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This document is the Fire Life Safety (FLS) Standard Design for FAA terminal facilities. It provides requirements and code references for the design of FLS systems, including emergency lighting, fire pumps, elevators, fire alarm systems, and stairwell pressurization. The standard specifies that a dedicated FLS distribution bus must be incorporated into the power distribution system, with separate transfer switches feeding emergency distribution panels, fire pumps, and elevators. It also addresses load shedding considerations for the FLS system. The document includes conceptual drawings for incorporating the FLS bus into various standard FAA power distribution system configurations. This standard must be applied to all new FAA terminal facility design and construction projects, and coordination with the FAA is required when upgrading existing facilities.

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Text version

Task Order 0025

Terminal Facilities Standard Design

FLS Bus Study

June 2, 2021

Fire Life Safety and Electrical Work Group Final

FLS Standard

TABLE OF CONTENTS PAGE

SECTION 1.0 EXECUTIVE SUMMARY

1.1 General Information

1.2 Purpose

1.3 Goal

1.4 Application

SECTION 2.0 CODE REQUIREMENT

2.1 Applicable Codes and Standards

2.2 General Information per Industry code and standards

2.3 Life Safety Systems Standard Requirements

2.4 FAA-Specific Fire Life Safety Systems Requirements

2.5 FLS Code References Table

SECTION 3.0 FAA FLS SYSTEM REQUIREMENT SUMMARY AND

CONSIDERATION

3.1 Fire Life Safety (FLS) Distribution Bus Design

3.2 Load Shedding Consideration

SECTION 4.0 APPENDICES

APPENDIX – 01

FLS Distribution Bus Concept Drawings

SECTION 1.0 EXECUTIVE SUMMARY

1.1 General Information

This design guideline was developed to ensure the FAA required Fire Life Safety (FLS)

Bus and associated designated load are incorporated into the power distribution systems of the Air Traffic Control Towers (ATCT) and Terminal Radar Approach

Control (TRACON) facilities based upon Technical Operations Services (AJW-24) and the FAA FLS workgroup inputs.

The primary focus of this standard is to illustrate the arrangement of commercial utility and standby power sources for fire pumps, elevators, stair pressurization equipment, egress lighting, and fire detection/alarm systems per standard and code requirements, and FAA Fire Life Safety design requirements.

This document captures the unique FLS design criteria (at a conceptual level) from evaluation and ongoing discussion with power services and the FLS workgroup.

Concept drawings in Appendix 01 include a Fire Life Safety (FLS) Bus added to four standard FAA power distribution system: Critical Power Distribution System (CPDS)

Type Basic, CPDS Type Radial, CPDS Type 1, and CPDS Type 2. The type of CPDS and associated detail standard design single line diagram for each project shall be coordinated with FAA.

Refer to Terminal Facility Design Standard (TFDS) Chapter 14 – Vertical Conveyance for elevator requirement.

Refer to TFDS and standard schematic drawings for power distribution system.

1.2 Purpose

The purpose of this design guideline is to provide the Design Engineer with FAA design requirements and code references to identify building systems that are required to be supplied from the FLS bus. This FLS design guideline also provides references on fire rating requirement of rooms that house and feed the FLS system and equipment.

1.3 Goal

The goal of this FLS guideline is to ensure code compliant and FAA specific fire life safety features/requirements are implemented in a consistent standardized approach.

The fire life safety feature includes:

• Emergency lighting equipment.

• Fire pump electric motors.

• Elevators

• Fire alarm detection system

• Stairwell pressurization system

1.4 Application

FLS standard shall be applied to all new terminal facility design/construction projects.

Where existing facilities require electrical system upgrade, coordination and investigation to existing system and site condition shall be performed. Confirm and verify feasibility of the FLS upgrade for existing facility with FAA.

