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pdfUNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
North American Electric Reliability
Corporation
)
)
Docket No. _______
JOINT PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION AND
WESTERN ELECTRICITY COORDINATING COUNCIL FOR APPROVAL OF
PROPOSED REGIONAL RELIABILITY STANDARD BAL-002-WECC-3
Steve Goodwill
Vice President, General Counsel, and
Corporate Secretary
Ruben Arredondo
Senior Legal Counsel
Western Electricity Coordinating Council
155 North 400 West, Suite 200
Salt Lake City, UT 84103
(801) 582-0353
[email protected]
[email protected]
Lauren Perotti
Senior Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
[email protected]
Counsel for the North American Electric
Counsel for the Western Electricity Coordinating Reliability Corporation
Council
September 6, 2019
TABLE OF CONTENTS
I.
SUMMARY ............................................................................................................................ 3
II.
NOTICES AND COMMUNICATIONS ................................................................................ 5
III. BACKGROUND .................................................................................................................... 5
A.
Regulatory Framework ..................................................................................................... 5
B.
WECC Regional Reliability Standards Development Process ........................................ 7
C.
Procedural History............................................................................................................ 8
D.
Development of Proposed Regional Reliability Standard BAL-002-WECC-3 ............... 9
IV. JUSTIFICATION FOR APPROVAL................................................................................... 10
V.
A.
Purpose and Applicability .............................................................................................. 10
B.
Retirement of Requirement R2 ...................................................................................... 11
C.
Enforceability of Proposed Regional Reliability Standard BAL-002-WECC-3 ............ 15
EFFECTIVE DATE .............................................................................................................. 16
VI. CONCLUSION ..................................................................................................................... 17
Exhibit A
Proposed Regional Reliability Standard BAL-002-WECC-3 – Contingency
Reserve
Exhibit A-1: Clean
Exhibit A-2: Redline to BAL-002-WECC-2a
Exhibit B
Implementation Plan
Exhibit C
Field Test Results, WECC-0115 BAL-002-WECC-2a Request to Retire
Requirement R2
Exhibit D
Order No. 672 Criteria
Exhibit E
Summary of Development History and Complete Record of Development
Exhibit F
Drafting Team Roster
Exhibit G
VRF and VSL Justification
i
UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
North American Electric Reliability
Corporation
)
)
Docket No. _______
JOINT PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION AND
WESTERN ELECTRICITY COORDINATING COUNCIL FOR APPROVAL OF
PROPOSED REGIONAL RELIABILITY STANDARD BAL-002-WECC-3
Pursuant to Section 215(d)(1) of the Federal Power Act (“FPA”) 1 and Section 39.5 2 of the
Federal Energy Regulatory Commission’s (“FERC” or the “Commission”) regulations, the North
American Electric Reliability Corporation (“NERC”) 3 and the Western Electricity Coordinating
Council (“WECC”) hereby submit proposed Regional Reliability Standard BAL-002-WECC-3 –
Contingency Reserve for Commission approval. Proposed Regional Reliability Standard BAL002-WECC-3 reflects the retirement of Requirement R2 in the currently effective standard BAL002-WECC-2a relating to the composition of the required Contingency Reserve.
NERC and WECC request that the Commission approve proposed Regional Reliability
Standard BAL-002-WECC-3 (Exhibit A) as just, reasonable, not unduly discriminatory or
preferential, and in the public interest. NERC and WECC also request approval of the associated
1
16 U.S.C. § 824o (2018).
18 C.F.R. § 39.5 (2018).
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).
Unless otherwise indicated, capitalized terms used in this Petition shall have the meaning set forth in the
Glossary of Terms Used in NERC Reliability Standards (“NERC Glossary”),
https://www.nerc.com/pa/Stand/Glossary%20of%20Terms/Glossary_of_Terms.pdf, or Appendix 2 to the NERC
Rules of Procedure, Definitions Used in the NERC Rules of Procedure,
https://www.nerc.com/AboutNERC/Pages/Rules-of-Procedure.aspx.
2
2
implementation plan (Exhibit B) as detailed in this petition, and the associated Violation Risk
Factors (“VRFs”) and Violation Severity Levels (“VSLs”) (Exhibit A), which remain unchanged
from currently effective Regional Reliability Standard BAL-002-WECC-2a (see Exhibit G).
As required by Section 39.5(a) 4 of the Commission’s regulations, this petition presents the
technical basis and purpose of proposed Regional Reliability Standard BAL-002-WECC-3, a
summary of the development proceedings (Section III.D and Exhibit E), and a demonstration that
the proposed Reliability Standard meets the criteria identified by the Commission in Order No.
672 5 (Exhibit D). Proposed Regional Reliability Standard BAL-002-WECC-3 was approved by
the WECC Board of Directors on June 19, 2019 and adopted by the NERC Board of Trustees on
August 15, 2019.
I.
SUMMARY
The purpose of currently effective Regional Reliability Standard BAL-002-WECC-2a –
Contingency Reserve is to provide a Regional Reliability Standard that specifies the quantity and
types of Contingency Reserve 6 required to ensure reliability under normal and abnormal
4
18 C.F.R. § 39.5(a).
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, 114 FERC ¶ 61,104, at PP 262, 321-37 (“Order No. 672”), order on reh’g, Order No.
672-A, 114 FERC ¶ 61,328 (2006).
6
Contingency Reserve is defined in the NERC Glossary as:
The provision of capacity that may be deployed by the Balancing Authority to
respond to a Balancing Contingency Event and other contingency requirements
(such as Energy Emergency Alerts as specified in the associated EOP standard).
A Balancing Authority may include in its restoration of Contingency Reserve
readiness to reduce Firm Demand and include it if, and only if, the Balancing
Authority:
• is experiencing a Reliability Coordinator declared Energy Emergency Alert
level, and is utilizing its Contingency Reserve to mitigate an operating emergency
in accordance with its emergency Operating Plan.
• is utilizing its Contingency Reserve to mitigate an operating emergency in
accordance with its emergency Operating Plan.
