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NERC – GADS Update on Reporting of Wind Data to NERC

NERC – GADS Update on Reporting of Wind Data to NERC. WECC Office Salt Lake City, UT December 27, 2010. GADS Move to Mandatory Report.

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NERC – GADS Update on Reporting of Wind Data to NERC

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  1. NERC – GADS Update onReporting of Wind Data to NERC WECC Office Salt Lake City, UT December 27, 2010

  2. GADS Move to Mandatory Report • In June, 2010 the NERC Planning Committee created a GADS Task Force with a mission to: “review and recommend whether Generation Owners on the NERC Compliance Registry should report GADS data on a mandatory basis.” • Conference calls and meeting were held in August and September to resolve the issue. • The preliminary report for the PC is being written now but here are some (not all) recommendations GADSTF:

  3. Preliminary Recommendations for Wind • Based on their individual and combined deliberations, the task force recommends that GADS be made mandatory and be collected from all generation owners following a data authorization using Section 1600 under NERC’s Rules of Procedures. This recommendation is based on the agreed upon desire to improve NERC’s reliability assessments and performance analysis.

  4. Preliminary Recommendations for Wind • Uniformity of data collection format is essential. All GADS data shall be collected using the GADS Data Reporting Instructions (DRI). All interpretations of the DRI will be coordinated with NERC. • Each reporting generating company will continue to be responsible for collecting, monitoring, updating and correcting their own GADS event, performance and design data.

  5. For wind facilities, the current NERC Statement of Compliance Registry, Rev. 5 and its requirements for Generation Operators should be applied, specifically for wind facilities equal to or greater than 75 MVA installed capacity.

  6. For wind facilities, sites with a commercial date prior to January 1, 2005 would not be required to report but could still report voluntarily. Any other Generating unit not on NERC’s Compliance Registry, are welcome to report to GADS on a voluntary basis using the same appropriate GADS Wind Turbine Generation Data Reporting Instructions format. This time frame would eliminate the issue of the expense of modifying or replacing older SCADA systems that might not be capable of providing the mandatory data.

  7. Mandatory GADS report for all units except the wind and solar should start January 1, 2012. GADS data will be due 30 days after each quarter year. The first mandatory data will be from January 1 to March 31, 2012 and will be due to NERC no later than April 30, 2012. For wind facilities and solar facilities, it is recommended that mandatory reporting start 12 months after the NERC Board approval date. A six month setup and test period maybe required.

  8. The following schedule is proposed:

  9. What If a GO Doesn’t Comply? • Possible NERC actions: • NERC may resort to a referral to FERC for only United States entities, not Canadian entities. NERC will make use of the mechanisms it has available for both U.S. and Canadian entities (notices, letters to CEO, requests to trade associations for assistance, peer pressure) to gain compliance with the NERC Rules. A failure to comply with NERC Rules could also be grounds for suspension or disqualification from membership in NERC. Whether or not NERC chooses to use that mechanism will likely depend on the facts and circumstances of the case. • NERC cannot impose penalties for a failure to comply with a data request.

  10. What If a GO Doesn’t Comply? • Possible FERC actions: • All members of NERC (US and Canadian) are bound by their membership agreement with NERC to follow NERC’s Reliability Standards and Rules of Procedure, including section 1600.   • Under section 215 of the Federal Power Act, FERC has jurisdiction over all users, owners, and operators of the bulk power system within the United States. • FERC could treat a failure by a U.S. entity to comply with an approved data request as a violation of a rule adopted under the Federal Power Act using its enforcement mechanisms in Part III of the FPA.

  11. What If a GO Doesn’t Comply? • What about Canada? • Canadian provinces who have signed agreements stating they recognize NERC’s ERO status, will be compliant with the NERC approved standards and Rules of Procedure issued by the NERC Board. • The obligation arises for the Canadian utilities if they are members of NERC. For example, if Canadian Utility “A” is a member of NERC, then it must go by the Rules of Procedure, standards, etc. If Canadian Utility “X” is not a NERC member but its providence recognizes NERC as their ERO, then Utility “X” is not under obligation to follow the rules.

  12. Questions?

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