvath
1Long Island Power AuthorityRobert Ganley Abstain
1Los Angeles Department of Water & PowerLy M Le
1Lower Colorado River AuthorityMartyn Turner Affirmative
1Manitoba Hydro Joe D Petaski Affirmative Please see comments submitted electronically.
1MEAG PowerDanny Dees Affirmative
1MidAmerican Energy Co.Terry Harbour Negative
1Minnkota Power Coop. Inc.Richard Burt
1Muscatine Power & WaterTim Reed
1National GridSaurabh Saksena
1New Brunswick Power Transmission CorporationRandy MacDonald Affirmative
1New York Power AuthorityArnold J. Schuff Affirmative
1New York State Electric & Gas Corp.Raymond P Kinney
1Northeast UtilitiesDavid Boguslawski Affirmative
1Northern Indiana Public Service Co.Kevin M Largura Affirmative
1NorthWestern EnergyJohn Canavan Negative
1Ohio Valley Electric Corp.Robert Mattey Negative
1Oklahoma Gas and Electric Co.Marvin E VanBebber Negative
1Omaha Public Power DistrictDoug Peterchuck Negative OPPD supports MRO and SPP RTO comments.
1Oncor Electric DeliveryBrenda Pulis Affirmative
1Pacific Gas and Electric CompanyBangalore Vijayraghavan
1PacifiCorpColt Norrish
1PECO EnergyRonald Schloendorn Affirmative
1Platte River Power AuthorityJohn C. Collins Affirmative
1Portland General Electric Co.Frank F Afranji Affirmative
1Potomac Electric Power Co.David Thorne Affirmative
1PowerSouth Energy CooperativeLarry D Avery Affirmative
1PPL Electric Utilities Corp.Brenda L Truhe Affirmative
1Progress Energy CarolinasSammy Roberts Affirmative
1Public Service Company of New MexicoLaurie Williams Affirmative
1Public Service Electric and Gas Co.Kenneth D. Brown Affirmative
1Public Utility District No. 1 of Chelan CountyChad Bowman
1Public Utility District No. 1 of Okanogan CountyDale Dunckel Affirmative
1Puget Sound Energy, Inc.Denise M Lietz Affirmative
1Raj RanaRajendrasinh D Rana
1Rochester Gas and Electric Corp.John C. Allen Affirmative
1Sacramento Municipal Utility DistrictTim Kelley Affirmative
1Salt River ProjectRobert Kondziolka Affirmative
1Santee CooperTerry L Blackwell Negative The implementation date should be at least twelve months to be consistent with TOP-001-2 and TOP-002-3. What was the rationale of reducing the implementation time from twenty-four months to ten months?
1SCE&GHenry Delk, Jr.
1Seattle City LightPawel Krupa Negative 3. The SDT made changes to TOP-003-2 in response to industry comments and the Quality Review. This includes all aspects of this standard – requirements, measures, and data retention. Do you agree with the changes the drafting team has made? If you do not support these changes or you agree in general but feel that alternative language would be more appropriate, please provide specific suggestions in your comments. 1 No Comments: While the idea of making each BA and TOP formally outline a data specification for all the information it needs to perform its Operational Planning Analysis is a worthy concept, the requirements in this Standard for evidence and data retention are onerous. Specifically the requirement to retain all electronic or hard copies of data transmittals or retain attestations from all receiving entities would require a tremendous amount of resources to be compliant. It may also be technically impossible to comply with these requirements because the data specifications developed individually by each entity may not be compatible with each other. The formats and periodicity of data collected by each entity may not be compatible with the specifications and it could be impossible to comply with these requests without major changes to the infrastructure. As an alternative, most of the NERC registered entities are currently required to provide that data to their Reliability Coordinators (RC) using the specifications already developed by the RCs and that data could be used by the TOPs and BAs to perform their functions. 4. The SDT is suggesting the retirement of three requirements in PRC-001 since those requirements deal with data handling and can now be incorporated in the data specification concept suggested for TOP-003-2. Do you agree with the changes the drafting team has made? If you do not support these changes or you agree in general but feel that alternative language would be more appropriate, please provide specific suggestions in your comments. 1 Yes 6. If you have any other comments on these standards that you have not already provided in response to the prior questions, please provide them here. Comments: Seattle City Light supports the efforts of the Real Time Operations Standards Drafting Team and approves of the direction proposed in these new TOP Standards. TOP-001 in particular clarifies the definition of Reliability Directive and provides straightforward requirements for reporting outages of relay and communication equipment. We are prepared to vote “affirmative” for all of the new TOP Standards of Project 2007-03 once details as discussed above are addressed and resolved.
