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2017-01 Modifications to BAL-003-1.1 SAR

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Start Date: 06/19/2017
End Date: 07/18/2017

Associated Ballots:

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

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Hot Answers

See comments in response to Question No. 5.

Dori Quam, On Behalf of: NorthWestern Energy - WECC - Segments 1

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ACES Standards Collaborators, Segment(s) 1, 3, 4, 7/18/2017

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Other Answers

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

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

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

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Southern agrees with correcting the inconsistency.

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

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

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Sean Bodkin, On Behalf of: Dominion - Dominion Resources, Inc., , Segments 3, 5, 6

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Table 1 in Attachment A is good demonstration of how IFRO is calculated, but some statistically determined data in the table may appear out-of-date for years when frequency response is improving.  Ideally, the parameters used to calculate the current IFRO should be updated to accurately reflect the general trend in most recent years.  If the goal is to shape Attachment 1 in such way that it will be modified as little as possible in the future, one feasible way is to let Table 1 just serve as a typical example of calculating IFRO while recording the latest parameters in a separate document, similar to how it is done for FRAA.  With respect to the ratio of C-to-B (“CBR” or CB Ratio), it’s necessary to update this key syntax according to the overall trend of recent system performance change, but it doesn’t have to exactly line up with the ratio from the latest FRAA.  The reason for this is that the ratio from each year’s measurement may individually contain unexpected random factors that could eventually introduce an abrupt change to IFRO.  Taking the performance of multiple recent years into consideration in determining the ratio can effectively smooth such impact.  Additionally, ISO-NE believes that using the CBR:  (1) does not accurately reflect that governor response has little to do with arresting frequency in the Eastern Interconnection, and (2) that the use of the current CBR provides a perverse incentive in that it essentially penalizes improved governor response.

Joshua Eason, On Behalf of: ISO New England, Inc., NPCC, Segments 2

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As a member of the NWPP Frequency Response Sharing Group, Idaho Power agrees with the proposed revision.

Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

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

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Kasey Bohannon, On Behalf of: Kasey Bohannon, , Segments 1, 3, 5, 6

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The IRC SRC has no comment. 

IRC Standards Review Committee, Segment(s) 2, 7/18/2017

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Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC, SPP RE - Segments 1, 3, 5, 6

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The SPP Standards Review Group recommends that the drafting team develop some proposed language that will provide more details or give a better understanding in reference to the component (CBR - which is the statistically determined ratio of the Point C to Value B) mentioned in Attachment A.  Also, we recommend that the drafting team mention a reference document that contains the IFRO calculation for informational purposes.

SPP Standards Review Group, Segment(s) , 7/18/2017

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RSC, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 7/18/2017

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Hot Answers

NorthWestern Energy supports modifying the RCPC for each Interconnection to ensure sufficient primary frequency response is maintained. However, rather than the Resources Subcommittee recommending how events are selected for each Interconnection, the appropriate group in each Interconnection should determine the criteria for its own Interconnection. In addition, see comments in response to Question No. 5.

Dori Quam, On Behalf of: NorthWestern Energy - WECC - Segments 1

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The SAR only identifies that changes to the BAL‐003‐1.1 standard and process documents will address inconsistencies within the Eastern Interconnection Resource Contingency Protection Criteria (RCPC).  In the 2016 Frequency Response Annual Analysis Report, NERC identifies that the RCPC of all Interconnections should be revised to help ensure sufficient primary frequency response is maintained.  We believe this should be clarified in the purpose and objectives of the SAR.

ACES Standards Collaborators, Segment(s) 1, 3, 4, 7/18/2017

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Other Answers

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

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

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

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Southern agrees with the proposed change and method of change.

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

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

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Sean Bodkin, On Behalf of: Dominion - Dominion Resources, Inc., , Segments 3, 5, 6

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After the proposed revision is made, the same RCC that is currently used in the Eastern Interconnection should continue to be used after August 3, 2017.  Strictly following the current RCPC without any change would impose a substantial change in the RCC after August 3, 2017 which would drastically impact the IFRO of the Eastern Interconnection.  Such sudden change in the IFRO is not desirable, particularly when primary frequency response continues to consistently improve.   If the latest system condition implies a scenario where the current RCC used in the Eastern Interconnection appears to no longer be valid, then the new criteria used to establish the RCC must be one that results in minimal impact to IFRO.

