NERC Petition for EOP-011-1

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

North American Electric Reliability
Corporation

)
)

Docket No. _______

PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF PROPOSED RELIABILITY STANDARD
EOP-011-1—EMERGENCY OPERATIONS
Gerald W. Cauley
President and Chief Executive Officer
North American Electric Reliability Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
(404) 446-2560
(404) 446-2595 – facsimile

Charles A. Berardesco
Senior Vice President and General Counsel
Holly A. Hawkins
Associate General Counsel
Stacey Tyrewala
Senior Counsel
Andrew C. Wills
Associate Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
[email protected]
[email protected]
[email protected]
[email protected]
Counsel for the North American Electric
Reliability Corporation

December 29, 2014

TABLE OF CONTENTS
I.

EXECUTIVE SUMMARY .................................................................................................... 2

II.

NOTICES AND COMMUNICATIONS ................................................................................ 3

III. BACKGROUND .................................................................................................................... 4
A.

Regulatory Framework ..................................................................................................... 4

B.

NERC Reliability Standards Development Process ......................................................... 5

C.

History of Project 2009-03, Emergency Operations ........................................................ 6

IV. JUSTIFICATION FOR APPROVAL .................................................................................... 6
A.

Justification on a Requirement-by-Requirement Basis for

EOP-011-1 – Emergency Operations.......................................................................................... 7
B.

Commission Directives Addressed ................................................................................ 12

C.

Proposed Definition of “Energy Emergency” ................................................................ 18

D.

Justification for Retirements .......................................................................................... 18

E.
V.

1.

Justification for Retirement of Reliability Standard EOP-001-2.1b........................... 18

2.

Justification for Retirement of Reliability Standard EOP-002-3.1............................. 20

3.

Justification for Retirement of Reliability Standard EOP-003-2................................ 23
Enforceability of EOP-011-1 ......................................................................................... 26

CONCLUSION ..................................................................................................................... 27

Exhibit A

Proposed Reliability Standard, EOP-011-1 – Emergency Operations

Exhibit B

Implementation Plan for EOP-011-1

Exhibit C

Order No. 672 Criteria for EOP-011-1

Exhibit D

Mapping Document

Exhibit E

Analysis of Violation Risk Factors and Violation Security Levels

Exhibit F

Analysis of Commission Directives

Exhibit G

Summary of Development History and Complete Record of Development

Exhibit H

Standard Drafting Team Roster for Project 2009-03, Emergency Operations

i

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

North American Electric Reliability
Corporation

)
)

Docket No. _______

PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF PROPOSED RELIABILITY STANDARD
EOP-011-1—EMERGENCY OPERATIONS
Pursuant to Section 215(d)(1) of the Federal Power Act (“FPA”)1 and Section 39.52 of the
Federal Energy Regulatory Commission’s (“FERC” or “Commission”) regulations, the North
American Electric Reliability Corporation (“NERC”)3 hereby submits proposed Reliability
Standard EOP-011-1 and the revised definition of “Energy Emergency” (“Definition”) for
Commission approval. NERC requests that the Commission approve proposed Reliability
Standard EOP-011-1 (Exhibit A) and the Definition and find that the proposed Reliability
Standard and Definition are just, reasonable, not unduly discriminatory or preferential, and in the
public interest.4 NERC also requests approval of the associated implementation plan (Exhibit
B), Violation Risk Factors (“VRFs”) and Violation Severity Levels (“VSLs”) (Exhibit E), as
detailed in this petition.
As required by Section 39.5(a)5 of the Commission’s regulations, this petition presents
the technical basis and purpose of proposed Reliability Standard EOP-011-1, a demonstration

1

16 U.S.C. § 824o (2006).
18 C.F.R. § 39.5 (2013).
3
The Commission certified NERC as the electric reliability organization (“ERO”) in accordance with
Section 215 of the FPA on July 20, 2006. N. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062 (2006) (“ERO
Certification Order”).
4
Unless otherwise designated, all capitalized terms shall have the meaning set forth in the Glossary of Terms
Used in NERC Reliability Standards, available at http://www.nerc.com/files/Glossary_of_Terms.pdf.
5
18 C.F.R. § 39.5(a) (2013).
2

1

that the proposed Reliability Standard meets the criteria identified by the Commission in Order
No. 6726 (Exhibit C) and a summary of the development history (Exhibit H). Proposed
Reliability Standard EOP-011-1 was approved by the NERC Board of Trustees on November 13,
2014.
I.

EXECUTIVE SUMMARY
The Emergency Preparedness and Operations (“EOP”) group of Reliability Standards

currently consists of eight Reliability Standards that address preparation for emergencies,
necessary actions during emergencies and system restoration and reporting following
disturbances. The purpose of proposed Reliability Standard EOP-011-1 is to address the effects
of operating Emergencies by ensuring each Transmission Operator and Balancing Authority has
developed Operating Plans to mitigate operating Emergencies, and that those plans are
coordinated within a Reliability Coordinator Area.
Proposed Reliability Standard EOP-011-1 is a fundamentally important Reliability
Standard that streamlines the requirements for Emergency operations of the Bulk Electric
System. Attachment 1, which is incorporated into Requirements R2 and R6, provides the
process and descriptions of the levels used by the Reliability Coordinator when communicating
the condition of a Balancing Authority that is experiencing an Energy Emergency. There are
three levels of Energy Emergency Alerts:
•

Energy Emergency Alert Level 1: All available generation resources in use.
This occurs when 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.