SECTION 2.0 CODE REQUIREMENT

2.1 Applicable Codes and Standards

International Building Code (IBC), 2021 Edition

International Fire Code (IFC), 2018 Edition

NFPA 20, Standard for the Installation of Stationary Pumps for Fire Protection, 2019

Edition

NFPA 25, Standard for the Inspection, Testing and Maintenance of Water-Based Fire

Protection Systems, 2020 Edition

NFPA 70, National Electrical Code, (NEC) 2020 Edition

NFPA 72, National Fire Alarm and Signaling Code, 2019 Edition

NFPA 101, Life Safety Code, (LSC), 2021 Edition

NFPA 110, Standard for Emergency and Standby Power Systems, 2019 Edition

FAA Order 6480.7E, Airport Traffic Control Tower (ATCT) and Terminal Radar Approach

Control (TRACON) Design Policy

FAA Order 6030.20G, Electrical Power Policy

FAA Order 6950.2E (CHG-2), Electrical Power Policy Implementation at National

Airspace System Facilities

Institute of Electrical and Electronics Engineers (IEEE), Standard 446-1995, Recommended Practice for Emergency and Standby Power Systems for Industrial and

Commercial

2.2 General Information per Industry code and standards

Chapter 27 of the IBC establishes the requirements for electrical installations within buildings and structures [IBC 2701.1]. Section 2702.2 identifies where emergency and standby power systems are required to be provided, e.g. elevators and platform lifts

[IBC 2702.2.2]; exit signs [IBC 2702.2.6]; means of egress lighting [IBC 2702.2.14];

smoke control systems [IBC 2702.2.17].

For detailed design and construction requirements for the electrical components, equipment and systems, the IBC references the NEC. The NEC categorizes these systems into three types:

1. Emergency systems (Article 700);

2. Legally required standby systems (Article 701); and

3. Optional standby systems (Article 702).

Emergency Systems: According to the IBC Commentary, emergency power systems are intended to provide electrical power for life safety systems, such as egress illumination, emergency communications, and fire pumps. In other words, emergency power is required when the loss of normal power would endanger occupants. One of the key features of emergency systems is the required response, or transfer time, of

10 seconds or less. Sources of power for emergency power systems [NEC 700.12] include storage batteries, generators, uninterruptible power supplies, separate services, fuel cell systems, DC microgrid systems, and unit equipment.

Standby Systems: According to the IBC Commentary, standby power systems are intended to provide electrical power for loads not as critical as those requiring emergency power. Standby power loads include smoke control systems; certain elevators (fire service access elevator, elevator as means of egress); certain hazardous material operations; smoke-proof enclosures; illumination; heating, ventilating and air-conditioning (HVAC) systems; refrigeration and sewage pumps. Standby power systems must provide power within 60 seconds of failure of primary (utility) power.

Sources of power for standby systems [NEC 701.12] include storage batteries, generators, uninterruptible power supplies, separate services, fuel cell systems, DC microgrid systems, unit equipment and a source that is taken from a point of connection ahead of the normal service disconnecting means. Where acceptable to the authority having jurisdiction, connections located ahead of and not within the same cabinet, enclosure, or vertical switchboard section as the service disconnecting means shall be permitted. The legally required standby service shall be sufficiently separated from the normal main service disconnecting means to prevent simultaneous interruption of supply through an occurrence within the building or groups of buildings served [NEC

701.12(F)].

Optional Standby Systems: Optional standby systems are those systems intended to supply power to public or private facilities or property where life safety does not depend on the performance of the system [NEC 702.2]. Optional standby systems are those in which failure can cause physical discomfort, serious interruption of an industrial process, damage to process equipment, or disruption of business. For example, failure of an optional standby generator at a frozen food processing plant [NEC Handbook].

This FLS design standard focuses on Emergency and Standby systems.

2.3 Life Safety Systems Standard Requirements

Various sections of the IBC establish which building systems and equipment are required to be provided with either a standby power system or an emergency power system.

IBC Requirements:

Per IBC sections 412 and 2702, the following systems and equipment in an ATCT are required to be provided with standby power and/or emergency power:

1. Elevator;

2. Fire pump

3. Lighting for egress illumination

4. Automatic smoke detection systems;

5. Fire command center

6. Smoke removal system

In addition to the code requirements, the fire life safety systems shall also meet the requirements indicated in section 2.4.

2.4 FAA-Specific Fire Life Safety Systems Requirements

A dedicated fire life safety electrical distribution is required with separate transfer switches that feed emergency distribution panel(s), fire pump, and elevator equipment.

The emergency distribution panelboard is originated from the facility dedicated “FLS” distribution bus.

The power pathway is provided to serve classified FLS and emergency loads per

NFPA-70, Article 700, Emergency Systems. FLS and emergency loads include:

• Exit signage, egress lighting;

• Facility emergency task illumination;

• Fire pump;

• Automatic smoke detection systems;

• Fire Command Center

The following system has been elevated to FLS system for FAA mission requirement:

• Stairwell pressurization system,

• Elevator(s).

