APS appreciates the opportunity to provide comments to the recently posted RC Data Request and Specification V13.1. In particular APS makes specific comments regarding Request Number 1.12.
As the text for request 1.12 starts, this request is asking for the "Status" of Non-RAS devices that perform automatic post-contingency action..." But the new clarifying language states "and current Protection System status when functionality is affected", which APS finds incongruent with the Data Transfer Method requested, ICCP. This is true for two reasons. First, the plain reading of this additional clarifying language would lead one to believe an entity only provides the status when "functionality is affected" and seemingly no other times. Also, when reading the guidance provided for this item in the accompanying document, the trigger for when a "Current protection system status" is affected is when "normal fault clearning zones or Contingency definitions are impacted." What "Status" is one to provide via ICCP when these conditions or contingencies have changed?
If the intent of this change is to clearly demonstrate where Peak is being provided "current Protection System status when functionality is affected", we believe Peak already has a documented request for this data. Request Numbers 5.10 and 5.11 provides Peak all the planned and unplanned outages of telemetering and control equipment of 30 minutes or more in duration. These outages of this telemetering and control equipment provides Peak with the current status of Protection Systems when their functionality is affected. If Peak does not believe that language is clear enough, APS would recommend clarifying the intent in these requests instead of 1.12.
If Peak continues to believe that Request 1.12 is the correct location for this clarification, APS would ask for additional clarifications around how to communicate non-normal fault clearning zones or impacted Contingency definitions for Protection Systems via ICCP. And if Request 1.12 continues to contain this information, APS believes Request 6.19 needs to be assessed for likely modification as well.