 This is Guillermo Salatia, your host here at Perspectives on Energy, here at Things at Kauai. And today we'll be discussing the challenges, like navigating NERC compliance challenges when it comes to integrating battery storage systems into existing generating facilities. So thank you again, welcome. And I am the Director of International Services at HSI. And earlier this week, we had the opportunity to actually have a webinar on this particular topic and definitely looking forward to actually having more discussions on this. And one of the things that there's a lot of concerns and anxiety regarding how NERC compliance is going to impact these different utilities or even the generator owners. So hopefully here we'll be able to describe what those challenges are and how to hopefully address them as we move forward. All right. So next slide please. Okay. So the integration of battery energy storage systems with BESSes. All right. In this case, one of the biggest issues of course now is the fact that up until now they had a threshold of 75 MBA or McWatt in that case. And there was a certain, I think it was 100 KB or above. Now they've lowered that threshold. NERC is making it 25 MBA. And it's of course, so now your overall facility aggregate output, if it's 25 MBA or above that you're definitely subject to these new standards, right? At the same time, you're also, if you're connecting to a transmission facility that is 60 KV and above, so used to be 100, now it's 60 kilovolts, then you're definitely now within the scope of NERC compliance requirements. So what does this all mean, right? So a lot of different entities have been considering whether they want to get into this business. Others have been thinking whether they want to divest and get out of this business. The truth is, it's really not that hard to be a NERC compliant. It just requires a little bit of planning, understanding the NERC standards, understanding what the requirements are, and just getting the right documentation. So hopefully we'll be able to outline some of the issues that are typically encountered in these particular challenges. Next slide, please. All right, so there's two different ways to actually incorporate into this, right? So one of the challenges is the, of course, a modified startup approach. When you're looking at either incorporating the BSSS or the, it should be treated as a modified startup process, or you can look at it as existing facility procedures, we need to be adjusted to account for the unit characteristics, right? So either it's, you're looking at starting from scratch when it comes to installing a holy facility, that will be probably the ideal case. But if you already have something existing that's already running, it's already gone commercial, that in this case you may need to revisit those procedures, those documentation, that evidence, and be able to account for that particular characteristic in those assets. What does that even mean, right? So let's go to the next slide. So looking at the existing procedure update, right? One of the things that we're looking at here is understanding, right? There's different standards that are impacted. So SIP, COM communications or TOP3. So let's go through each of these, right? So when it comes to SIP, of course, critical infrastructure protection, you're looking at cybersecurity, who has access to these sites. Now mind you, any of these facilities that's connected to the bulk electric system, which is these transmission elements have tied to the general important to the general grid, right? Potentially you could actually impact the reliability and performance of the grid in general by affecting these assets. So that's why SIP standards become important, whether it's who gets training, access, firewalls, and pretty much everything that impacts the general facilities for a typical generation will impact this. Now in this case, for example, identifying, for example, whether you're at your high impact or low impact facility, whether you're a facility that is close to, for example, a larger power plant or even close to a vital transmission system, that'll make you more of a medium or higher impact facility. If you're somewhere pretty remotely far off, chances are you may be a lower impact facility in this case, right? The other interesting thing here as well is that you also access. If you have, for example, physical access to the facility versus cyber access facilities, those are things that are going to have to be examined that understood. In most cases, you're already doing that. A lot of it is basically good housekeeping when it comes to IT and cybersecurity. You're doing the same thing when it comes to physical security. But if some of these places right now you may require, for example, electronic badge access, logging in, logging out, and then, which most places already have, just the old day of basically just putting a simple lock in the fence and then leaving the actual control house unlocked. It's no longer the case, but in most cases, most of us have a monitored alarm system, monitored electronic access system. Most places already have that in place. So that will be an example of cybersecurity, right? Expansion of physical and electronic access, right? When it comes to com communication standards, there's two of them. Com 001, Com 002. Here, for example, you have the initial training. If you have an operator that is going to be receiving instructions from a control center somewhere else, from the balancing authority or from the reliability coordinator, you're usually a balancing authority or transmission operator while they need to be trained on how to receive and respond to operating instructions or how to communicate with these different entities. And usually it's a protocol they follow on three-part communication. The other thing that Com 001 may have the need to actually have testing or have a primary and backup training