1Sierra Pacific Power Co.Rich Salgo Negative
1South Texas Electric CooperativeRichard McLeon
1Southern California Edison Co.Dana Cabbell
1Southern Company Services, Inc.Robert A. Schaffeld Affirmative
1Southern Illinois Power Coop.William Hutchison Affirmative
1Southwest Transmission Cooperative, Inc.James Jones Affirmative Generally, we agree with the standard. However, we have one concern regarding the Data Retention section. The third bullet compels the Transmission Operator to retain evidence for three calendar years that it distributed its data specification. Because the data needs do not change frequently, it is possible that the Transmission Operator will have periods greater than three years in which the data specification was not updated and, thus, not communicated. What data and information would the Transmission Operator use to demonstrate compliance in this situation? Would an attestation be appropriate? If so, the measure should be updated to reflect this. All of the responses to comments regarding concerns of Requirement R5 indicate that the SDT intended for Requirement R5 to apply to the general satisfaction of the data specification and not any specific data points. However, the Data Retention section does not support this view point. It requires retention of 90 days worth of data. Normally, short periods of data are retained when they are expected to be voluminous. Thus, we assume the Data Retention section was anticipating that the actual data supplied would be retained. This seems inconsistent with the concept of generally satisfying the data specification. It would make more sense to have a statement from the Transmission Operator indicating the data specification has been satisfied or documentation of the enabling of data links to demonstrate general satisfaction of the data requirements. Under the Compliance Enforcement Authority section, we suggest “entities” in the first bullet and “functional entities” in the second bullet should be changed to “registered entities”. This will make them consistent with one another and the function model. The “Reliability Functional Model Technical Document” describes a functional entity not as a specific company but rather a specific part of the functional model such as a Balancing Authority. Registered entities are specific companies. For example, SPP is a registered entity that works for their Regional Entity as the Reliability Coordinator functional entity.
1Sunflower Electric Power CorporationNoman Lee Williams
1Tampa Electric Co.Beth Young
1Tennessee Valley AuthorityLarry Akens Affirmative
1Tri-State G & T Association, Inc.Tracy Sliman Affirmative
1Tucson Electric Power Co.John Tolo
1United Illuminating Co.Jonathan Appelbaum Affirmative
1Westar EnergyAllen Klassen Negative SDT has not adequately addressed previous comments.
1Western Area Power AdministrationBrandy A Dunn Affirmative
1Xcel Energy, Inc.Gregory L Pieper Affirmative
2Alberta Electric System OperatorMark B Thompson Affirmative
2BC HydroVenkataramakrishnan Vinnakota Affirmative
2California ISORich Vine Affirmative
2Electric Reliability Council of Texas, Inc.Charles B Manning Affirmative ERCOT supports the SDT’s modifications.
2Independent Electricity System OperatorKim Warren
2ISO New England, Inc.Kathleen Goodman Affirmative
2Midwest ISO, Inc.Marie Knox
2New Brunswick System OperatorAlden Briggs Affirmative
2New York Independent System OperatorGregory Campoli Affirmative Comments have been provided
2PJM Interconnection, L.L.C.Tom Bowe Affirmative
2Southwest Power Pool, Inc.Charles H. Yeung Affirmative We continue to disagree with the successive ballot process that forces entities to decide on a voting position concurrent with the submittal of comments on the same. NERC needs to explore other ways to expedite the voting/comment process without forcing industry to have faith that changes will be made after approval. Although SPP votes in favor of this standard, we have outstanding comments that should be addressed. We have submittted them in the standards processs and reiterate some of them here. The Purpose Statement is too general and does not provide any direction of how the proposed standard will meet its stated intent. As written the Purpose Statement is applicable to any NERC standard that exists or can be imagined. We suggest additional wording of how this particular standard intends to do what it intends to is needed. For example, "...through requiring all operating parties who need to take action have the knowledge and obligation to do so." Deleting the requirements from PRC-001 and including them in R1 and R2 of TOP-003-2 raises the question of what other types of data or information need to be included in the specification that do not normally come to mind when considering this type of information. To be sure that all the bases are covered, we would suggest that the SDT provide a guideline which incorporates the types of data and information they envisioned when drafting these requirements. Additionally, incorporating protective relay information in the data specifications of R1 and R2 raises the potential for auditors to question the contents of an entity’s specification. Again, guidance is needed on the part of the TOP and BA in developing the specification initially. Could the SDT provide this initial guidance, or list of examples, in the form of a guideline? We have concerns with R1 and R2 being as open-ended as they are, especially since they are followed by the obligation to provide that data contained in R5. For example, how do you resolve issues when a mutual agreement cannot be reached? If an entity feels that the requestor is asking for data that goes beyond what they would reasonably need to perform their analysis, what process is used to resolve the stand-off?
