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Bulk Electric System

Bulk Electric System. John D. Martinsen, P.E. Snohomish County Public Utility District (SNPD). Summary. Part 1 “Performance Based” Bulk Electric System (“BES”) definition BES definition(s) NERC , WECC, and electric industry efforts in defining the BES Part 2

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Bulk Electric System

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  1. Bulk Electric System John D. Martinsen, P.E. Snohomish County Public Utility District (SNPD)

  2. Summary • Part 1 • “Performance Based” Bulk Electric System (“BES”) definition • BES definition(s) • NERC, WECC, and electric industry efforts in defining the BES • Part 2 • Examples of BPA Transmission and Distribution systems

  3. “Performance Based” BES Definition • What function does the facility serve? • local distribution service? • support a WECC transfer path? • If the facilities fail, do they impact other transmission owners and operators?

  4. Bulk Electric System Definition Task Force (“BESDTF”) • Western Interconnection development of a “performance based” standard • FERC support of WECC effort in Order 743-A • BPA comments on the revision of the ERO definition of the BES (Docket No. RM09-18-000) • “…Western Interconnection, utilities must use higher voltage facilities, i.e., 115 kV, to accomplish what is effectively a distribution function with in the utility. Where demonstrated, these facilities should be categorized as distribution network components, not as bulk electric system facilities…” • “… Bonneville urges the Commission to provide an additional option for the ERO to submit a Regional Entities material impact methodology for Commission approval…” • “…Agrees with the need to exempt FAC that have low impact on the BES…” • “…Bonneville believes many facilities in the Western Interconnection rated at 100kV and above should not be included in the BES because they have no material impact on the bulk power system reliability…”

  5. Historic BES Definition • NERC Bulk Electric System Glossary of Terms approved by both the EC and OC at the July 16, 1996 Joint EC/OC Meeting: • “A term commonly applied to the portion of an electric utility system that encompasses the electrical generation resources and bulk transmission system” • “Transmission — An interconnected group of lines and associated equipment for the movement or transfer of electric energy between points of supply and points at which it is transformed for delivery to customers or is delivered to other electric systems” • “Bulk Transmission — A functional or voltage classification relating to the higher voltage portion of the transmission system” • “Subtransmission — A functional or voltage classification relating to the lower voltage portion of the transmission system.”

  6. Current BES Definition • BES definition, NERC approved 2/8/2005, FERC approved 3/16/2007: • “As defined by the Regional Reliability Organization, the electrical generation resources, transmission lines, interconnections with neighboring systems, and associated equipment, generally operated at voltages of 100 kV or higher. Radial transmission facilities serving only load with one transmission source are generally not included in this definition”

  7. Revised BES Definition at FERC • “Unless modified by the lists shown below, all Transmission Elements operated at 100 kV or higher and Real Power and Reactive Power resources connected at 100 kV or higher. This does not include facilities used in the local distribution of electric energy” • With inclusions & exclusions listed • Approved by the electric industry’s NERC ballot body and the NERC Board of Trustees

  8. Load Service Exclusions • Radial systems: A group of contiguous transmission Elements that emanates from a single point of connection of 100 kV or higher and: • a) Only serves Load. Or.. • Note - A normally open switching device between radial systems, as depicted on prints or one-line diagrams for example, does not affect this exclusion

  9. Radial System

  10. Load Service Exclusions • “Local Networks (LN): A group of contiguous transmission Elements operated at or above 100 kV but less than 300 kV that distribute power to Load rather than transfer bulk power across the interconnected system. LN’s emanate from multiple points of connection at 100 kV or higher to improve the level of service to retail customer Load and not to accommodate bulk power transfer across the interconnected system”

  11. LN Characteristics • The LN is characterized by all of the following: • b) Power flows only into the LN and the LN does not transfer energy originating outside the LN for delivery through the LN; and • c) Not part of a Flowgate or transfer path: The LN does not contain a monitored Facility of a permanent Flowgate in the Eastern Interconnection, a major transfer path within the Western Interconnection, or a comparable monitored Facility in the ERCOT or Quebec Interconnections, and is not a monitored Facility included in an Interconnection Reliability Operating Limit (IROL).