5
3
conditions. The standard consists of four requirements. Requirement R1 provides that each
Balancing Authority and each Reserve Sharing Group shall maintain a minimum amount of
Contingency Reserve, and that the Contingency Reserve shall consist of any combination of a list
of specified reserve types. Requirement R2 provides that at least half of the minimum amount of
Contingency Reserve shall be Operating Reserve – Spinning that meets certain reserve
characteristics. Requirements R3 and R4 require entities to maintain a minimum amount of
Operating Reserve.
Since the regional standard was originally developed, a continent-wide Reliability
Standard has come into effect that renders Regional Reliability Standard BAL-002-WECC-2a
Requirement R2 redundant and no longer needed for reliability in the Western Interconnection.
Reliability Standard BAL-003-1.1 Requirement R1 provides that each Frequency Response
Sharing Group or Balancing Authority shall achieve an annual Frequency Response Measure that
is equal to or more negative than its Frequency Response Obligation to ensure that it is providing
sufficient Frequency Response. This continent-wide requirement helps ensure that sufficient
Frequency Response is provided to maintain Interconnection frequency in support of the reliable
operation of the Interconnection. In light of this continent-wide Reliability Standard, and as
supported by the results of a field test (see Exhibit C), WECC has determined that Requirement
R2 of currently effective Regional Reliability Standard BAL-002-WECC-2a should be retired.
For these reasons, and as discussed more fully herein, NERC and WECC respectfully
request the Commission approve proposed Regional Reliability Standard BAL-002-WECC-3 and
the associated elements. The following petition presents the justification for approval and
supporting documentation.
4
II.
NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the
following: 7
Steve Goodwill*
Vice President, General Counsel, and
Corporate Secretary
Ruben Arredondo*
Senior Legal Counsel
Steve Rueckert*
Director of Standards
Western Electricity Coordinating Council
155 North 400 West, Suite 200
Salt Lake City, UT 84103
(801) 582-0353
[email protected]
[email protected]
[email protected]
III.
Lauren Perotti*
Senior Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
[email protected]
BACKGROUND
The following background information is provided below: (a) an explanation of the
regulatory framework for NERC and Regional Reliability Standards; (b) an explanation of the
WECC Regional Reliability Standards development process; and (c) a summary of the
development process for the proposed Reliability Standard.
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
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, to allow the inclusion of more
than two persons on the service list in this proceeding.
8
16 U.S.C. § 824o.
5
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.
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 FPA 12 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.
Similarly, the Commission approves regional differences proposed by Regional Entities,
such as Regional Reliability Standards and Variances, if the regional difference is just, reasonable,
not unduly discriminatory or preferential, and in the public interest. 14 In addition, Commission
Order No. 672 requires further criteria for regional differences. A regional difference from a
continent-wide Reliability Standard must either be: (1) more stringent than the continent-wide
9
10
11
12
13
14
Id. § 824o(b)(1).
Id. § 824o(d)(5).
18 C.F.R. § 39.5(a).
16 U.S.C. § 824o(d)(2).
18 C.F.R. § 39.5(c)(1).
16 U.S.C. § 824o(d)(2) and 18 C.F.R. § 39.5(a).
6
Reliability Standard, including a regional difference that addresses matters that the continent-wide
Reliability Standard does not; or (2) necessitated by a physical difference in the Bulk-Power
System. 15 The Commission must give due weight to the technical expertise of a Regional Entity,
like WECC, that is organized on an Interconnection-wide basis with respect to a regional
difference to be applicable within that Interconnection. 16
B.
WECC Regional Reliability Standards Development Process
Proposed Regional Reliability Standard BAL-002-WECC-3 was developed in an open and
fair manner and in accordance with the Commission-approved WECC Reliability Standards
Development Procedures (“RSDP”). 17 WECC’s RSDP provides for reasonable notice and
opportunity for public comment, due process, openness, and a balance of interests in developing
Regional Reliability Standards and thus addresses several of the Commission’s criteria for
approving Reliability Standards. The development process is open to any person or entity that is
an interested stakeholder. WECC considers the comments of all stakeholders, and a vote of
stakeholders and the WECC Board of Directors is required to approve a WECC Regional
Reliability Standard or Variance. NERC posts each Regional Reliability Standard or Variance
developed by a Regional Entity such as WECC for an additional comment period. The NERC
Board of Trustees must adopt a proposed Regional Reliability Standard or Variance before it is
submitted to the Commission for approval.
15
Order No. 672 at P 291.
Id. at P 344.
17
The currently effective WECC RSDP was approved by the Commission on October 27, 2017 (see N. Am.
Elec. Reliability Corp., RR17-5-000 (Oct. 27, 2017) (delegated letter order)) and is available at
https://www.nerc.com/FilingsOrders/us/Regional%20Delegation%20Agreements%20DL/WECC%20RSDP_201710
27.pdf.
16
7
C.
Procedural History
The Commission approved Regional Reliability Standard BAL-002-WECC-2 –
Contingency Reserve in Order No. 789, issued on November 21, 2013. 18 In approving the regional
standard, the Commission found that it contained a more stringent set of requirements than those
provided in the continent-wide disturbance control standard in effect at that time, Reliability
Standard BAL-002-1 – Disturbance Control Performance. 19 On January 24, 2017, the Commission
approved NERC’s petition for approval of BAL-002-WECC-2a, which added an interpretation to
Requirement R2. 20
Since the BAL-002-WECC-2 standard was originally approved, the Commission has
approved several continent-wide BAL Reliability Standards. The Commission approved the
current version of the continent-wide disturbance control standard, Reliability Standard BAL-0023 – Disturbance Control Standard – Contingency Reserve for Recovery from a Balancing
Contingency Event, in 2018. 21 Relevant to the proposal described in this petition, the Commission
also approved Reliability Standard BAL-003-1 – Frequency Response and Frequency Bias Setting
in 2014 in Order No. 794. 22 (The Commission subsequently approved errata version BAL-003-1.1
on November 13, 2015. 23 ) In accordance with the approved implementation plan, Reliability
Standard BAL-003-1.1 Requirement R1 became effective in the United States on April 1, 2016.
18
Regional Reliability Standard BAL-002-WECC-2 – Contingency Reserve, Order No. 789, 145 FERC ¶
61,141 at P 1 (2013).
