Reliability Standards-EOP-011-1

EOP-011-1 Emergency Operations

A. Introduction
1.

Title:

Emergency Operations

2.

Number:

EOP-011-1

3.

Purpose: To address the effects of operating Emergencies by ensuring each
Transmission Operator and Balancing Authority has developed Operating Plan(s) to
mitigate operating Emergencies, and that those plans are coordinated within a
Reliability Coordinator Area.

4.

Applicability:
4.1. Functional Entities:
4.1.1 Balancing Authority
4.1.2 Reliability Coordinator
4.1.3 Transmission Operator

5.

Effective Date:
See Implementation Plan for EOP-011-1

6.

Background:
EOP-011-1 consolidates requirements from three standards: EOP-001-2.1b, EOP-0023.1, and EOP-003-2.
The standard streamlines the requirements for Emergency operations for the Bulk
Electric System into a clear and concise standard that is organized by Functional Entity.
In addition, the revisions clarify the critical requirements for Emergency Operations,
while ensuring strong communication and coordination across the Functional Entities.

B. Requirements and Measures
R1.

Each Transmission Operator shall develop, maintain, and implement one or more
Reliability Coordinator-reviewed Operating Plan(s) to mitigate operating Emergencies
in its Transmission Operator Area. The Operating Plan(s) shall include the following, as
applicable: [Violation Risk Factor: High] [Time Horizon: Real-Time Operations,
Operations Planning, Long-term Planning]
1.1. Roles and responsibilities for activating the Operating Plan(s);
1.2. Processes to prepare for and mitigate Emergencies including:
1.2.1. Notification to its Reliability Coordinator, to include current and
projected conditions, when experiencing an operating Emergency;
1.2.2. Cancellation or recall of Transmission and generation outages;
1.2.3. Transmission system reconfiguration;
1.2.4. Redispatch of generation request;

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EOP-011-1 Emergency Operations

1.2.5. Provisions for operator-controlled manual Load shedding that minimizes
the overlap with automatic Load shedding and are capable of being
implemented in a timeframe adequate for mitigating the Emergency; and
1.2.6. Reliability impacts of extreme weather conditions.
M1. Each Transmission Operator will have a dated Operating Plan(s) developed in
accordance with Requirement R1 and reviewed by its Reliability Coordinator;
evidence such as a review or revision history to indicate that the Operating Plan(s) has
been maintained; and will have as evidence, such as operator logs or other operating
documentation, voice recordings or other communication documentation to show
that its Operating Plan(s) was implemented for times when an Emergency has
occurred, in accordance with Requirement R1.
R2.

Each Balancing Authority shall develop, maintain, and implement one or more
Reliability Coordinator-reviewed Operating Plan(s) to mitigate Capacity Emergencies
and Energy Emergencies within its Balancing Authority Area. The Operating Plan(s)
shall include the following, as applicable: [Violation Risk Factor: High] [Time Horizon:
Real-Time Operations, Operations Planning, Long-term Planning]
2.1. Roles and responsibilities for activating the Operating Plan(s);
2.2. Processes to prepare for and mitigate Emergencies including:
2.2.1. Notification to its Reliability Coordinator, to include current and
projected conditions when experiencing a Capacity Emergency or Energy
Emergency;
2.2.2. Requesting an Energy Emergency Alert, per Attachment 1;
2.2.3. Managing generating resources in its Balancing Authority Area to
address:
2.2.3.1.

capability and availability;

2.2.3.2.

fuel supply and inventory concerns;

2.2.3.3.

fuel switching capabilities; and

2.2.3.4.

environmental constraints.

2.2.4. Public appeals for voluntary Load reductions;
2.2.5. Requests to government agencies to implement their programs to
achieve necessary energy reductions;
2.2.6. Reduction of internal utility energy use;
2.2.7. Use of Interruptible Load, curtailable Load and demand response;
2.2.8. Provisions for operator-controlled manual Load shedding that minimizes
the overlap with automatic Load shedding and are capable of being
implemented in a timeframe adequate for mitigating the Emergency; and
2.2.9. Reliability impacts of extreme weather conditions.
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EOP-011-1 Emergency Operations

M2. Each Balancing Authority will have a dated Operating Plan(s) developed in accordance
with Requirement R2 and reviewed by its Reliability Coordinator; evidence such as a
review or revision history to indicate that the Operating Plan(s) has been maintained;
and will have as evidence, such as operator logs or other operating documentation,
voice recordings, or other communication documentation to show that its Operating
Plan(s) was implemented for times when an Emergency has occurred, in accordance
with Requirement R2.
R3.