3Alabama Power CompanyRichard J. Mandes Affirmative
3Ameren ServicesMark Peters Affirmative
3APSSteven Norris Affirmative
3Atlantic City Electric CompanyNICOLE BUCKMAN Affirmative
3Avista Corp.Robert Lafferty Affirmative
3BC Hydro and Power AuthorityPat G. Harrington Affirmative
3Bonneville Power AdministrationRebecca Berdahl Affirmative
3Central Lincoln PUDSteve Alexanderson Affirmative
3City of Austin dba Austin EnergyAndrew Gallo Affirmative
3City of FarmingtonLinda R Jacobson Affirmative
3City of GarlandRonnie C Hoeinghaus Negative The requirements should be written such that they will support VSL levels of Lower, Moderate, and High - not Severe only for R5. It should take minimal requirement sentence strucuring to allow for all VSL levels to be assigned
3City of Green Cove SpringsGregg R Griffin
3City of ReddingBill Hughes Affirmative
3City Water, Light & Power of SpringfieldRoger Powers
3Clatskanie People's Utility DistrictBrian Fawcett
3Cleco CorporationMichelle A Corley Affirmative
3Colorado Springs UtilitiesLisa Cleary
3ComEdBruce Krawczyk Affirmative Voted
3Consolidated Edison Co. of New YorkPeter T Yost Affirmative See NPCC group comments
3Constellation EnergyCJ Ingersoll Abstain
3Consumers Energy David A. Lapinski Negative
3Cowlitz County PUDRussell A Noble Negative Comment submitted.
3CPS EnergyJose Escamilla Affirmative
3Delmarva Power & Light Co.Michael R. Mayer Affirmative
3Detroit Edison CompanyKent Kujala Affirmative
3Dominion Resources ServicesMichael F. Gildea Affirmative
3Duke Energy CarolinaHenry Ernst-Jr Affirmative comments submitted
3East Kentucky Power Coop.Sally Witt
3EntergyJoel T Plessinger Affirmative
3FirstEnergy SolutionsKevin Querry Affirmative FE appreciates the hard work of the standards drafting team. Please see additional comments and suggestions submitted through the formal comment period.
3Florida Power and Light / NextEra EnergyChantel Haswell
3Florida Power CorporationLee Schuster Affirmative
3Gainesville Regional UtilitiesKenneth Simmons Abstain
3Georgia Power CompanyAnthony L Wilson Affirmative
3Georgia Systems Operations CorporationWilliam N. Phinney Affirmative
3Grays Harbor PUDWesley W Gray Affirmative
3Great River EnergySam Kokkinen Affirmative Great River Energy agrees with the comments of the MRO NSRF.
3Gulf Power CompanyPaul C Caldwell Affirmative
3Hydro One Networks, Inc.David Kiguel Affirmative
3Imperial Irrigation DistrictJesus S. Alcaraz Affirmative
3JEAGarry Baker Affirmative
3Kansas City Power & Light Co.Charles Locke Negative Comments and concerns with the proposed standards have been expressed within the NERC comment form.
3Kissimmee Utility AuthorityGregory D Woessner Negative
3Lakeland ElectricMace D Hunter
3Lincoln Electric SystemBruce Merrill
3Louisville Gas and Electric Co.Charles A. Freibert Affirmative LG&E and KU Services LLC is concerned that the first paragraph is being added to Section 1.3 Data Retention on all four Standards. This language is unnecessary as it is already included in the NERC Rules of Procedure, Appendix 4C, Section 3.1.4.2. Adding redundant boilerplate language to Standards is counterproductive to the goal of NERC to improve the efficiency of the Standards Development Process. The title of Section 1.3 is also not consistent with similar sections in Project 2007-09, which have been changed from “Data Retention” to “Evidence Retention.” In PRC-001-2, Section 1.2 Compliance Monitoring and Reset Time Frame is also inconsistent with the other proposed Standards in Project 2007-03 that include Section 1.2 Compliance Monitoring and Enforcement Processes. LG&E and KU Services LLC suggests not adding the boilerplate language, standardizing the Section titles, and adding consistency to Section 1.2 information."