or primary or bike communications capabilities so they can actually have a phone call or be able to be accessed at any given time. In some cases, actually just having simple emails usually suffices, right? The idea is to actually have a defined primary communications and then maybe participate in the whole backup. Most everybody has a backup communication capability. Here, they don't even require to test them. You just require to have one. For the Com 001, usually all they need is initial training. Basically, you get training one time for the operators before they're put on the job and ready to receive operating instructions. So something is not that onerous. A lot of cases, if you already have personnel on site, just adding one of these BE SSS to your facility just may not even change anything because they already have all that training. So really all that is is training new operators. The TOP3 scope, in this case, is usually a data spec. What sort of data you're going to provide to your local entities, your host entity, the transmission provider, or even the reliability coordinator. So that information is usually the same thing that everybody else offers. And it's already telemetry that you're going to have provided on your panels in your system anyway. So the information you're going to be providing is information you want to see anyway. So that's usually already in that whole package and module that you're doing when you buy one of these new facilities. It was an existing facility. Chances are you pretty much already have that. You're just really not providing it to these local entities. So getting that up to speech shouldn't be too difficult. The other one is next slide, please. So EOP4, usually that means event reporting. That's a lot of cases, right? Part of that, we've got reporting plan. All you have to do is make sure that this new facility is included in the entity's event reporting procedure, whether it's the TOP or the BA. In some cases, if you're reporting, for example, say you had an incident or somebody broke the fence and came in to steal stuff, or you have, for example, a problem in the facility, meaning that it's no longer available because of damage that you would be reporting to the BA or the TOP anyway. So in this case, it's something you're probably already doing. But again, when it comes to the EOP4, that's something that you're going to be working with when you're your local transmission provider or your balancing authority. So make sure you have that ready. EOP11 is another really, really interesting, very timely challenge in this case. Because most facilities, for example, have had issues with winterization. We just had a recent freeze in the mainland over the last couple of weeks. Now, in Hawaii, that's not really a problem. In fact, most facilities in Hawaii aren't even subject to this whole presentation because of the fact that you don't have any nerve standards out there. However, you do have some IEEE, FERC, and Department of Energy requirements that are usually parallels or analogies to these particular requirements. So going back to EOP11, in this case, with all of these winterization, it just means you have to have a procedure that you've developed, that you've tested, that you've trained everybody on. And one of the questions is, when it comes to these particular batteries, really is, what's the threshold and temperature that these devices will just cease to function adequately, or they're going to have issues operating? So that's the things you need to understand. Other cases, you have problems with cooling. So some of these battery facilities have issues with cooling. Others actually have assault and water, for example, that presents another problem in these extreme weather events. So the whole point is to make sure that you have all these parameters clearly defined, understanding what these temperature thresholds are, and to make sure that those are reported to your host, balancing authorities, or your host transmission operators. FAC1 and FAC02, this is how you interconnect to your host entities. So you may be subject, you will be subject to these new, well, these old standards that have been around for a while, but all that is really is how you interconnect. Now, the fact of the matter is that, if you're already in an existing facility, chances are you already have all of that done, and you have paperwork to prove it. It's important that you have paperwork to prove it. Otherwise, you may need to get for yourself some updates with your local transmission operators, and transmission owner, right? Same thing with the balancing authorities, right? You're understanding how they were notified of your output when it comes to megawatt MVA, and the real reactive power capabilities to your different host entities. Next slide, please. Okay, the next one, vegetation management, right? So if you're already hooked up to a transmission facility, chances are that's already being managed for you, but if you own the transmission assets, if you own the transmission line that connects your facility to another transmission area, then you will be subject to that particular standard of the requirements they're in. So transmission management, vegetation management, really is just a matter of making sure you follow the guidance when it comes to maintaining vegetation away from the transmission right away. So in this case, it becomes a problem. Now, when it comes to substations that you may have, you of course have to maintain the perimeter or that substations prevent vegetation of getting into your energized assets in that station. IRO 10 and ITO P3, again, from the previous slide, it's just what it is, is the data exchange spec with the RC, the TOP and the VA. So it's the reliability coordinator, you're gonna share data with the transmission operator and of course the balancing authority. So IRO pertains to the RC, TOP pertains to the TOP and