The FLS and emergency distribution system overcurrent protective scheme must be designed to achieve the selective coordination requirements per article 700. A selectively coordinated overcurrent protection scheme that localizes and minimizes the extent of an interruption of power due to the opening of a protective device is a critical safety element. Selective coordination is to be carried through each level of distribution that supplies power to the emergency system.

Selective Coordination Definition per NFPA70:

Localization of an overcurrent condition to restrict outages to the circuit or equipment affected, accomplished by the selection and installation of overcurrent protective devices and their ratings or settings for the full range of available overcurrents, from overload to the available fault current, and for the full range of overcurrent protective device opening times associated with those overcurrents.

The table in section 2.5 summarizes the requirements and code references for the fire life safety systems.

2.5 FLS Code References Table

Line

Item

No.

System per IBC

FAA Standby

Power

Systems

Classification1

FAA

Power

Bus2

Code Reference

Code/Stds Version Section

1 a.

Stair

Pressurization

System

Fire/Life

Safety

Standby

Power

Systems

(FLS-SPS)

Fire / Life

Safety

IBC 2021

412.2.3 b.

Automatic

Smoke

Detection

Systems

412.2.3.1 c.

Fire Command

Center 412.2.3.2

412.2.3.3

IBC 2021

909.11

909.20.7.1

909.20.7.2

IBC 2021 911

NFPA 101

(LSC)

2021 7.2.3.12

Item

No.

System per IBC

FAA Standby

Power

Systems

Classification1

FAA

Power

Bus2

Code Reference

Code/Std. Version Section

2 a. Exit signs

Fire/Life

Safety

Standby

Power

Systems

(FLS-SPS)

Fire / Life

Safety

IBC

1008.3 b.

Means of egress illumination

1008.3.1

1008.3.2

1008.3.3

IBC 2021 1013.6.3

NFPA 70 2020 700.17

NFPA 101

(LSC)

7.9.2.1

7.9.2.2

3 a.

Fire Service

Access Elevator

Fire/Life

Safety

Standby

Power

Systems

(FLS-SPS)

Fire / Life

Safety

IBC 2021 412.2.5

IBC 2021 2702.2.2

b.

Elevator

Machine Room

IBC 2021 3003

IBC 2021

3007.4

3007.5.2

3007.7

3007.8

Systems

Classification1

FAA

Power

Bus2

Code Reference

Code/Std. Version Section c.

Elevator as part of Means of

Egress

Fire/Life

Safety

Standby

Power

Systems

(FLS-SPS)

Fire / Life

IBC 2021 1009.4

**Refer to TFDS chapter 14 – Vertical

Conveyance for elevator requirement**

NFPA 101

(LSC)

2021 7.5.4.7

4 a.

Fire Alarm

System Fire/Life

Safety

Standby

Power

Systems

(FLS-SPS)

Fire / Life

IBC 2021 907.2

NFPA 72 2019

10.6.3.2

10.6.4.2

10.6.11.3.

1.1

10.6.11.3.

1.2

5 a. Fire pump

Fire/Life

Safety

Standby

Power

Systems

(FLS-SPS)

Fire / Life

IBC 2021 913.1

b.

Fire pump supply conductors

NFPA 70 2020

695.3 (A)

695.3 (B)

695.6

NFPA 20 2019 9.6.2

Systems

Classification1

FAA

Power

Bus2

Code Reference

Code/Std. Version Section

6 a.

Emergency system feeder conductor

Fire/Life

Safety

Standby

Power

Systems

(FLS-SPS)

Fire / Life

Safety

NFPA 70 2020 700.10

a.

FAA NAS

Equipment

NAS

Standby

Power

Systems

(NAS-SPS).

Critical

FAA

6030.20

G

3-4, 4-2 b.