The Reliability Coordinator shall review the Operating Plan(s) to mitigate operating
Emergencies submitted by a Transmission Operator or a Balancing Authority
regarding any reliability risks that are identified between Operating Plans. [Violation
Risk Factor: High] [Time Horizon: Operations Planning]
3.1. Within 30 calendar days of receipt, the Reliability Coordinator shall:
3.1.1. Review each submitted Operating Plan(s) on the basis of compatibility
and inter-dependency with other Balancing Authorities’ and Transmission
Operators’ Operating Plans;
3.1.2. Review each submitted Operating Plan(s) for coordination to avoid risk to
Wide Area reliability; and
3.1.3. Notify each Balancing Authority and Transmission Operator of the results
of its review, specifying any time frame for resubmittal of its Operating
Plan(s) if revisions are identified.

M3. The Reliability Coordinator will have documentation, such as dated e-mails or other
correspondences that it reviewed Transmission Operator and Balancing Authority
Operating Plans within 30 calendar days of submittal in accordance with Requirement
R3.
R4.

Each Transmission Operator and Balancing Authority shall address any reliability risks
identified by its Reliability Coordinator pursuant to Requirement R3 and resubmit its
Operating Plan(s) to its Reliability Coordinator within a time period specified by its
Reliability Coordinator. [Violation Risk Factor: High] [Time Horizon: Operation
Planning]

M4. The Transmission Operator and Balancing Authority will have documentation, such as
dated emails or other correspondence, with an Operating Plan(s) version history
showing that it responded and updated the Operating Plan(s) within the timeframe
identified by its Reliability Coordinator in accordance with Requirement R4.
R5.

Each Reliability Coordinator that receives an Emergency notification from a
Transmission Operator or Balancing Authority within its Reliability Coordinator Area
shall notify, within 30 minutes from the time of receiving notification, other Balancing
Authorities and Transmission Operators in its Reliability Coordinator Area, and
neighboring Reliability Coordinators. [Violation Risk Factor: High] [Time Horizon: RealTime Operations]
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EOP-011-1 Emergency Operations

M5. Each Reliability Coordinator that receives an Emergency notification from a Balancing
Authority or Transmission Operator within its Reliability Coordinator Area will have,
and provide upon request, evidence that could include, but is not limited to, operator
logs, voice recordings or transcripts of voice recordings, electronic communications,
or equivalent evidence that will be used to determine if the Reliability Coordinator
communicated, in accordance with Requirement R5, with other Balancing Authorities
and Transmission Operators in its Reliability Coordinator Area, and neighboring
Reliability Coordinators .
R6.

Each Reliability Coordinator that has a Balancing Authority experiencing a potential or
actual Energy Emergency within its Reliability Coordinator Area shall declare an
Energy Emergency Alert, as detailed in Attachment 1. [Violation Risk Factor: High]
[Time Horizon: Real-Time Operations]

M6. Each Reliability Coordinator, with a Balancing Authority experiencing a potential or
actual Energy Emergency within its Reliability Coordinator Area, will have, and provide
upon request, evidence that could include, but is not limited to, operator logs, voice
recordings or transcripts of voice recordings, electronic communications, or
equivalent evidence that it declared an Energy Emergency Alert, as detailed in
Attachment 1, in accordance with Requirement R6.

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EOP-011-1 Emergency Operations

C. Compliance
1.

Compliance Monitoring Process
1.1. Compliance Enforcement Authority
As defined in the NERC Rules of Procedure, “Compliance Enforcement Authority”
(CEA) means NERC or the Regional Entity in their respective roles of monitoring
and enforcing compliance with the NERC Reliability Standards.
1.2. Evidence Retention
The Balancing Authority, Reliability Coordinator, and Transmission Operator shall
keep data or evidence to show compliance, as identified below, unless directed
by its Compliance Enforcement Authority (CEA) to retain specific evidence for a
longer period of time as part of an investigation. For instances where the
evidence retention period specified below is shorter than the time since the last
audit, the CEA may ask an entity to provide other evidence to show that it was
compliant for the full time period since the last audit.