19
Id. at P 26.
20
N. Am. Elec. Reliability Corp., Docket No. RD17-3-000 (Jan. 24, 2017) (delegated letter order).
21
N. Am. Elec. Reliability Corp., Docket No. RD18-7-000 (Sep. 25, 2018) (delegated letter order).
22
Frequency Response and Frequency Bias Setting Reliability Standard, Order No. 794, 146 FERC ¶ 61,024
(2014).
23
N. Am. Elec. Reliability Corp., Docket No. RD15-6-000 (Nov. 13, 2015) (delegated letter order).
8
D.
Development of Proposed Regional Reliability Standard BAL-002-WECC-3
As further described in Exhibit E hereto, WECC developed proposed Regional Reliability
Standard BAL-002-WECC-3 in accordance with the WECC RSDP. On May 6, 2015, WECC
received a Standard Authorization Request to retire Requirement R2 of the regional standard on
the basis that the regional requirement would become redundant upon the April 1, 2016 effective
date of continent-wide Reliability Standard BAL-003-1.1 Requirement R1. The WECC drafting
team (Exhibit F) consisted of individuals with relevant expertise in the subject matter area.
From May 1, 2017 through April 30, 2018, WECC conducted a field test to evaluate
whether the retirement of Requirement R2 would impact reliability in the Western
Interconnection. 24 As discussed more fully in Exhibit C and summarized below, WECC
determined that the retirement of Requirement R2 would have no adverse impact on reliability.
The WECC standard drafting team drafted proposed Regional Reliability Standard BAL-002WECC-3 to reflect the retirement of Requirement R2.
On April 11, 2019, the WECC ballot body approved the proposed Regional Reliability
Standard with a 100 percent weighted affirmative vote at 89.5 percent quorum. The WECC Board
of Directors approved the proposed Regional Reliability Standard on June 19, 2019. NERC posted
the Regional Reliability Standard for a 45-day comment period from June 20, 2019 through August
5, 2019. Commenters agreed that WECC’s process was open, inclusive, balanced, and transparent,
and that it provided due process. The NERC Board of Trustees adopted proposed Regional
Reliability Standard BAL-002-WECC-3 on August 15, 2019.
24
As WECC did not have a separate procedure for the conduct of field tests, WECC conducted the field test
in accordance with the processes specified in Section 6.2 of the then-effective NERC Standard Processes Manual,
Appendix 3A to the NERC Rules of Procedure. As part of this field test, WECC (with NERC approval) provided
each responsible entity with a waiver of compliance for Requirement R2.
9
IV.
JUSTIFICATION FOR APPROVAL
This section provides a description of the purpose and applicability of proposed Reliability
Standard BAL-002-WECC-3, a summary of the changes reflected in the proposed standard, and a
discussion of the enforceability of the proposed standard. As discussed more fully below, the main
change in the proposed standard is the retirement of Requirement R2. NERC and WECC propose
to retire Requirement R2 because the requirement became redundant and no longer necessary for
reliability upon the April 1, 2016 effective date of continent-wide Reliability Standard BAL-0031.1 Requirement R1. Proposed Regional Reliability Standard BAL-002-WECC-3 continues to
represent a more stringent set of requirements for entities in the Western Interconnection than those
found in the continent-wide disturbance control standard, Reliability Standard BAL-002-3, and it
continues to remain necessary for reliability within the Interconnection.
A.
Purpose and Applicability
The stated purpose of proposed Regional Reliability Standard BAL-002-WECC-3, which
remains unchanged from the currently effective version, is “to specify the quantity and types of
Contingency Reserve required to ensure reliability under normal and abnormal conditions.” The
proposed Regional Reliability Standard applies to Balancing Authorities and Reserve Sharing
Groups, which is unchanged from the currently effective version.
B.
Summary of Revisions
In proposed Regional Reliability Standard BAL-002-WECC-3, the text of Requirement R2
is struck in its entirety and replaced with the word “Reserved.” Corresponding revisions are made
to the measures and VSL table, and the approved Interpretation to Requirement R2 is removed
from Section E., Interpretations. Additionally, minor editorial and formatting changes are made
throughout the document. These changes are shown in redline in Exhibit A.
10
C.
Retirement of Requirement R2
As noted above, proposed Regional Reliability Standard BAL-002-WECC-3 reflects the
retirement of Requirement R2 of the currently effective standard. Regional Reliability Standard
BAL-002-WECC-2a Requirement R2 provides:
R2. Each Balancing Authority and each Reserve Sharing Group shall
maintain at least half of its minimum amount of Contingency
Reserve identified in Requirement R1, as Operating Reserve –
Spinning that meets both of the following reserve characteristics.
2.1
Reserve that is immediately and automatically responsive to
frequency deviations through the action of a governor or
other control system;
2.2
Reserve that is capable of fully responding within ten
minutes.
A similar version of this requirement was present in the first version of the regional
standard, WECC-BAL-STD-002-0, which was approved by the Commission in 2007. 25 The
original intent of this requirement was to: (1) aid in frequency recovery (through governor action)
for large generation loss events across the Western Interconnection; and (2) provide a part of the
Contingency Reserves for generation trip events within the Balancing Authority or Reserve
Sharing Group area. It was based on a historical, pre-Reliability Standards paradigm in which
visibility, data exchange, and understanding of other Balancing Authority areas was minimal,
frequency deviation was largely addressed by manual and analog intervention, and coordination
between Balancing Authority areas was accomplished through mutual cooperation unsupported by
mandatory standards.
Regional Reliability Standard WECC-BAL-STD-002-0 carried forward criteria from the
Reliability Management System (“RMS”) of WECC’s predecessor, the Western Systems
25
N. Am. Elec. Reliability Corp., 119 FERC ¶ 61,260 (2007).
11
Coordinating Council (“WSCC”). The RMS program was comprised of approximately 17
“criteria” that came from the NERC Operating Policies. When the initial set of NERC’s Version
0 standards was developed, WSCC reviewed the standards to determine if the RMS criteria had
been included. Where an RMS criterion was not addressed in a continent-wide standard, WSCC
initiated development of a Regional Reliability Standard to transition the RMS criteria to a
mandatory standard. The criteria and language from RMS had to be translated to a requirement
in the Regional Reliability Standard without revision. In some instances, the RMS criteria were
more stringent than the continent-wide requirements. This included the criteria carried forward in
WECC-BAL-STD-002-0.
