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2010-14.2.2 Phase 2 of BARC | BAL-004-0 SAR

Description:

Start Date: 03/17/2015
End Date: 04/16/2015

Associated Ballots:

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

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See the Unofficial Comment Form on the Project Page for additional background information.

Hot Answers

John Merrell, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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Fuchsia Davis, On Behalf of: Bonneville Power Administration - WECC - Segments 1, 3, 5, 6

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Other Answers

Dan Roethemeyer, On Behalf of: Dan Roethemeyer, , Segments 5

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Charles Yeung, On Behalf of: Southwest Power Pool, Inc. (RTO), SPP RE, Segments 2

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John Fontenot, On Behalf of: John Fontenot, , Segments 1, 5

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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Kaleb Brimhall, On Behalf of: Kaleb Brimhall, , Segments 1, 5, 6

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

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ISO Standards Review Committee, Segment(s) 2, 4/9/2015

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Molly Devine, On Behalf of: Molly Devine, , Segments 1

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

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Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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Dominion - RCS, Segment(s) 1, 6, 3, 5, 4/6/2015

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Kathleen Black, On Behalf of: DTE Energy, RF, Segments 3, 4, 5

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christina bigelow, On Behalf of: christina bigelow, , Segments 2

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Mike Lowman on Behalf of Duke Energy, Segment(s) 1, 5, 6, 4/13/2015

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NPCC RSC 2010-14.2.2, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 4/15/2015

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Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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SPP Standards Review Group, Segment(s) , 4/15/2015

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 4/8/2015

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PPL NERC Registered Affiliates, Segment(s) 1, 3, 5, 6, 3/4/2015

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ACES Standards Collaborators - BARC Project, Segment(s) 1, 4, 5, 3, 6, 4/15/2015

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Craig Figart, On Behalf of: Avista - Avista Utilities, WECC, Segments NA - Not Applicable

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Hot Answers

John Merrell, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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Fuchsia Davis, On Behalf of: Bonneville Power Administration - WECC - Segments 1, 3, 5, 6

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Other Answers

Dan Roethemeyer, On Behalf of: Dan Roethemeyer, , Segments 5

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Charles Yeung, On Behalf of: Southwest Power Pool, Inc. (RTO), SPP RE, Segments 2

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John Fontenot, On Behalf of: John Fontenot, , Segments 1, 5

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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Kaleb Brimhall, On Behalf of: Kaleb Brimhall, , Segments 1, 5, 6

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

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ISO Standards Review Committee, Segment(s) 2, 4/9/2015

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Molly Devine, On Behalf of: Molly Devine, , Segments 1

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

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Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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Dominion - RCS, Segment(s) 1, 6, 3, 5, 4/6/2015

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Kathleen Black, On Behalf of: DTE Energy, RF, Segments 3, 4, 5

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christina bigelow, On Behalf of: christina bigelow, , Segments 2

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Mike Lowman on Behalf of Duke Energy, Segment(s) 1, 5, 6, 4/13/2015

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NPCC RSC 2010-14.2.2, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 4/15/2015

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Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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SPP Standards Review Group, Segment(s) , 4/15/2015

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 4/8/2015

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PPL NERC Registered Affiliates, Segment(s) 1, 3, 5, 6, 3/4/2015

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ACES Standards Collaborators - BARC Project, Segment(s) 1, 4, 5, 3, 6, 4/15/2015

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Craig Figart, On Behalf of: Avista - Avista Utilities, WECC, Segments NA - Not Applicable

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Hot Answers

John Merrell, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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NO: NOT YET for WECC*

BPA believes the manual TEC (MTEC) could be eliminated for all other interconnections, but not yet for WECC.  In the WECC, Automatic Time Error Correction (ATEC) per BAL-004-WECC-2 is used to manage Time Error automatically by holding BA’s accountable for managing and paying their own, “primary”, inadvertent Interchange (PII) energy accumulations back to the interconnection.  So yes, assuming ATEC is accomplishing its intended goal, MTECs can be eliminated in theory for the WECC, but only after proper analysis has been made.  WECC PWG is currently performing data analysis on this very topic.  Since June 9, 2014, WECC’s Time Error bandwidth was widened out from +/- 5 seconds to +/- 30 seconds, with the intent of minimizing the number of equal and opposite Time Error Corrections.  Accordingly, manual TEC events have been reduced significantly; however, we have experienced a few large Time Error swings (i.e. +20 down to -30 seconds within a month last fall).  Once analysis for these large swings have been made, then consideration of phasing out MTECs for WECC would be satisfactory.

