This comment form is no longer interactive because the comment period is closed.

2017-06 Modifications to BAL-002-2 | BAL-002-3

Description:

Start Date: 03/22/2018
End Date: 05/08/2018

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End
2017-06 Modifications to BAL-002-2 BAL-002-3 IN 1 ST 2017-06 Modifications to BAL-002-2 BAL-002-3 03/22/2018 04/20/2018 04/27/2018 05/08/2018

Filter:

Hot Answers

  1. We believe the proposed reference to “preceding two bullet points” should be clarified, as compliance with this requirement can be confusing.  Very few NERC Reliability Requirements identify an action and then follow that with an exemption to the action based on a specific condition.  The proposed changes are made to the exemption portion of the requirement, which already implies that compliance with Requirement R1 part 1.1 is unnecessary.  The embedded dual condition within the proposed bullet should be split to provide clarity.  One bullet should identify the inhibitive reasoning provided to the RC from the distressed BA or RSG that is unable to restore its ACE to the appropriate Preā€Reporting Contingency Event ACE Value within the Contingency Event Recovery Period.  The second bullet should also identify that the ACE recovery plan was provided to the RC.
  2. The reference to “recovery time” should be replaced with the appropriate NERC Glossary Term, Contingency Event Recovery Period.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 6, 5/7/2018

- 0 - 0

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

Other Answers

N/A to BHC

Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - WECC - Segments 1, 3, 5, 6

- 0 - 0

Yvonne McMackin, 4/9/2018

- 0 - 0

N/a

Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5

- 0 - 0

Glen Farmer, Avista - Avista Corporation, 5, 4/27/2018

- 0 - 0

BPA suggests rewording of “an ACE recovery plan” to “actions it will take to recover its ACE”.  BPA believes this rewording will help R1 sound less like a defined term which will depend on or require additional documentation.  BPA’s concern is that “an ACE recovery plan” will be assumed to be an additional document such as the Emergency Operating Plan. 

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

SRP supports the proposed revisions.

Neil Swearingen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

Kevin Salsbury, Berkshire Hathaway - NV Energy, 5, 4/30/2018

- 0 - 0

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 5/2/2018

- 0 - 0

Michelle Amarantos, APS - Arizona Public Service Co., 5, 5/3/2018

- 0 - 0

While the SAR and the proposed changes address the stated FERC directive from one perspective, NERC is authorized to propose an equally effective alternative to achieve the reliability objective.  We believe the approach in the draft standard could negatively impact reliability. 

Our comments below outline issues with the standard and the direction it is taking.  The change will distract operators from their primary tasks in order to develop and discuss a plan following a contingency during an Energy Emergency Alert (EEA).    

The provisions being changed deal with exclusions to compliance.  We believe the better path is for the drafting team to work with NERC (with input from the NERC OC) to create Implementation Guidance and a companion CMEP Practice Guide that outlines approaches for multi-contingent events, events > Most Severe Single Contingencies, and for ERO Compliance Staff to handle Reportable Balancing Contingency Events (RBCEs) during EEAs. 

We also believe there is more to gain from a reliability perspective to pass these rare events through the Events Analysis process to create lessons-learned.

Finally, if the drafting team rejects our comments, we believe the change should be limited to: “Notified the RC that they have experienced a Reportable Balancing Contingency Event (RBCE) in cases where the BA expects recovery to take > 30 minutes and provided proposed actions and an expected recovery time.”

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 5/2/2018

- 0 - 0

While the proposed changes appear to clearly state the intention of the SAR, certain parts appear to be redundant with some of the existing requirements while other parts seem unnecessary if an alternative means, such as an exception to compliance, is developed.

 

Firstly, Point (i) in the forth bullet under Part 1.3.1 is unnecessary:

 

  1. The first bullet under Part 1.3.1 implies that a BA’s RC is already aware of the EEA declaration (since it makes that declaration itself!)

  2. The RC is already notified of its BA’s emergency condition via EOP-011, Requirement R2 (Part 2.2.1).

 

Secondly, regarding Point (ii) in Part 1.3.1, a BA’s priority under either an EEA or a capacity or energy emergency is to mitigate the emergency condition to return the BA Area to normal state. Developing and notifying its RC a plan to recover ACE under either condition should not be a priority as such a task may actually jeopardize reliability. A BA should be allowed time to manage its EEA and/or emergency. Only when such issues are duly addressed and the BA is out of EEA and/or emergency should it be required to notify its RC of an ACE recovery plan, including target recovery time, or the actions being undertaken to recover ACE.