VA. And there's even a BAL standard and there's somewhere to talk about how you share data with your balancing authorities. MLD standards in this case, right? What it is really is to understand all the testing that goes on with these particular facilities, usually when you go commercial, right? It's not when you're testing or connecting to the web, it's just a net for the first time and putting on megawatts, but rather when you go commercial, when you're actually selling those megawatts and megawatts is what everybody matters. So at that point, you need to make sure all of your testing has been completed and you are now entering your whole, they call maintenance cycle where it can be five, 10 years when you do all the other testing. So again, all of that needs to make sure you are completed and then of course verification of these tests need to be completed within a year of going commercial. So my advice there usually isn't the fact that you wanna get that done right around the time you go commercial before you actually do testing after the fight because that's usually where most of the contractors leave. A lot of cases, the contractors installing some of these like battery storage facilities are just contractors and they're once we're done with you, they wanna rush and work on the next project after that. So it's important to make sure you put it in the contract and part of the commissioning requirements that they provide you with the adequate documentation, adequate testing records and all that information before they get their final payment. So that's something that could be incorporated into a contract to make sure you get everything you need. But NERC is still pretty lenient when it comes to the whole 365 days, right? Within going commercial, but in reality, it's something I don't always advise and I make sure I give everybody enough time to make sure that they have all their documentation and evidence ready at this point. Existing procedure update, right? So the relay, the PRC is protection and control and relay standards. Here, for example, you gotta make sure that you have all of your, whether the loadability, you have the performance. So one of the things that they always wanna know about of course is your ability to ride through a disturbance, whether it's a voltage or a frequency disturbance. And these battery storage facilities, usually now they come with the settings that are made according to the standard, but it's important to get those tested and make sure that they are the latest spec, right? And then of course, the other thing of course is that they have that right documentation showing that they were tested indeed. VAR 032, of course, that is your voltage schedule. Make sure that if your facility is going to be able to support the voltage, whether you're putting out VARs or you're absorbing VARs, there's a procedure in place to be able to report that. The last one for, as I was talking about that earlier, right? One of the issues you have there of course is the contours and vendors are available after commissioning day, commercial day to respond to questions. One thing I always ask for here is to make sure you have everything you need right before they get the final payment because it gets to the point where it's really difficult to track everybody down if there's a missing piece of evidence that you don't have that you need for an audit. The other important thing is that I've been in a few projects where I've noticed that the contractor, all they did was they got all the test evidence, all the prints, all of the, what they call station checks where they basically get a copy of the print and they're basically with a color highlighter or a color pen or pencil, they're checking out for all different parts of the circuit, which is important in order to do it. That's the way I used to do it when I was in the field. Problem is that all of that gets rolled into one long PDF because it got scanned together and then they end up giving you a huge file that would know we're just not searchable. So that becomes a problem. So my advice always is to, if they have these prints that are all written on sort of thing, that would be a whole separate file or set of files and then the actual test records are like a nice clean PDF that's searchable and most of the test equipment out there, test software, produce very nicely searchable documentation to prove that your tests were successful. The other issue that we've seen is that sometimes they'll get lazy or cute with some of the station names and locations and it's important to have the station clearly identified, to have the actual asset clearly identified if it's a certain breaker or a certain switch that you're testing or certain panel to make sure that panel will nominate, that panel information is clearly indicated in that test record because then eventually it's an auditor could go ahead and doubt your test results that they don't match the panel you're actually being audited on. So it's important to remember that. Next slide, please. So a little bit more of a PRC file compliance and this is all I was saying earlier, this is one of the bigger challenges, right? When it comes to having, but NERC has already provided you with the actual template, the actual spreadsheet to populate all of these like facilities. So in this case, it's just a matter of having all the correct test evidence done for all of your relay equipment, all of your panels and in a nice and clean searchable fashion. And then of course, all of the associated diagrams, right? That when they did their station checks, whether it's DC elementary or AC elementary, so AC is gonna be all your different current transformer circuits versus the DC elementary is all your relaying, oftentimes, right? Those like I said earlier have a lot of check marks on them where they were done by hand. And so that's the case and they're scanning that as evidence for