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2017-06 Modifications to BAL-002-2 | Standards Authorization Request

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Start Date: 06/20/2017
End Date: 07/20/2017

Associated Ballots:

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

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Hot Answers

Elizabeth Axson, On Behalf of: Elizabeth Axson, , Segments 2

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We caution the use of “15-minute ACE recovery period” in the SAR.  We believe the SDT should have clear direction to instead leverage the previously NERC Glossary-defined term, “Contingency Event Recovery Period.”  This term is referenced frequently within the standard and aligns with the efforts of the previous Standard Drafting Team.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 6, 4, 7/20/2017

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Other Answers

John Williams, On Behalf of: John Williams, , Segments 1, 3, 5

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Currently there is no requirement for a Reserve Sharing Group to have a 24 hour, manned, operations center. This would be required if this proposal is implemented. Furthermore, it would also require the Reserve Sharing Group to have authority in some manner over the participating BAs to devise and implement a recovery plan. A proposed alternative could be that BAs that are a part of a RSG must notify their RC if they will not be able to recover their individual ACE in the recovery period as well as providing their recovery plan and target recovery time.

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

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

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Please see response to Queston #2.

Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

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

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

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

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

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Scott Downey, On Behalf of: Scott Downey, , Segments 1

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Mike Smith, On Behalf of: Manitoba Hydro , , Segments 1, 3, 5, 6

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The Cityy Light subjet amtter expert feels that there should be no requirement that forces a Reserve Sharing Group to have a 24 hour a day operations center.  An alternative would be for BA’s that are part of an RSG and cause the RSG to be in a disturbance provide the Reliability Coordinator with an ACE recovery plan if they will not be able to recover their ACE in 15 minutes.

Seattle City Light Ballot Body, Segment(s) 1, 4, 6, 5, 3, 12/2/2016

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

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

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The SPP Standards Review Group recommends that the drafting team provides clarity on what the FERC Order is requiring and the situation that has been identified in Requirement R1 Part 1.3.1 of the Standard. From our perspective, there may be some confusion on what goals that need to be accomplished for a Responsible Entity pertaining to this requirement. It’s not clear on if a the event drives the situation in to 1.3.1 or b has the EEA Event already occurred and then the Responsible Entity needs to notify the RC about not meeting their recovery time as well as submitting a Recovery Plan. Also, we recommend that if the FERC Order addresses a then BAL-002-2 may be the appropriate document to conduct the proposed revisions. However, if the concerns are more applicable to b then the group would recommend making the appropriate revisions to the EOP-011-1 Standard.

SPP Standards Review Group, Segment(s) , 7/20/2017

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

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In its comments to FERC’s Notice of Proposed Rulemaking (NOPR) in Docket No. RM16-7-000, Arizona Public Service Company (APS) outlined a proposal regarding notice to the RC when the extenuating conditions listed in Requirement R1.3.1 are met and the BA is unable to recover its ACE within the 15-minute recovery period. This proposal addressed FERC’s concerns with extension of the 15-minute ACE recovery period, but also allowed appropriate flexibility to BAs when extenuating circumstances are present. (Order No. 835, P 36.)

NorthWestern Energy agrees with the proposal that was outlined by APS in its comments to the FERC NOPR. (APS Comments, Accession No. 20160720-2146, Section II-A, pages 3–9.)

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

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Hot Answers

The IRC Standards Review Committee (SRC) provides these comments: As one of the “alternative modifications” the SRC proposes the SDT consider converting the Standard to a communication guide (developed under the auspices of the NERC OC) that could be converted to a standard if such a need were identified by the RCs.

Elizabeth Axson, On Behalf of: Elizabeth Axson, , Segments 2

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We thank you for this opportunity to provide these comments.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 6, 4, 7/20/2017

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Other Answers

John Williams, On Behalf of: John Williams, , Segments 1, 3, 5

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

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

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PacifiCorp is concerned that (1) the requirement to notify the reliability coordinator of the conditions set forth in Requirement R1, Part 1.3.1 preventing it from complying with the 15-minute ACE recovery period; and (2) to provide the reliability coordinator with its ACE recovery plan, including a target recovery time, will be distracting requirements as the balancing area operators are working towards recovery in the 15-minute period.  Setting aside recovering from the event to provide notification to the reliability coordinator could impede efforts towards the recovery itself.  We fail to see the value in these additional requirements and wonder if is this more suitable for the Eastern Interconnection – Western Interconnection power pool agencies are not 7x24 shops.

Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

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

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

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

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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 objective of this SAR is to provide clear, unambiguous requirements to address the directives in the January 19, 2017 FERC Order regarding the recovery from a Balancing Contingency Event, or alternatively propose modifications that address the Commission concerns.” 

 

Since BAL-002-2 is addressing recovery from a Reportable Balancing Contingency Event (as distinct from a separately defined [non-reportable] Balancing Contingency Event), and since the FERC Order requires NERC to develop modifications regarding such Reportable events, in order to avoid any ambiguity or confusion we recommend that the SAR Objective be revised to state:

 

“The objective of this SAR is to provide clear, unambiguous requirements to address the directives in the January 19, 2017 FERC Order regarding the recovery from a Reportable Balancing Contingency Event, or alternatively propose modifications that address the Commission concerns.”

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

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Peak appreciates the opportunity to provide comments on the BAL-002-2 SAR. Peak requests consideration be given to intended and/or unintended expectations resulting from the provision of the information to the Reliability Coordinator that may or may not be covered by additional NERC Reliability Standards.

Scott Downey, On Behalf of: Scott Downey, , Segments 1

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Mike Smith, On Behalf of: Manitoba Hydro , , Segments 1, 3, 5, 6

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Seattle City Light Ballot Body, Segment(s) 1, 4, 6, 5, 3, 12/2/2016

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In order to provide clear, unambiguous requirements to address the FERC directive, Texas RE recommends the standard drafting team (SDT) consider specifying a time-frame in which the notification and provision of a recovery plan is expected to occur. Developing a recovery plan and target recovery time may not be feasible within 15 minutes, so it may be more practical to require notification to the Reliability Coordinator (RC) within 15 minutes of the event, and provision of a recovery plan within an agreed upon time-frame.

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

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Duke Energy agrees that the SAR aligns with the directive from FERC, and also agrees with the scope of this project as written currently.

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

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The SPP Standards Review Group recommends that the drafting team evaluate the expansion of SAR that are associated with part 1.3.2 of the Standard. Our concern pertains to contingencies impacting frequency that is outside of the Responsible Entity’s area that has a significant impact on the Responsible Entity meeting the 15 minute recovery.

SPP Standards Review Group, Segment(s) , 7/20/2017

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

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

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