6

The Commission specified in Order No. 672 certain general factors it would consider when assessing
whether a particular Reliability Standard is just and reasonable. See Rules Concerning Certification of the Electric
Reliability Organization; and Procedures for the Establishment, Approval, and Enforcement of Electric Reliability
Standards, Order No. 672, FERC Stats. & Regs. ¶ 31,204, at P 262, 321-37, order on reh’g, Order No. 672-A,
FERC Stats. & Regs. ¶ 31,212 (2006).

2

•

Energy Emergency Alert Level 2: Load management procedures in effect.
This occurs when 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 to
mitigated Emergencies. An energy deficient Balancing Authority is still able to
maintain minimum Contingency Reserve requirements.

•

Energy Emergency Alert Level 3: Firm Load interruption is imminent or in
process. This occurs when the energy deficient Balancing Authority is unable to
meet minimum Contingency Reserve requirements.

The proposed Reliability Standard consolidates requirements from three existing
Reliability Standards; EOP-001-2.1b, EOP-003.1, and EOP-003-2, into a single Reliability
Standard that clarifies the critical requirements for Emergency Operations while ensuring strong
communication and coordination across the functional entities. NERC requests that the
Commission approve proposed Reliability Standard EOP-011-1 and find that the proposed
Reliability Standard is just, reasonable, not unduly discriminatory or preferential, and in the
public interest.
II.

NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the

following:7

7

Persons to be included on the Commission’s service list are identified by an asterisk. NERC respectfully
requests a waiver of Rule 203 of the Commission’s regulations, 18 C.F.R. § 385.203 (2013), to allow the inclusion
of more than two persons on the service list in this proceeding.

3

Charles A. Berardesco*
Senior Vice President and General Counsel
Holly A. Hawkins*
Associate General Counsel
Stacey Tyrewala*
Senior Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
[email protected]
[email protected]
[email protected]
III.

Valerie Agnew*
Director of Standards
North American Electric Reliability Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
(404) 446-2560
(404) 446-2595 – facsimile
[email protected]

BACKGROUND
A.

Regulatory Framework

By enacting the Energy Policy Act of 2005,8 Congress entrusted the Commission with the
duties of approving and enforcing rules to ensure the reliability of the nation’s Bulk-Power
System, and with the duties of certifying an ERO that would be charged with developing and
enforcing mandatory Reliability Standards, subject to Commission approval. Section 215(b)(1)9
of the FPA states that all users, owners, and operators of the Bulk-Power System in the United
States will be subject to Commission-approved Reliability Standards. Section 215(d)(5)10 of the
FPA authorizes the Commission to order the ERO to submit a new or modified Reliability
Standard. Section 39.5(a)11 of the Commission’s regulations requires the ERO to file with the
Commission for its approval each Reliability Standard that the ERO proposes should become
mandatory and enforceable in the United States, and each modification to a Reliability Standard
that the ERO proposes should be made effective.

8
9
10
11

16 U.S.C. § 824o (2006).
Id. § 824(b)(1).
Id. § 824o(d)(5).
18 C.F.R. § 39.5(a) (2012).

4

The Commission has the regulatory responsibility to approve Reliability Standards that
protect the reliability of the Bulk-Power System and to ensure that such Reliability Standards are
just, reasonable, not unduly discriminatory or preferential, and in the public interest. Pursuant to
Section 215(d)(2) of the FPA12 and Section 39.5(c)13 of the Commission’s regulations, the
Commission will give due weight to the technical expertise of the ERO with respect to the
content of a Reliability Standard.
B.

NERC Reliability Standards Development Process

The proposed Reliability Standard was developed in an open and fair manner and in
accordance with the Commission-approved Reliability Standard development process.14 NERC
develops Reliability Standards in accordance with Section 300 (Reliability Standards
Development) of its Rules of Procedure and the NERC Standard Processes Manual.15 In its ERO
Certification Order, the Commission found that NERC’s proposed rules provide for reasonable
notice and opportunity for public comment, due process, openness, and a balance of interests in
developing Reliability Standards and thus satisfies certain of the criteria for approving Reliability
Standards.16 The development process is open to any person or entity with a legitimate interest
in the reliability of the Bulk-Power System. NERC considers the comments of all stakeholders,
and a vote of stakeholders and the NERC Board of Trustees is required to approve a Reliability
Standard before the Reliability Standard is submitted to the Commission for approval.

12

16 U.S.C. § 824o(d)(2).
18 C.F.R. § 39.5(c)(1).
14
Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the
Establishment, Approval, and Enforcement of Electric Reliability Standards, Order No. 672, FERC Stats. & Regs. ¶
31,204, order on reh’g, Order No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006).
15
The NERC Rules of Procedure are available at http://www.nerc.com/AboutNERC/Pages/Rules-ofProcedure.aspx. The NERC Standard Processes Manual is available at
http://www.nerc.com/comm/SC/Documents/Appendix_3A_StandardsProcessesManual.pdf.
16
116 FERC ¶ 61,062 at P 250 (2006).
13

5

C.

