Regional Standard:
Classification of Bulk Power System Elements
Comment Period (8/23/2019 - 10/9/2019)
10/09/2019Hydro One IncView Attachment
10/09/2019Vermont Transco 
Comments: The A-10 testing methodology flows nicely into the Directory 4 applicability determination. We have utilized the BPS determination from the A-10 testing for Directory 1 applicability, but this may have been too broad if the intent was to identify parts of the system that are critical to "big A" Area performance. This affects both operations and planning of the system. Speaking to the planning requirements, I think it is appropriate to identify those parts/elements that are BPS from a Directory 4 applicability, but not from an Area performance perspective. However, I am not entirely convinced that performing a Directory 1 test to determine Directory 1 applicability is the best approach. There may in fact be a simpler test, which may emerge eventually as we gain experience with this exclusion process. We also need to agree on what we mean by sufficient experience and the amount of time horizon needed to reconsider the exclusion process.
10/09/2019Maine Public Utilities CommissionView Attachment
Comments: Please accept attached joint comment of the Maine Public Utilities Commission and the Massachusetts Attorney General
10/09/2019ISO-New England, Inc.View Attachment
Comments: Please see ISO New England's comments in the attached document.
10/09/2019Consolidated Edison Company of New York, Inc. 
Comments: Con Edison appreciates the opportunity to comment toward the draft of NPCC Document A-10 “Classification of Bulk Power System Elements” and thanks the Task Force on Coordination of Planning (TFCP) and the CP-11 Working Group for the consideration of Con Edison’s concerns and suggestions during the extensive revision process which started in 2017. Given that the proposed revisions do significantly improve NPCC Document A-10 Classification of Bulk Power System Elements, Con Edison supports the adoption of this draft. In particular, Con Edison is in full support of the automatic exclusion of radial and single-terminal elements from Directory 1 applicability and the study based exclusion of networked transmission elements from Directory 1 applicability. The exclusions were technically justified and as such the revised NPCC Document A-10 “Classification of Bulk Power System Elements” identifies only the critical facilities for the applicability of the NPCC directories
10/09/2019Independent Electricity System OperatorView Attachment
10/09/2019Nova Scotia Power Inc. 
Comments: Nova Scotia Power Inc supports the proposed revisions to the A-10 methodology, including the proposal to make the study based exclusion test optional.
10/09/2019Hydro-Quebec TransEnergieView Attachment
10/08/2019 View Attachment
Comments: Connecticut Municipal Electric Energy Cooperative (CMEEC) Comments on the Proposed Revision to NPCC Classification of Bulk Power System Elements, Document A-10 Our colleagues at EVERSOURCE have made us aware of their underlying concerns with the study-based exclusion testing introduced in the proposed A-10 revision. CMEEC shares those concerns, specifically: • The study-based exclusion test is listed as “optional”. On the basis that the NPCC members may or may not choose to exercise the proposed study-based exclusions, it invites inconsistency between areas, even if it may be manageable by each Planning Authority within their respective areas. • If the proposed study-based exclusion methodology remains, we do not achieve one of the stated objectives of the A-10 revision, specifically to improve study efficiency. Instead the A-10 analysis will become more complex to implement. • We understand Joint TFCO and TFCP discussions have indicated that changes to Directory #1 applicability will not materially affect Operation’s monitored contingencies or operating procedures. This causes us to further question the need or value of relaxing NPCC planning criteria during a time of significant change to the transmission system. CMEEC further opposes the proposed changes because they go against the level of reliability that is needed (and not yet achieved in many instances) in the region. Reclassifying as non-BPS key substations and consequently their elements from the NPCC Directory compromise the reliability needed and expected by our member utility service territories. Changing NPCC criteria, for example, so as not to recognize constraints arising from DCT and circuit breaker failures introduces intra-regional reliability differences between those issues previously addressed with these criteria in place, and those issues addressed after removal of the criteria. We view as unacceptable the resulting service reliability discrimination among customers subject to like cost incurrence.
10/04/2019National GridView Attachment
10/02/2019Eversource EnergyView Attachment
10/02/2019Avangrid (CMP, NYSEG, RG&E, UI)View Attachment
Comments: AVANGRID, in conjunction with Eversource and National Grid, respectfully submits the attached comments as part of the Open Process review of the revised Criteria A-10.