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2010-14.2.1 Phase 2 of Balancing Authority Reliability-based Controls: Inadvertent Interchange | BAL-006 Survey

Description:

Start Date: 09/16/2015
End Date: 09/25/2015

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End

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Q:

1. Based on comments related to the SAR, the Independent Expert Review Report, and the Periodic Review Team’ recommendations, the industry agrees that BAL-006 is an energy accounting standard and not a Reliability Standard, however, it is unclear what the industry supports as a replacement.  The SDT has developed a white paper for the industry to consider.  Based on the concepts within the white paper, do you support maintaining Reliability Standard BAL-006?[1]

 

[1]               When responding to this survey and providing comments, please keep in mind that draft proposed Reliability Standard BAL-006-3 has been posted under 2010-14.2.1 Phase 2 of Balancing Authority Reliability-based Controls, in connection with draft proposed Reliability Standards BAL-005-1 and FAC-001-3.  Proposed Reliability Standard BAL-005-1, at Requirements R1 and R8, would include the obligations currently under Requirement R3 of Reliability Standard BAL-006-2.

Hot Answers

We believe the SDT has provided adequate analysis on supporting rationale to eliminate BAL-006.  Inadvertent Interchange is addressed through other existing reliability and commercial requirements.  However, we believe the SDT could have provided better documentation to support its conclusions by identifying how each requirement are addressed individually.  We believe the SDT should develop a “mapping document” that accompanies its white paper to better substantiate its conclusions.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 6, 9/25/2015

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

Other Answers

Laurel Brandt, On Behalf of: Tennessee Valley Authority, SERC, Segments 1, 3, 5, 6

- 0 - 0

The current effective version of BAL-006 requires metering at all BAA interconnection points (R3).  The proposed version of BAL-006 removes the requirement for metering.  Although requirement for metering may be addressed in changes to other BAL or FAC Standards, until that occurs BAL-006 should remain as written.

Matthew Beilfuss, On Behalf of: WEC Energy Group, Inc., MRO, RF, Segments 3, 4, 5, 6

- 0 - 0

Nick Vtyurin, On Behalf of: Manitoba Hydro - MRO - Segments 1, 3, 5, 6

- 0 - 0

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

Our preference is to eliminate this  standard with one caveat.  We believe BAL-006 should be converted to a guide and placed in the NERC Operating Manual.  The tasks done under this standard are useful housekeeping tasks that support validation of balancing data. 

IRC-SRC, Segment(s) 2, 9/24/2015

- 0 - 0

Southern agrees with the PRT that BAL-006 is an energy accounting standard and not a Reliability Standard.

Southern Company, Segment(s) 1, 6, 3, 5, 4/13/2015

- 0 - 0

Duke Energy supports the elimination of BAL-006 as a Reliability Standard, based on the belief that the requirements,  with the exception of certain provisions of R4 incorporated into the proposed BAL-005-1, are business in nature and are not needed to support the reliable operation of the Bulk Power System.

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

- 0 - 0

While PJM agrees it is important to maintain requirements to calculate and account for Inadvertent Interchange, PJM suggest this be moved to a NAESB standard.

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

 In order to maintain enforcement capability, BAL-006 should remain a Reliability Standard. 

PPL NERC Registered Affiliates, Segment(s) 3, 1, 5, 6, 9/25/2015

- 0 - 0

FE supports PJM comments on this issue.

While PJM agrees it is important to maintain requirements to calculate and account for Inadvertent Interchange, PJM suggest this be moved to a NAESB standard.

FE RBB, Segment(s) 1, 3, 4, 5, 0, 3/3/2015

- 0 - 0

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Santee Cooper , Segment(s) 1, 3, 6, 9/25/2015

- 0 - 0

Adam Padgett, On Behalf of: TECO - Tampa Electric Co., FRCC, Segments 1, 3, 5, 6

- 0 - 0

Hot Answers

We believe the SDT has provided adequate analysis on supporting reasons why BAL-006 should be eliminated.  We also believe that Paragraph 81 criteria could be applied to eliminate the remaining requirements.  Based on Paragraph 81 Criteria for Administrative and Reporting, we feel the SDT has provided sufficient technical basis to substantiate that these requirements do “not support reliability and is needlessly burdensome.”  We also feel that in the instance when Adjacent BAs do not agree upon interchange quantities, the need to report such disputes to Regional Entities aligns with the definition of the Paragraph 81 Reporting Criterion.  This specific criterion states that “these are requirements that obligate responsible entities to report to a Regional Entity on activities which have no discernible impact on promoting the reliable operation of the BES and if the entity failed to meet this requirement there would be little reliability impact.”

ACES Standards Collaborators, Segment(s) 1, 3, 5, 6, 9/25/2015

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

Other Answers

Laurel Brandt, On Behalf of: Tennessee Valley Authority, SERC, Segments 1, 3, 5, 6

- 0 - 0

Comments: The purpose listed in the draft of BAL-006 has not been changed from the previously approved standard and does not appear directly related to the drafted requirements.