History of Project 2009-03, Emergency Operations

NERC is required to conduct a periodic review of each NERC Reliability Standard at
least once every 10 years, or once every five years for any Reliability Standard approved by the
American National Standards Institute as an American National Standard. The Emergency
Operations Five-Year Review Team (“EOP FYRT”) was appointed by the Standards Committee
Executive Committee on April 22, 2013. The EOP FYRT reviewed the following Emergency
Operations standards: EOP-001-2.1b (Emergency Operations Planning), EOP-002-3.1 (Capacity
and Energy Emergencies) and EOP-003-2 (Load Shedding Plans) to determine if the standards
should be retained, retired or if revisions were needed in the scope of this project in relation to
P81 criteria, Independent Expert report and FERC directives.
The scope of the review included consideration of recommendations from the Industry
Expert Review Panel report, Paragraph 81 recommendations and criteria, outstanding FERC
Order No. 693 directives, and industry comments. The EOP FYRT posted its draft
recommendations to revise the standards for stakeholder comment. After reviewing stakeholder
comments, the EOP FYRT submitted its final recommendations to the Standards Committee,
along with a Standard Authorization Request (“SAR”). This SAR replaced an earlier SAR, and
the new SAR provided the scope for the work of Project 2009-03. The EOP drafting team
implemented the EOP FYRT recommendations into proposed reliability standard EOP-011-1.
IV.

JUSTIFICATION FOR APPROVAL
As discussed in detail in Exhibit C, proposed Reliability Standard EOP-011-1--

Emergency Operations satisfies the Commission’s criteria in Order No. 672 and is just,
reasonable, not unduly discriminatory or preferential, and in the public interest. The purpose of
proposed Reliability Standard EOP-011-1 is to address the effects of operating Emergencies by
ensuring that each Transmission Operator and Balancing Authority has developed Operating
6

Plans to mitigate operating Emergencies, and that those plans are coordinated within a Reliability
Coordinator Area. Provided below is an explanation of the applicability of the proposed
Reliability Standard and a justification on a Requirement-by-Requirement basis.
A.

Justification on a Requirement-by-Requirement Basis for
EOP-011-1 – Emergency Operations

The proposed Reliability Standard consists of six Requirements and Attachment 1 and is
applicable to Balancing Authorities, Reliability Coordinators, and Transmission Operators.
Attachment 1 describes the levels used by the Reliability Coordinator when communicating the
condition of a Balancing Authority that is experiencing an Energy Emergency.
Proposed Requirement R1 addresses the need for Transmission Operators to develop,
maintain and implement Operating Plans to mitigate operating Emergencies and specifies
minimum requirements for the plans.17 Proposed Requirement R2 addresses the need for
Balancing Authorities to develop, maintain, and implement Operating Plans to mitigate Capacity
Emergencies and Energy Emergencies. Proposed Requirement R3 requires Reliability
Coordinators to review the Operating Plans submitted by Transmission Operators and Balancing
Authorities and is designed to ensure that there is appropriate coordination with respect to
reliability risks identified in those Operating Plans. Proposed Requirement R4 requires
Transmission Operators and Balancing Authorities to resolve any issues identified by the
Reliability Coordinator during its review of plans submitted pursuant to Requirement R3 and
resubmit the plan to the Reliability Coordinator for additional review.

17

An “Operating Plan” is defined in the Glossary of Terms Used in NERC Reliability Standards as “A
document that identifies a group of activities that may be used to achieve some goal. An Operating Plan may contain
Operating Procedures and Operating Processes. A company-specific system restoration plan that includes an
Operating Procedure for black-starting units, Operating Processes for communicating restoration progress with other
entities, etc., is an example of an Operating Plan.”

7

Proposed Requirements R5 and R6 address communication and coordination by
Reliability Coordinators during an Emergency. Proposed Requirement R5 requires Reliability
Coordinators to notify other Balancing Authorities and Transmission Operators in its Reliability
Coordinator Area, and neighboring Reliability Coordinators within 30 minutes of receiving an
Emergency notification from a Balancing Authority or Transmission Operator. Requirement R6
requires a Reliability Coordinator that has a Balancing Authority experiencing a potential or
actual Energy Emergency within its Reliability Coordinator Area to declare an Energy
Emergency Alert, as detailed in Attachment 1. Collectively, these Requirements satisfy the
Commission’s directives in Order No. 693 and are intended to streamline the requirements for
Emergency Operations.
Proposed Requirements
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:
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;
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.
Requirement R1 of proposed Reliability Standard EOP-011-1 requires Transmission

Operators to develop, maintain, and implement one or more Reliability Coordinator-reviewed
Operating Plans to mitigate operating Emergencies. An Operating Plan can be one plan or it can
be multiple plans. An Operating Plan is implemented by carrying out its stated actions. The
8

Operating Plan must include the elements enumerated in Parts 1.1 and 1.2 (including sub-parts
1.2.1 through 1.2.6). Given the need for flexibility to account for regional differences and preexisting methods for mitigating Emergencies, the drafting team included the language “as
applicable.” Where any of these specified elements are not applicable, an entity should provide
in the plan that the element is not applicable and include an explanation. Transmission Operators
are expected to “maintain” Operating Plans by keeping them current and up-to-date. In
accordance with the principles of Paragraph 81, the proposed Reliability Standard does not
include a specific timeframe or requirement to update Operating Plans as entities are expected to
maintain their plans on an on-going and as-needed basis.18

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:
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

18

See Criterion B1, B3 and B5. Paragraph 81 White Paper available at:
http://www.nerc.com/pa/Stand/Project%20201302%20Paragraph%2081%20RF/P81_Phase_I_technical_white_pape
r_FINAL.pdf.