3Manitoba Hydro Greg C. Parent Affirmative Please see comments submitted by Joe Petaski (Manitoba Hydro)
3MidAmerican Energy Co.Thomas C. Mielnik Negative
3Mississippi PowerDon Horsley Affirmative See comments submitted via the electronic comments form by Antonio Grayson.
3Municipal Electric Authority of Georgia Steven M. Jackson Affirmative
3Muscatine Power & WaterJohn S Bos Negative Please see comments submitted by the MRO NSRF
3Nebraska Public Power DistrictTony Eddleman Affirmative NPPD joins comments submitted by the Southwest Power Pool (SPP).
3New York Power AuthorityMarilyn Brown Affirmative
3Niagara Mohawk (National Grid Company)Michael Schiavone Affirmative
3Northern Indiana Public Service Co.William SeDoris Affirmative
3Omaha Public Power DistrictBlaine R. Dinwiddie
3Orange and Rockland Utilities, Inc.David Burke Affirmative
3Orlando Utilities CommissionBallard K Mutters Affirmative
3Owensboro Municipal UtilitiesThomas T Lyons Affirmative
3Pacific Gas and Electric CompanyJohn H Hagen Affirmative
3PacifiCorpJohn Apperson
3Platte River Power AuthorityTerry L Baker Affirmative
3Potomac Electric Power Co.Robert Reuter Affirmative
3Progress Energy CarolinasSam Waters Affirmative
3Public Service Electric and Gas Co.Jeffrey Mueller Affirmative
3Public Utility District No. 1 of Chelan CountyKenneth R. Johnson
3Public Utility District No. 2 of Grant CountyGreg Lange
3Puget Sound Energy, Inc.Erin Apperson Affirmative
3Rutherford EMCThomas M Haire Affirmative
3Sacramento Municipal Utility DistrictJames Leigh-Kendall Affirmative
3Salt River ProjectJohn T. Underhill Affirmative
3Santee CooperJames M Poston Negative
3Seattle City LightDana Wheelock Negative 3. The SDT made changes to TOP-003-2 in response to industry comments and the Quality Review. This includes all aspects of this standard – requirements, measures, and data retention. Do you agree with the changes the drafting team has made? If you do not support these changes or you agree in general but feel that alternative language would be more appropriate, please provide specific suggestions in your comments. 1 No Comments: While the idea of making each BA and TOP formally outline a data specification for all the information it needs to perform its Operational Planning Analysis is a worthy concept, the requirements in this Standard for evidence and data retention are onerous. Specifically the requirement to retain all electronic or hard copies of data transmittals or retain attestations from all receiving entities would require a tremendous amount of resources to be compliant. It may also be technically impossible to comply with these requirements because the data specifications developed individually by each entity may not be compatible with each other. The formats and periodicity of data collected by each entity may not be compatible with the specifications and it could be impossible to comply with these requests without major changes to the infrastructure. As an alternative, most of the NERC registered entities are currently required to provide that data to their Reliability Coordinators (RC) using the specifications already developed by the RCs and that data could be used by the TOPs and BAs to perform their functions. 4. The SDT is suggesting the retirement of three requirements in PRC-001 since those requirements deal with data handling and can now be incorporated in the data specification concept suggested for TOP-003-2. Do you agree with the changes the drafting team has made? If you do not support these changes or you agree in general but feel that alternative language would be more appropriate, please provide specific suggestions in your comments. 1 Yes 6. If you have any other comments on these standards that you have not already provided in response to the prior questions, please provide them here. Comments: Seattle City Light supports the efforts of the Real Time Operations Standards Drafting Team and approves of the direction proposed in these new TOP Standards. TOP-001 in particular clarifies the definition of Reliability Directive and provides straightforward requirements for reporting outages of relay and communication equipment. We are prepared to vote “affirmative” for all of the new TOP Standards of Project 2007-03 once details as discussed above are addressed and resolved.
3Seminole Electric Cooperative, Inc.James R Frauen Affirmative
3South Carolina Electric & Gas Co.Hubert C Young Abstain
3Southern California Edison Co.David Schiada
3Tacoma Public UtilitiesTravis Metcalfe Affirmative If a Transmission Operator or a Balancing Authority is requesting data from another entity, they must demonstrate a reliability impact validating the need for the requested data.