The elimination of the currently effective BAL-006 R4 in the draft removes a requirement that no other standard addresses.

See also answer to question 1.

Matthew Beilfuss, On Behalf of: WEC Energy Group, Inc., MRO, RF, Segments 3, 4, 5, 6

- 0 - 0

Nick Vtyurin, On Behalf of: Manitoba Hydro - MRO - Segments 1, 3, 5, 6

- 0 - 0

NA as AZPS does not support retaining as a NERC standard.

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

IRC-SRC, Segment(s) 2, 9/24/2015

- 0 - 0

We suggest BAL-006 be retired.

Southern Company, Segment(s) 1, 6, 3, 5, 4/13/2015

- 0 - 0

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

- 0 - 0

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

 To address FERC's recommendation for a metric to bind the magnitude of a BA's inadvertent accumulation, LG&E and KU suggest a multiplier of L10.  For example, for a BA with an L10 of 100, a multiplier of 250 would permit an accumulation of up to 25,000 MWHs.  The limit on the accumulation needs to reflect the relative size of the BA. 

PPL NERC Registered Affiliates, Segment(s) 3, 1, 5, 6, 9/25/2015

- 0 - 0

FE RBB, Segment(s) 1, 3, 4, 5, 0, 3/3/2015

- 0 - 0

BPA supports eliminating NERC BAL-006-2 as a reliability standard based on the NERC SDT (Standard Drafting Team) white paper provided for consideration.  As the white paper suggests, the current requirements in NERC BAL-006-2 of a reliability nature should be addressed through the requirements of the proposed BAL-005-1.

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Santee Cooper , Segment(s) 1, 3, 6, 9/25/2015

- 0 - 0

Adam Padgett, On Behalf of: TECO - Tampa Electric Co., FRCC, Segments 1, 3, 5, 6

- 0 - 0

Hot Answers

We agree that commercial alternative arrangements, such as a NAESB Business Practices, are a better fit for Inadvertent Interchange.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 6, 9/25/2015

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

Other Answers

Laurel Brandt, On Behalf of: Tennessee Valley Authority, SERC, Segments 1, 3, 5, 6

- 0 - 0

NERC could accomplish the data collection under rules of procedure as opposed to a reliability standard. 

See answers to question 1 and 2 for elements of the current BAL-006 that would need to be addressed in reliability standards.

Matthew Beilfuss, On Behalf of: WEC Energy Group, Inc., MRO, RF, Segments 3, 4, 5, 6

- 0 - 0

Nick Vtyurin, On Behalf of: Manitoba Hydro - MRO - Segments 1, 3, 5, 6

- 0 - 0

Reconciliation of inadvertent

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

We do not support turning this over to NAESB or FERC.  NAESB business practices ultimately become part of a transmission provider’s tariff.  Not all transmission providers are Balancing Authorities.  Additionally, not all Balancing Authorities are FERC jurisdictional.  Rather than creating gaps and make the data unverifiable, our preference is that BAL-006 be converted to a guide or procedure and placed in the NERC Operating Manual. 

The guidelines or procedure could be drafted and maintained in the operating manual by taking the existing verbiage and replace “shall” with “will”, “needs to”, or “should”. 

IRC-SRC, Segment(s) 2, 9/24/2015

- 0 - 0

Southern would prefer this be handled with agreements between the entities.  However, if a standard is required, we suggest it be within NAESB and not a NERC Reliability Standard.

Southern Company, Segment(s) 1, 6, 3, 5, 4/13/2015

- 0 - 0

Duke Energy recommends moving the responsibilities present in R1-R3, as well as R4.1 of BAL-006 to the NAESB standards.  NAESB already handles certain aspects of Interchange, and Inadvertent accounting is considered to be a business practice or commercial in nature.  We believe the requirements listed above fit that description.  We have excluded R4 from moving to NAESB, as we believe it would be covered by the proposed BAL-005-1 upon approval.

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

- 0 - 0

PJM believes the requirements in BAL-006 should be moved to a NAESB standard. In order for Inadvertent Interchange to be calculated appropriately the standard should include requirements similar to what the PRT has suggested for BAL-006. However PJM also believes that Adjacent Balancing Authorities should operate to a Net Interchange Schedule as this is important to avoid many potential dispute resolutions.

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

PPL NERC Registered Affiliates, Segment(s) 3, 1, 5, 6, 9/25/2015

- 0 - 0

FE supports PJM comments on this issue.

PJM believes the requirements in BAL-006 should be moved to a NAESB standard. In order for Inadvertent Interchange to be calculated appropriately the standard should include requirements similar to what the PRT has suggested for BAL-006. However PJM also believes that Adjacent Balancing Authorities should operate to a Net Interchange Schedule as this is important to avoid many potential dispute resolutions.

FE RBB, Segment(s) 1, 3, 4, 5, 0, 3/3/2015

- 0 - 0

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

We support maintaining the current reporting requirements through the CERTS Inadvertent Interchange Reporting Application. 

Santee Cooper , Segment(s) 1, 3, 6, 9/25/2015

- 0 - 0

Refer it to NAESB and incorporate all of the BAL-006 requirements in a NAESB standard.