 

We therefore urge the SDT to seek an alternative means (such as an exception to compliance) to meet the FERC directive on providing an ACE recovery plan, or to create a Part 1.4 that will require a BA to notify its RC of an ACE recovery plan, including target recovery time or its actions being undertaken to recover ACE, after it has recovered from an EEA or a capacity or energy emergency.

Leonard Kula, Independent Electricity System Operator, 2, 5/4/2018

- 0 - 0

Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 5, 5/4/2018

- 0 - 0

The SDT may wish to clarify when the ACE recovery plan must be submitted for a BA to qualify for the exemption.  The proposed BAL-002-3 R 1.3 now specifies that a BA may be exempt from BAL-002-3 R1.1 if it has “during communications with its Reliability Coordinator in accordance with the Energy Emergency Alert procedure” notified the RC of conditions preventing it from responding and “provided the Reliability Coordinator with an ACE recovery plan, including target recovery time.”

Rachel Coyne, Texas Reliability Entity, Inc., 10, 5/4/2018

- 0 - 0

PPL NERC Registered Affiliates, Segment(s) 3, 1, 5, 6, 2/9/2017

- 0 - 0

: FMPA is concerned that the proposed modifications could potentially be a distraction for operators and negatively impact reliability.  We agree with the following comments submitted by MRO:

While the SAR and the proposed changes address the stated FERC directive from one perspective, NERC is authorized to propose an equally effective alternative to achieve the reliability objective.  We believe the approach in the draft standard could negatively impact reliability. 

Our comments below outline issues with the standard and the direction it is taking.  The change will distract operators from their primary tasks in order to develop and discuss a plan following a contingency during an Energy Emergency Alert (EEA).    

The provisions being changed deal with exclusions to compliance.  We believe the better path is for the drafting team to work with NERC (with input from the NERC OC) to create Implementation Guidance and a companion CMEP Practice Guide that outlines approaches for multi-contingent events, events > Most Severe Single Contingencies, and for ERO Compliance Staff to handle Reportable Balancing Contingency Events (RBCEs) during EEAs. 

We also believe there is more to gain from a reliability perspective to pass these rare events through the Events Analysis process to create lessons-learned.

Finally, if the drafting team rejects our comments, we believe the change should be limited to: “Notified the RC that they have experienced a Reportable Balancing Contingency Event (RBCE) in cases where the BA expects recovery to take > 30 minutes and provided proposed actions and an expected recovery time.”

FMPA, Segment(s) , 10/23/2017

- 0 - 0

OUC is concerned that the proposed modifications could potentially be a distraction for operators and negatively impact reliability.  We agree with the following comments submitted by MRO:

While the SAR and the proposed changes address the stated FERC directive from one perspective, NERC is authorized to propose an equally effective alternative to achieve the reliability objective.  We believe the approach in the draft standard could negatively impact reliability. 

Our comments below outline issues with the standard and the direction it is taking.  The change will distract operators from their primary tasks in order to develop and discuss a plan following a contingency during an Energy Emergency Alert (EEA).    

The provisions being changed deal with exclusions to compliance.  We believe the better path is for the drafting team to work with NERC (with input from the NERC OC) to create Implementation Guidance and a companion CMEP Practice Guide that outlines approaches for multi-contingent events, events > Most Severe Single Contingencies, and for ERO Compliance Staff to handle Reportable Balancing Contingency Events (RBCEs) during EEAs. 

We also believe there is more to gain from a reliability perspective to pass these rare events through the Events Analysis process to create lessons-learned.

Finally, if the drafting team rejects our comments, we believe the change should be limited to: “Notified the RC that they have experienced a Reportable Balancing Contingency Event (RBCE) in cases where the BA expects recovery to take > 30 minutes and provided proposed actions and an expected recovery time.”

Richard Kinas, 5/7/2018

- 0 - 0

Laura Nelson, 5/7/2018

- 0 - 0

While the SAR and the proposed changes address the stated FERC directive from one perspective, NERC is authorized to propose an equally effective alternative.  We believe the approach in the draft standard could negatively impact reliability. 

Our comments below outline issues with the standard and the direction it is taking.  The change will distract operators from their primary tasks in order to develop and discuss a plan following a contingency during an EEA.    