3Tampa Electric Co.Ronald L Donahey
3Tennessee Valley AuthorityIan S Grant Affirmative
3Tri-State G & T Association, Inc.Janelle Marriott Affirmative
3Wisconsin Electric Power MarketingJames R Keller Affirmative
3Xcel Energy, Inc.Michael Ibold Affirmative
4Alliant Energy Corp. Services, Inc.Kenneth Goldsmith Affirmative
4American Municipal PowerKevin Koloini Affirmative
4Blue Ridge Power AgencyDuane S Dahlquist Affirmative
4Central Lincoln PUDShamus J Gamache Affirmative
4City of New Smyrna Beach Utilities CommissionTim Beyrle Negative
4City of ReddingNicholas Zettel Affirmative
4City Utilities of Springfield, MissouriJohn Allen Negative City Utilities of Springfield, MO supports the comments from SPP.
4Consumers Energy David Frank Ronk Negative
4Cowlitz County PUDRick Syring Negative Comment submitted.
4Detroit Edison CompanyDaniel Herring
4Florida Municipal Power AgencyFrank Gaffney Negative Please see FMPA comments submitted separately.
4Fort Pierce Utilities AuthorityThomas W. Richards
4Georgia System Operations CorporationGuy Andrews Affirmative
4Illinois Municipal Electric AgencyBob C. Thomas Affirmative
4Imperial Irrigation DistrictDiana U Torres Affirmative
4LaGenRichard Comeaux Negative
4Madison Gas and Electric Co.Joseph DePoorter Affirmative
4Ohio Edison CompanyDouglas Hohlbaugh Affirmative FE appreciates the hard work of the standards drafting team. Please see additional comments and suggestions submitted through the formal comment period.
4Oklahoma Municipal Power AuthorityTerri Pyle
4Public Utility District No. 1 of Douglas CountyHenry E. LuBean Affirmative
4Public Utility District No. 1 of Snohomish CountyJohn D Martinsen Affirmative
4Sacramento Municipal Utility DistrictMike Ramirez Affirmative
4Seattle City LightHao Li Negative 3. The SDT made changes to TOP-003-2 in response to industry comments and the Quality Review. This includes all aspects of this standard – requirements, measures, and data retention. Do you agree with the changes the drafting team has made? If you do not support these changes or you agree in general but feel that alternative language would be more appropriate, please provide specific suggestions in your comments. 1 No Comments: While the idea of making each BA and TOP formally outline a data specification for all the information it needs to perform its Operational Planning Analysis is a worthy concept, the requirements in this Standard for evidence and data retention are onerous. Specifically the requirement to retain all electronic or hard copies of data transmittals or retain attestations from all receiving entities would require a tremendous amount of resources to be compliant. It may also be technically impossible to comply with these requirements because the data specifications developed individually by each entity may not be compatible with each other. The formats and periodicity of data collected by each entity may not be compatible with the specifications and it could be impossible to comply with these requests without major changes to the infrastructure. As an alternative, most of the NERC registered entities are currently required to provide that data to their Reliability Coordinators (RC) using the specifications already developed by the RCs and that data could be used by the TOPs and BAs to perform their functions. 4. The SDT is suggesting the retirement of three requirements in PRC-001 since those requirements deal with data handling and can now be incorporated in the data specification concept suggested for TOP-003-2. Do you agree with the changes the drafting team has made? If you do not support these changes or you agree in general but feel that alternative language would be more appropriate, please provide specific suggestions in your comments. 1 Yes 6. If you have any other comments on these standards that you have not already provided in response to the prior questions, please provide them here. Comments: Seattle City Light supports the efforts of the Real Time Operations Standards Drafting Team and approves of the direction proposed in these new TOP Standards. TOP-001 in particular clarifies the definition of Reliability Directive and provides straightforward requirements for reporting outages of relay and communication equipment. We are prepared to vote “affirmative” for all of the new TOP Standards of Project 2007-03 once details as discussed above are addressed and resolved.
4Seminole Electric Cooperative, Inc.Steven R Wallace
4South Mississippi Electric Power AssociationSteven McElhaney
4Tacoma Public UtilitiesKeith Morisette Affirmative If a Transmission Operator or a Balancing Authority is requesting data from another entity, they must demonstrate a reliability impact validating the need for the requested data.
4Wisconsin Energy Corp.Anthony Jankowski Affirmative
5AEP Service Corp.Brock Ondayko Negative Comments are being submitted via electronic form by Thad Ness on behalf of American Electric Power.
