1. NERC Footnote b / 12 – Load Loss
Joe Seabrook Electric Transmission Contracts

2. TPL-002-0, footnote b and TPL-001-3, footnote 12
Non-Consequential Load Loss: Non-Interruptible Load loss that does not include: (1) Consequential Load Loss, (2) the response of voltage sensitive Load, or (3) Load that is disconnected from the System by end-user equipment. (Defined in TPL-001-3)
Footnote b and 12 is about conditional requirements for some contingencies when Non-Consequential Load Loss might be allowed
Footnote b and 12 with respect to some N-1 outages, and generator followed by N-1 outages
Footnote 12 in TPL is applied for the same contingencies in HV and EHV (above 300 kV)

3. TPL-001-3, footnote 12, Table 1 P1 – Loss of one of the following:
Generator
Transmission Circuit
Transformer
Shunt Device
Single Pole of a DC line
P2 – Opening of a line section w/o a fault
P3 – Loss of generator, system adjustments, then loss of:

4. TPL-001-3, footnote 12, Table 1
Note that for P2, Non-Consequential Load Loss is not allowed for EHV for:
A Bus Section Fault
A non-Bus-tie Breaker Internal Breaker Fault
But could allow Non-Consequential Load Loss for EHV for loss of:
Generator
Transmission Circuit
Transformer
Shunt Device
Single Pole of a DC line
Opening of a line section w/o a fault

5. TPL-001-3, footnote 12, text
12. An objective of the planning process should be to minimize the likelihood and magnitude of Non-Consequential Load Loss following Contingency events. However, in limited circumstances Non-Consequential Load Loss may be needed to ensure that BES performance requirements are met. When Non-Consequential Load Loss is utilized within the planning process to address BES performance requirements, such interruption is meets the conditions shown in Attachment 1. In no case can the planned Firm Demand interruption under footnote 12 exceed ‘x’ MW.

6. The Conditions shown in Attachment 1.
Attachment 1 labeled “I. Stakeholder Process”
Meetings for all affected stakeholders
Requirements for notifications
Procedures to involve stakeholders
Dispute resolution for questioning and concerned stakeholders.
Extensive reporting requirements
Future plans to mitigate Firm Demand interruption
Alternatives considered
Regulatory approval required if EHV, or if ≥ 25 MW
Regional Entity verification of no Adverse Reliability Impact is required.

7. Conclusion
An alternative would be to leave customers on radial connections.
‘x’ MW is not defined in:
“In no case can the planned Firm Demand interruption under footnote 12 exceed ‘x’ MW.”
The SDT is expected to define ‘x’ MW