Another concern is if Time Error were to grow beyond +/- 99.999 seconds.  WECC (PEAK RC) Symmetricom clocks that are used to track Time Error are only capable of measuring Time Error out to within +/- 99.999 seconds. Should Time Error grow to beyond +/- 99.999 seconds, then the ability to calculate an accurate Delta Time Error, as used in the BAL-004-WECC-2 standard, would be compromised.

Also, NERC BAL-001-1, E.B.1 would require modification to account for the removal of the +/-0.02Hz frequency schedule offsets from MTEC.

Fuchsia Davis, On Behalf of: Bonneville Power Administration - WECC - Segments 1, 3, 5, 6

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Other Answers

Dan Roethemeyer, On Behalf of: Dan Roethemeyer, , Segments 5

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Action should be taken to meet with NERC and FERC representatives to determine need for a commercial or other alrernative standard.

Charles Yeung, On Behalf of: Southwest Power Pool, Inc. (RTO), SPP RE, Segments 2

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John Fontenot, On Behalf of: John Fontenot, , Segments 1, 5

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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Kaleb Brimhall, On Behalf of: Kaleb Brimhall, , Segments 1, 5, 6

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

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The SRC supports a Project to retire BAL-004-0.

ISO Standards Review Committee, Segment(s) 2, 4/9/2015

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Molly Devine, On Behalf of: Molly Devine, , Segments 1

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

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While we agree that Manual Time Error Corrections (TEC) should be removed from the NERC standards, the practice of conducting TEC should continue as either a procedure in the NERC Operating Manual or affirmatively turned over to NAESB as a Business Practice Standard.  The only thing that may need to be retained in a standard (and could be put in BAL—005 or BAL-006) is a requirement to set the maximum offset for TECs or unilateral Inadvertent Interchange Payback to either:

•             A frequency offset of 20% of Frequency Bias Setting.

•             An interchange schedule representing 20% of Frequency Bias Setting.

Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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Dominion - RCS, Segment(s) 1, 6, 3, 5, 4/6/2015

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We agree that time error correction does not have an impact on BES reliability.  No objection to eliminating time error correction and retiring BAL-004-0.

Kathleen Black, On Behalf of: DTE Energy, RF, Segments 3, 4, 5

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ERCOT understands and agrees with the conclusion in the SAR and associated White Paper that Time Error Correction (TEC) is primarily a commercial function and, therefore, that the associated reliability standard (BAL-004) could be retired without materially impacting the reliability of the Bulk Electric System (BES).  ERCOT does not, however, agree that the practice of manual TEC should be eliminated altogether and further disagrees that associated commercial business practices should be retired concurrently.  Accordingly, ERCOT can support retirement of BAL-004 so long as there is an appropriate, applicable commercial standard to ensure that billing, settlements, and other aspects of wholesale markets are not adversely impacted by either the retirement of reliability standard BAL-004 or the time period needed to convert impacted BES devices to alternate time sources.  Hence, ERCOT respectfully suggests that the SAR be modified to set forth an obligation for the SDT to ensure that there will not be a lapse in the provision of this commercial service.

christina bigelow, On Behalf of: christina bigelow, , Segments 2

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Duke Energy agrees with the retirement of BAL-004-0 and Time Error Correction.

Mike Lowman on Behalf of Duke Energy, Segment(s) 1, 5, 6, 4/13/2015

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The Drafting Team will have to evaluate whether the terms Time Error and Time Error
Correction can be removed from the NERC Glossary, and whether any other NERC documents are
impacted.

NPCC RSC 2010-14.2.2, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 4/15/2015

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Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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We agree that the NERC Reliability Standard BAL-004-0 should be retired as it serves no purpose towards maintaining a reliable Bulk Electric System.  In fact it could be characterized as contributing somewhat towards unreliable impacts such as inadvertent interchange and reducing system frequency closer to an unstable point and Under Frequency Load Shedding trip points as stated in the white paper. 