9

of being implemented in a timeframe adequate for mitigating the
Emergency; and
2.2.9. Reliability impacts of extreme weather conditions.
Proposed Requirement R2 requires Balancing Authorities to develop, maintain, and
implement one or more Reliability Coordinator-reviewed Operating Plan to mitigate Capacity
Emergencies and Energy Emergencies within its Balancing Authority Area. Proposed
Requirement R2 specifies that the Balancing Authorities should complete these actions “within
its Balancing Authority Area” to articulate the regional bounds of the responsibility of the
Balancing Authority. As with proposed Requirement R1, an Operating Plan can be one plan or it
can be multiple plans and is implemented by carrying out its stated actions. Balancing
Authorities are expected to “maintain” Operating Plans by keeping them current and up-to-date.
In accordance with the principles of Paragraph 81, the proposed Reliability Standard does not
include a specific timeframe or requirement to update Operating Plans as entities are expected to
maintain their plans on an on-going and as-needed basis.

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.
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.
Proposed Requirement R3 ensures that Reliability Coordinators review Operating Plans

submitted by Transmission Operators and Balancing Authorities in a timely manner and to
identify specific reliability risks. For those Plans that require revisions, the Reliability
Coordinator is required by Proposed Requirement R3 Part 3.1.3 to articulate a timeframe for
10

resubmittal of the revised plan. This is consistent with the Reliability Coordinator’s role within
the NERC Functional Model.

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.
Proposed Requirement R4 supports the coordination of Operating Plans within a

Reliability Coordinator Area in order to identify and correct any Wide Area reliability risks.
Proposed Requirement R4 is designed to ensure that the Reliability Coordinator’s review of
Operating Plans is effective. Any reliability risks identified by the Reliability Coordinator must
be addressed by the Transmission Operator or Balancing Authority within a time period
specified by the Reliability Coordinator. A specific timeframe is not included in order to allow
entities flexibility to address the identified risks, which could vary widely from entity to entity.
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.

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.
Proposed Requirement R5 is designed to ensure that there is communication among

Balancing Authorities and Transmission Operators when an entity is experiencing an
Emergency. As the entity with the Wide Area view, the Reliability Coordinator is designated as
the entity responsible for ensuring that this communication occurs and in a timely manner.

11

The drafting team used the existing requirement in currently-effective Reliability
Standard 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.

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.
Proposed Requirement R6 requires Reliability Coordinators to declare an Energy

Emergency Alert when a Balancing Authority is experiencing a potential or actual Energy
Emergency. The declaration of the Energy Emergency by the Reliability Coordinator instead of
the Balancing Authority is consistent with current industry practice and ensures that Energy
Emergencies are not declared precipitously.

B.

Commission Directives Addressed

As explained in Exhibit F and detailed below, the proposed Reliability Standard satisfies
seven Commission directives from Order No. 693, including in an equally efficient and effective
alternative manner.
1.

Order No. 693, Paragraph 561, Optimum Number of Continent-Wide
System States

In Order No. 693, the Commission directed NERC to determine the optimum number of

12

Continent-wide system states and their attributes and to modify EOP-001-0 through the
Reliability Standards development process to accomplish this objective.19 While proposed
Reliability Standard EOP-011-1 does not define the optimum number of continent-wide system
states, as Emergency system states are case-specific and therefore difficult to define, the
proposed standard does require Transmission Operators and Balancing Authorities to identify
conditions that put them into an Emergency state via proposed Requirements R1 and R2.
Therefore, this directive from Order No. 693 has been satisfied in an equally efficient and
effective manner.
2.

Order No. 693, Paragraph 562, Consideration of a Pilot Program

In Order No. 693, the Commission directed NERC to consider a pilot program as it
modifies EOP-010-1. “Such testing will help assure that all applicable entities and their
personnel understand how the terms will be used and will allow operators to train staff to make
any necessary changes to their policies and procedures.”20 Given that the drafting team met the
directive in Paragraph 561 of Order No. 693 in an alternative manner, the directive in Paragraph
562 is not directly applicable. The drafting team considered this proposal, thereby satisfying the
directive--however, the team concluded that a field test would not be a viable option with
Emergency states, as one would not intentionally create an Emergency state on the system.
Further, proposed Reliability Standard EOP-010-1 provides flexibility by allowing Transmission
Operators and Balancing Authorities to identify conditions that put them into an Emergency state
via proposed Requirements R1 and R2. For these reasons, the directive from Order No. 693 has
been satisfied in an equally efficient and effective manner.

19
20

Order No. 693 at P 561.
Order No. 693 at P 562.

13

3.

Order No. 693, Paragraph 571, Clarification of Insufficient Transmission
Capability

In Order No. 693, the Commission directed NERC to consider whether to clarify the term
“insufficient transmission capability” and referenced the NOPR issued prior to Order No. 693
where the Commission noted that Reliability Standard EOP-002-1 addresses only generation
capacity and energy emergencies and does not address emergencies resulting from inadequate
transmission capability.21 Proposed Reliability Standard EOP-011-1 includes transmissionrelated items that impact transmission capability in the Transmission Operator’s Emergency
Operating Plan in Parts 1.2.2 through 1.2.4 of Requirement R1.
1.2.2. Cancellation or recall of Transmission and generation outages;
1.2.3. Transmission system reconfiguration;
1.2.4. Redispatch of generation request;
Redispatch of generation is included because it can impact transmission capability. Typically,
redispatching generation means that you are lowering generation in one area and raising it in
another. This changes the transmission flows and can have a significant impact and reduce any
real or potential System Operating Limit and Interconnection Reliability Operating Limit
exceedances that an entity might have, plus it could also free up transmission capability to import
power from other Balancing Authorities.
While NERC did not clarify the term “insufficient transmission capability,” proposed
Reliability Standard EOP-011-1 addresses emergencies resulting from inadequate transmission
capability and is therefore an equally effective and efficient alternative.

