Comment form for FRCC Standard for Regional Generator Performance During Frequency and Voltage Excursions (FRCC-S-PRC-024) version 3
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1 Please use this form to submit comments on version 3 of an FRCC Standard on Regional Generator Performance During Frequency and Voltage Excursions. Comments must be submitted by April 18, 2007 (this standard has also been referred to as the Generator Coordination standard). You must submit the completed form by ing it to the FRCC Standards Process Manager at FRCCStandard@frcc.com, with the words FRCC Generator Coordination Standard in the subject line. If you have any questions, please contact Anne Brown at abrown@frcc.com, or ALL COMMENTS ON THIS FORM WILL BE POSTED ON THE FRCC WEBSITE. DO: Do enter text only, with no formatting or styles added Do use punctuation and capitalization as needed (except quotations) Do use more than one form if responses do not fit in the spaces provided Do submit any formatted text or markups in a separate WORD file. DO NOT: Do not insert tabs or paragraph returns in any data field. Do not use numbering or bullets in any data field. Do not use quotation marks in any data field. Do not submit a response in an unprotected copy of this form Individual Commenter Information (Complete this page for comments from one organization or an individual) Name: Robert C. Williams Organization: Florida Municipal Power Agency Telephone: bob.williams@fmpa.com
2 Please Enter All Comments in Simple Text Format. Insert a check mark in the appropriate boxes by clicking in the gray areas. 1. In response to comments received, the Drafting Team (DT) has modified the data retention period of the Compliance section to three (3) years. Do you agree with this change? 2. In response to comments received, appendix A has been modified to include islanding in order to match Requirement R1. Appendix A has also been modified to clarify the generator protection coordination technical requirements. Do you agree with these clarifications? 3. Do you agree that the DT has fairly and appropriately addressed all comments received on the posted versions of this standard?
3 4. The DT feels that version 3 is ready to be presented to the FRCC Operating Committee and Planning Committee with a recommendation for adoption as a Regional Reliability standard. Do you agree? 5. Please provide any other comments that the DT should consider.
4 Please use this form to submit comments on version 3 of an FRCC Standard on Regional Generator Performance During Frequency and Voltage Excursions. Comments must be submitted by April 18, 2007 (this standard has also been referred to as the Generator Coordination standard). You must submit the completed form by ing it to the FRCC Standards Process Manager at FRCCStandard@frcc.com, with the words FRCC Generator Coordination Standard in the subject line. If you have any questions, please contact Anne Brown at abrown@frcc.com, or ALL COMMENTS ON THIS FORM WILL BE POSTED ON THE FRCC WEBSITE. DO: Do enter text only, with no formatting or styles added Do use punctuation and capitalization as needed (except quotations) Do use more than one form if responses do not fit in the spaces provided Do submit any formatted text or markups in a separate WORD file. DO NOT: Do not insert tabs or paragraph returns in any data field. Do not use numbering or bullets in any data field. Do not use quotation marks in any data field. Do not submit a response in an unprotected copy of this form Individual Commenter Information (Complete this page for comments from one organization or an individual) Name: Bernie Budnik Organization: Reedy Creek Improvement District Telephone: Bernie.budnik@disney.com
5 Please Enter All Comments in Simple Text Format. Insert a check mark in the appropriate boxes by clicking in the gray areas. 1. In response to comments received, the Drafting Team (DT) has modified the data retention period of the Compliance section to three (3) years. Do you agree with this change? 2. In response to comments received, appendix A has been modified to include islanding in order to match Requirement R1. Appendix A has also been modified to clarify the generator protection coordination technical requirements. Do you agree with these clarifications? Requirements to the standard should not be contained in an Appendix, all requirements should be listed in the Requirements Section. 3. Do you agree that the DT has fairly and appropriately addressed all comments received on the posted versions of this standard?
6 4. The DT feels that version 3 is ready to be presented to the FRCC Operating Committee and Planning Committee with a recommendation for adoption as a Regional Reliability standard. Do you agree? See previous and following comments. 5. Please provide any other comments that the DT should consider. The Applicability section should only contain the entity that the standard is applicable to (Example: Generator Owner). Currently, requirements are contained in this section as drafted. Requirements for the size units within the Generator Owners fleet that the standard is applicable to are/should be contained within the requirements section. Additionally, requirements should not be embedded in the Appendix. All requirements should be numbered and assigned a Risk Factor within the requirements section. Requirement R2 as written is unnecessary, the M2 measure addresses this. Levels of n-compliance 2.1 and 2.2 should both be Level 1 noncompliance violations. From a compliance point of view they both require the submission of documentation (which is late/not provided). Why is documentation of requirement R3 a more severe violation than R1?
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