During the development of the RMS criteria in the late 1990s, WSCC did not conduct
any simulations or assessments to determine or identify that the 50 percent level that was later
specified in BAL-002-WECC Requirement R2 was what was needed for optimal system
reliability. Rather, it was an agreed upon value established by a majority of the RMS drafters.
While it could be assumed that a 100 percent level would be best, such a requirement would have
come with unacceptably high costs. Conversely, a requirement to carry zero percent would have
been unacceptable from a reliability perspective. In the end, most the participants gravitated to
the number in the middle, 50 percent. There was no other technical analysis done.
In the intervening years, NERC developed a continent-wide Reliability Standard
specifically to address frequency response. The stated purpose of Reliability Standard BAL-0031.1 is “[t]o require sufficient Frequency Response from the Balancing Authority (BA) to maintain
Interconnection Frequency within predefined bounds by arresting frequency deviations and
supporting frequency until the frequency is restored to its scheduled value” and “[t]o provide
consistent methods for measuring Frequency Response and determining the Frequency Bias
12
Setting.” Requirement R1, which became mandatory and enforceable on entities in the United
States on April 1, 2016, provides as follows:
R1.
Each Frequency Response Sharing Group (FRSG) or Balancing
Authority that is not a member of a FRSG shall achieve an annual
Frequency Response Measure (FRM) (as calculated and reported in
accordance with Attachment A) that is equal to or more negative
than its Frequency Response Obligation (FRO) to ensure that
sufficient Frequency Response is provided by each FRSG or BA that
is not a member of a FRSG to maintain Interconnection Frequency
Response equal to or more negative than the Interconnection
Frequency Response Obligation.
Reliability Standard BAL-003-1.1 addresses the same frequency response components
covered in currently effective Regional Reliability Standard BAL-002-WECC-2a Requirement R2
but in a results-based manner. Requirement R2 of the regional standard requires the entity to
maintain at least half of its Contingency Reserve as Operating Reserve – Spinning. By contrast,
Reliability Standard BAL-003-1.1 requires the entity to achieve a calculated Frequency Response
Measure and allows the entity to meet this measure through a variety of services or arrangements.
The WECC standard drafting team determined that retention of the regional minimum Operating
Reserve – Spinning requirement, alongside the continent-wide frequency response requirement,
could lead to confusion and the needless procurement of additional reserves, thereby increasing
costs without providing additional reliability benefits.
To evaluate the potential impact on reliability in the Western Interconnection should
Requirement R2 be retired, WECC conducted a field test from May 1, 2017 through April 30,
2018, the results of which are summarized below and discussed in detail in Exhibit C. To provide
more accurate results, WECC, with NERC approval, provided a compliance waiver for
Requirement R2 to responsible entities. As part of the field test, responsible entities provided the
following information: (1) for any reportable Disturbance Control Standard (“DCS”) event, the
13
date and time of the event, the required amount of Contingency Reserves at the time of the event,
the actual amount of Operating Reserves – Spinning at the time of the event, and the actual DCS
performance; and (2) for all instances of a loss of resources 700 megawatts (“MW”) or greater,
whether it is a reportable DCS event or not, the date and time of the event, the name of the
resource(s), and the total MW loss.
To evaluate the resulting impacts on reliability, the WECC standard drafting team applied
two metrics. The first metric, DCS performance, monitored the performance of each Reserve
Sharing Group/Balancing Authority for every reportable DCS event to see whether any were
unable to meet the DCS recovery period for a DCS event. The second metric evaluated system
performance for any loss of resources greater than 700 MW and for any adverse impact on
frequency response.
As discussed more fully in Exhibit C, analysis of the data demonstrates that all 66 DCS
events occurring during the field test period had a 100 percent pass rate, showing no degradation
to DCS performance. Entities carried and deployed enough reserves for post disturbance Area
Control Error recovery. For 63 of the total 66 events, entities carried more than the required 50
percent Operating Reserve – Spinning (on average, 166.38 percent). For the remaining three
events, entities carried less than 50 percent Operating Reserve – Spinning (on average, 5.3 percent
less). 26
Western Interconnection frequency performance was assessed to further determine the
impact of the field test on the Interconnection. Frequency performance data was collected for the
32 events having a verified resource loss of more than 700 MW. NERC’s Essential Reliability
Services Measure 4 describes a comprehensive set of frequency response measures capturing speed
26
Exhibit C, Field Test Report at 6-8.
14
of frequency response and response withdrawal at all relevant time frames; these measures were
used to analyze the collected data. 27 The WECC standard drafting team’s analysis also included
frequency response information from the 2018 NERC State of Reliability Report. 28 The standard
drafting team’s analysis indicated that frequency response performance did not degrade in the
Western Interconnection during the field test period. 29
Based on the results of the field test, the WECC standard drafting team determined that the
retirement of Requirement R2 is unlikely to have an adverse impact on reliability in the Western
Interconnection. 30 In light of these results, and in consideration of the redundancy with continentwide Reliability Standard BAL-003-1.1, it is appropriate to retire Requirement R2 in the BAL002-WECC regional standard.
D.
Enforceability of Proposed Regional Reliability Standard BAL-002-WECC-3
Proposed Regional Reliability Standard BAL-002-WECC-3 includes VRFs and VSLs. 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 three remaining requirements in
proposed Regional Reliability Standard BAL-002-WECC-3 are unchanged from the currently
effective version of the standard.
27
Exhibit C, Field Test Report at 8. For additional description of these measures, see NERC, Essential
Reliability Services Task Force Measures Framework Report (Nov. 2015),
https://www.nerc.com/comm/Other/essntlrlbltysrvcstskfrcDL/ERSTF%20Framework%20Report%20-%20Final.pdf.
28
See Exhibit C, Field Test Report at 9-10 (citing 2018 NERC State of Reliability Report at Table 2.1).
29
Exhibit C, Field Test Report at 8-10.
30
Id. at 2.