21

Order No. 693 at P 571.

14

4.

Order No. 693, Paragraph 573, Technically Feasible Options

In Order No. 693, the Commission directed NERC to modify Reliability Standard EOP002-2 to include all technically feasible options in the management of emergencies.22 “These
options should include generation resources, demand response resources and other technologies
that meet comparable technical performance requirements.”23
Requirements R1 and R2 of proposed Reliability Standard EOP-011-1 include a variety
of options to prepare for and mitigate emergencies. Specifically, management of generation
resources is included in Part 2.2.3 and demand response is included in Part 2.2.7 of Requirement
R2 of proposed Reliability Standard EOP-011-1. For these reasons, the proposed Reliability
Standard EOP-011-1 satisfies the Commission’s directive in Paragraph 573 of Order No. 693.
5.

Order No. 693, Paragraph 595, Load Shedding Capability

In Order No. 693, the Commission directed NERC to modify Reliability Standard EOP003-1 to:
ensure that adequate load shedding capabilities are provided so that system
operators have an effective operating measure of last resort to contain system
emergencies and prevent cascading. The Commission recognizes that the amount
of load shedding capability required is dependent on system characteristics and
therefore it may not be feasible to have a uniform nationwide load shedding
capability. This, however, does not preclude a uniform nationwide criterion on the
methodology for establishing load shedding capability that would specify the
minimum amount of load shedding capability that should be provided based on
system characteristics and conditions and the maximum amount of delay before
load shedding can be implemented.

Requirement R1 of proposed Reliability Standard EOP-011-1, Part 1.2.5 addresses load shedding
and provides that Transmission Providers include in their Operating Plan(s): “Provisions for
operator-controlled manual Load shedding that minimizes the overlap with automatic Load

22
23

Order No. 693 at P 573.
Id.

15

shedding and are capable of being implemented in a timeframe adequate for mitigating the
Emergency.” Requirement R2 of proposed Reliability Standard EOP-011-1, Part 2.2.8 also
addresses load shedding and provides that Balancing Authorities include in their Operating
Plan(s): “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.” Collectively, these Requirements address the difficulties of
establishing a uniform nationwide load shedding capability and allow entities the flexibility
needed to account for differences in system characteristics. For these reasons, proposed
Reliability Standard EOP-011-1 satisfies the Commission’s directive in Paragraph 595 of Order
No. 693.
6.

Order No. 693, Paragraphs 597 and 603, Periodic Drills of Simulated
Load Shedding

In Order No. 693, the Commission stated that “periodic drills of simulated load shedding
should involve all participants required to ensure successful implementation of load shedding
plans. As such, the drills should extend beyond system operators to distribution operators and
LSEs. The Reliability Standard should require periodic drills by entities subject to section 215,
and require those entities to seek participation by other entities. The drills should test the
readiness and functionality of the load shedding plans, including, at times, the actual deployment
of personnel.”24 In Order No. 693, the Commission directed NERC to modify Reliability
Standard EOP-003-1 to require periodic drills of simulated load shedding.25 As noted herein,
Reliability Standard EOP-003-1 is proposed for retirement. However, this directive is addressed

24
25

Order No. 693 at P 597.
Order No. 693 at P 603.

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by several currently-effective Reliability Standards, including EOP-006-2 – System Restoration
Coordination, and PER-005-1 – Operations Personnel Training.
Currently-effective Reliability Standard EOP-006-2, Requirement R10 addresses periodic
drills and provides:
R10.

Each Reliability Coordinator shall conduct two System restoration drills, exercises, or
simulations per calendar year, which shall include the Transmission Operators and
Generator Operators as dictated by the particular scope of the drill, exercise, or
simulation that is being conducted.
R10.1. Each Reliability Coordinator shall request each Transmission Operator
identified in its restoration plan and each Generator Operator identified in the
Transmission Operators’ restoration plans to participate in a drill, exercise, or
simulation at least every two calendar years.

While Requirement R10 and Sub-Requirement 10.1 do not explicitly require simulated load
shedding, it certainly could be included in the required drills and exercises. In addition,
Requirement R3 of currently-effective Reliability Standard PER-005-1 provides:
R3.

At least every 12 months each Reliability Coordinator, Balancing Authority and
Transmission Operator shall provide each of its System Operators with at least 32 hours
of emergency operations training applicable to its organization that reflects emergency
operations topics, which includes system restoration using drills, exercises or other
training required to maintain qualified personnel.
R3.1. Each Reliability Coordinator, Balancing Authority and Transmission Operator
that has operational authority or control over Facilities with established IROLs or
has established operating guides or protection systems to mitigate IROL
violations shall provide each System Operator with emergency operations training
using simulation technology such as a simulator, virtual technology, or other
technology that replicates the operational behavior of the BES during normal and
emergency conditions.

Again, while not explicitly included, the training required by PER-005-1 (and included in
Requirement R4 of future-effective Reliability Standard PER-005-2) could include simulated
load shedding. For these reasons the Commission’s directive has been addressed in an equally
effective and efficient manner.
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7.

Order No. 693, Paragraph 601, Consideration of Comments

In Order No. 693, NERC directed FERC to consider comments submitted regarding
coordination of trip settings and automatic and manual load shedding plans. The drafting team
considered these comments and addressed the coordination and planning of automatic and
manual Load shedding by requiring Transmission Operators and Balancing Authorities to have a
Reliability Coordinator-reviewed Operating Plan to mitigate operating Emergencies. Therefore,
the Commission’s directive in Paragraph 601 of Order No. 693 has been addressed.
C.