Joshua Eason, On Behalf of: ISO New England, Inc., NPCC, Segments 2

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As a member of the NWPP Frequency Response Sharing Group, Idaho Power agrees with the proposed revision.

Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

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

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Kasey Bohannon, On Behalf of: Kasey Bohannon, , Segments 1, 3, 5, 6

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The IRC SRC has no comment.  SPP does not join this response.

IRC Standards Review Committee, Segment(s) 2, 7/18/2017

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Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC, SPP RE - Segments 1, 3, 5, 6

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The SPP Standards Review Group recommends that the drafting team develop some proposed language that will provide more details or give a better understanding in reference to the component (RCPC) in Attachment A and how the RCC component is associated as well.  Also, we recommend that the drafting team provides clarity on how they intend to address the potential changes of the RCC component and what impacts it will have on the industry.

SPP Standards Review Group, Segment(s) , 7/18/2017

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RSC, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 7/18/2017

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Hot Answers

NorthWestern agrees with revising Attachment A; however, NorthWestern believes any Reference Documents or Reliability Guidelines developed should be Interconnection specifi — i.e., Consider transferring supporting procedural and process steps from Attachment A into an ERO and NERC Operating Committee approved Interconnection-Specific Reference Document or Reliability Guideline.

In addition, see comments in response to Question No. 5.

Dori Quam, On Behalf of: NorthWestern Energy - WECC - Segments 1

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The authors of the SAR failed to uniformly incorporate the relocation of the standard’s Attachment A to a NERC Operating Committee-approved Reference Document or Reliability Guideline.  The relocation of Attachment A should be identified upfront in the purpose and objectives of the SAR.  We believe Attachment A should be relocated, as its contents identify calculated values that should be periodically reevaluated outside the Standards Development Process.

ACES Standards Collaborators, Segment(s) 1, 3, 4, 7/18/2017

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Other Answers

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

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

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

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Southern agrees this allows flexibility to correct the process in the future.

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

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

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Sean Bodkin, On Behalf of: Dominion - Dominion Resources, Inc., , Segments 3, 5, 6

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In Attachment A, the Frequency Response Measure section can be made more concise by including only the necessary information such as the basic description of the measurement methodology, the definition of timeframes associated with A, B, and C values, and the typical data sources for measurement.  Other details could be removed from the current version of Attachment A to be incorporated to the instruction portion of Forms 1 and 2 or a separate document such as the user manual for Forms 1 and 2 where more detailed instructions and “what if” examples could be added.  Preferably, the section on the Timeline for Balancing Authority Frequency Response and Frequency Bias Setting Activities should be retained and remain in Attachment A, because the timelines are important to keep in mind and there’s no better place for them.

Joshua Eason, On Behalf of: ISO New England, Inc., NPCC, Segments 2

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As a member of the NWPP Frequency Response Sharing Group, Idaho Power agrees with the proposed revision.

Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

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Texas RE is concerned process and timeline specifications in a supplemental document would not be enforceable.  Texas RE strongly encourages the SDT to closely evaluate which steps are being moved to ensure they are purely administrative and not reliability tasks that are essential for the reliable operation of the Bulk Electric System (BES).

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

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Kasey Bohannon, On Behalf of: Kasey Bohannon, , Segments 1, 3, 5, 6

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The IRC SRC has no comment.  SPP does not join this response.

IRC Standards Review Committee, Segment(s) 2, 7/18/2017

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Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC, SPP RE - Segments 1, 3, 5, 6

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The SPP Standard Review Group recommends that the drafting team develop some proposed language explaining why they recommend the removal of any supporting procedural and process steps from the Attachment A in the standard and transferring this information to a Reliability Guideline. Additionally, we recommend that the proposed language clearly states that once the information is removed from the standard and placed into a guideline, this information can no longer be considered to have compliance/audit implications.

SPP Standards Review Group, Segment(s) , 7/18/2017

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RSC, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 7/18/2017

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Hot Answers

See comments in response to Question No. 5.