5AES CorporationLeo Bernier Abstain
5AmerenueSam Dwyer Affirmative
5Arizona Public Service Co.Edward Cambridge Affirmative
5Avista Corp.Edward F. Groce Affirmative
5BC Hydro and Power AuthorityClement Ma Affirmative
5Black Hills CorpGeorge Tatar Abstain
5Boise-Kuna Irrigation District/dba Lucky peak power plant projectMike D Kukla Negative
5Bonneville Power AdministrationFrancis J. Halpin Affirmative Comments csubmitted separately.
5BrightSource Energy, Inc.Chifong Thomas
5Chelan County Public Utility District #1John Yale Abstain
5City of Austin dba Austin EnergyJeanie Doty Affirmative
5City of Grand IslandJeff Mead Abstain
5City of ReddingPaul Cummings Affirmative
5City of Tacoma, Department of Public Utilities, Light Division, dba Tacoma PowerMax Emrick
5City of TallahasseeBrian Horton Affirmative
5Cleco PowerStephanie Huffman Affirmative
5Colorado Springs UtilitiesJennifer Eckels Abstain
5Consolidated Edison Co. of New YorkWilket (Jack) Ng Affirmative See NPCC group comments.
5Consumers Energy James B Lewis Negative
5Cowlitz County PUDBob Essex Negative Comment submitted.
5Detroit Edison CompanyChristy Wicke Affirmative
5Dominion Resources, Inc.Mike Garton Affirmative
5Duke Energy Dale Q Goodwine Affirmative Comments submitted.
5Dynegy Inc.Dan Roethemeyer Affirmative
5E.ON Climate & Renewables North America, LLCDana Showalter
5East Kentucky Power Coop.Stephen Ricker Negative The standard as proposed does not appear to comply with the stated intent of Project 2007-03, that being: “The industry needs clearer, unambiguous and enforceable standards in order to effectively operate the Bulk Electric System.” Not only are the changes to TOP-003 as vague—or ambiguous--if not more so than the previous TOP-003-1 standard, the requirements do not provide for any consistency between companies. For example, who between two parties determines, or in the case of an inability to reach agreement, who is responsible for arbitrating an agreement when two neighboring entities are attempting to establish a “mutually agreeable format”. Resolution could be problematic when required changes to a format between entities A and B would require format changes between entities A and C, A and D, and A and E, and would potentially require entity A to maintain several different format standards to meet the requirements for coordination between entities B, C, D, and E. Many items previously in TOP-003-1 appear to have been completely abandoned in lieu of much less prescriptive specifications in TOP-003-2. For example, clear provisions regarding timing of data availability listed in TOP-003-1 are not specified in any form in TOP-003-2 other than to require that entities needing to share data essentially “work it out amongst themselves”. The standard needs to better guide entities in regard to the type of data—at a minimum—they SHOULD be requesting and obtaining. Alternately, such format specifications should be left to the authority of the RC to coordinate among TO/BA entities for which they are responsible.
5Exelon NuclearMichael Korchynsky Affirmative
5ExxonMobil Research and EngineeringMartin Kaufman Abstain
5FirstEnergy SolutionsKenneth Dresner Affirmative FE appreciates the hard work of the standards drafting team. Please see additional comments and suggestions submitted through the formal comment period.
5Florida Municipal Power AgencyDavid Schumann Negative Please see FMPA comments submitted separately.
5Great River EnergyPreston L Walsh Affirmative Great River Energy agrees with the comments of the MRO NSRF.
5Green Country EnergyGreg Froehling
5I do not represent an EntityBruce Paggeot
5Indeck Energy Services, Inc.Rex A Roehl
5JEAJohn J Babik Affirmative
5Kansas City Power & Light Co.Scott Heidtbrink
5Kissimmee Utility AuthorityMike Blough Negative
5Lakeland ElectricJames M Howard Negative Please refer to comments submitted by FMPA.
5Liberty Electric Power LLCDaniel Duff Negative
5Lincoln Electric SystemDennis Florom
5Los Angeles Department of Water & PowerKenneth Silver Affirmative
5Lower Colorado River AuthorityTom Foreman Affirmative
5Luminant Generation Company LLCMike Laney Negative Comments provided via NERC web comment form.
5Manitoba Hydro S N Fernando Affirmative Please see comments submitted by Joe Petaski (Manitoba Hydro)
5Massachusetts Municipal Wholesale Electric CompanyDavid Gordon Affirmative
5MEAG PowerSteven Grego Affirmative
5MidAmerican Energy Co.Christopher Schneider Negative
5Muscatine Power & WaterMike Avesing Negative
5Nebraska Public Power DistrictDon Schmit Affirmative NPPD joins comments submitted by the Southwest Power Pool (SPP).