Proposed Definition of “Energy Emergency”

The currently-effective definition of “Energy Emergency” is proposed to be revised as follows:
Energy Emergency - A condition when a Load-Serving Entity or Balancing Authority has
exhausted all other resource options and can no longer meet its customers’ expected
energy Load obligations.
The proposed revisions are intended to clarify that an Energy Emergency is not
necessarily limited to a Load-Serving Entity. The drafting team evaluated the impact of these
revisions on the body of NERC Reliability Standards and determined that the proposed revisions
do not change the reliability intent of other requirements of Definitions.
D.

Justification for Retirements

Proposed Reliability Standard EOP-011-1 replaces currently-effective Reliability
Standards EOP-001-2.1b, EOP-002-3.1, and EOP-003-2. Provided below is an explanation of
how these currently-effective Reliability Standards are addressed and improved upon in
proposed Reliability Standard EOP-011-1. Additional information is also included in Exhibit D.
1.

Justification for Retirement of Reliability Standard EOP-001-2.1b

Currently-effective Reliability Standard EOP-001-2.1b consists of six requirements and is
applicable to Balancing Authorities and Transmission Operators. The purpose of currently-

18

effective Reliability Standard EOP-001-2.1b is to require Transmission Operators and Balancing
Authorities to develop, maintain, and implement a set of plans to mitigate operating emergencies.
Requirements R1 and R2 of proposed Reliability Standard EOP-011-1 address
Requirements R1 through R5 of currently-effective Reliability Standard EOP-001-2.1b.
Requirement R1 of currently-effective Reliability Standard EOP-001-2.1b requires
Balancing Authorities to have operating agreements with adjacent Balancing Authorities is
replaced by proposed Requirement R2 of Reliability Standard EOP-011-1 which requires
Balancing Authorities to develop, maintain and implement a Reliability-Coordinator reviewed
Operating Plan. Currently-effective Reliability Standard EOP-001-2.1b, Requirement R2 which
requires Transmission Operators and Balancing Authorities to develop, maintain and implement
a set of plans to mitigate operating emergencies on the transmission system and for insufficient
generating capacity and is replaced by proposed Requirements R1 and R2 of Reliability Standard
EOP-011-1. Requirements R1 and R2 of proposed Reliability Standard EOP-011-1 require
Transmissions Operators and Balancing Authorities to develop, maintain and implement a
Reliability-Coordinator reviewed Operating Plan.
Currently-effective Reliability Standard EOP-001-2.1b, Requirement R2.3 requires
Transmission Operators and Balancing Authorities to develop, maintain and implement a set of
plans for load shedding, and this requirement is maintained in proposed Reliability Standard
EOP-011-1 Requirement R1, Part 1.2.5.
Currently-effective Reliability Standard EOP-001-2.1b, Requirement R3 requires
Transmission Operators and Balancing Authorities to have emergency plans and specifies
elements that must be included in those plans. Proposed Requirements R1 and R2 of Reliability
Standard EOP-011-1 require Transmission Operators and Balancing Authorities to develop,
maintain, and implement a Reliability-Coordinator reviewed Operating Plan to mitigate
19

operating Emergencies, and sub-parts of Requirements R1 and R2 specify elements that must be
included in those plans.
Currently-effective Reliability Standard EOP-001-2.1b, Requirement R6 requires
Transmission Operators and Balancing Authorities to coordinate emergency plans with other
Transmission Operators and Balancing Authorities as appropriate, and is proposed for
retirement. For these reasons, the proposed retirement of currently-effective Reliability Standard
EOP-001-2.1b is expected to have little to no impact on the reliability of the Bulk-Power System.
2.

Justification for Retirement of Reliability Standard EOP-002-3.1

Currently-effective Reliability Standard EOP-002-3.1 consists of nine requirements and
is applicable to Balancing Authorities, Reliability Coordinators, and Load-Serving Entities. The
purpose of currently-effective Reliability Standard EOP-002-2.1 is to ensure Reliability
Coordinators and Balancing Authorities are prepared for capacity and energy emergencies.
Requirement R1 of currently-effective Reliability Standard EOP-002-3.1 states that each
Balancing Authority and Reliability Coordinator shall have the responsibility and clear decisionmaking authority to take whatever actions are needed to ensure the reliability of its respective
area and shall exercise specific authority to alleviate capacity and energy emergencies. As the
Commission noted in Order No. 693-A, “a reliability coordinator’s authority to issue directives
arises out of the Commission’s approval of Reliability Standards that mandate compliance with
such directives.”26 Proposed Reliability Standard IRO-001-4, Requirement R1 states that each
Reliability Coordinator shall act to address the reliability of its Reliability Coordinator Area via
direct actions or by issuing Operating Instructions. Proposed Reliability Standard IRO-001-4 is
part of Project 2014-03 and is being submitted for Commission approval in a separate petition.

26

Order No. 693-A at P 112.