Facility Normal

Lighting &

Equipment

Essential 3-4, 4-2

1 Classification of FAA Standby Power Systems per FAA Power Policy 6030.20G:

• Fire/Life Safety Standby Power Systems [FLS-SPS] = NEC Art 700 [Emergency System];

• NAS Standby Power System [NAS-SPS] = NEC Art 701 [Legally Required Standby Systems]

2 Power Bus Description per FAA Power Policy 6030.20G:

• Fire/Life Safety Bus – Provide unconditioned AC prime and standby power to approved Fire/Life Safety systems and equipment. [Commercial Utility + Standby E/G power source]

• Essential Bus – Provide unconditioned AC prime and standby power to approved FAA and non-FAA systems and systems. [Commercial Utility + Standby E/G power source]

• Critical Bus - Provide conditioned, uninterruptible AC prime and standby power to approved NAS system and equipment, non-NAS FAA sensitive electronic processing equipment, and non-FAA system for site support. [Essential + Uninterruptible Power Supply (UPS)]

SECTION 3.0 FAA FLS System Requirement Summary and

Consideration

3.1 Fire Life Safety (FLS) Distribution Bus Design

1) The FLS Distribution Bus Concept design included in Appendix 01 shall be utilized as the basis of design for all new FAA Terminal Facilities. System configuration (Standard Radial, CPDS, etc) shall be coordinated and determined with the FAA.

2) Provide dedicated automatic transfer switch (ATS) for all elevators(s), Fire

Pump and Emergency Distribution Panelboard.

3) Battery-powered lighting equipment is used to achieve compliance with NFPA-

70 class emergency systems and to ensure continuity of FAA operational mission within the facility in the event of failure to either commercial power or

E/G supplied standby power systems. Battery powered equipment is the most feasible method to mitigate the potential risk of losing facility safety lighting in the event of total loss of power.

4) Battery lights shall be provided in the exit stairwells, egress path, and where deemed necessary for the facility operation.

5) FAA requires additional battery backup powered lighting in addition to code required safety lighting for following areas:

• E/G room,

• Main electrical room, and

• UPS room

6) The use of generator transfer device (GTD) or other technology may be proposed to the FAA for review and concurrence on a case-by-case basis.

3.2 Load Shedding Consideration

Load shedding should be considered as a last resort and only after fire pump is being right sized for the new facility/design. Load shedding may be employed if the fire pump motor HP rating results in significant increase in E/G size. Load shedding operation shall be initiated by the fire pump ATS/controller’s load shed contact.

The following scenarios shall be considered when load shedding sequence of operation is being developed:

Scenario 1: Loss of commercial utility power -> E/G start while fire pump in off state.

Scenario 2: Loss of commercial utility power -> E/G start while fire pump in run state.

Scenario 3: FAA facility load is connected to E/G while fire pump is connected to utility in run state -> loss of utility -> fire pump in run state to transfer to E/G

Sequence of transfer / operation of facility ATSs, including ATS supplying FLS distribution panelboard, fire pump, and elevators, shall be considered when load shedding is required.

SECTION 4.0 APPENDICES

Appendix – 01: FLS Distribution Bus Concept Drawings

APPENDIX – 01

FLS Distribution Bus Concept Drawings

Appendix – 01: FLS Distribution Bus Concept Drawings

Tab No. Description

Tab-01 FLS Distribution Bus – Basic Power Distribution

Tab-02 FLS Distribution Bus – CPDS Typical Radial Distribution

Tab-03 FLS Distribution Bus – CPDS Type 1 Distribution

Tab-04 FLS Distribution Bus – CPDS Type 2 Distribution

The FLS Bus configuration drawings indicated above depict the FAA standard Basic and CPDS power distribution systems.

Basic Power Distribution / CPDS Typical Radial Distribution – One commercial utility power feed plus a standby engine generator. A single essential automatic transfer switch provides both commercial and standby E/G power to the facility essential main distribution panel. The entire facility is backed up by the E/G power source. FLS bus is originated from the E/G distribution panel.

CPDS Type 1 Distribution – One Commercial utility power feed plus one standby engine generator. Two essential automatic transfer switches provide both commercial and standby

E/G power to two facility main essential distribution panels. Normal power distribution panel without E/G backed up power is available. FLS bus is originated from the E/G distribution panel.

CPDS Type 2 Distribution – Two Commercial utility power feeds plus two standby engine generators and associated distribution panels. Two essential automatic transfer switches provide both commercial and standby E/G power to two facility main essential distribution panels. Normal power distribution panel without E/G backed up power is available. FLS bus is originated from one of the E/G distribution panels.