While we agree that some parties may feel there is a need to continue the use of Time Error Corrections in some form for certain needs, we feel that need does not rise to the level that requires a Reliability Standard.  As such, BAL-004-0 should be retired.  A separate means of establishing the need and process for conducting manual Time Error Corrections outside of Reliability Standards could be investigated. Perhaps there is a business practice or some other means to continue to accomplish the practice of TEC.  Are there any potential impacts of discontinuing the practice of manual Time Error Corrections altogether?  Can it impact timing references on equipment used to analyze performance of the BES?  Prior to discontinuing the practice, a survey should be used to assess any reliability impacts.

SPP Standards Review Group, Segment(s) , 4/15/2015

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While we agree that Manual Time Error Corrections (TEC) should be removed from the NERC standards, the practice of conducting TEC should continue as either a procedure in the NERC Operating Manual or affirmatively turned over to NAESB as a Business Practice Standard.  The only thing that may need to be retained in a standard (and could be put in BAL—005 or BAL-006) is a requirement to set the maximum offset for TECs or unilateral Inadvertent Interchange Payback to either:

1)   A frequency offset of 20% of Frequency Bias Setting.

2) An interchange schedule representing 20% of Frequency Bias Setting.

MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 4/8/2015

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These comments are submitted on behalf of the following PPL NERC Registered Affiliates:  LG&E and KU Energy, LLC; PPL Electric Utilities Corporation, PPL EnergyPlus, LLC; PPL Generation, LLC; PPL Susquehanna, LLC and PPL Montana, LLC. The PPL NERC Registered Affiliates are registered in six regions (MRO, NPCC, RFC, SERC, SPP, and WECC) for one or more of the following NERC functions: BA, DP, GO, GOP, IA, LSE, PA, PSE, RP, TO, TOP, TP, and TSP.

 

PPL NERC Registered Affiliates, Segment(s) 1, 3, 5, 6, 3/4/2015

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We support the SAR and retirement of the BAL-004-0.  However, we are concerned that a NERC whitepaper recommends retirement of the associated NAESB standard.  We do not believe the NERC whitepaper should make such a recommendation.  Rather, NERC should, at most, notify NAESB of its intent to retire that standard.  NAESB can then take appropriate action.  

ACES Standards Collaborators - BARC Project, Segment(s) 1, 4, 5, 3, 6, 4/15/2015

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YES, Manual TEC (MTEC) could be eliminated for all other interconnections, but NO, not yet for WECC.  In the WECC, Automatic Time Error Correction (ATEC) per BAL-004-WECC-2 is used to manage Time Error automatically by holding BA’s accountable for managing and paying their own, “primary”, inadvertent Interchange (PII) energy accumulations back to the interconnection.  So yes, assuming ATEC is accomplishing its intended goal, MTECs can be eliminated in theory for the WECC, but only after it’s proven that WECC’s ATEC implementation keeps Time Error to within boundary values of +/- 99.999 seconds.  That’s because WECC (PEAK RC) Symmetricom clocks that are used to track Time Error are only capable of measuring Time Error out to within +/- 99.999 seconds. 

PWG is currently performing data analysis on this very topic.  Since June 9, 2014, WECC’s Time Error bandwidth was widened out from +/- 5 seconds to +/- 30 seconds, allowing the system to “breathe” more naturally.  Accordingly, manual TEC events have been reduced significantly, however, we have experienced a few large Time Error swings (i.e. +20 down to -30 seconds within a month during fall 2014) due to significant payback swings of Primary Inadvertent energy by larger BA’s.  So I would like to see a staged elimination of MTEC in WECC, BUT ONLY triggered after most WECC BA’s, particularly larger BA’s, accumulated PII balances are much closer to zero.  Otherwise, I’m afraid that once the larger BA’s in WECC get their accumulations down to near zero, we might be sitting out in excess of +/- 99.999 seconds of time error, for example, without an ability to manually correct time back to within bounds of current clock technology.  I would recommend continuing Manual TECs until sometime after these large PII accumulations are paid back, particularly by the larger BAs, and then verify that ATEC manages Time Error to within +/- 99.999 seconds.  Additionally, tighter controls needs to be considered on the maximum PII accumulation threshold down from the current window of +/-150% Peak Load/Gen in order for ATEC to more effectively automatically manage Time Error to within these +/- 99.999 second bounds.  Then MTECs can be considered for elimination and ATEC can go to work targeting a Time Error of zero seconds within a +/- 99.999 second Time Error window. 