The Transmission Operator shall retain the current Operating Plan(s),
evidence of review or revision history plus each version issued since the
last audit and evidence of compliance since the last audit for
Requirements R1 and R4and Measures M1 and M4.



The Balancing Authority shall retain the current Operating Plan(s),
evidence of review or revision history plus each version issued since the
last audit and evidence of compliance since the last audit for
Requirements R2 and R4, and Measures M2 and M4.



The Reliability Coordinator shall maintain evidence of compliance since
the last audit for Requirements R3, R5, and R6 and Measures M3, M5,
and M6.

If a Balancing Authority, Reliability Coordinator or Transmission Operator is
found non-compliant, it shall keep information related to the non-compliance
until found compliant.
The Compliance Enforcement Authority shall keep the last audit records and all
requested and submitted subsequent audit records.
1.3. Compliance Monitoring and Assessment Processes:
As defined in the NERC Rules of Procedure; “Compliance Monitoring and
Assessment Processes” refers to the identification of the processes that will be
used to evaluate data or information for the purpose of assessing performance
or outcomes with the associated reliability standard.
1.4. Additional Compliance Information
None

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EOP-011-1 Emergency Operations

Table of Compliance Elements
R#

Time Horizon

VRF

Violation Severity Levels
Lower VSL

R1

Real-time
Operations,
Operations
Planning, Longterm Planning

High

Moderate VSL

The Transmission
Operator developed
a Reliability
Coordinatorreviewed Operating
Plan(s) to mitigate
operating
Emergencies in its
Transmission
Operator Area but
failed to maintain it.

High VSL

The Transmission
Operator developed
an Operating Plan(s)
to mitigate
operating
Emergencies in its
Transmission
Operator Area but
failed to have it
reviewed by its
Reliability
Coordinator.

Severe VSL

The Transmission
Operator failed to
develop an
Operating Plan(s)
to mitigate
operating
Emergencies in its
Transmission
Operator Area.
OR
The Transmission
Operator
developed a
Reliability
Coordinatorreviewed Operating
Plan(s) to mitigate
operating
Emergencies in its
Transmission s
Operator Area but
failed to implement
it.

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EOP-011-1 Emergency Operations

R#

Time Horizon

VRF

Violation Severity Levels
Lower VSL

R2

Real-time
Operations,
Operations
Planning, Longterm Planning

High

N/A

Moderate VSL

The Balancing
Authority developed a
Reliability
Coordinator-reviewed
Operating Plan(s) to
mitigate operating
Emergencies within
its Balancing
Authority Area but
failed to maintain it.

High VSL

The Balancing
Authority developed
an Operating Plan(s)
to mitigate
operating
Emergencies within
its Balancing
Authority Area but
failed to have it
reviewed by its
Reliability
Coordinator.

Severe VSL

The Balancing
Authority failed to
develop an
Operating Plan(s)
to mitigate
operating
Emergencies within
its Balancing
Authority Area.
OR
The Balancing
Authority
developed a
Reliability
Coordinatorreviewed Operating
Plan(s) to mitigate
operating
Emergencies within
its Balancing
Authority Area but
failed to implement
it.

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EOP-011-1 Emergency Operations

R#

Time Horizon

VRF

Violation Severity Levels
Lower VSL

Moderate VSL

High VSL

Severe VSL

R3

Operations
Planning

High

N/A

N/A

The Reliability
Coordinator
identified a
reliability risk but
failed to notify the
Balancing Authority
or Transmission
Operator within 30
calendar days.

The Reliability
Coordinator
identified a
reliability risk but
failed to notify the
Balancing Authority
or Transmission
Operator.

R4

Operations
Planning

High

N/A

N/A

The Transmission
Operator or
Balancing Authority
failed to update and
resubmit tis
Operating Plan(s) to
its Reliability
Coordinator within
the timeframe
specified by its
Reliability
Coordinator.

