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  • https://www.naes.com/news/environmental-considerations-in-a-new-year-new-administration/
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In the News

Home Communications In the News Environmental Considerations in a New Year & New Administration

2.23.2021

Environmental Considerations in a New Year & New Administration

by Pamela Berner, Director of Environmental Services

 

On January 20, 2021, President Biden signed Executive Order 13990, “Protecting Public Health and The Environment and Restoring Science to Tackle the Climate Crisis”.

This order established initiatives for executive departments and agencies to revisit rules finalized between January 2017 and January 2021 to ensure consistency with the overall policy and purpose of environmental regulation and protection in the United States.

These regulations should:

  • Be founded in science-based regulatory decisions
  • Ensure access to clean air and water
  • Limit exposure to dangerous chemicals and pesticides
  • Hold polluters accountable
  • Address social justice issues
  • Strengthen the country’s resilience to climate change

Each executive agency is to review the regulatory actions taken over the past four (4) years and make recommendations for necessary options available to address or reverse impacts where warranted.

Several of the actions addressed in the Order pertain to the energy industry, with considerable focus on oil and gas, energy efficiency, greenhouse gas emissions, and the analysis of their impact.

What we will see is each agency reviewing the regulatory activity and creating a plan to restore, alter, or promulgate new regulations to address gaps in recent regulations that may contravene a more protective environmental policy.

The leads of each agency have ninety (90) days from when President Biden signed the order to get their recommendation plans together.

Here is a summary of the programs and regulations that are on the radar for review by the agencies:

  • Actions relating to Reduction of Methane Emissions in the Oil and Gas Sector, especially those Standards for New, Reconstructed, and Modified Sources Reconsideration recently issued in September 2020. Recent regulations had initially provided relief for the Oil and Gas Sector regarding leak inspection and repair requirements. Planned initiatives would reinstate these protective monitoring and repair measures.
  • Recent regulations relating to Safer Affordable Fuel-Efficient Vehicles that warrant further inclusion of labor unions, States, and Industry in the regulatory development to ensure the inclusion of “Ambitious, Job-Creating Fuel Economy Standards”.
  • Job-Creating Appliance- and Building-Efficiency Standards addressing Energy Conservation for Appliance Standards, Procedures for Use in New or Revised Energy Conservation Standards and Test Procedures for Consumer Products and Commercial/Industrial Equipment.
  • Reconsideration of the “National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units—Reconsideration of Supplemental Finding and Residual Risk and Technology Review”. “Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process,” as soon as possible.

NAES Environmental Services will continue to monitor the regulatory actions in the coming months and provide updates as information warrants.

For any information regarding tracking of environmental or Department of Transportation regulations, please reach out to environmental@naes.com.

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    CAISO Generator Modeling Process and Data Requirements

    Don’t wait until the last minute. You should allow time for at least one iteration with CAISO so that you are complete and deemed compliant before your deadline.

    On August 1, 2018, CAISO introduced a revised Business Practice Manual for Transmission Planning Process (BPM), which includes new data requirements for interconnected generation resources within the ISO’s footprint. Section 10 of the BPM establishes revised data requirements and compliance procedures for all participating generators including non-NERC registered entities. While additional requirements have been placed on larger NERC registered facilities, these changes may pose an even greater burden to entities that have been exempt from NERC mandated modeling and protection requirements.

    New data requirements include voltage and frequency protection models, power flow models, and in some cases, sub-synchronous resonance models. These models must be verified using criteria listed in the BPM, which can only be performed by entities with modeling software and knowledge of modeling practices.

    NAES is prepared to assist entities with data aggregation, modeling, and testing to ensure compliance with CAISO’s data requests. The following links will allow entities to determine when to expect their individual data requests (phase) and what data will be required (category).

    Business Practice Manual (BPM)

    Entity Category and Phase Listing

    CAISO Transmission Planning Website

    TPL-007

    TPL-007 establishes planning criteria for induced currents caused by geomagnetic disturbances. The standard is applicable to facilities using transformer(s) with a high side, wye grounded winding operated above 200 kV and can require both submittal of general geomagnetic data (R2) and thermal impact assessments (R6) depending on results of Planning Coordinator analysis.

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    VAR-501-WECC

    VAR-501-WECC requires applicable entities within the WECC region to confirm performance settings and characteristics of Power System Stabilizers (PSS). NAES provides physical testing and reporting services to address WECC’s specific PSS requirements.

    PERSONNEL PERFORMANCE, TRAINING AND QUALIFICATIONS

    PER-006

    PER-006 requires Generator Operators to provide training to personnel who are responsible for the Real-time control of a generator. NAES has developed specific protection system training materials suitable for compliance with the Standard and provides this training both on and off site

    PROTECTION AND CONTROL (PRC) STANDARDS

    PRC-001

    PRC-001 requires entities to coordinate protection system changes with other affected parties. NAES offers both procedural documentation and engineering services to establish the required coordination for both PRC-001 and PRC-027.

    PRC-002

    PRC-002 requires the installation and operation of disturbance monitoring equipment (DME) for applicable entities. NAES can assist with the design and installation of DME as well as ongoing compliance support.

    PRC-019

    PRC-019 requires applicable entities to show coordination between voltage regulating controls, limiters, equipment capabilities, and protection settings. NAES produces PRC-019 specific coordination studies for both traditional generators and renewable projects to establish compliance with the Standard.

    PRC-023

    PRC-023 requires load responsive protective relays be set according to criteria within the Standard to ensure settings do not limit transmission loadability. NAES provides full engineering analyses to maintain compliance with this Standard.

    PRC-024

    PRC-024 requires applicable entities to ensure generator protective relays do not trip within predefined frequency and voltage limits. NAES can complete protection settings analyses and provide compliance documentation that clearly identifies protection settings as they relate to NERC’s “no trip” zones.

    PRC-025

    PRC-025 establishes minimum settings requirements for load-responsive relays protecting generators, step up transformers, and auxiliary transformers. NAES utilizes predefined calculation options as well as simulations to determine a facility’s compliance status and development of new relay settings if required.

    PRC-026

    PRC-026 requires applicable entities to perform load responsive relay settings analyses based on criteria identified within the Standard. Entities are typically notified by the Planning Coordinator when an analysis is required. NAES performs all required studies to establish compliance.

    MODELING, DATA, AND ANALYSIS (MOD) STANDARDS

    MOD-025

    MOD-025 requires Real and Reactive Power capability testing for individual generating units over 20 MVA or facilities with over 75 MVA of generation capacity. NAES offers site specific test procedures and/or complete onsite testing services to meet the requirements of this standard.

    MOD-026

    MOD-026 requires verification of excitation or volt/var control dynamic models through utilization of either system disturbances or physical testing. NAES offers full testing and modeling services to meet the requirements of this standard.

    MOD-027

    MOD-027 requires verification of governor or active power/frequency control dynamic models through utilization of either system disturbances or physical testing. NAES offers full testing and modeling services to meet the requirements of this standard.