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Requirement R2 of proposed Reliability Standard EOP-011-1 replaces Requirements R2
through R7 of currently-effective Reliability Standard EOP-002-3.1. Requirement R2 of
currently-effective Reliability Standard EOP-002-3.1 requires Balancing Authorities to take one
or more actions as described in its capacity and energy emergency plan and this is addressed in
the implementation of Reliability Coordinator-reviewed Operating Plans required by
Requirement R2 of proposed Reliability Standard EOP-011-1. Requirement R3 of currentlyeffective Reliability Standard EOP-002-3.1 requires Balancing Authorities experiencing an
operating capacity or energy emergency to communicate its current and future system conditions
to its Reliability Coordinator and neighboring Balancing Authorities. This notification is
addressed in Part 2.2.1 of Requirement R2 of proposed Reliability Standard EOP-011-1.
The drafting team determined that to have a Transmission Operator or Balancing Authority
contact other Transmission Operators and Balancing Authorities takes them away from the
Emergency at hand, plus they do not have a wide-area view. The Reliability Coordinator can
give an indication of impact and make high-level determinations. The Reliability Coordinator
has the wide-area overview and can quickly determine impacts of neighboring Transmission
Operators, Balancing Authorities and Reliability Coordinators. The Reliability Coordinator is to
make contact within 30 minutes of notification pursuant to Requirement R5 of proposed
Reliability Standard EOP-011-1. From there, Reliability Standards IRO-005, IRO-006 and IRO007 would address the specific actions to be taken.
Requirement R4 of currently-effective Reliability Standard EOP-002-3.1 requires a
Balancing Authority anticipating an operating capacity or energy emergency to perform all
actions necessary and this is addressed in Part 2.2 of Requirement R2 of proposed Reliability
Standard EOP-011-1, which requires Balancing Authorities to have processes to prepare for and
mitigate Emergencies, including the elements listed in Parts 2.2.1 through 2.2.3. Requirement
21

R5 of currently-effective Reliability Standard EOP-002-3.1 requires a deficient Balancing
Authority to only use the assistance provided by the Interconnection’s frequency bias for the
time needed to implement corrective actions. This requirement is addressed by Commissionapproved Reliability Standard BAL-003-1, which is designed to ensure that Balancing
Authorities do not lean on an Interconnection’s frequency. Requirement R6 of currentlyeffective Reliability Standard EOP-002-3.1 specifies remedies that a Balancing Authority shall
implement when it cannot comply with the Control Performance and Disturbance Control
Standards. These remedies are incorporated into Parts 2.2.1 through 2.2.9 of proposed
Reliability Standard EOP-011-1. Requirement R7 of currently-effective Reliability Standard
EOP-002-3.1 applies when a Balancing Authority has exhausted the remedies in Requirement R6
and requires Balancing Authorities to manually shed load and request the Reliability Coordinator
to declare an Energy Emergency Alert in accordance with Attachment 1. This requirement is
incorporated into Requirement R2 of proposed Reliability Standard EOP-011-1, which requires
Balancing Authorities to include processes to prepare for and mitigate Emergencies in their
Operating Plans.
Requirement R8 of currently-effective Reliability Standard EOP-002-3.1 is addressed by
Requirement R6 of proposed Reliability Standard EOP-011-1. Requirement R8 requires a
Reliability Coordinator that has any Balancing Authority within its Reliability Coordinator area
experiencing a potential or actual Energy Emergency to initiate an Energy Emergency Alert as
detailed in Attachment 1. The Reliability Coordinator must act to mitigate the emergency,
including requesting emergency assistance. Requirement R6 of proposed Reliability Standard
EOP-011-1 requires Reliability Coordinators that have a Balancing Authority experiencing a
potential or actual Energy Emergency within its Reliability Coordinator Area to declare an
Energy Emergency Alert as detailed in Attachment 1.
22

For these reasons, the proposed retirement of currently-effective Reliability Standard
EOP-002-3.1 is expected to have little to no impact on the reliability of the Bulk-Power System.
3.

Justification for Retirement of Reliability Standard EOP-003-2

Currently-effective Reliability Standard EOP-003-2 consists of eight requirements and is
applicable to Transmission Operators and Balancing Authorities. Requirement R2, R4 and R7 of
currently-effective Reliability Standard EOP-003-2 are addressed by proposed Reliability
Standard PRC-010-1, which is part of Project 2008-02, Undervoltage Load Shedding and
Underfrequency Load Shedding. Proposed Reliability Standard PRC-010-1 was coordinated
with the instant project and is proposed for Commission approval in a separate petition.
Requirement R1 of currently-effective Reliability Standard EOP-003-2 requires
Transmission Operators or Balancing Authorities operating with insufficient generation or
transmission capacity to shed customer load rather than risk an uncontrolled failure of
components or cascading outages of the Interconnection. This requirement is addressed by
proposed Requirements R1 and R2 of proposed Reliability Standard EOP-011-1, which require
Transmission Operators and Balancing Authorities to develop and implement Operating Plans
that include processes to prepare for and mitigate Emergencies, including provisions for Load
Shedding.
Requirement R2 of currently-effective Reliability Standard EOP-003-2 requires
Transmission Operators to establish plans for automatic load shedding for undervoltage
conditions if the Transmission Operator or its associated Transmission Planner or Planning
Coordinator determine that an undervoltage load shedding scheme is required. This requirement
is addressed by Requirement R1 of proposed Reliability Standard PRC-010-1 – Undervoltage
Load Shedding, which provides:

23

R1.

Each Planning Coordinator or Transmission Planner that is developing a UVLS Program
shall evaluate its effectiveness and subsequently provide the UVLS Program’s
specifications and implementation schedule to the UVLS entities responsible for
implementing the UVLS Program. The evaluation shall include, but is not limited to,
studies and analyses that show:
1.1. The implementation of the UVLS Program resolves the identified undervoltage
issues that led to its development and design.
1.2.
The UVLS Program is integrated through coordination with generator voltage
ride‐through capabilities and other protection and control systems, including,
but not limited to, transmission line protection, autoreclosing, Remedial Action
Schemes, and other undervoltage‐based load shedding programs.