make sure you have that in a file that's not been intermingled with the other PDFs that need to be searchable. So very important things. Next slide, please. Slide nine. Okay. So one of the things that are interesting here is like if you're going to have these assets, right? And into your existing, for example, say you have a generating facility that has a combined cycle plans or something else and then you're gonna add this and then you're gonna connect it to this one of the same bosses and then become integrated system. Maybe it's gonna be standalone. You're looking at your own substation and your own transmission line. That's an interesting thing and your approach will be different in most respects, but similar in others, right? So remember, these batteries have their own protection system components. They have their own panels, they have their own breakers, they have their own devices, right? So one of the important things to understand, right, is whether you're going to be tying into the same switch chart. In this case now, this is for new construction. If you already have somebody that's existing, that's already a move point and that ship has sailed. Now it's a matter of making sure you have the correct evidence to show that you adequately tested all these devices and you have an adequate test cycle, which is periodic, right? And your procedure's baked in, right? Now if you're building something new, in this case, then your decision you're making will impact how you operate this system. Nothing wrong with either one, right? You can install one of the things I've seen. They've installed a battery set to a power plant. That thing, I think it was like a 20 megawatt capacity and I'm sorry, a 10 megawatt capacity. And this battery set was really used for Blackstart and was really innovative and helpful. And this allowed to do grid forming operations. Now once the combustion turbines that were attached to that same bus were up and running, that battery set then became a load to balance those combustion turbines output. And then they had the little island at that point and then they were able to build their grid from there. Next slide please. Okay, so commissioning dates very important. In this case, when you go commercial, when you're out there producing, setting power officially, that's when you have your commercial operations date or your COD date, right? And it's very important to actually have those dates and clearly identified because at that point, right? You have your whole, your testing period of the city coming to a fact, whether it could be every year, every five years, every six years, every 10 years, right? It is very important to actually have that very well coordinated in this case, right? The other thing is whether you commissioned the whole site, you commissioned parts of the site as another thing that will also affect when you're able to carry out testing and when you will carry out testing. So very important thing to understand these are commercial dates. So when you go commercial, that's your official commissioning date in this case. Next slide please, 11. Okay, the rating scope in this case, right? One of the things that's very interesting in this case is like you gotta remember it went from 75 megawatts to like 25 and in this case, now you're pushing out the megawatts that if you have been commercial for a while and now all of a sudden this threshold move beneath you, now you're suddenly, of course, it also needs to be connected to a 60 KV or above. Now all of a sudden you are subject to these standards, right? In this case, one of the things to consider right now, if you're deciding to build facilities that are going to be limited to under the threshold, that's up to you, but remember in the future, NERC and FERC may decide to actually change this threshold once again, so you can be operating four or five years from now and everybody decided to just build facilities that are right beneath this threshold and then NERC decided to go ahead and move the goalpost once again, now you're back into the situation you are now. So again, things to understand when you install your facilities to your existing facility, you may need to reevaluate how this impacts your output whether it's bars or how you support the voltage in this case. Okay, the other thing here, the last one that we're talking about is PER-066 and this is important regarding generating facilities and the personnel that operate those facilities. So in this case, for example, if you already have a generating facility and then you're adding this BESS, you may need to update your training and let them know how the facility will impact the bulk electric system. If you already have a generating cyber personnel, you should have already had this training done, so just a matter of updating it and to let them know what adding this new battery storage system will do and what impact that will have in the system. If it's a brand new site, then of course, you need to train and educate your operators on how the operation of this battery so that the services can have an impact on the bulk electric system. So in this case requires, for example, a lot of coordination and planning and to understand how they will have an impact on the grid that they're connecting to. So this is pretty much it, last slide. And then if you have any questions, if you want to leave some comments below on the video or if you're free to look us up on HSI or email me directly or send me a message, we'll be happy to answer them. So again, a little short one, we had a similar video a few months ago on what was looming and here it is, as we grow closer, we're already looking at the particular standard. So thank you again for joining us and go ahead and like and subscribe. And I encourage you to ask questions and add comments so you can follow up anything you have questions with. Right, thank you so much and have a wonderful afternoon.