UTILITY

UTILITY TRANSFORMER

NORMAL

FIRE PUMP

DISCONNECT LOAD BANK

TEMPORARY

GENERATOR

CONNECTION

STANDBY

ENGINE-GENERATOR G

FLS

MUST COMPLY WITH

NFPA-695.3 (B)

COLOR CODE DESCRIPTION:

FP

FIRE PUMP

FACILITY NORMAL

LIGHTING

FAA NAS LOADS

OTHER

FIRE LIFE SAFETY

STAIR

PRESSURIZATION

Emergency Panel(s)

FIRE

SERVICE

FIRE

SERVICE

ELEVATOR

ATS ATS

BUS WITH SHARED POWER LOADS

UTILITY "NORMAL" POWER

EMERGENCY NEC, ARTICLE 700

STANDBY NEC, ARTICLE 701

FIRE PUMP NEC, ARTICLE 695

FAA, ESSENTIAL

NOTES:

Emergency Distribution Panel

ATS FLS

2 2 2

1 1

ESSENTIAL BUS FLS BUS

ATS

Controller

ATS with

Fire Pump

ELEVATOR

FLS DISTRIBUTION BUSFAA ATO

TERMINAL FACILITIES STANDARD DESIGNS SCHEMATIC DIAGRAM TYPE - BASIC

DIST PANEL

Essential Distribution Panel

Generator Panel

Main Service

1 1

FUNCTION’S PRIORITY ELEVATED TO EMERGENCY FOR

FAA PURPOSE.

OPTIONAL DIRECT CONNECTION FROM SEPARATE

UTILITY SERVICE.

CENTRALIZED BATTERY SYSTEM OR UNIT EQUIPMENT

IN STAIRWELLS AND DESIGNATED TASK AREAS.

PROVIDE 1'-0" VERTICAL & 4'-0" HORIZONTAL

SEPARATION BETWEEN FACILITY NORMAL LIGHTING

CIRUITS & EMERGENCY LIGHTING CIRCUITS.

PROVIDE 2-HOUR ROOM CONSTRUCTION.

AND FEEDER PROTECTION.

PROVIDE 2-HOUR FEEDER RATING FOR CONSTRUCTION

FOR BRANCH CIRCUIT LOADS.

CONSTRUCTION PROTECTION IS NOT APPLICABLE

2-HR RATING REQUIREMENT FOR FEEDER AND

5 7

CIRCUITS

LIGHTING

UTILITY

NORMAL

FIRE PUMP

DISCONNECT LOAD BANK

TEMPORARY

GENERATOR

CONNECTION

STANDBY

ENGINE-GENERATOR G

FLS

MUST COMPLY WITH

NFPA-695.3 (B)

COLOR CODE DESCRIPTION:

FP

FIRE PUMP

FACILITY NORMAL

LIGHTING

FAA NAS LOADS

OTHER

FIRE LIFE SAFETY

STAIR

PRESSURIZATION

Emergency Panel(s)

FIRE

SERVICE

FIRE

SERVICE

ELEVATOR

ATS ATS

BUS WITH SHARED POWER LOADS

UTILITY "NORMAL" POWER

EMERGENCY NEC, ARTICLE 700

STANDBY NEC, ARTICLE 701

FIRE PUMP NEC, ARTICLE 695

FAA, ESSENTIAL

NOTES:

Emergency Distribution Panel

ATS FLS

2 2 2

1 1

ESSENTIAL BUS FLS BUS

ATS

Controller

ATS with

Fire Pump

ELEVATOR

FLS DISTRIBUTION BUSFAA ATO

TERMINAL FACILITIES STANDARD DESIGNS SCHEMATIC DIAGRAM TYPE - RADIAL

DIST PANEL

Main Service

Generator Panel

Essential Distribution Panel

1 1

5 7

CIRCUITS

LIGHTING

FUNCTION’S PRIORITY ELEVATED TO EMERGENCY FOR

FAA PURPOSE.

OPTIONAL DIRECT CONNECTION FROM SEPARATE

UTILITY SERVICE.

CENTRALIZED BATTERY SYSTEM OR UNIT EQUIPMENT

IN STAIRWELLS AND DESIGNATED TASK AREAS.

PROVIDE 1'-0" VERTICAL & 4'-0" HORIZONTAL

SEPARATION BETWEEN FACILITY NORMAL LIGHTING

CIRUITS & EMERGENCY LIGHTING CIRCUITS.