Dori Quam, On Behalf of: NorthWestern Energy - WECC - Segments 1

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ACES Standards Collaborators, Segment(s) 1, 3, 4, 7/18/2017

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Other Answers

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

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

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

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Southern agrees the RS needs the ability to ensure that RSG’s are performing.

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

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

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Sean Bodkin, On Behalf of: Dominion - Dominion Resources, Inc., , Segments 3, 5, 6

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ISO-NE believes that each FRSG should be treated as one whole entity (i.e. as though it were an intact BA that neglects internal connections) in collection and submission of performance data.  This will allow the FRSG to be judged for compliance as a single collective, which is the presumed intent of a Frequency Response Sharing Group. 

Joshua Eason, On Behalf of: ISO New England, Inc., NPCC, Segments 2

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As a member of the NWPP Frequency Response Sharing Group, Idaho Power agrees with the proposed revision.

Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

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

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Kasey Bohannon, On Behalf of: Kasey Bohannon, , Segments 1, 3, 5, 6

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The IRC SRC has no comment. 

IRC Standards Review Committee, Segment(s) 2, 7/18/2017

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Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC, SPP RE - Segments 1, 3, 5, 6

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SPP Standards Review Group, Segment(s) , 7/18/2017

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RSC, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 7/18/2017

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Hot Answers

NorthWestern Energy participated with 18 other Balancing Authorities to draft a SAR and technical support document for BAL-003, through the coordination of the Northwest Power Pool (NWPP) Frequency Response Sharing Group (FRSG). If the FRSG SAR is approved, NorthWestern Energy requests that the two SARs be combined. If the FRSG SAR is not approved, each Interconnection should be allowed to develop its own Frequency Response and Frequency Bias Setting Standard.

Dori Quam, On Behalf of: NorthWestern Energy - WECC - Segments 1

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(1) We caution that the scope identified within the SAR is too broad and appears to have no definite deadlines.  The rush to address inconsistencies in the ratio of Point C to Value B, RCPC, and frequency nadir point limitations, as identified within the 2016 Frequency Response Annual Analysis Report, does not align with a similar deadline to introduce Attachment A and FRS Form enhancements.  The latter clarifications could delay the standard development process unnecessarily.  We believe the SAR should remove references to identify and incorporate all process modifications, and instead identify only enhancements to Attachment A and FRS Forms that are supportive of the 2016 Frequency Response Annual Analysis Report.

(2) We thank you for this opportunity to provide these comments.

ACES Standards Collaborators, Segment(s) 1, 3, 4, 7/18/2017

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Other Answers

BPA participated with 18 other Balancing Authorities to draft another SAR and technical support document for BAL-003, through the coordination of the Frequency Response Sharing Group (FRSG). If the FRSG SAR is approved, BPA requests that the two SARs are combined.

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

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

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

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No other comments at this time.

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

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Duke Energy agrees with the scope of the SAR, and agrees with the modifications as currently proposed.

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

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Sean Bodkin, On Behalf of: Dominion - Dominion Resources, Inc., , Segments 3, 5, 6

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Joshua Eason, On Behalf of: ISO New England, Inc., NPCC, Segments 2

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Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

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Texas RE requests a link to the 2016 FRAA report be made available on the project page.

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

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AZPS appreciates and agrees that the language in Appendix A would greatly benefit from a thorough review and revision to make the information easier to understand.  For example, we note that there is no description of where the Starting Frequency (FStart) for each Interconnection is derived.  The current language claims that “detailed descriptions of the calculations used in Table 1…are defined in the Procedure for ERO Support of Frequency Response and Frequency Bias Setting Standard.”  But in actuality, they are not.  Additionally, the last sentence of first paragraph of Attachment A (A maximum delta frequency (MDF) is calculated by adjusting a starting frequency) implies that the starting frequency is being adjusted where is it is the delta frequency which is being adjusted.

Kasey Bohannon, On Behalf of: Kasey Bohannon, , Segments 1, 3, 5, 6

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The IRC SRC has no comment. 

IRC Standards Review Committee, Segment(s) 2, 7/18/2017

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Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC, SPP RE - Segments 1, 3, 5, 6

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SPP Standards Review Group, Segment(s) , 7/18/2017

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RSC, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 7/18/2017

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