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

2010-14.2.2 Phase 2 of Balancing Authority Reliability-based Controls | BAL-004-0

Description:

Start Date: 09/24/2015
End Date: 11/12/2015

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End
2010-14.2.2 Phase 2 of Balancing Authority Reliability-based Controls BAL-004-0 IN 1 ST 2010-14.2.2 Phase 2 of Balancing Authority Reliability-based Controls BAL-004-0 09/24/2015 10/23/2015 11/03/2015 11/12/2015

Filter:

Hot Answers

We support the SDT's recommendation to retire BAL-004-0 Time Error Correction standard.

RSC, Segment(s) 1, 0, 2, 3, 4, 5, 6, 7, 11/12/2015

- 0 - 0

1)      We would like to commend the drafting team in its efforts to strengthen its case for the retirement of the Time Error Correction standard.  The addition of two new appendices to its white paper provides essential background on time error corrections and alternative methods that registered entities can use to achieve similar results.

2)      While we continue to support the retirement of this standard, as we feel it puts an undue risk on the reliability of the BES, we have concerns regarding the direction taken by the SDT as part of this process.  The implementation plan states the retirement of this standard is dependent on the retirement of NAESB standard WEQ-006.  While we agree this is necessary, the limited coordination with NAESB we have observed will only delay these efforts.  We believe a letter of support from NAESB should be included in the white paper to demonstrate joint collaboration from all aspects of industry and strengthen your conclusions.

3)      We also feel the SDT should identify, within the implementation plan, revising the NERC Operating Manual as a listed prerequisite for the retirement of this standard.  We feel specific initiation and monitoring criteria listed within the retired standards should be moved to the time error correction section within the Manual.  We also recommend the addition of the alternative methods provided within the white paper to complement this revision.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 6, 4, 11/12/2015

- 0 - 0

Other Answers

John Fontenot, 9/24/2015

- 0 - 0

Thomas Lyons, Owensboro Municipal Utilities, 3, 10/19/2015

- 0 - 0

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

- 0 - 0

That said, Seattle City Light would like to reiterate that we still feel Standard BAL-004-WECC-02, Automatic Time Error Correction,is a good standard to have. This standard is very effective in automatically correcting time errors, supporting system frequency and reducing primary and secondary inadvertent accumulations. It is our opinion, automatic time error correction programs similar to WECC could help in reliable operations of other Interconnections.

Seattle City Light Ballot Body, Segment(s) 1, 3, 4, 6, 5, 9/11/2015

- 0 - 0

Scott McGough, Georgia System Operations Corporation, 3, 11/9/2015

- 0 - 0

Scott McGough, Georgia System Operations Corporation, 3, 11/9/2015

- 0 - 0

Jennifer Losacco, On Behalf of: NextEra Energy - Florida Power and Light Co., FRCC, Segments 1

- 0 - 0

ReliabilityFirst agrees that the practice of using manual TEC to place the Interconnection closer to the settings for automatic underfrequency load shedding does not support or enhance reliability. Therefore, RF believes the BAL-004-0 should be retired as long as sufficient advance notice of retiring the standard and adoption of specific business practices by applicable entities is adopted which will help eliminate any potential adverse unintended consequences.

Anthony Jablonski, ReliabilityFirst , 10, 11/9/2015

- 0 - 0

While we agree that TECs are primarily a commercial service and that the process should be converted to a procedure in the NERC Operating Manual or a NAESB business practice, we should not stop the implementation of TECs.  NIST has demonstrated that there are equipment and processes that use grid frequency as a time reference.

While the reliability impact of TECs is miniscule, there are simple things that can be done to reduce the magnitude and impact of TECs.  Europe uses clock-day TECs with a 0.01Hz offset and a 30 second window.  NERC used to have a unilateral payback process that not only helped manage Inadvertent Interchange, it also reduced the magnitude of Time Error.

NERC could keep a simple requirement that sets the maximum offset for TECs and the process could be managed in a procedure similar to the Time Monitoring Procedure in the NERC Operating Manual.

See the attached slides for additional information.

Terry BIlke, 11/10/2015

Summary of past Time Error Discussions and Recommendations.pptx

- 0 - 0

While we agree that TECs are primarily a commercial service and that the process should be converted to a procedure in the NERC Operating Manual or a NAESB business practice, we should not stop the implementation of TECs.  NIST has demonstrated that there are equipment and processes that use grid frequency as a time reference.

While the reliability impact of TECs is miniscule, there are simple things that can be done to reduce the magnitude and impact of TECs.  Europe uses clock-day TECs with a 0.01Hz offset and a 30 second window.  NERC used to have a unilateral payback process that not only helped manage Inadvertent Interchange, it also reduced the magnitude of Time Error.

NERC could keep a simple requirement that sets the maximum offset for TECs and the process could be managed in a procedure similar to the Time Monitoring Procedure in the NERC Operating Manual.

See the attachment for past NERC and NAESB discussions on TECs.

Terry BIlke, 11/10/2015

Summary of past Time Error Discussions and Recommendations.pptx

- 0 - 0

While, fundamentally, we agree that TECs do not rise to the level of Reliability Standard, it doesn’t appear that the SDT has done any coordination with NAESB to retire BAL-004 at the same time as the NAESB companion business practice, as outlined in the implementation plan. It is our belief that TECs should be relegated to a procedure in the NERC Operating Manual. We are also concerned that the SDT offers no reversion plan, should time drift excessively and NERC is asked to take action. We would be in favor of the SDT presenting an alternative to a Standard for TEC, and, until such alternatives are presented, will be voting no.

MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 11/11/2015

- 0 - 0

Duke Energy is in agreement with the retirement of the Time Error Correction standard, BAL-004-0.

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

- 0 - 0

Jared Shakespeare, 11/12/2015

- 0 - 0

While BPA supports the retirement of BAL-004-0, BPA recommends that industry retains the ability for Manual Time Error Corrections to be made outside of a Reliability Standard. Thank you.

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

- 0 - 0

We agree that BAL-004-0 should be retired and the retirement of this particular standard has no reliability impact on the BES.

SPP Standards Review Group, Segment(s) 1, 3, 5, 11/12/2015

- 0 - 0