consistent with its System Operating Limit proposed revisions do not change the intent of the standard IROLs are establishing for its RC Methodology (“SOL Methodology”) as the RC develop the SOL Methodology for establishing Area, consistent with its SOL established in FAC-011-4. SOLs in its RC Area, and the TOP following the RC SOL Methodology. Methodology in establishing those SOLs. Accordingly, the FAC-014-2 Requirement R2 – proposed Requirement R2 requires that the TOP establish Requires the TOP to establish SOLs SOLs as required by the RC SOL Methodology. The SDT consistent with the RC SOL believes this clarifies the appropriate responsibilities of the Methodology. respective functional entities, while not creating ambiguity in the requirements in requiring the RC to do something that the TOP is, in all actuality, required to do. Additionally, this requirement carries forward the obligation of the RC to establish IROLs for its RC Area. The RC maintains primary responsibility for establishment of IROLs because these limits have the potential to impact a Question 1: Do you agree with that the Reliability Coordinator (RC) should have primary responsibility for establishing IROLs for its RC Area? If not, please provide your comments on the appropriate break down of responsibilities (between RC and TOP) in establishing IROLs. Yes No Comments: Proposed Reliability Standard: FAC-014-3, Requirement R2 Relevant Requirements in Existing Proposed New/Revised Requirement Explanation of Proposed Revision Reliability Standard(s)
consistent with its System Operating Limit Methodology (“SOL Methodology”) as established in FAC-011-4. proposed revisions do not change the intent of the standard the RC develop the SOL Methodology for establishing SOLs in its RC Area, and the TOP following the RC SOL Methodology in establishing those SOLs. Accordingly, the proposed Requirement R2 requires that the TOP establish SOLs as required by the RC SOL Methodology. The SDT believes this clarifies the appropriate responsibilities of the respective functional entities, while not creating ambiguity in the requirements in requiring the RC to do something that the TOP is, in all actuality, required to do. Additionally, this requirement carries forward the obligation of the RC to establish IROLs for its RC Area. The RC maintains primary responsibility for establishment of IROLs because these limits have the potential to impact a IROLs are establishing for its RC Area, consistent with its SOL Methodology. FAC-014-2 Requirement R2 – Requires the TOP to establish SOLs consistent with the RC SOL Methodology. Question 1: Do you agree with that the Reliability Coordinator (RC) should have primary responsibility for establishing IROLs for its RC Area? If not, please provide your comments on the appropriate break down of responsibilities (between RC and TOP) in establishing IROLs. Yes No Comments: Proposed Reliability Standard: FAC-014-3, Requirement R2 Proposed New/Revised Requirement Explanation of Proposed Revision Relevant Requirements in Existing Reliability Standard(s)
2015-09_FAC-014-3%20-%20Comment%20Form%20Questions.docx