The provisions being changed deal with exclusions to compliance.  We believe the better path is for the drafting team to work with NERC (with input from the NERC OC) to create a CMEP Practice Guide that outlines an approach for ERO Compliance Staff to handle RBCEs during these situations. 

We also believe there is more to gain from a reliability perspective to pass these rare events through the Events Analysis process to create lessons-learned.

Finally, if the drafting team rejects our comments, we believe the change should be limited to: “Notified the RC that they have experienced a Reportable Balancing Contingency Event (RBCE) and provided an expected recovery time”.

Richard Vine, On Behalf of: Richard Vine, , Segments 2

- 0 - 0

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

- 0 - 0

Dominion, Segment(s) 3, 5, 1, 4/6/2017

- 0 - 0

Richard Jackson, U.S. Bureau of Reclamation, 1, 5/7/2018

- 0 - 0

Wendy Center, U.S. Bureau of Reclamation, 5, 5/7/2018

- 0 - 0

We believe that the conditions set forth in the first requirement of the FERC order are already accomplished through the requirements in EOP-011 for declaring an EEA 3 and should not be restated here in BAL-002.  A BA experiencing the conditions set forth in the first three bullets in R1.3.1 is by definition experiencing EEA 3 conditions and the required communication to the RC is satisfied through the request to declare an EEA 3.  Restating them in this standard could lead to conflicts between the standards as they evolve over time.   We are also concerned that the current language in the draft could cause a delay in recovery from an event as the contingent BA’s time is occupied creating a detailed level of audit evidence documenting the official recovery plan and recovery time estimate during the Recovery Period of the event and then communicating those to the RC.  This would only serve to prolong the threat to the BES caused by the supply shortage which occurred as a result of the contingency.

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

Ameren believes that any Requirement for actions an entity is required to take when experiencing an RC declared EEA level belongs in EOP-011, Emergency Operations.

 

In lieu thereof, Ameren believes the following BAL-002-3 language would be an acceptable alternative to meet the intent and spirit of the FERC directive, until a revision of EOP-011-1 occurs as described below:

 

In addition to the redline changes for R1.3 and R1.3.1, Ameren suggests adding the additional bullets as stated below:

 

•provide updates to the ACE recovery plan, including target recovery time, to its Reliability Coordinator, during its communications with the RC as required in "Attachment 1-EOP-011-1 Energy Emergency Alerts"

 

•and implements the ACE recovery plan when given an Operating Instruction to do so by its RC.

 

David Jendras, Ameren - Ameren Services, 3, 5/7/2018

- 0 - 0

Selene Willis, On Behalf of: Edison International - Southern California Edison Company, , Segments 1, 3, 5, 6

- 0 - 0

SPP Standards Review Group, Segment(s) , 5/7/2018

- 0 - 0

TVA believes that the conditions set forth in the 1st requirement of the FERC order are already accomplished through the requirements in EOP-011 for declaring an EEA 3 and should not be restated here in BAL-002.  A BA experiencing the conditions set forth in the first three bullets in R1.3.1 is by definition experiencing EEA 3 conditions and the required communication to the RC is satisfied through the request to declare an EEA 3.  Restating them in this standard could lead to conflicts between the standards as they evolve over time.   We are also concerned that the current language in the draft could cause a delay in recovery from an event as the contingent BA’s time is occupied creating a detailed level of audit evidence documenting the official recovery plan and recovery time estimate during the Recovery Period of the event and then communicating those to the RC.  This would only serve to prolong the threat to the BES caused by the supply shortage which occurred as a result of the contingency.

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 9/7/2017

- 0 - 0

While the proposed changes appear to clearly state the intention of the SAR, certain parts appear to be redundant with some of the existing requirements while other parts seem unnecessary if an alternative means, such as an exception to compliance, is developed.

 

Firstly, Point (i) in the forth bullet under Part 1.3.1 is unnecessary:

 

  1. The first bullet under Part 1.3.1 implies that a BA’s RC is already aware of the EEA declaration (since it makes that declaration itself!)

  2. The RC is already notified of its BA’s emergency condition via EOP-011, Requirement R2 (Part 2.2.1).

 

Secondly, regarding Point (ii) in Part 1.3.1, a BA’s priority under either an EEA or a capacity or energy emergency is to mitigate the emergency condition to return the BA Area to normal state. Developing and notifying its RC a plan to recover ACE under either condition should not be a priority as such a task may actually jeopardize reliability. A BA should be allowed time to manage its EEA and/or emergency. Only when such issues are duly addressed and the BA is out of EEA and/or emergency should it be required to notify its RC of an ACE recovery plan, including target recovery time, or the actions being undertaken to recover ACE.