5New Harquahala Generating Co. LLCNathaniel Larson
5New York Power AuthorityGerald Mannarino Affirmative
5Northern Indiana Public Service Co.William O. Thompson Affirmative
5Occidental ChemicalMichelle R DAntuono Affirmative See Ingleside Cogeneration LP comment form
5Omaha Public Power DistrictMahmood Z. Safi Negative Please see MRO NSRF and SPP Comments.
5Orlando Utilities CommissionRichard Kinas
5Pacific Gas and Electric CompanyRichard J. Padilla
5PacifiCorpSandra L. Shaffer Affirmative
5Platte River Power AuthorityPete Ungerman
5PowerSouth Energy CooperativeTim Hattaway Affirmative
5PPL Generation LLCAnnette M Bannon Affirmative
5Progress Energy CarolinasWayne Lewis Affirmative
5PSEG Fossil LLCMikhail Falkovich Affirmative
5Puget Sound Energy, Inc.Tom Flynn Affirmative
5Reedy Creek Energy ServicesBernie Budnik
5Sacramento Municipal Utility DistrictBethany Hunter Affirmative
5Salt River ProjectGlen Reeves Affirmative
5Santee CooperLewis P Pierce Negative The implementation date should be at least twelve months to be consistent with TOP-001-2 and TOP-002-3. What was the rationale of reducing the implementation time from twenty-four months to ten months?
5Seattle City LightMichael J. Haynes Negative
5Seminole Electric Cooperative, Inc.Brenda K. Atkins Affirmative
5Snohomish County PUD No. 1Sam Nietfeld Affirmative
5Southern California Edison Co.Denise Yaffe Affirmative
5Southern Company GenerationWilliam D Shultz Affirmative Please see comments submitted by Antonio Grayson on behalf of each part of Southern Company.
5Tampa Electric Co.RJames Rocha
5Tenaska, Inc.Scott M. Helyer Abstain
5Tennessee Valley AuthorityDavid Thompson Affirmative
5Tri-State G & T Association, Inc.Barry Ingold
5U.S. Army Corps of EngineersMelissa Kurtz Abstain
5U.S. Bureau of ReclamationMartin Bauer Affirmative
5Wisconsin Electric Power Co.Linda Horn Affirmative
5Wisconsin Public Service Corp.Leonard Rentmeester
5Xcel Energy, Inc.Liam Noailles Affirmative
6AEP MarketingEdward P. Cox
6Arizona Public Service Co.Justin Thompson
6Bonneville Power AdministrationBrenda S. Anderson Affirmative Please see BPA's comments.
6City of ReddingMarvin Briggs Affirmative
6Cleco Power LLCRobert Hirchak Affirmative
6Colorado Springs UtilitiesLisa C Rosintoski
6Consolidated Edison Co. of New YorkNickesha P Carrol Affirmative See NPCC group comments
6Constellation Energy Commodities GroupBrenda L Powell Abstain
6Dominion Resources, Inc.Louis S. Slade Affirmative
6Duke Energy CarolinaWalter Yeager
6Entergy Services, Inc.Terri F Benoit Affirmative
6Eugene Water & Electric BoardDaniel Mark Bedbury Affirmative
6Exelon Power TeamPulin Shah Affirmative
6FirstEnergy SolutionsMark S Travaglianti Affirmative FE appreciates the hard work of the standards drafting team. Please see additional comments and suggestions submitted through the formal comment period.
6Florida Municipal Power AgencyRichard L. Montgomery Negative Please see FMPA comments submitted separately.
6Florida Municipal Power PoolThomas Washburn Affirmative See FMPA comments
6Florida Power & Light Co.Silvia P. Mitchell Affirmative
6Imperial Irrigation DistrictCathy Bretz Affirmative
6Kansas City Power & Light Co.Jessica L Klinghoffer Negative Comments and concerns with the proposed standards have been expressed within the NERC comment form
6Lakeland ElectricPaul Shipps Negative "Please see FMPA comments submitted separately"
6Lincoln Electric SystemEric Ruskamp Negative Please refer to comments submitted by the MRO NSRF for LES’ concerns.
6Los Angeles Department of Water & PowerBrad Packer Affirmative
6Luminant EnergyBrad Jones Negative TOP-003-2 as currently written does not provide any recourse for the entity receiving a data request if that entity feels the data request is unreasonable either in content or timing or if the entity does not have the data available to submit. As such I would recommend modify R5 as follows: R5. Each……shall satisfy the obligations of the documented specification for data. R5.1. If the entity receiving the data request cannot provide the requested data either in content or timing then the entity receiving the data request shall notify the requesting entity and provide a reason for not providing the data.