PROVIDE 2-HOUR ROOM CONSTRUCTION.

AND FEEDER PROTECTION.

PROVIDE 2-HOUR FEEDER RATING FOR CONSTRUCTION

FOR BRANCH CIRCUIT LOADS.

CONSTRUCTION PROTECTION IS NOT APPLICABLE

2-HR RATING REQUIREMENT FOR FEEDER AND

UTILITY UTILITY

NORMAL

FIRE PUMP

DISCONNECT LOAD BANK

TEMPORARY

GENERATOR

CONNECTION

STANDBY

ENGINE-GENERATOR G

FLS STANDBY FLS

UTILITY TRANSFORMER

Main Service B

NORMAL

ENGINE-GENERATOR G

MUST COMPLY WITH

NFPA-695.3 (B)

COLOR CODE DESCRIPTION:

FP

FIRE PUMP

ATS A ATS B

FACILITY NORMAL

LIGHTING

FAA NAS LOADS

FACILITY NORMAL

LIGHTING

OTHER

FIRE LIFE SAFETY

STAIR

PRESSURIZATION

Emergency Panel(s)

FIRE

SERVICE

ELEVATOR

FIRE

SERVICE

ELEVATOR

ATS ATS

BUS WITH SHARED POWER LOADS

UTILITY "NORMAL" POWER

EMERGENCY NEC, ARTICLE 700

STANDBY NEC, ARTICLE 701

FIRE PUMP NEC, ARTICLE 695

MAINTENANCE

FAA, ESSENTIAL

NOTES:

FUNCTION’S PRIORITY ELEVATED TO EMERGENCY FOR

FAA PURPOSE.

OPTIONAL DIRECT CONNECTION FROM SEPARATE

UTILITY SERVICE.

CENTRALIZED BATTERY SYSTEM OR UNIT EQUIPMENT

IN STAIRWELLS AND DESIGNATED TASK AREAS.

PROVIDE 1'-0" VERTICAL & 4'-0" HORIZONTAL

SEPARATION BETWEEN FACILITY NORMAL LIGHTING

CIRUITS & EMERGENCY LIGHTING CIRCUITS.

Generator Panel A Generator Panel B

TEMPORARY

GENERATOR

CONNECTION

LOAD BANK

Main Service A

DIST PANEL A

DIST PANEL B

Emergency Distribution Panel

Essential Distribution Panel BEssential Distribution Panel A

ATS FLS

2 2

1 1

ESSENTIAL BUS ESSENTIAL BUS

FLS BUS

Controller

ATS with

Fire Pump

FLS DISTRIBUTION BUSFAA ATO

TERMINAL FACILITIES STANDARD DESIGNS SCHEMATIC DIAGRAM TYPE - CPDS 2

1 1

PROVIDE 2 HOUR ROOM CONSTRUCTION.

PROVIDE 2 HOUR FEEDER RATING FOR CONSTRUCTION

SOURCE SWITCHING EVENTS.

IS LEFT WITHOUT NORMAL LIGHTING DURING POWER

MAINTENANCE PROCEDURES AND ENSURE NO SPACE

REQUIRED TO FACILITATE POWER PATH A/B FEEDER

PATHS A/B. CIRCUIT DIVERSITY IN THESE SPACES IS

HAVE LIGHTING LOADS DIVERSIFIED BETWEN POWER

ROOMS WITH POWER SWITCHING EQUIPMENT SHOULD

AND FEEDER PROTECTION.

CIRCUITS

LIGHTING

FOR BRANCH CIRCUIT LOADS.

CONSTRUCTION PROTECTION IS NOT APPLICABLE

2-HR RATING REQUIREMENT FOR FEEDER AND

Section 1 - Executive Summary
Section 2 - Code Requirement
2.1 - Applicable Codes and Standards
2.2 - General Information per Industry Code and Stadnards
2.3 - Life Safety Systems Standard Requirements
2.4 - FAA Specific FLS Requirements
2.5 - FLS Code References Table
Section 3 - FAA FLS System Requirement Summary and Consideration
3.1 FLS Dist Bus Design
3.2 Load Shedding Consideration
Appendix-01
FLS Diagrams
Basic
Radial
CPDS 1
CPDS 2

FLS Bus Study - Final - Cover

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