 

We therefore urge the SDT to seek an alternative means (such as an exception to compliance) to meet the FERC directive on providing an ACE recovery plan, or to create a Part 1.4 that will require a BA to notify its RC of an ACE recovery plan, including target recovery time or its actions being undertaken to recover ACE, after it has recovered from an EEA or a capacity or energy emergency.

RSC no Dominion and NYISO, Segment(s) 10, 2, 4, 5, 7, 1, 3, 6, 0, 5/7/2018

- 0 - 0

Hot Answers

We thank you for this opportunity to comment.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 6, 5/7/2018

- 0 - 0

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

Other Answers

Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - WECC - Segments 1, 3, 5, 6

- 0 - 0

Yvonne McMackin, 4/9/2018

- 0 - 0

Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5

- 0 - 0

Glen Farmer, Avista - Avista Corporation, 5, 4/27/2018

- 0 - 0

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

No additional comments.

Neil Swearingen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

Kevin Salsbury, Berkshire Hathaway - NV Energy, 5, 4/30/2018

- 0 - 0

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 5/2/2018

- 0 - 0

Since it is necessary for a Balancing Authority to be in the conditions described in the first three bullets and have communicated those conditions to their Reliability Coordinator in order to be declared in an EEA, it is not necessary to repeat those steps in the proposed language in the fourth bullet of 1.3.1.  The resulting fourth bullet would then read “has provided the Reliability Coordinator with an ACE recovery plan, including target recovery time

Michelle Amarantos, APS - Arizona Public Service Co., 5, 5/3/2018

- 0 - 0

We have concerns related to the unintended reliability consequences associated with the proposed changes in BAL-002-3 regarding the development and discussion of plans with the Reliability Coordinator in real time to restore ACE following a contingency during capacity shortages.

One thing that seems to be overlooked is that both the BA and RC have obligations in other standards to take action if a BA’s ACE is negatively impacting frequency or transmission limits.

The exclusion provisions in the current BAL-002-2 deal with situations where the BA has multiple problems (capacity emergency, previous contingencies or multiple contingencies).  The priorities of a Balancing Authority following multiple contingencies are to:

  • Assess the incoming alarms and determine the extent of the problem.
  • Prioritize actions depending on the location of the event, whether there is a frequency issue or what transmission is being negatively impacted.
  • Direct generators to load to correct ACE or to adjust (in coordination with the Transmission Operator) to manage flows.
  • Coordinate with its TOP, adjacent BAs, and request assistance from the RC as needed.

There can be dozens of actions taking place in a matter of 10-15 minutes.

The role of the Reliability Coordinator is not to manage or approve the local actions taken by the Balancing Authority.  The proposed changes would put two sets of hands on the wheel and delay action.  This is the equivalent of asking the pilot upon the loss of an engine to map out actions and reach out to the air traffic controller to discuss the pilot’s proposal.

The role of the RC is to assist the BA as needed and point out external issues the Balancing Authority might not see.  Only if a BA is not taking action and there are likely adverse reliability impacts should the RC intervene.

The original Disturbance Control Standard (DCS) prior to 2007 had basically two requirements:

  • Recover from large events less than or equal to MSSC in 15 minutes.
  • Replenish your reserves in 90 minutes such that you can recover from subsequent events.

There was an expectation that the BA made best efforts to recover from larger events as demonstrated by the reporting form that included events > MSSC and which NERC has tracked over the years.  The remainder of the original DCS just explained how the two requirements above were accomplished in the context of a Reserve Sharing Group as well as provided administrative information to support the standard.

While BAL-002-0 made the original DCS more complex, any operator could understand the objectives and explain how performance is demonstrated.  The currently enforceable BAL-002-2 is so complex that we believe no two operators asked to explain compliance would come up with the same answer.  Version 3 not only layers complexity in the compliance evaluation; it will distract operators from their primary tasks.

We are layering complexity in this standard at the same time NERC has a major project to streamline and focus the standards.  Reliability would be better served if the standard were simplified under the Standards Efficiency Review process to the following requirements:

  • Recover from Reportable Balancing Contingency Events in 15 minutes.
  • Replenish reserves within 90 minutes as demonstrated by successful recovery from subsequent Reportable Balancing Contingency Events.
  • Make best efforts and report recovery performance for events > MSSC or when reserves are diminished due to other contingencies.