The Transmission
Operator or
Balancing Authority
failed to update and
resubmit its
Operating Plan(s) to
its Reliability
Coordinator.

R5

Real-time
Operations

N/A

N/A

High

The Reliability
Coordinator that
received an
Emergency

The Reliability
Coordinator that
received an
Emergency

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EOP-011-1 Emergency Operations

R#

Time Horizon

VRF

Violation Severity Levels
Lower VSL

R6

Real-time
Operations

High

N/A

Moderate VSL

N/A

High VSL

Severe VSL

notification from a
Transmission
Operator or Balancing
Authority did notify
neighboring
Reliability
Coordinators,
Balancing Authorities
and Transmission
Operators but failed
to notify within 30
minutes from the
time of receiving
notification.

notification from a
Transmission
Operator or
Balancing Authority
failed to notify
neighboring
Reliability
Coordinators,
Balancing
Authorities and
Transmission
Operators.

N/A

The Reliability
Coordinator that
had a Balancing
Authority
experiencing a
potential or actual
Energy Emergency
within its Reliability
Coordinator Area
failed to declare an
Energy Emergency
Alert.

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EOP-011-1 Emergency Operations

D. Regional Variances
None.
E. Interpretations
None.
F. Associated Documents
None.

Version History

Version

Date

Action

Change Tracking

1

November 13,
2014

Adopted by Board of Trustees Merged EOP-001-2.1b, EOP002-3.1 and EOP-003-2.

1

November 19,
2015

FERC approved EOP-011-1.
Docket Nos. RM15-7-000,
RM15-12-000, and RM15-13000. Order No. 818

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Attachment 1
Attachment 1-EOP-011-1
Energy Emergency Alerts
Introduction
This Attachment provides the process and descriptions of the levels used by the Reliability
Coordinator in which it communicates the condition of a Balancing Authority which is
experiencing an Energy Emergency.
A.

General Responsibilities
1. Initiation by Reliability Coordinator. An Energy Emergency Alert (EEA) may be initiated
only by a Reliability Coordinator at 1) the Reliability Coordinator’s own request, or 2)
upon the request of an energy deficient Balancing Authority.
2. Notification. A Reliability Coordinator who declares an EEA shall notify all Balancing
Authorities and Transmission Operators in its Reliability Coordinator Area. The Reliability
Coordinator shall also notify all neighboring Reliability Coordinators.

B. EEA Levels
Introduction
To ensure that all Reliability Coordinators clearly understand potential and actual Energy
Emergencies in the Interconnection, NERC has established three levels of EEAs. The
Reliability Coordinators will use these terms when communicating Energy Emergencies to
each other. An EEA is an Emergency procedure, not a daily operating practice, and is not
intended as an alternative to compliance with NERC Reliability Standards.
The Reliability Coordinator may declare whatever alert level is necessary, and need not
proceed through the alerts sequentially.
1. EEA 1 — All available generation resources in use.
Circumstances:


The Balancing Authority is experiencing conditions where all available generation
resources are committed to meet firm Load, firm transactions, and reserve
commitments, and is concerned about sustaining its required Contingency Reserves.



Non-firm wholesale energy sales (other than those that are recallable to meet reserve
requirements) have been curtailed.

2. EEA 2 — Load management procedures in effect.
Circumstances:


The Balancing Authority is no longer able to provide its expected energy requirements
and is an energy deficient Balancing Authority.



An energy deficient Balancing Authority has implemented its Operating Plan(s) to
mitigate Emergencies.

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Attachment 1


An energy deficient Balancing Authority is still able to maintain minimum Contingency
Reserve requirements.