15
The proposed Regional Reliability Standard also includes 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. 31 The measures for the three remaining
requirements in proposed Regional Reliability Standard BAL-002-WECC-3 are unchanged from
the currently effective version of the standard.
V.
EFFECTIVE DATE
NERC respectfully requests that the Commission approve the proposed implementation
plan, provided in Exhibit B hereto. Because the only substantive change in the proposed standard
is the retirement of Requirement R2, the proposed implementation plan provides that proposed
Regional Reliability Standard BAL-002-WECC-3 would become effective immediately upon
regulatory approval.
31
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.”).
16
VI.
CONCLUSION
For the reasons set forth above, NERC and WECC respectfully request that the Commission
approve:
•
proposed Regional Reliability Standard BAL-002-WECC-3 and the other associated
elements, including the VRFs and VSLs, included in Exhibit A;
•
the proposed implementation plan, included in Exhibit B; and
•
the retirement of currently effective Regional Reliability Standard BAL-002-WECC2a.
Respectfully submitted,
/s/ Lauren Perotti
Steve Goodwill
Vice President, General Counsel, and
Corporate Secretary
Ruben Arredondo
Senior Legal Counsel
Western Electricity Coordinating Council
155 North 400 West, Suite 200
Salt Lake City, UT 84103
(801) 582-0353
[email protected]
[email protected]
Counsel for the Western Electricity
Coordinating Council
Lauren Perotti
Senior Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
[email protected]
Counsel for the North American Electric
Reliability Corporation
Date: September 6, 2019
17
Exhibit A
Proposed Regional Reliability Standard
BAL-002-WECC-3 – Contingency Reserve
WECC Standard BAL-002-WECC-3—Contingency Reserve
A. Introduction
1.
Title:
Contingency Reserve
2.
Number:
BAL-002-WECC-3
3.
Purpose:
To specify the quantity and types of Contingency Reserve required to
ensure reliability under normal and abnormal conditions.
4.
Applicability:
4.1. Functional Entities:
4.1.1 Balancing Authority
4.1.1.1
The Balancing Authority is the responsible entity unless the
Balancing Authority is a member of a Reserve Sharing Group, in
which case, the Reserve Sharing Group becomes the responsible
entity.
4.1.2 Reserve Sharing Group
5.
4.1.2.1
The Reserve Sharing Group when comprised of a Source Balancing
Authority becomes the source Reserve Sharing Group.
4.1.2.2
The Reserve Sharing Group when comprised of a Sink Balancing
Authority becomes the sink Reserve Sharing Group.
Effective Date:
Immediately upon receipt of regulatory approval.
B. Requirements and Measures
R1.
Each Balancing Authority and each Reserve Sharing Group shall maintain a minimum
amount of Contingency Reserve, except within the first sixty minutes following an
event requiring the activation of Contingency Reserve, that is: [Violation Risk Factor:
High] [Time Horizon: Real-time operations]
1.1. The greater of either:
•
The amount of Contingency Reserve equal to the loss of the most severe
single contingency;
•
The amount of Contingency Reserve equal to the sum of three percent of
hourly integrated Load plus three percent of hourly integrated generation.
1.2. Composed of any combination of the reserve types specified below:
BAL-002-WECC-3
•
Operating Reserve—Spinning
•
Operating Reserve—Supplemental
•
Interchange Transactions designated by the Source Balancing Authority as
Operating Reserve—Supplemental
Page 1 of 12
WECC Standard BAL-002-WECC-3—Contingency Reserve
•
Reserve held by other entities by agreement that is deliverable on Firm
Transmission Service
•
A resource, other than generation or load, that can provide energy or reduce
energy consumption
•
Load, including demand response resources, Demand-Side Management
resources, Direct Control Load Management, Interruptible Load or
Interruptible Demand, or any other Load made available for curtailment by
the Balancing Authority or the Reserve Sharing Group via contract or
agreement.
•
All other load, not identified above, once the Reliability Coordinator has
declared an energy emergency alert signifying that firm load interruption is
imminent or in progress.
1.3. Based on real-time hourly load and generating energy values averaged over each
Clock Hour (excluding Qualifying Facilities covered in 18 C.F.R.§ 292.101, as
addressed in FERC Order 464).
1.4. An amount of capacity from a resource that is deployable within ten minutes.
M1. Each Balancing Authority and each Reserve Sharing Group will have documentation
demonstrating its Contingency Reserve was maintained, except within the first sixty
minutes following an event requiring the activation of Contingency Reserve.
Part 1.1
Each Balancing Authority and each Reserve Sharing Group will have dated
documentation that demonstrates its Contingency Reserve was maintained in
accordance with the amounts identified in Requirement R1, Part 1.1, except within the
first sixty minutes following an event requiring the activation of Contingency Reserve.
Attachment A is a practical illustration showing how the generation amount may be
calculated under Requirement R1.
•
•
Where Dynamic Schedules are used as part of the generation amount upon
which Contingency Reserve is predicated, additional evidence of compliance
with Requirement R1, Part 1.1 may include, but is not limited to,
documentation showing a reciprocal acknowledgement as to which entity is
carrying the reserves. This transfer may be all or some portion of the physical
generator and is not limited to the entire physical capability of the generator.
Where Pseudo-Ties are used as part of the generation amount upon which
Contingency Reserve is predicated, additional evidence of compliance with
Requirement R1, Part 1.1, may include, but is not limited to, documentation
accounting for the transfers included in the Pseudo-Ties.
Part 1.2
Each Balancing Authority and each Reserve Sharing Group will have dated
documentation that demonstrates compliance with Requirement R1, Part 1.2.
BAL-002-WECC-3
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WECC Standard BAL-002-WECC-3—Contingency Reserve
Evidence may include, but is not limited to, documentation that reserves were
comprised of the types listed in Requirement R1, Part 1.2 for purposes of meeting the
Contingency Reserve obligation of Requirement R1. Additionally, for purposes of the
last bullet of Requirement R1, Part 1.2, evidence of compliance may include, but is not
limited to, documentation that the reliability coordinator had issued an energy
emergency alert, indicating that firm Load interruption was imminent or was in
progress.