As mentioned earlier, BAs are still held to the Balancing Authority ACE Limit as well as IROL requirements no matter what the size of the event.  NERC collects DCS performance data for its State of Reliability Report, to include events > MSSC.  NERC’s report shows that BA performance has been stellar.  If problems develop in the future, new requirements can be implemented.

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 5/2/2018

- 0 - 0

Leonard Kula, Independent Electricity System Operator, 2, 5/4/2018

- 0 - 0

Ozan Ferrin, Tacoma Public Utilities (Tacoma, WA), 5, 5/4/2018

- 0 - 0

It appears that this version needs some clean-up prior to the final version.  Texas RE noticed the following:

  • The grammatical structure of Requirement 1 Part 1.3 is unclear as to whether the bullets are just for the RSG or the BA as well.

  • In the “Rationales” document there is a reference to changes in definition of Contingency Reserve “in the posting” but it does not specify which posting.

  • Texas RE requests to see a draft updated CR Form 1 since it is an associated document in Section F of the standard.  Will this form be housed with the related documents?

Rachel Coyne, Texas Reliability Entity, Inc., 10, 5/4/2018

- 0 - 0

PPL NERC Registered Affiliates suggests that NERC post a complete redline of Proposed Reliability Standard BAL-002-3 to ensure the industry is fully aware of the transition of the Supplemental Material to a Technical Rationale document.  The Redline to Last Approved Version of Proposed Reliability Standard BAL-002-3 posted to the NERC project page on March 22, 2018 is not a complete redline as it does not show the removal of the “Supplemental Material” (also known as Technical Rationale), which is currently included in the effective version BAL-002-2(i). 

Furthermore, the document entitled “Rationales for BAL-002-3” should be entitled “Technical Rationale for BAL-002-3” in accordance with the NERC Technical Rationale for Reliability Standards Policy, and a redline to the last version of this document approved by industry should also be posted.

Additionally, the document entitled “Rationales for BAL-002-3” seems to include implementation guidance as it states “Requirement R1 does not apply when…”.

PPL NERC Registered Affiliates, Segment(s) 3, 1, 5, 6, 2/9/2017

- 0 - 0

FMPA is concerned that proposed modifications could negatively impact reliability by causing additional actions for the sake of compliance.  Additionally, there seems to be some redundancy with EOP-011-1 2.2.1 which states “Notification to its Reliability Coordinator, to include current and projected conditions when experiencing a Capacity Emergency or Energy Emergency;”. Having redundancy and overlap in the standards goes against the current Standards Efficiency Review effort that is underway.  FMPA agrees with the following comments submitted by MRO:

We have concerns related to the unintended reliability consequences associated with the proposed changes in BAL-002-3 regarding the development and discussion of plans with the Reliability Coordinator in real time to restore ACE following a contingency during capacity shortages.

One thing that seems to be overlooked is that both the BA and RC have obligations in other standards to take action if a BA’s ACE is negatively impacting frequency or transmission limits.

The exclusion provisions in the current BAL-002-2 deal with situations where the BA has multiple problems (capacity emergency, previous contingencies or multiple contingencies).  The priorities of a Balancing Authority following multiple contingencies are to:

Assess the incoming alarms and determine the extent of the problem.

Prioritize actions depending on the location of the event, whether there is a frequency issue or what transmission is being negatively      impacted.

Direct generators to load to correct ACE or to adjust (in coordination with the Transmission Operator) to manage flows.

Coordinate with its TOP, adjacent BAs, and request assistance from the RC as needed.

There can be dozens of actions taking place in a matter of 10-15 minutes.

The role of the Reliability Coordinator is not to manage or approve the local actions taken by the Balancing Authority.  The proposed changes would put two sets of hands on the wheel and delay action.  This is the equivalent of asking the pilot upon the loss of an engine to map out actions and reach out to the air traffic controller to discuss the pilot’s proposal.

The role of the RC is to assist the BA as needed and point out external issues the Balancing Authority might not see.  Only if a BA is not taking action and there are likely adverse reliability impacts should the RC intervene.

The original Disturbance Control Standard (DCS) prior to 2007 had basically two requirements:

{C}·         Recover from large events less than or equal to MSSC in 15 minutes.

