direct testimony of the capital expenditures, reliability, and - nyseg

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Case 09-E-____; Case 09-G-____ (NYSEG)DIRECT TESTIMONY OF THE CAPITAL EXPENDITURES,RELIABILITY, AND OPERATIONS PANEL123456789101112131415161718192021("RRO"), the electrical generation resources, transmission lines, interconnectionswith neighboring systems, and associated equipment, generally operated atvoltages of 100 kV or higher. Radial transmission facilities serving only loadwith one transmission source are generally not included in this definition.Because NERC allowed for regional definition, the Northeast NPCC had its ownapproach to defining the BES; NPCC includes its own definition of "bulk powersystem" as follows:The interconnected electrical systems within northeastern NorthAmerica comprised of system elements on which faults ordisturbances can have a significant adverse impact outside of thelocal area.According to NERC, NPCC analyzes all system elements within its footprintregardless of size (voltage) to determine impact based on this definition. NERC'sfiling included NPCC's "Classification of Bulk Power System Elements,"("BPSE") which provides further information on the above definition and how itis applied. Each "Area," i.e., balancing authority, within NPCC maintains andupdates lists of bulk power system elements. The New York control authority(now called the "balancing authority"), NYISO, has developed multiple lists ofBPSE, each with some variation. The NPCC Document A-10, Classification ofBulk Power System Elements ("A-10 methodology"), listed New York facilitiesabove 200 kV as BPSE.47
Case 09-E-____; Case 09-G-____ (NYSEG)DIRECT TESTIMONY OF THE CAPITAL EXPENDITURES,RELIABILITY, AND OPERATIONS PANEL12345678910111213141516171819202122Q. How has NYSEG defined its BES?A. NYSEG has defined its BES with the same definition adopted by the NYSRC forthe New York BPS. NYSRC defines the BPS as the portion of the bulk powersystem within the New York control area, generally comprising generating units300 MW and larger and generally comprising transmission facilities 230 kV andabove. However, smaller generating units and lower voltage transmissionfacilities on which faults and disturbances can have a significant adverse impactoutside of the local control area are also a part of the New York State BPS.Q. Is the NPCC definition of BES under review by FERC?A. Yes. NPCC is the only regional entity in the United States that uses a risk-basedassessment methodology. The other seven RROs use a "bright line" test thatfollow FERC's recommendation that the BES be defined at 100 kV and above.FERC has expressed concern over the A-10 methodology. On December 18,2008, FERC issued an Order to NPCC and NERC to collect data on the elementsincluded in NPCC's BES, and elements over 100 kV not included in NPCC's BES.FERC stated that the other seven regional entities use either a modified orunmodified definition of the BES at 100 kV and above. FERC has initiated aproceeding under Docket No. RC09-3-000 to review this matter.Potential Outcome of FERC Action on BES Definition IssueQ. What action may be taken by FERC on the definition of BES?A. On February 20, 2009, NERC and NPCC submitted a comprehensive list offacilities at 100 kV and above in the United States portion of the NPCC region,48
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