Part 1.3
Each Balancing Authority and each Reserve Sharing Group will have dated
documentation that demonstrates compliance with Requirement R1, Part 1.3.
Evidence of compliance with Requirement R1, Part 1.3 may include, but is not limited
to, documentation that Contingency Reserve amounts are based upon load and
generating data averaged over each Clock Hour and excludes Qualifying Facilities
covered in 18 C.F.R.§ 292.101, as addressed in FERC Order 464.
Part 1.4
Evidence of compliance with Requirement R1, Part 1.4 may include, but is not limited
to, documentation that the reserves maintained to comply with Requirement R1, Part
1.4 are fully deployable within ten minutes.
R2. Reserved.
M2. Reserved.
R3.
Each Sink Balancing Authority and each sink Reserve Sharing Group shall maintain an
amount of Operating Reserve, in addition to the minimum Contingency Reserve in
Requirement R1, equal to the amount of Operating Reserve–Supplemental for any
Interchange Transaction designated as part of the Source Balancing Authority’s
Operating Reserve–Supplemental or source Reserve Sharing Group’s Operating
Reserve–Supplemental, except within the first sixty minutes following an event
requiring the activation of Contingency Reserve. [Violation Risk Factor: High] [Time
Horizon: Real-time operations]
M3. Each Sink Balancing Authority and each sink Reserve Sharing Group will have dated
documentation demonstrating it maintained an amount of Operating Reserve, in
addition to the Contingency Reserve identified in Requirement R1, equal to the
amount of Operating Reserve–Supplemental for any Interchange Transaction
designated as part of the Source Balancing Authority’s Operating Reserve–
Supplemental or source Reserve Sharing Group’s Operating Reserve–Supplemental,
for the entire period of the transaction, except within the first sixty minutes following
an event requiring the activation of Contingency Reserves, in accordance with
Requirement 3.
R4.
Each Source Balancing Authority and each source Reserve Sharing Group shall
maintain an amount of Operating Reserve, in addition to the minimum Contingency
Reserve amounts identified in Requirement R1, equal to the amount and type of
BAL-002-WECC-3
Page 3 of 12
WECC Standard BAL-002-WECC-3—Contingency Reserve
Operating Reserves for any Operating Reserve transactions for which it is the Source
Balancing Authority or source Reserve Sharing Group. [Violation Risk Factor: High]
[Time Horizon: Real-time operations]
M4. Each Source Balancing Authority and each source Reserve Sharing Group will have
dated documentation that demonstrates it maintained an amount of additional
Operating Reserves identified in Requirement R1, greater than or equal to the amount
and type of that identified in Requirement 4, for the entire period of the transaction.
C. Compliance
1.
Compliance Monitoring Process
1.1. Compliance Enforcement Authority:
For entities that do not work for the Regional Entity, the Regional Entity shall
serve as the Compliance Enforcement Authority.
For Reliability Coordinators and other functional entities that work for their
Regional Entity, the ERO or a Regional Entity approved by the ERO and FERC or
other applicable governmental authorities shall serve as the Compliance
Enforcement Authority.
For responsible entities that are also Regional Entities, the ERO or a Regional
Entity approved by the ERO and FERC or other applicable governmental
authorities shall serve as the Compliance Enforcement Authority.
1.2. Compliance Monitoring and Assessment Processes:
Compliance Audit
Self-Certification
Spot-Checking
Compliance Investigation
Self-Reporting
Complaint
1.3.
Evidence Retention:
The following evidence retention periods identify the period of time an entity is
required to retain specific evidence to demonstrate compliance. For instances
where the evidence retention period specified below is shorter than the time
since the last audit, the Compliance Enforcement Authority may ask an entity to
provide other evidence to show that it was compliant for the full-time period
since the last audit.
Each Balancing Authority and each Reserve Sharing Group shall keep evidence
for Requirement R1 through R4 for three years plus calendar current.
BAL-002-WECC-3
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WECC Standard BAL-002-WECC-3—Contingency Reserve
1.4. Additional Compliance Information:
1.4.1 This Standard shall apply to each Balancing Authority and each Reserve
Sharing Group that has registered with WECC as provided in Part 1.4.2 of
Section C.
Each Balancing Authority identified in the registration with WECC as
provided in Part 1.4.2 of Section C shall be responsible for compliance with
this Standard through its participation in the Reserve Sharing Group and
not on an individual basis.
1.4.2 A Reserve Sharing Group may register as the Responsible Entity for
purposes of compliance with this Standard by providing written notice to
the WECC: 1) indicating that the Reserve Sharing Group is registering as the
Responsible Entity for purposes of compliance with this Standard, 2)
identifying each Balancing Authority that is a member of the Reserve
Sharing Group, and 3) identifying the person or organization that will serve
as agent on behalf of the Reserve Sharing Group for purposes of
communications and data submissions related to or required by this
Standard.
1.4.3 If an agent properly designated in accordance with Part 1.4.2 of Section C
identifies individual Balancing Authorities within the Reserve Sharing Group
responsible for noncompliance at the time of data submission, together
with the percentage of responsibility attributable to each identified
Balancing Authority, then, except as may otherwise be finally determined
through a duly conducted review or appeal of the initial finding of
noncompliance: 1) any penalties assessed for noncompliance by the
Reserve Sharing Group shall be allocated to the individual Balancing
Authorities identified in the applicable data submission in proportion to
their respective percentages of responsibility as specified in the data
submission, 2) each Balancing Authority shall be solely responsible for all
penalties allocated to it according to its percentage of responsibility as
provided in subsection 1) of this Part 1.4.3 of Section C, and 3) neither the
Reserve Sharing Group nor any member of the Reserve Sharing Group shall
be responsible for any portion of a penalty assessed against another
member of the Reserve Sharing Group in accordance with subsection 1) of
this Part 1.4.3 of Section C (even if the member of Reserve Sharing Group
against which the penalty is assessed is not subject to or otherwise fails to
pay its allocated share of the penalty).