{C}·         Replenish your reserves in 90 minutes such that you can recover from subsequent events.

There was an expectation that the BA made best efforts to recover from larger events as demonstrated by the reporting form that included events > MSSC and which NERC has tracked over the years.  The remainder of the original DCS just explained how the two requirements above were accomplished in the context of a Reserve Sharing Group as well as provided administrative information to support the standard.

While BAL-002-0 made the original DCS more complex, any operator could understand the objectives and explain how performance is demonstrated.  The currently enforceable BAL-002-2 is so complex that we believe no two operators asked to explain compliance would come up with the same answer.  Version 3 not only layers complexity in the compliance evaluation; it will distract operators from their primary tasks.

We are layering complexity in this standard at the same time NERC has a major project to streamline and focus the standards.  Reliability would be better served if the standard were simplified under the Standards Efficiency Review process to the following requirements:

Recover from Reportable Balancing Contingency Events in 15 minutes.

Replenish reserves within 90 minutes as demonstrated by successful recovery from subsequent Reportable Balancing Contingency Events.

Make best efforts and report recovery performance for events > MSSC or when reserves are diminished due to other contingencies.

As mentioned earlier, BAs are still held to the Balancing Authority ACE Limit as well as IROL requirements no matter what the size of the event.  NERC collects DCS performance data for its State of Reliability Report, to include events > MSSC.  NERC’s report shows that BA performance has been stellar.  If problems develop in the future, new requirements can be implemented.

FMPA, Segment(s) , 10/23/2017

- 0 - 0

OUC is concerned that proposed modifications could negatively impact reliability by causing additional actions for the sake of compliance.  Additionally, there seems to be some redundancy with EOP-011-1 2.2.1 which states “Notification to its Reliability Coordinator, to include current and projected conditions when experiencing a Capacity Emergency or Energy Emergency;”. Having redundancy and overlap in the standards goes against the current Standards Efficiency Review effort that is underway.  OUC agrees with the following comments submitted by MRO:

We have concerns related to the unintended reliability consequences associated with the proposed changes in BAL-002-3 regarding the development and discussion of plans with the Reliability Coordinator in real time to restore ACE following a contingency during capacity shortages.

One thing that seems to be overlooked is that both the BA and RC have obligations in other standards to take action if a BA’s ACE is negatively impacting frequency or transmission limits.

The exclusion provisions in the current BAL-002-2 deal with situations where the BA has multiple problems (capacity emergency, previous contingencies or multiple contingencies).  The priorities of a Balancing Authority following multiple contingencies are to:

Assess the incoming alarms and determine the extent of the problem.

Prioritize actions depending on the location of the event, whether there is a frequency issue or what transmission is being negatively impacted.

Direct generators to load to correct ACE or to adjust (in coordination with the Transmission Operator) to manage flows.

Coordinate with its TOP, adjacent BAs, and request assistance from the RC as needed.

There can be dozens of actions taking place in a matter of 10-15 minutes.

The role of the Reliability Coordinator is not to manage or approve the local actions taken by the Balancing Authority.  The proposed changes would put two sets of hands on the wheel and delay action.  This is the equivalent of asking the pilot upon the loss of an engine to map out actions and reach out to the air traffic controller to discuss the pilot’s proposal.

The role of the RC is to assist the BA as needed and point out external issues the Balancing Authority might not see.  Only if a BA is not taking action and there are likely adverse reliability impacts should the RC intervene.

The original Disturbance Control Standard (DCS) prior to 2007 had basically two requirements:

Recover from large events less than or equal to MSSC in 15 minutes.

Replenish your reserves in 90 minutes such that you can recover from subsequent events.

There was an expectation that the BA made best efforts to recover from larger events as demonstrated by the reporting form that included events > MSSC and which NERC has tracked over the years.  The remainder of the original DCS just explained how the two requirements above were accomplished in the context of a Reserve Sharing Group as well as provided administrative information to support the standard.

While BAL-002-0 made the original DCS more complex, any operator could understand the objectives and explain how performance is demonstrated.  The currently enforceable BAL-002-2 is so complex that we believe no two operators asked to explain compliance would come up with the same answer.  Version 3 not only layers complexity in the compliance evaluation; it will distract operators from their primary tasks.