6Manitoba Hydro Daniel Prowse Affirmative Please see comments submitted by Joe Petaski (Manitoba Hydro)
6MidAmerican Energy Co.Dennis Kimm
6Northern Indiana Public Service Co.Joseph O'Brien Affirmative
6NRG Energy, Inc.Alan Johnson Abstain
6Omaha Public Power DistrictDavid Ried Negative Please see OPPD comments from Doug Peterchuck
6Orlando Utilities CommissionClaston Augustus Sunanon
6PacifiCorpScott L Smith Affirmative
6Platte River Power AuthorityCarol Ballantine Affirmative
6PPL EnergyPlus LLCMark A Heimbach Affirmative
6Progress EnergyJohn T Sturgeon Affirmative
6PSEG Energy Resources & Trade LLCPeter Dolan Affirmative
6Public Utility District No. 1 of Chelan CountyHugh A. Owen Abstain
6Sacramento Municipal Utility DistrictClaire Warshaw Affirmative
6Salt River ProjectSteven J Hulet Affirmative
6Santee CooperSuzanne Ritter
6Seattle City LightDennis Sismaet Negative While the idea of making each BA and TOP formally outline a data specification for all the information it needs to perform its Operational Planning Analysis is a worthy concept, the requirements in this Standard for evidence and data retention are onerous. Specifically the requirement to retain all electronic or hard copies of data transmittals or retain attestations from all receiving entities would require a tremendous amount of resources to be compliant. It may also be technically impossible to comply with these requirements because the data specifications developed individually by each entity may not be compatible with each other. The formats and periodicity of data collected by each entity may not be compatible with the specifications and it could be impossible to comply with these requests without major changes to the infrastructure. As an alternative, most of the NERC registered entities are currently required to provide that data to their Reliability Coordinators (RC) using the specifications already developed by the RCs and that data could be used by the TOPs and BAs to perform their functions. Seattle City Light supports the efforts of the Real Time Operations Standards Drafting Team and approves of the direction proposed in these new TOP Standards. We are prepared to vote “affirmative” once details as discussed above are addressed and resolved.
6Seminole Electric Cooperative, Inc.Trudy S. Novak Affirmative
6Shell Energy North America (US), L.P.Paul Kerr Affirmative
6South California Edison CompanyLujuanna Medina
6Tacoma Public UtilitiesMichael C Hill Affirmative
6Tampa Electric Co.Benjamin F Smith II
6Tennessee Valley AuthorityMarjorie S. Parsons Affirmative
6Western Area Power Administration - UGP MarketingPeter H Kinney
6Xcel Energy, Inc.David F. Lemmons Affirmative
8 Edward C Stein Affirmative
8 James A Maenner
8 Roger C Zaklukiewicz Affirmative
8 Merle Ashton
8INTELLIBINDKevin Conway Negative The Requirements are confusing and refer to other requiremtns. The original concept was that requirments shall stand alone, and not be dependent on other requirments or standards. Violation of R1 or R2 will cascade to addtional violations based on the structure of the Standard. These issues should be repaired as a part of this revision.
8JDRJC AssociatesJim Cyrulewski Affirmative
8Utility Services, Inc.Brian Evans-Mongeon Abstain
8Volkmann Consulting, Inc.Terry Volkmann Affirmative
9California Energy CommissionWilliam M Chamberlain Abstain
9Commonwealth of Massachusetts Department of Public UtilitiesDonald Nelson Affirmative
9National Association of Regulatory Utility CommissionersDiane J Barney Affirmative
9Utah Public Service CommissionRic Campbell Affirmative
10Florida Reliability Coordinating CouncilLinda Campbell Abstain
10Midwest Reliability OrganizationJames D Burley Affirmative Please refer to comments submitted by MRO NSRF
10New York State Reliability CouncilAlan Adamson Affirmative
10Northeast Power Coordinating CouncilGuy V. Zito Affirmative
10ReliabilityFirst CorporationAnthony E Jablonski Abstain ReliabilityFirst abstains and offers the same comments as submitted via the previous comment posting period.
10SERC Reliability CorporationCarter B. Edge Affirmative
10Southwest Power Pool REStacy Dochoda Negative
10Texas Reliability Entity, Inc.Larry D. Grimm Negative
10Western Electricity Coordinating CouncilSteven L. Rueckert Affirmative