During EEA 2, Reliability Coordinators and energy deficient Balancing Authorities have the
following responsibilities:
2.1 Notifying other Balancing Authorities and market participants. The energy deficient
Balancing Authority shall communicate its needs to other Balancing Authorities and
market participants. Upon request from the energy deficient Balancing Authority, the
respective Reliability Coordinator shall post the declaration of the alert level, along with
the name of the energy deficient Balancing Authority on the RCIS website.
2.2 Declaration period. The energy deficient Balancing Authority shall update its Reliability
Coordinator of the situation at a minimum of every hour until the EEA 2 is terminated.
The Reliability Coordinator shall update the energy deficiency information posted on
the RCIS website as changes occur and pass this information on to the neighboring
Reliability Coordinators, Balancing Authorities and Transmission Operators.
2.3 Sharing information on resource availability. Other Reliability Coordinators of
Balancing Authorities with available resources shall coordinate, as appropriate, with the
Reliability Coordinator that has an energy deficient Balancing Authority.
2.4 Evaluating and mitigating Transmission limitations. The Reliability Coordinator shall
review Transmission outages and work with the Transmission Operator(s) to see if it’s
possible to return to service any Transmission Elements that may relieve the loading on
System Operating Limits (SOLs) or Interconnection Reliability Operating Limits (IROLs).
2.5 Requesting Balancing Authority actions. Before requesting an EEA 3, the energy
deficient Balancing Authority must make use of all available resources; this includes,
but is not limited to:
2.5.1 All available generation units are on line. All generation capable of being on line
in the time frame of the Emergency is on line.
2.5.2 Demand-Side Management. Activate Demand-Side Management within
provisions of any applicable agreements.
3.

EEA 3 —Firm Load interruption is imminent or in progress.
Circumstances:


The energy deficient Balancing Authority is unable to meet minimum Contingency
Reserve requirements.
During EEA 3, Reliability Coordinators and Balancing Authorities have the following
responsibilities:

3.1 Continue actions from EEA 2. The Reliability Coordinators and the energy deficient
Balancing Authority shall continue to take all actions initiated during EEA 2.

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Attachment 1
3.2 Declaration Period. The energy deficient Balancing Authority shall update its Reliability
Coordinator of the situation at a minimum of every hour until the EEA 3 is terminated.
The Reliability Coordinator shall update the energy deficiency information posted on
the RCIS website as changes occur and pass this information on to the neighboring
Reliability Coordinators, Balancing Authorities, and Transmission Operators.
3.3 Reevaluating and revising SOLs and IROLs. The Reliability Coordinator shall evaluate
the risks of revising SOLs and IROLs for the possibility of delivery of energy to the
energy deficient Balancing Authority. Reevaluation of SOLs and IROLs shall be
coordinated with other Reliability Coordinators and only with the agreement of the
Transmission Operator whose Transmission Owner (TO) equipment would be affected.
SOLs and IROLs shall only be revised as long as an EEA 3 condition exists, or as allowed
by the Transmission Owner whose equipment is at risk. The following are minimum
requirements that must be met before SOLs or IROLs are revised:
3.3.1 Energy deficient Balancing Authority obligations. The energy deficient Balancing
Authority, upon notification from its Reliability Coordinator of the situation, it
will immediately take whatever actions are necessary to mitigate any undue risk
to the Interconnection. These actions may include Load shedding.
3.4 Returning to pre-Emergency conditions. Whenever energy is made available to an
energy deficient Balancing Authority such that the Systems can be returned to its preEmergency SOLs or IROLs condition, the energy deficient Balancing Authority shall
request the Reliability Coordinator to downgrade the alert level.
3.4.1 Notification of other parties. Upon notification from the energy deficient
Balancing Authority that an alert has been downgraded, the Reliability
Coordinator shall notify the neighboring Reliability Coordinators (via the RCIS),
Balancing Authorities and Transmission Operators that its Systems can be
returned to its normal limits.
Alert 0 - Termination. When the energy deficient Balancing Authority is able to
meet its Load and Operating Reserve requirements, it shall request its Reliability
Coordinator to terminate the EEA.
0.1

Notification. The Reliability Coordinator shall notify all other Reliability
Coordinators via the RCIS of the termination. The Reliability Coordinator shall
also notify the neighboring Balancing Authorities and Transmission Operators.