Requirement R1 of proposed Reliability Standard PRC-010-1 also replaces Requirement R4 of
currently-effective Reliability Standard EOP-003-2, which requires Transmission Operators to
consider one or more of the following factors in designing an automatic undervoltage load
shedding scheme: voltage level, rate of voltage decay, or power flow levels. The elements listed
in Requirement R4 of currently-effective Reliability Standard EOP-003-2 are integrated into Part
1.1 of Requirement R1 of proposed Reliability Standard PRC-010-1, as explained in the
Guidelines and Technical Basis section of the standard. Requirement R7 of currently-effective
Reliability Standard EOP-003-2, requires Transmission Operators to coordinate automatic
undervoltage load shedding throughout their areas with tripping of shunt capacitors, and other
automatic actions that will occur under abnormal voltage or power flow conditions. Part 1.2 of
proposed Reliability Standard PRC-010-1 addresses the elements of Requirement R7 of
currently-effective Reliability Standard EOP-003-2, as explained in the Guidelines and Technical
Basis section of the standard.
Requirement R3 of currently-effective Reliability Standard EOP-003-2 requires
Transmission Operators and Balancing Authorities to coordinate load shedding plans, excluding
automatic underfrequency load shedding plans, among other interconnected Transmission

24

Operators and Balancing Authorities. This coordination is addressed by Requirements R1 and
R2 of proposed Reliability Standard EOP-011-1, as explained herein.
Requirement R5 of currently-effective Reliability Standard EOP-003-2 requires
Transmission Operators or Balancing Authorities to implement load shedding, in steps
established to minimize the risk of further uncontrolled separation, loss of generation, or system
shutdown. This requirement is addressed by Requirements R1 and R2 of proposed Reliability
Standard EOP-011-1, which require Transmission Operators and Balancing Authorities to
develop and implement Operating Plans that include processes to prepare for and mitigate
Emergencies, including provisions for Load Shedding.
Requirement R6 of currently-effective Reliability Standard EOP-003-2 requires that after
a Transmission Operator or Balancing Authority Area separates from the Interconnection, if
there is insufficient generating capacity to restore system frequency following automatic
underfrequency load shedding, the Transmission Operator or Balancing Authority shall shed
additional load. Similar to Requirement R1 and R5 of currently-effective Reliability Standard
EOP-003-2, this requirement is addressed by Requirements R1 and R2 of proposed Reliability
Standard EOP-011-1, which require Transmission Operators and Balancing Authorities to
develop and implement Operating Plans that include processes to prepare for and mitigate
Emergencies, including provisions for Load Shedding.
Requirement R8 of currently-effective Reliability Standard EOP-003-2 requires
Transmission Operators or Balancing Authorities to have plans for operator controlled manual
load shedding to respond to real-time emergencies, and the Transmission Operator or Balancing
Authority must be capable of implementing the load shedding in a timeframe adequate for
responding to the emergency. This requirement is addressed by Requirements R1 and R2 of
proposed Reliability Standard EOP-011-1, which require Transmission Operators and Balancing
25

Authorities to develop and implement Operating Plans that include processes to prepare for and
mitigate Emergencies, including provisions for Load Shedding. Part 1.2.5 of Requirement R1
and Part 2.2.8 of Requirement R2 of proposed Reliability Standard EOP-011-1 also incorporate
the concept of a timeframe adequate for mitigating an Emergency.
For these reasons, the proposed retirement of currently-effective Reliability Standard
EOP-003-2 is expected to have little to no impact on the reliability of the Bulk-Power System.
E.

Enforceability of EOP-011-1

The proposed Reliability Standard includes Violation Severity Levels (“VSLs”) and
Violation Risk Factors (“VRFs”). The VSLs provide guidance on the way that NERC will
enforce the Requirements of the proposed Reliability Standard. The VRFs are one of several
elements used to determine an appropriate sanction when the associated Requirement is violated.
The VRFs assess the impact to reliability of violating a specific Requirement. The VRFs and
VSLs for the proposed Reliability Standards comport with NERC and Commission guidelines
related to their assignment. For a detailed review of the VRFs, the VSLs, and the analysis of
how the VRFs and VSLs were determined using these guidelines, please see Exhibit E.
The proposed Reliability Standard also include Measures that support each Requirement
by clearly identifying what is required and how the Requirement will be enforced. These
Measures help ensure that the Requirements will be enforced in a clear, consistent, and nonpreferential manner and without prejudice to any party.27

27

Order No. 672 at P 327 (“There should be a clear criterion or measure of whether an entity is in compliance
with a proposed Reliability Standard. It should contain or be accompanied by an objective measure of compliance
so that it can be enforced and so that enforcement can be applied in a consistent and non-preferential manner.”).

26

V.

CONCLUSION
For the reasons set forth above, NERC respectfully requests that the Commission:
•

approve the proposed Reliability Standard and Definition and associated elements
included in Exhibit A, effective as proposed herein;

•

approve the implementation plan included in Exhibit B as proposed herein.
Respectfully submitted,
/s/ Stacey Tyrewala
Charles A. Berardesco
Senior Vice President and General Counsel
Holly A. Hawkins
Associate General Counsel
Stacey Tyrewala
Senior Counsel
Andrew Wills
Associate Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
[email protected]
[email protected]
[email protected]
[email protected]
Counsel for the North American Electric
Reliability Corporation

Date: December 29, 2014

27