1.4.4 If an agent properly designated in accordance with Part 1.4.2 of Section C
fails to identify individual Balancing Authorities within the Reserve Sharing
Group responsible for noncompliance at the time of data submission or
fails to specify percentages of responsibility attributable to each identified
Balancing Authority, any penalties for noncompliance shall be assessed
against the agent on behalf of the Reserve Sharing Group, and it shall be
BAL-002-WECC-3
Page 5 of 12
WECC Standard BAL-002-WECC-3—Contingency Reserve
the responsibility of the members of the Reserve Sharing Group to allocate
responsibility for such noncompliance.
1.4.5 Any Balancing Authority that is a member of a Reserve Sharing Group that
has failed to register as provided in Part 1.4.2 of Section C shall be subject
to this Standard on an individual basis.
BAL-002-WECC-3
Page 6 of 12
WECC Standard BAL-002-WECC-3—Contingency Reserve
Violation Severity Levels
Violation Severity Levels
R#
Lower VSL
R1.
The Balancing Authority or
the Reserve Sharing Group
that incurs one Clock Hour,
during a calendar month, in
which Contingency Reserve
is less than 100% but greater
than or equal to 90% of the
required Contingency
Reserve amount, with the
characteristics specified in
Requirement R1.
R2.
Reserved.
R3.
The Balancing Authority or
the Reserve Sharing Group
that incurs one hour, during
a calendar month, in which
Contingency Reserve is less
than 100% but greater than
or equal to 90% of the
required Operating Reserve
amount specified in
Requirement R3.
The Balancing Authority or
the Reserve Sharing Group
that incurs one hour, during
a calendar month, in which
R4.
BAL-002-WECC-3
Moderate VSL
High VSL
Severe VSL
The Balancing Authority or
the Reserve Sharing Group
that incurs one Clock Hour,
during a calendar month, in
which Contingency Reserve
is less than 90% but greater
than or equal to 80% of the
required Contingency
Reserve amount, with the
characteristics specified in
Requirement R1.
The Balancing Authority or
the Reserve Sharing Group
that incurs one Clock Hour,
during a calendar month, in
which Contingency Reserve
is less than 80% but greater
than or equal to 70% of the
required Contingency
Reserve amount, with the
characteristics specified in
Requirement R1.
The Balancing Authority or
the Reserve Sharing Group
that incurs one Clock Hour,
during a calendar month, in
which Contingency Reserve
is less than 70% of the
required Contingency
Reserve amount, with the
characteristics specified in
Requirement R1.
The Balancing Authority or
the Reserve Sharing Group
that incurs one hour, during
a calendar month, in which
Contingency Reserve is less
than 90% but greater than or
equal to 80% of the required
Operating Reserve amount
specified in Requirement R3.
The Balancing Authority or
the Reserve Sharing Group
that incurs one hour, during
a calendar month, in which
Contingency Reserve is less
than 80% but greater than
or equal to 70% of the
required Operating Reserve
amount specified in
Requirement R3.
The Balancing Authority or
the Reserve Sharing Group
that incurs one hour, during
a calendar month, in which
The Balancing Authority or
the Reserve Sharing Group
that incurs one hour, during
a calendar month, in which
Contingency Reserve is less
than 70% of the required
Operating Reserve amount
specified in Requirement R3.
The Balancing Authority or
the Reserve Sharing Group
that incurs one hour, during
a calendar month, in which
The Balancing Authority or
the Reserve Sharing Group
that incurs one hour, during
a calendar month, in which
Page 7 of 12
WECC Standard BAL-002-WECC-3—Contingency Reserve
Contingency Reserve
Operating Reserve is less
than 100% but greater than
or equal to 90% of the
required Operating Reserve
amount specified in
Requirement R4.
Contingency Reserve
Operating Reserve is less
than 90% but greater than or
equal to 80% of the required
Operating Reserve amount
specified in Requirement R4.
Contingency Reserve
Operating Reserve is less
than 80% but greater than
or equal to 70% of the
required Operating Reserve
amount specified in
Requirement R4.
Contingency Reserve
Operating Reserve is less
than 70% of the required
Operating Reserve amount
specified in Requirement R4.
D. Regional Variances
None.
E. Interpretations
None.
F. Associated Documents
None.
BAL-002-WECC-3
Page 8 of 12
WECC Standard BAL-002-WECC-3—Contingency Reserve
Version History
Version
1
1
2
Date
October 29, 2008
October 21, 2010
November 7, 2012
2
November 21, 2013
2a
Action
Adopted by NERC Board
of Trustees
Order issued remanding
BAL-002-WECC-1
Adopted by NERC Board
of Trustees
FERC Order issued
approving BAL-002WECC-2. (Order becomes
effective 1/28/14.)
December 1, 2015
Approved by WECC Board
of Directors
January 24, 2017
FERC approved
2a
3
TBD
BAL-002-WECC-3
TBD
Change Tracking
Clarified resources
available for use in
Requirement R2
The Interpretation
provides clarification
regarding the types of
resources that may be
used to satisfy
Contingency Reserve.
The Interpretation was
removed. Requirement
R2 was deleted.
Template and
formatting were
updated. Syntax and
verb tense in Guideline
section were
corrected.
Page 9 of 12
WECC Standard BAL-002-WECC-3—Contingency Reserve
Standard Attachments
Attachment A
Attachment A is illustrative only; it is not a requirement. Requirement R1 calls for an amount of
Contingency Reserve to be maintained, predicated on an amount of generation and load
required in Requirement R1, Part 1.1., specifically:
“1.1
The greater of either:
•
The amount of Contingency Reserve equal to the loss of the most severe
single contingency;
•
The amount of Contingency Reserve equal to the sum of three percent of
hourly integrated Load plus three percent of hourly integrated generation.”
Attachment A illustrates one possible way to account for and calculate the amount of
generation upon which the Contingency Reserve amount is predicated.
Below is a practical illustration showing how the generation amount may be calculated under
Requirement R1 for Balancing Authorities (BA) and Reserve Sharing Groups (RSG).