We are layering complexity in this standard at the same time NERC has a major project to streamline and focus the standards.  Reliability would be better served if the standard were simplified under the Standards Efficiency Review process to the following requirements:

Recover from Reportable Balancing Contingency Events in 15 minutes.

Replenish reserves within 90 minutes as demonstrated by successful recovery from subsequent Reportable Balancing Contingency Events.

Make best efforts and report recovery performance for events > MSSC or when reserves are diminished due to other contingencies.

As mentioned earlier, BAs are still held to the Balancing Authority ACE Limit as well as IROL requirements no matter what the size of the event.  NERC collects DCS performance data for its State of Reliability Report, to include events > MSSC.  NERC’s report shows that BA performance has been stellar.  If problems develop in the future, new requirements can be implemented.

Richard Kinas, 5/7/2018

- 0 - 0

Laura Nelson, 5/7/2018

- 0 - 0

We have concerns related to the unintended reliability consequences associated with the proposed changes in BAL-002-3 regarding the development and discussion of plans with the Reliability Coordinator in real time to restore ACE following a contingency during capacity shortages.

One thing that seems to be overlooked is that both the BA and RC have obligations in other standards to take action if a BA’s ACE is negatively impacting frequency or transmission limits.

The exclusion provisions in the current BAL-002-2 deal with situations where the BA has multiple problems (capacity emergency, previous contingencies or multiple contingencies).  Under these situations the BA may likely need to perform dozens of tasks in a 15 minute period. 

The role of the Reliability Coordinator is not to manage or approve the local actions taken by the Balancing Authority.  The proposed changes would put two sets of hands on the wheel and delay action.  This is the equivalent of asking the pilot upon the loss of an engine to map out actions and reach out to the air traffic controller to discuss the pilot’s proposal.

The original Disturbance Control Standard (DCS) in Policy 1 had basically two requirements:

  • Recover from large events less than or equal to MSSC in 15 minutes.

  • Replenish your reserves in 90 minutes such that you can recover from subsequent events.

There was an expectation that the BA made best efforts to recover from larger events as demonstrated by the reporting form that included events > MSSC and which NERC has tracked over the years.  The remainder of the original DCS just explained how the two requirements above were accomplished in the context of a Reserve Sharing Group as well as provided administrative information to support the standard.

We are layering complexity in this standard at the same time NERC has a major project to streamline and focus the standards.  Reliability would be better served if the standard were simplified under the Standards Efficiency Review process to the following requirements:

  • Recover from Reportable Balancing Contingency Events in 15 minutes.

  • Replenish reserves within 90 minutes as demonstrated by successful recovery from subsequent Reportable Balancing Contingency Events.

  • Make best efforts and report recovery performance for events > MSSC or when reserves are diminished due to other contingencies.

The redline change to the standard has the BA telling the RC something they both already know and also expects the BA during an emergency to specifically mention two bullets in the standard.  It should also be noted that the requirement is basically duplicative of EOP-011 R2.

As mentioned earlier, BAs are still held to the Balancing Authority ACE Limit as well as IROL requirements no matter what the size of the event.  NERC collects DCS performance data for its State of Reliability Report, to include events > MSSC.  NERC’s report shows that BA performance has been stellar.  If problems develop in the future, new requirements can be implemented.  

Richard Vine, On Behalf of: Richard Vine, , Segments 2

- 0 - 0

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

- 0 - 0

Dominion Energy has a concern regarding the Technical Rationale document. It appears that SDT has transitioned the existing GTB document to a Technical Rationale document without completely addressing all of the compliance langugae contained in the document.

"Requirement R1 does not apply when an entity experiences a Balancing Contingency Event that exceeds its MSSC (which includes multiple Balancing Contingency Events as described in R1 part 1.3.2 below) because a fundamental goal of the SDT is to assure the Responsible Entity has enough flexibility to maintain service to Demand while managing reliability."

This first example states when an entity does not have to comply and the standard is not applicable. It is not intent, it is a statement that directly impacts compliance.  While the latter section of the section does state what the intent of the SDT was when developing the language and, in isolation would be appropriate for the TR document, the former part of the statement is not appropriate for the TR document. Just because a statement is not a specific example of how to comply does not render it appropriate for the TR document.

"In addition, the drafting team has added language to R 1.3.1 clarifying that if a BA is experiencing an EEA event underwhich its contingency reserve has been activated, the RSG in which it resides would also be considered to be exempt from R1 compliance."

