20150812AVU to Staff 46.doc

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 08/03/2015
CASE NO.: AVU-E-15-05/AVU-G-15-01 WITNESS: Bryan Cox
REQUESTER: IPUC RESPONDER: Garth Brandon
TYPE: Production Request DEPARTMENT: Transmission Operations
REQUEST NO.: Staff - 046 TELEPHONE: [phone]

REQUEST:

Please provide a copy of the Company’s method for differentiating between distribution and transmission components (See Cox DI, pg. 11, line 20). How do the newly developed Bulk Electric System (BES) definitions and policies change the Company’s definitions of transmission vs. distribution components? Do these changes impact the Company’s reliability analysis (i.e., contingency or path rating analysis) and Transmission Revenue Adjustment? Please explain.

RESPONSE:
Avista has always operated to Bulk Electric System (BES) facilities being 100 kV and above. Avista has made no changes to, or removed any facilities, as a result of the newly developed BES definitions. Hence there are no impacts to Avista’s reliability analysis (i.e., contingency or path rating analysis) or Transmission Revenue Adjustments due to the newly developed Bulk Electric System (BES) definition. Avista references the NERC definition as the company’s method for differentiating between distribution and transmission components. See NERC BES definition below:

Glossary of Terms Used in NERC Reliability Standards 18
Continent-wide Term Acronym BOT Approved Date FERC Approved Date Definition
Bulk Electric System
[Archive]
BES
11/21/2013
3/20/14 (Becomes effective 7/1/2014)
(Please see the Imple-mentation Plan for Phase 2 Compliance obligations.)
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.
Inclusions:
 I1 - Transformers with the primary terminal and at least one secondary terminal operated at 100
kV or higher unless excluded by application of Exclusion E1 or E3.
 I2 – Generating resource(s) including the generator terminals through the high-side of the step-up transformer(s) connected at a voltage of 100 kV or above with:
a) Gross individual nameplate rating greater than 20 MVA. Or,
b) Gross plant/facility aggregate nameplate rating greater than 75 MVA.
 I3 - Blackstart Resources identified in the Transmission Operator’s restoration plan.
 I4 - Dispersed power producing resources that aggregate to a total capacity greater than 75 MVA (gross nameplate rating), and that are connected through a system designed primarily for delivering such capacity to a common point of connection at a voltage of 100 kV or above.
Thus, the facilities designated as BES are:
Glossary of Terms Used in NERC Reliability Standards 19
Continent-wide Term Acronym BOT Approved Date FERC Approved Date Definition
Bulk Electric System
(Continued)
BES
a) The individual resources, and
b) The system designed primarily for delivering capacity from the point where those resources aggregate to greater than 75 MVA to a common point of connection at a voltage of 100 kV or above.
 I5 –Static or dynamic devices (excluding generators) dedicated to supplying or absorbing Reactive Power that are connected at 100 kV or higher, or through a dedicated transformer with a high-side voltage of 100 kV or higher, or through a transformer that is designated in Inclusion I1 unless excluded by application of Exclusion E4.
Exclusions:
 E1 - 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,
b) Only includes generation resources, not identified in Inclusions I2, I3, or I4, with an aggregate capacity less than or equal to 75 MVA (gross nameplate rating). Or,
c) Where the radial system serves Load and includes generation resources, not identified in Inclusions I2, I3 or I4, with an aggregate capacity of non-retail generation less than or equal to 75 MVA (gross nameplate rating).
Glossary of Terms Used in NERC Reliability Standards 20
Continent-wide Term Acronym BOT Approved Date FERC Approved Date Definition
Bulk Electric System
(Continued)
BES
Note 1 – A normally open switching device between radial systems, as depicted on prints or one-line diagrams for example, does not affect this exclusion.
Note 2 – The presence of a contiguous loop, operated at a voltage level of 50 kV or less, between configurations being considered as radial systems, does not affect this exclusion.
 E2 - A generating unit or multiple generating units on the customer’s side of the retail meter that serve all or part of the retail Load with electric energy if: (i) the net capacity provided to the BES does not exceed 75 MVA, and (ii) standby, back-up, and maintenance power services are provided to the generating unit or multiple generating units or to the retail Load by a Balancing Authority, or provided pursuant to a binding obligation with a Generator Owner or Generator Operator, or under terms approved by the applicable regulatory authority.
 E3 - Local networks (LN): A group of contiguous transmission Elements operated at 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 customers and not to accommodate bulk power transfer across the interconnected system. The LN is characterized by all of the following:
a) Limits on connected generation: The LN and its underlying Elements do not include generation resources identified in Inclusions I2, I3, or I4 and do not have an aggregate capacity of non-retail
Glossary of Terms Used in NERC Reliability Standards 21
Continent-wide Term Acronym BOT Approved Date FERC Approved Date Definition
Bulk Electric System
(Continued)
BES
generation greater than 75 MVA (gross nameplate rating);
b) Real 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 any part 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).
 E4 – Reactive Power devices installed for the sole benefit of a retail customer(s).
Note - Elements may be included or excluded on a case-by-case basis through the Rules of Procedure exception process.

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