4/1/2014. FAC-003 Transmission Vegetation Management. Agenda. About NERC. About NERC. About NERC. About NERC. About NERC and FERC

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1 Agenda FAC-003 Transmission Vegetation Management Robert Novembri Novembri Consulting, LLC and FERC FAC-003 Requirements and FERC Order 777 Preparing for FAC Enforcement Dates for Transmission Owners and Generator Owners North American Electric Reliability Corporation: A not-for-profit entity whose mission is to ensure the reliability of the Bulk-Power System in North America. NERC develops and enforces Reliability Standards Annually assesses seasonal and long-term reliability Monitors the Bulk-Power System through system awareness Educates, trains, and certifies industry personnel Over 1900 Registered Entities Balancing Authority Distribution Provider Generator Owner Generator Operator Interchange Authority Load-Serving Entity Planning Authority Purchasing-Selling Reliability Coordinator Reserve Sharing Group Resource Planner Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider NERC Certification is required for three of the fifteen registration categories Balancing Authority Transmission Operator Reliability Coordinator 1

2 There are 114 NERC Standards that contain over 1200 requirements and subrequirements Each NERC Standard contains the following: Purpose Applicability Requirements Measures Violation Risk Factors (VRFs) Violation Severity Levels (VSLs) NERC Reliability Standards are developed using an ANSI-accredited process that: Ensures the process is open to all persons who are directly and materially affected by the reliability of the Bulk Power System Is transparent to the public Demonstrates the consensus for each standard Fairly balances the interests of all stakeholders Provides for reasonable notice and opportunity for comment About FERC NERC is subject to oversight by the Federal Energy Regulatory Commission and governmental authorities in Canada The Federal Energy Regulatory Commission is an independent agency that regulates the interstate transmission of electricity, natural gas, and oil Protects the reliability of the high voltage interstate transmission system through mandatory reliability standards Enforces FERC regulatory requirements through imposition of civil penalties and other means Approves NERC Board of Trustees adopted reliability standards FERC can also revise NERC BOT adopted reliability standards or set expectations for requirements FAC-003 Examples FERC Commented on the following in Order 777 Requirements 1, 2, 3, 6, & 7 Modified the Violation Risk Factor from Medium to High for Requirement 2 The corridor of land under a transmission line needed to operate the line The width of the corridor is established by engineering or construction standards as documented in either: 1. Construction documents 2. Pre-2007 vegetation maintenance records 3. By the blowout standard in effect when the line was built The ROW width in no case exceeds the applicable Transmission Owner s or applicable Generator Owner s legal rights but may be less based on the aforementioned criteria 2

3 FERC Order 777: auditors will be able to request supporting information used to set the width of the right-of-way, including any of the available information listed in the right-of-way definition. When are pre-2007 vegetation maintenance records to be used for defining a ROW? Were there are no engineering or construction standards that reference the width of ROW to be maintained for vegetation; and Evidence exists in maintenance records for a width that was in fact maintained prior to the standard becoming mandatory Requirements 1 & 2 Requirements 1 & 2 Each applicable TO and applicable GO shall manage vegetation to prevent encroachments into the MVCD of its applicable lines operating within their Rating and all Rated Electrical Operating Conditions of the types shown below: Observed in real time, no sustained outage Fall-in inside the ROW, sustained outage Blowing together of lines and vegetation inside the ROW, sustained outage Vegetation growth, sustained outage FERC Order 777: while clearances required at the time of maintenance may vary from one region or area to another, our proposed approval of FAC is based on our understanding, which is drawn directly from NERC s statements in its petition, that transmission operators [owners] will manage vegetation to distances beyond the MVCD to ensure no encroachment into the MVCD. Requirement 3 Requirement 3 Each applicable TO and applicable GO shall have documented maintenance strategies or procedures or processes or specifications it uses to prevent the encroachment of vegetation into the MVCD of its applicable lines that accounts for the following: Movement of applicable line conductors under their Rating and all Rated Electrical Operating Conditions; Inter-relationships between vegetation growth rates, vegetation control methods, and inspection frequency FERC Order 777: While accommodating flexibility, these documented strategies must have sufficient specification to provide a means to follow the transmission owner s strategy through a paper trail or guidelines. Documented strategies cannot be so vague as to fail to provide any clear guidance for auditors 3

4 Requirements 4 & 5 R4 Reporting of vegetation likely to cause a fault R5 Constraints from performing needed vegetation work Neither were commented on in FERC Order 777 Each applicable TO and applicable GO shall perform a Vegetation Inspection of 100% of its applicable transmission lines at least once per calendar year and with no more than 18 calendar months between inspections on the same ROW FERC Order 777: the fall-in of a danger tree from outside the defined right-of-way but within a transmission owner s control would likely merit examination to determine whether the transmission owner is properly conducting the annual Vegetation Inspection as required by Requirement R6 FERC Order 777: A fall-in from outside of the defined right-of-way may give reason to review a transmission owner s compliance with the annual inspection and work plan requirements. In the context of fall-ins from outside the defined right-ofway, enforcement decisions should be based on a review of the quality of the transmission owner s program and its execution of that program Requirement 7 Requirement 7 Each applicable TO and applicable GO shall complete 100% of its annual vegetation work plan of applicable lines to ensure no vegetation encroachments occur within the MVCD FERC Order 777: the fall-in of a danger tree from outside the defined right-of-way but within a transmission owner s control would likely merit examination to determine whether the transmission owner is properly performing the annual work plan as required by Requirement R7 4

5 /1/2014 Fall-in Outages - Outside ROW Grow-in Outages C A TEGO R Y 3 C A TEGO R Y TVMP Preparing for FAC Ensure each requirement of FAC is thoroughly addressed in your program documentation Measures Ensure you have a clear understanding of the measures for each requirement and what supporting documentation and information is needed to comply with them Evidence Retention Ensure you meet the evidence retention periods for each requirement FAC Enforcement Dates Mandatory and Enforceable: July 1, 2014 Inactive: November 25, 2013 FAC (Transmission Owners) Mandatory and Enforceable: July 1, 2014 FAC (Generator Owners) Requirement 3 becomes Mandatory and Enforceable January 1, 2015 Remaining Requirements become Mandatory and Enforceable January 1, 20 FAC-003 Transmission Vegetation Management 5