  12. Local Network

  13. FERC’s Seven-Factor Test Presented by: Philip Hanser June 13, 2012

  14. Agenda • Overview of FERC’s Seven-Factor Test • Application of the Test by State Commissions • Application of the Test by FERC • Takeaways

  15. FERC’s Seven-Factor Test for Local Distribution Facilities • In Order 888, the FERC set out a seven-factor test to distinguish distribution facilities from transmission facilities when establishing whether the delivery component of an unbundled retail power sale was transmission or distribution: • local distribution facilities are normally in close proximity to retail customers • local distribution facilities are primarily radial in character • power flows into local distribution systems, and rarely, if ever flows out • when power enters a local distribution system, it is not reconsigned or transported on to some other market • power entering a local distribution system is consumed in a comparatively restricted geographic area • meters are based at the transmission/local distribution interface to measure flow into the local distribution system • local distribution systems will be of reduced voltage

  16. State Case 1 (Iowa Utilities Board):MidAmerican Energy Co. Order Issued April 30, 1999 • In November 1998, MidAmerican filed a petition for an Iowa Utilities Board order recommending delineation of local distribution facilities (subject to Board’s jurisdiction) and transmission facilities (subject to FERC jurisdiction). • MidAmerican proposed to classify all lines 69 kV and below as well as certain 161 kV lines as distribution • Classification of 69 kV and 161 kV lines was contested • The Board noted that: • In accordance with Order 888, FERC will defer to states’ determinations of which facilities are transmission vs. distribution. • Such delineation is only needed when states unbundle retail rates—FERC has said that the delineation is not required when states only implement retail access programs of short length (deemed “pilots” or “experiments”). • In administering the Test, “some lines or facilities classified as distribution may not meet all the indicators of distribution lines.” • No single factor is determinative and all factors should be evaluated and weighted in establishing the delineation.

  17. Board’s Discussion of Evidence 161 kV lines (in Waterloo) satisfied all FERC factors except #7: • Factors 1 and 5: Lines are in close proximity to retail customers in a comparatively restricted area. • Factor 2: Although not radially configured, the lines function and provides service as though they are primarily radial in character. • Factor 3 and 4: Power rarely, if ever, flows out of the system and is not transported out to another market. • Factor 6: Equipment installed at each interface distinguishes transmission system vs. distribution system power flows. • Factor 7: The 161 kV Lines do not appear to meet the reduced voltage test of Factor 7. • However, since “the lines meet an overwhelming preponderance of the factors, the Board believes it is most reasonable to classify them as distribution.” • 69 kV lines satisfied all FERC factors

  18. FERC Case 1:California Pacific Electric Company (CalPeco) Order Issued October 7, 2010 • CalPeco is a California Company formed for the purpose of acquiring the assets and operations of Sierra Pacific Power Company electric distribution system in CA (“California Distribution System”) • Due to geographic remoteness of some parts of the service territory, as well as historic interconnections, CalPeco was required to provide “minimal” delivery and reliability services to Sierra to enable Sierra to reliably supply power to its Nevada customers • CalPeco made several requests to FERC, including that it declares that all distribution facilities that are acquired by CalPecoare considered to be local distribution facilities. • CalPeco argued the application of the seven-factor test confirmed that the California Distribution System should be classified as a local distribution system

  19. CalPeco’s Arguments

  20. CalPeco’s Arguments (cont’d) • FERC found that: • The California Distribution System meets factors 1, 2, 5, 6, and 7 • The application of factors 3 and 4 is somewhat complicated in this case. CalPeco described four instances, in which power actually flowed out of the California Distribution System • However, power flowing out of the California Distribution System would be for: (1) border communities; or, (2) emergency assistance • Based on the “totality of circumstances” the California Distribution System met the seven-factor test.