Craig Figart, On Behalf of: Avista - Avista Utilities, WECC, Segments NA - Not Applicable

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Hot Answers

John Merrell, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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Fuchsia Davis, On Behalf of: Bonneville Power Administration - WECC - Segments 1, 3, 5, 6

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Other Answers

Dan Roethemeyer, On Behalf of: Dan Roethemeyer, , Segments 5

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Charles Yeung, On Behalf of: Southwest Power Pool, Inc. (RTO), SPP RE, Segments 2

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John Fontenot, On Behalf of: John Fontenot, , Segments 1, 5

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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Kaleb Brimhall, On Behalf of: Kaleb Brimhall, , Segments 1, 5, 6

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

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ISO Standards Review Committee, Segment(s) 2, 4/9/2015

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Molly Devine, On Behalf of: Molly Devine, , Segments 1

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

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NERC went through an exercise not long ago to try to eliminate manual TECs.  There was significant pushback from multiple stakeholders (commerce and transportation commissions, Federal regulators, newspapers, a congressman, markets) as it could impact facilities that rely on grid frequency as their time reference.

We have heard of no call from the industry to eliminate manual TECs and it is unclear why we are spending resources to try this again.  We should be finding ways to do fewer TECs and make them less intrusive in the frequency profile.  

Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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Minor comment; neither of the links provided in the SAR work (Roster, IERP report).

Dominion - RCS, Segment(s) 1, 6, 3, 5, 4/6/2015

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Kathleen Black, On Behalf of: DTE Energy, RF, Segments 3, 4, 5

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Importantly, the White Paper assumes the availability and usage of alternate time sources by devices on the BES.  However, this assumption may not be applicable to all stakeholders and all devices in the ERCOT Interconnection.  For example, in the ERCOT Region, existing market guides have provisions for manual TEC to facilitate maintenance of meter equipment accuracy.  Thus, where constituents have utilized manual TECs historically, the transition to an alternate time source may not be simple and may, in fact, be a complex, lengthy process requiring modifications to devices and associated cyber systems, data, software, and configurations.  Accordingly, it is likely that constituents that currently rely on manual TEC would have significant concerns with retirement of the standard where there exists no commercial or other standard to govern the consistency of processes within and among Interconnections during the transition to alternate time sources.

christina bigelow, On Behalf of: christina bigelow, , Segments 2

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Mike Lowman on Behalf of Duke Energy, Segment(s) 1, 5, 6, 4/13/2015

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The links are not established in the SAR for sarcomm@nerc.com, Roster, and Independent
Expert Review Project report.

NPCC RSC 2010-14.2.2, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 4/15/2015

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Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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There are no known concerns with retiring the Reliability Standard BAL-004-0.  We are not stating here whether we support discontinuing the practice of manual TEC after retirement of the Standard.

SPP Standards Review Group, Segment(s) , 4/15/2015

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NERC went through an exercise not long ago to try to eliminate manual TECs.  There was significant pushback from multiple stakeholders (commerce commissions, Federal regulators, newspapers, a congressman, markets) as it could impact facilities that rely on grid frequency as their time reference.

We have heard of no call from the industry to eliminate manual TECs and it is unclear why we are spending resources to try this again.  We should find ways to do fewer TECs and make them less intrusive in the frequency profile. 

MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 4/8/2015

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These comments are submitted on behalf of the following PPL NERC Registered Affiliates:  LG&E and KU Energy, LLC; PPL Electric Utilities Corporation, PPL EnergyPlus, LLC; PPL Generation, LLC; PPL Susquehanna, LLC and PPL Montana, LLC. The PPL NERC Registered Affiliates are registered in six regions (MRO, NPCC, RFC, SERC, SPP, and WECC) for one or more of the following NERC functions: BA, DP, GO, GOP, IA, LSE, PA, PSE, RP, TO, TOP, TP, and TSP.

 

PPL NERC Registered Affiliates, Segment(s) 1, 3, 5, 6, 3/4/2015

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ACES Standards Collaborators - BARC Project, Segment(s) 1, 4, 5, 3, 6, 4/15/2015

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Craig Figart, On Behalf of: Avista - Avista Utilities, WECC, Segments NA - Not Applicable

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