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Application Guidelines
Guidelines and Technical Basis
Rationale:

During development of this standard, text boxes were embedded within the standard to explain
the rationale for various parts of the standard. Upon BOT approval, the text from the rationale
text boxes was moved to this section.
Rationale for R1:
The EOP SDT examined the recommendation of the EOP Five-Year Review Team (FYRT) and FERC
directive to provide guidance on applicable entity responsibility that was included in EOP-0012.1b. The EOP SDT removed EOP-001-2.1b, Attachment 1, and incorporated it into this standard
under the applicable requirements. This also establishes a separate requirement for the
Transmission Operator to create an Operating Plan(s) for mitigating operating Emergencies in its
Transmission Operator Area.
The Operating Plan(s) can be one plan, or it can be multiple plans.
“Notification to its Reliability Coordinator, to include current and projected conditions, when
experiencing an operating Emergency” was retained. This is a process in the plan(s) that
determines when the Transmission Operator must notify its Reliability Coordinator.
To meet the associated measure, an entity would likely provide evidence that such an evaluation
was conducted along with an explanation of why any overlap of Loads between manual and
automatic load shedding was unavoidable or reasonable.
An Operating Plan(s) is implemented by carrying out its stated actions.
If any Parts of Requirement R1 are not applicable, the Transmission Operator should note “not
applicable” in the Operating Plan(s). The EOP SDT recognizes that across the regions, Operating
Plan(s) may not include all the elements listed in this requirement due to restrictions, other
methods of managing situations, and documents that may already exist that speak to a process
that already exists. Therefore, the entity must provide in the plan(s) that the element is not
applicable and detail why it is not applicable for the plan(s).
With respect to automatic Load shedding schemes that include both UVLS and UFLS, the EOP
SDT’s intent is to keep manual and automatic Load shed schemes as separate as possible, but
realizes that sometimes, due to system design, there will be overlap. The intent in Requirement
R1 Part 1.2.5. is to minimize, as much as possible, the use of manual Load shedding which is
already armed for automatic Load shedding. The automatic Load shedding schemes are the
important backstops against Cascading outages or System collapse. If any entity manually sheds a
Load which was included in an automatic scheme, it reduces the effectiveness of that automatic
scheme. Each entity should review their automatic Load shedding schemes and coordinate their
manual processes so that any overlapping use of Loads is avoided to the extent reasonably
possible.

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Application Guidelines
Rationale for R2:
To address the recommendation of the FYRT and the FERC directive to provide guidance on
applicable entity responsibility in EOP-001-2.1b, Attachment 1, the EOP SDT removed EOP-0012.1b, Attachment 1, and incorporated it into this standard under the applicable requirements.
EOP-011-1 also establishes a separate requirement for the Balancing Authority to create its
Operating Plan(s) to address Capacity and Energy Emergencies.
The Operating Plan(s) can be one plan, or it can be multiple plans.
An Operating Plan(s) is implemented by carrying out its stated actions.
If any Parts of Requirement R2 are not applicable, the Balancing Authority should note “not
applicable” in the Operating Plan(s). The EOP SDT recognizes that across the regions, Operating
Plan(s) may not include all the elements listed in this requirement due to restrictions, other
methods of managing situations, and documents that may already exist that speak to a process
that already exists. Therefore, the entity must provide in the plan(s) that the element is not
applicable and detail why it is not applicable for the plan(s).
The EOP SDT retained the statement “Operator-controlled manual Load shedding,” as it was in
the current EOP-003-2 and is consistent with the intent of the EOP SDT.
With respect to automatic Load shedding schemes that include both UVLS and UFLS, the EOP
SDT’s intent is to keep manual and automatic Load shedding schemes as separate as possible, but
realizes that sometimes, due to system design, there will be overlap. The intent in Requirement
R2 Part 2.2.8. is to minimize as much as possible the use manual Load shedding which is already
armed for automatic Load shedding. The automatic Load shedding schemes are the important
backstops against Cascading outages or System collapse. If an entity manually sheds a Load that
was included in an automatic scheme, it reduces the effectiveness of that automatic scheme.
Each entity should review its automatic Load shedding schemes and coordinate its manual
processes so that any overlapping use of Loads is avoided to the extent possible.
The EOP SDT retained Requirement R8 from EOP-002-3.1 and added it to the Parts in
Requirement R2.
Rationale for R3:
The SDT agreed with industry comments that the Reliability Coordinator does not need to
approve BA and TOP plan(s). The SDT has changed this requirement to remove the approval but
still require the RC to review each entity’s plan(s), looking specifically for reliability risks. This is
consistent with the Reliability Coordinator’s role within the Functional Model and meets the
FERC directive regarding the RC’s involvement in Operating Plan(s) for mitigating Emergencies.
Rationale for Requirement R4:
Requirement R4 supports the coordination of Operating Plans within a Reliability Coordinator
Area in order to identify and correct any Wide Area reliability risks. The EOP SDT expects the
Reliability Coordinator to make a reasonable request for response time. The time period
requested by the Reliability Coordinator to the Transmission Operator and Balancing Authority
to update the Operating Plan(s) will depend on the scope and urgency of the requested change.