Adam Padgett, On Behalf of: TECO - Tampa Electric Co., FRCC, Segments 1, 3, 5, 6

- 0 - 0

Hot Answers

We suggest that the SDT eliminate BAL-006.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 6, 9/25/2015

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

Other Answers

Laurel Brandt, On Behalf of: Tennessee Valley Authority, SERC, Segments 1, 3, 5, 6

- 0 - 0

Matthew Beilfuss, On Behalf of: WEC Energy Group, Inc., MRO, RF, Segments 3, 4, 5, 6

- 0 - 0

Nick Vtyurin, On Behalf of: Manitoba Hydro - MRO - Segments 1, 3, 5, 6

- 0 - 0

Support transferring to NAESB

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

IRC-SRC, Segment(s) 2, 9/24/2015

- 0 - 0

NA

Southern Company, Segment(s) 1, 6, 3, 5, 4/13/2015

- 0 - 0

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

- 0 - 0

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

PPL NERC Registered Affiliates, Segment(s) 3, 1, 5, 6, 9/25/2015

- 0 - 0

FE supports PJM comments on this issue.

This question is not applicable as PJM feels that Inadvertent Interchange requirements should be moved to a NAESB standard.

FE RBB, Segment(s) 1, 3, 4, 5, 0, 3/3/2015

- 0 - 0

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

n/a

Santee Cooper , Segment(s) 1, 3, 6, 9/25/2015

- 0 - 0

Adam Padgett, On Behalf of: TECO - Tampa Electric Co., FRCC, Segments 1, 3, 5, 6

- 0 - 0

Hot Answers

We question the practice of NERC posting this survey with the expectation of a nine-day, weekend included, turnaround for the possible elimination of a reliability standard.  This survey was posted during a week with NERC Technical Committee meetings, which likely impacted the availability of many industry and NERC subject matter experts to provide comments.  We hope this condensed commenting period was an oversight and a one-time occurrence.

 

Thank you for the opportunity to comment.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 6, 9/25/2015

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

Other Answers

Laurel Brandt, On Behalf of: Tennessee Valley Authority, SERC, Segments 1, 3, 5, 6

- 0 - 0

Requirements in BAL-006 as proposed for deletion are of value in a Standard, see answers to Question 1 and 2.

Matthew Beilfuss, On Behalf of: WEC Energy Group, Inc., MRO, RF, Segments 3, 4, 5, 6

- 0 - 0

Nick Vtyurin, On Behalf of: Manitoba Hydro - MRO - Segments 1, 3, 5, 6

- 0 - 0

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

If our suggestion is not supported, we would suggest balloting the posted standard and make the VRFs and VSLs reflect the fact that the requirements in this standard have little or no impact on reliability. 

IRC-SRC, Segment(s) 2, 9/24/2015

- 0 - 0

NA

Southern Company, Segment(s) 1, 6, 3, 5, 4/13/2015

- 0 - 0

Duke Energy’s support for the elimination of BAL-006 as a Reliability Standard, and the aforementioned requirements transition to the NAESB standards, predicated on the assumption that the Real-time reliability requirements of BAL-006 will be covered in one way (approval of proposed BAL-005-1) or another (incorporated into an existing BAL standard).

Given that the proposed BAL-005-1 will include a requirement covering the current BAL-006 R4, Duke Energy recommends that the BAL-005-1 implementation plan factor in the possible hand over of BAL-006 responsibilities from NERC to NAESB so that there isn’t the possibility of BAL-005-1 being effective at the same time that BAL-006 is still in place with a duplicate requirement.

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

- 0 - 0

As part of Project 2010-14.2.1 Phase 2 it was suggested that BAL-006-2 Requirement R3 be moved into BAL-005-3. While PJM agrees it is important to calculate MWh values for Inadvertent Interchange, PJM suggests this be moved to a NAESB standard.

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

 LG&E and KU are not opposed to handling inadvertent via a NAESB standard or business practice; the concern is enforceability.  A NAESB standard or business practice for inadvertent would lack enforcement "teeth." Thus LG&E and KU question whether a NAESB standard can as effectivelty achieve the desired result.

LG&E and KU are not in favor of financial or FERC established processes for settlement of accumulated inadvertent accounts.

PPL NERC Registered Affiliates, Segment(s) 3, 1, 5, 6, 9/25/2015

- 0 - 0

FE supports PJM comments on this issue.

As part of Project 2010-14.2.1 Phase 2 it was suggested that BAL-006-2 Requirement R3 be moved into BAL-005-3. While PJM agrees it is important to calculate MWh values for Inadvertent Interchange, PJM suggests this be moved to a NAESB standard.

FE RBB, Segment(s) 1, 3, 4, 5, 0, 3/3/2015

- 0 - 0

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

n/a

Santee Cooper , Segment(s) 1, 3, 6, 9/25/2015

- 0 - 0

Adam Padgett, On Behalf of: TECO - Tampa Electric Co., FRCC, Segments 1, 3, 5, 6

- 0 - 0