  21. FERC Case 2:City of Pella, IowaOrder Issued February 2, 2011 • Pella owns and operates a municipal electric utility in Marion County, IA—the electricity is distributed by Pella to residential, public, and industrial customers with retail boundaries prescribed by the state of Iowa. • Pella has been a MISO market participant since 2004 and a network integration transmission service (NITS) MISO customer since Sep. 2009 (when MidAmerican joined MISO)—prior to that, Pella bought point-to-point transmission as needed. • Pella requested that the FERC reclassify its 69 kV facilities as transmission facilities • FERC noted that, in the late 1990s, MidAmerican asked the Iowa Commission to reclassify all lines 69 kV and below as distribution, including the lines that interconnect with Pella’s 69 kV facilities. • The Iowa Commission accepted MidAmerican’s reclassification proposal and the FERC adopted the determination in 2000 [see earlier slides on State Case 1].

  22. Pella’s Arguments in Support of Transmission Classification

  23. Pella’s Arguments (cont’d) • FERC accepted Pella’s arguments that its 69 kV facilities should be classified as transmission facilities and noted that: • The 69 kV facilities are not in close proximity to retail customers, but are used to support service to communities across a wide region. • Power that enters Pella's 69 kV facilities is transported across its system to other marketsand the facilities are “not primarily radial in character” • Average of 30 percent of the energy flowing into Pella's interconnection points between 2007 and 2009 flowed out of Pella's facilities. • Power that enters Pella's 69 kV facilities is transported across its system to other markets. • Power that enters Pella's system is not consumed in a comparatively restricted geographical area. • Pella’s meters are used to measure bilateral flows. • Pella’s 69 kV facilities operate at a higher voltage than those facilities that Pella uses to serve retail load.

  24. Takeaways • The primary functionality of the system plays a substantial role in the application of the seven-factor test: • In CalPeco, power was shown to flow out of the system in several types of situations related to reliability, emergency assistance, and serving border communities—the primary function of the system, however, was determined to satisfy the seven-factor test • In MidAmerican, the Board acknowledged that the 161 kV lines do not satisfy factor 7, but ruled that the overwhelming evidence points to a distribution facility classification. • In Pella, FERC reclassified MidAmerican’s 69kV lines to transmission on the basis of Pella’s demonstrating they primarily performed transmission functions

  25. PART 2 • Examples of BPA Transmission and Distribution systems • BPA Radial System • BPA Radial (Open Loop) • BPA LN (Radial in Character) • BPA BES Network (Part of a Transfer Path) • BPA BES Network or Distribution? • Methodology for Consideration

  26. BPA Radial System • D1=27 miles • D2=46 miles • D3=19 miles • Power flows into the 115 kV system • Outages on the radial system do not cause adjacent 230 kV 0r 115kV system voltage or thermal violations

  27. BPA Radial (Open Loop) • D1=2 miles • D2=2 miles • D3=2 miles • D4= 2 miles • D5=1 miles • D6=16 miles • D7=1 miles • Open loop configuration (Normally open switch ) • Power always flows into the 115 kV system • Outages on the radial system do not cause adjacent 230 kV 0r 115kV system voltage or thermal violations

  28. BPA LN (Radial in Character) • D1=11 miles • D2=15 miles • Closed loop configuration • Power flows into the 115 kV system • Outages on the Local Network do not cause adjacent 230 kV 0r 115kV system voltage or thermal violations

  29. BPA BES Network(Part of a Transfer Path) • D1=28 miles • D2=54 miles • Closed loop configuration • 11 MW flows in and 2 MW flows out of the 115 kV system • Part of a major transfer path within the Western Interconnection

  30. BPA BES Network or Distribution? • D1=4 miles • D2=38 miles • D3=4 miles • D4=38 miles • D5=38 miles • Closed loop configuration • 60MW flows in and 22 MW flows out of the 115 kV system • Not Part of a major transfer path within the Western Interconnection • Outages on the Local Network do not cause adjacent 230 kV 0r 115kV system voltage or thermal violations under heavy winter base case condition • Requires further “performance based” assessment

  31. Methodology for Consideration • Consistent methodology for reliability and commercial purposes • Can the facilities adversely or favorably impact neighboring systems? • Radial systems that do not impact neighboring systems • BPA Radial Systems • BPA Radial (Open Loop) • BPA Local Network (Radial in Character) • Networked system that impact neighboring systems • BPA BES Network (Part of a Transfer Path) • Networked system that may or may not impact neighboring systems • Use a “performance based” assessment

  32. Thank You

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