The second quotation also makes a specific compliance statement, exempting a specific entity from compliance of the Requirement. While not an ‘example’ that could be directly ported to an IG document, it is compliance language that is not appropriate for a TR document. As stated before, just because compliance language does not fit the definition of IG does not render it appropriate for TR.

"Under the Energy Emergency Alert procedures, the BA must inform the RC of the conditions and necessary requirements to meet reliability and the RC must approve of the information being provided before issuing an Energy Emergency Alert."

The third quotation is a statement that clearly states how to comply with the EEA process. Once again, while not specific IG that statement  is not appropriate for a TR document.

Dominion, Segment(s) 3, 5, 1, 4/6/2017

- 0 - 0

Richard Jackson, U.S. Bureau of Reclamation, 1, 5/7/2018

- 0 - 0

Wendy Center, U.S. Bureau of Reclamation, 5, 5/7/2018

- 0 - 0

We believe that given the amount of actions BA’s are required to make during a Reportable Disturbance, and the very short window of time allowed in the standard to successfully complete those actions, that the Standards should not put additional regulatory burden on the operators to create documentation and notifications during this window.  This small amount of time should be dedicated to restoring the BES to a stable condition.  It is also important to note that the contingent BA is still subject to the BAAL limit during a contingency any time the BES is threatened with a negative supply balance; therefore, the BA still has a compliance obligation to restore its balance anytime the interconnection is threatened even if the BA is not subject to compliance under BAL-002.  Given the small amount of Contingency Reserves available to the BA in this situation and the degree of time urgency, the BA should make every effort to recover its imbalance and deploy all remaining Contingency Reserves in order to recover as much imbalance as possible.  Only once those actions are completed should the BA focus on communicating the recovery plan and target recovery time to the RC, and this should not be required to be within the Recovery Period in order to be granted a waiver from compliance under BAL-002.

The proposed revision should be based on BAL-002-2(i), which is the last approved and currently effective version.

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

David Jendras, Ameren - Ameren Services, 3, 5/7/2018

- 0 - 0

Selene Willis, On Behalf of: Edison International - Southern California Edison Company, , Segments 1, 3, 5, 6

- 0 - 0

The SPP Standards Review Group suggests that the drafting team provide clarity on the intent of the proposed language pertaining to Requirement R1 Part 1.3.1. The proposed language in BAL-002 (Part 1.3.1) is addressing entities that would be in an EEA 3 knowing that they wouldn’t return to an acceptable status in the required 15 minutes. Looking at EOP-011, any entity that is in an EEA 3 per Attachment 1, that entity would have to report their status to the Reliability Coordinator (RC) every hour. To our understanding, the entity being identified in BAL-002 (Part 1.3.1-which would be in an EEA 3 situation and would not be in compliance) could make their report in that same hour until they return to an acceptable status. We ask the drafting team to clarify whether there is connection between the required actions of these two standards. If the drafting team agrees with our understanding, we would suggest that the drafting team include some language discussing the connection of both standards in BAL-002-3. This would provide clarity on the expectations of entities that don’t recover in the required 15 minutes as well as being in an EEA 3 condition.

SPP Standards Review Group, Segment(s) , 5/7/2018

- 0 - 0

TVA believes that given the amount of actions BA’s are required to make during a Reportable Disturbance, and the very short window of time allowed in the standard to successfully complete those actions, that the Standards should not put additional regulatory burden on the operators to create documentation and notifications during this window.  This small amount of time should be dedicated to restoring the BES to a stable condition.  It is also important to note that the contingent BA is still subject to the BAAL limit during a contingency any time the BES is threatened with a negative supply balance; therefore, the BA still has a compliance obligation to restore its balance anytime the interconnection is threatened even if the BA is not subject to compliance under BAL-002.   Given the small amount of Contingency Reserves available to the BA in this situation and the degree of time urgency, the BA should make every effort to recover its imbalance and deploy all remaining Contingency Reserves in order to recover as much imbalance as possible.  Only once those actions are completed should the BA focus on communicating the recovery plan and target recovery time to the RC, and this should not be required to be within the Recovery Period in order to be granted a waiver from compliance under BAL-002.

The proposed revision should be based on BAL-002-2(i), which is the last approved and currently effective version.

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 9/7/2017

- 0 - 0

RSC no Dominion and NYISO, Segment(s) 10, 2, 4, 5, 7, 1, 3, 6, 0, 5/7/2018

- 0 - 0