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Application Guidelines
Rationale for R5
The EOP SDT used the existing requirement in EOP-002-3.1 for the Balancing Authority and
added the words “within 30 minutes from the time of receiving notification” to the
requirement to communicate the intent that timeliness is important, while balancing the
concern that in an Emergency there may be a need to alleviate excessive notifications on
Balancing Authorities and Transmission Operators. By adding this time limitation, a measurable
standard is set for when the Reliability Coordinator must complete these notifications.
Rationale for Introduction
LSEs were removed from Attachment 1, as an LSE has no Real-time reliability functionality
with respect to EEAs.
EOP-002-3.1 Requirement R9 was in place to allow for a Transmission Service Provider to
change the priority of a service request, as permitted in its transmission tariff, informing the
Reliability Coordinator so that the service would not be curtailed by a TLR; and since the
Tagging Specs did not allow profiles to be changed, this was the only method to accomplish it.
Under NAESB WEQ E-tag Specification v1811 R3.6.1.3, this has been modified and now the TSP
has the ability to change the Transmission priority which, in turn, is reflected in the IDC. This
technology change allows for the deletion of Requirement R9 in its entirety. Requirement R9
meets with Criterion A of Paragraph 81 and should be retired.
Rationale for (2) Notification
The EOP SDT deleted the language, “The Reliability Coordinator shall also notify all other
Reliability Coordinators of the situation via the Reliability Coordinator Information System
(RCIS). Additionally, conference calls between RCs shall be held as necessary to communicate
system conditions. The RC shall also notify the other RCs when the alert has ended” as
duplicative to proposed IRO-014-3 Requirement R1:
R1. Each Reliability Coordinator shall have and implement Operating Procedures,
Operating Processes, or Operating Plans, for activities that require notification or
coordination of actions that may impact adjacent Reliability Coordinator Areas, to support
Interconnection reliability. These Operating Procedures, Operating Processes, or
Operating Plans shall include, but are not limited to, the following:
1.1 Communications and notifications, and the process to follow in making those

notifications.
1.2 Energy and capacity shortages.
1.3 Control of voltage, including the coordination of reactive resources.

Exchange of information including planned and unplanned outage information to
support its Operational Planning Analyses and Real-time Assessments.
1.5 Authority to act to prevent and mitigate system conditions which could adversely

impact other Reliability Coordinator Areas.
1.6 Provisions for weekly conference calls.

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Application Guidelines
Rationale for EEA 2:
The EOP SDT modified the “Circumstances” for EEA 2 to show that an entity will be in this level
when it has implemented its Operating Plan(s) to mitigate Emergencies but is still able to
maintain Contingency Reserves.
Rationale for EEA 3:
This rationale was added at the request of stakeholders asking for justification for moving a lack
of Contingency Reserves into the EEA3 category.
The previous language in EOP-002-3.1, EEA 2 used “Operating Reserve,” which is an all-inclusive
term, including all reserves (including Contingency Reserves). Many Operating Reserves are
used continuously, every hour of every day. Total Operating Reserve requirements are kind of
nebulous since they do not have a specific hard minimum value. Contingency Reserves are used
far less frequently. Because of the confusion over this issue, evidenced by the comments
received, the drafting team thought that using minimum Contingency Reserve in the language
would eliminate some of the confusion. This is a different approach but the drafting team
believes this is a good approach and was supported by several commenters.
Using Contingency Reserves (which is a subset of Operating Reserves) puts a BA closer to the
operating edge. The drafting team felt that the point where a BA can no longer maintain this
important Contingency Reserves margin is a most serious condition and puts the BA into a
position where they are very close to shedding Load (“imminent or in progress”). The drafting
team felt that this warrants categorization at the highest level of EEA.

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