BA1 / RSG 1
Generator 1
Generator 2
Generator 3 (Pseudo-Tied out to BA2)
Generator 4 QF (has backup contract)
Generator 5 QF in EMS
Generator 6
Generation
300 MWs online
200 MWs online
100 MWs online
10 MWs online
10 MWs online
0 MWs online
Dynamic Schedule to BA2 from BA1 1
(50 MWs)
Generation
BA generation (EMS)
Generation to use Under BAL-002-WECC-1
620 MWs
510 MWs
460 MWs**
Part of Generator
Yes
Yes
No
No
Yes
Yes
(The sum of gen 1–6)
(The sum of gen 1, 2, and 5)
(The sum of gen 1, 2, and 5
minus Dynamic Schedule)
** Assumes BA1 and BA2 agree on Dynamic Schedule treatment. If no agreement, BA1 would
maintain reserves based on 510 MWs Generation.
BA2 / RSG2
Generator 11
Generator 12
Generator 3 (Pseudo-Tied in from BA1)
Dynamic Schedule from BA1 to BA2
Generation
BA generation (EMS)
1
Generation
Part of Generator
100 MWs
100 MWs
100 MWs
Yes
Yes
Yes
50 MWs
Yes
300 MWs
300 MWs
(The sum of gen 11, 12 and 3.)
(The sum of gen 11, 12 and 3)
Note: This Dynamic Schedule is not the same as the Generator 3 Pseudo-Tie.
BAL-002-WECC-3
Page 10 of 12
WECC Standard BAL-002-WECC-3—Contingency Reserve
Generation to use Under BAL-002-WECC-1
350 MWs**
(The sum of gen 11, 12 and 3
plus Dynamic Schedule)
** Assumes BA1 and BA2 agree on Dynamic Schedule treatment. If no agreement, BA1 would
have to maintain reserves based on 510MWs Generation and BA2 would determine its
generation to be 300 MWs.
BAL-002-WECC-3
Page 11 of 12
WECC Standard BAL-002-WECC-3—Contingency Reserve (Attachment C)—Supplemental Material
Guideline and Technical Basis
A Guidance Document addressing implementation of this standard was filed with Version 2.
BAL-002-WECC-3
Page 12 of 12
WECC Standard BAL-002-WECC-2a — 3—Contingency Reserve
A. Introduction
1.
Title:
Contingency Reserve
2.
Number:
BAL-002-WECC-2a3
3.
Purpose:
To specify the quantity and types of Contingency Reserve required to
ensure reliability under normal and abnormal conditions.
4.
Applicability:
4.1. Functional Entities:
4.1.1 Balancing Authority
4.1.1.24.1.1.1
4.1.1. The Balancing Authority is the responsible entity
unless the Balancing Authority is a member of a Reserve Sharing
Group, in which case, the Reserve Sharing Group becomes the
responsible entity.
4.1.2 Reserve Sharing Group
4.1.2.24.1.2.1
4.2.1. The Reserve Sharing Group when comprised of a
Source Balancing Authority becomes the source Reserve Sharing
Group.
4.1.2.44.1.2.2
4.2.2. The Reserve Sharing Group when comprised of a
Sink Balancing Authority becomes the sink Reserve Sharing Group.
6.5. 5.
Effective Date: On the first day
Immediately upon
receipt of the third quarter following applicable regulatory approval.
B. Requirements and Measures
R2.R1.
R1.
Each Balancing Authority and each Reserve Sharing Group shall maintain
a minimum amount of Contingency Reserve, except within the first sixty minutes
BAL-002-WECC-3
Page 1 of 18
WECC Standard BAL-002-WECC-2a — 3—Contingency Reserve
following an event requiring the activation of Contingency Reserve, that is: [Violation
Risk Factor: High] [Time Horizon: Real-time operations]
2.2.1.1.
1.1
The greater of either:
•
The amount of Contingency Reserve equal to the loss of the most severe
single contingency;
•
The amount of Contingency Reserve equal to the sum of three percent of
hourly integrated Load plus three percent of hourly integrated generation.
2.4.1.2.
1.2
ComprisedComposed of any combination of the reserve types
specified below:
•
Operating Reserve – —Spinning
•
Operating Reserve - —Supplemental
•
Interchange Transactions designated by the Source Balancing Authority as
Operating Reserve – —Supplemental
•
Reserve held by other entities by agreement that is deliverable on Firm
Transmission Service
•
A resource, other than generation or load, that can provide energy or reduce
energy consumption
•
Load, including demand response resources, Demand-Side Management
resources, Direct Control Load Management, Interruptible Load or
Interruptible Demand, or any other Load made available for curtailment by
the Balancing Authority or the Reserve Sharing Group via contract or
agreement.
•
All other load, not identified above, once the Reliability Coordinator has
declared an energy emergency alert signifying that firm load interruption is
imminent or in progress.
2.6.1.3.
1.3
Based on real-time hourly load and generating energy values
averaged over each Clock Hour (excluding Qualifying Facilities covered in 18
C.F.R.§ 292.101, as addressed in FERC Order 464).
BAL-002-WECC-3
Page 2 of 18
WECC Standard BAL-002-WECC-2a — 3—Contingency Reserve
2.8.1.4.
1.4
An amount of capacity from a resource that is deployable within
ten minutes.
M2.M1. M1. Each Balancing Authority and each Reserve Sharing Group will have
documentation demonstrating its Contingency Reserve was maintained, except within
the first sixty minutes following an event requiring the activation of Contingency
Reserve.
Part 1.1
Each Balancing Authority and each Reserve Sharing Group will have dated
documentation that demonstrates its Contingency Reserve was maintained in
accordance with the amounts identified in Requirement R1, Part 1.1, except within the
first sixty minutes following an event requiring the activation of Contingency Reserve.
Attachment A is a practical illustration showing how the generation amount may be
calculated under Requirement R1.
•
•
Where Dynamic Schedules are used as part of the generation amount upon
which Contingency Reserve is predicated, additional evidence of compliance
with Requirement R1, Part 1.1 may include, but is not limited to,
documentation showing a reciprocal acknowledgement as to which entity is
carrying the reserves. This transfer may be all or some portion of the physical
generator and is not limited to the entire physical capability of the generator.
Where Pseudo-Ties are used as part of the generation amount upon which
Contingency Reserve is predicated, additional evidence of compliance with
Requirement R1, Part 1.1, may include, but is not limited to, documentation
accounting for the transfers included in the Pseudo-Ties.
Part 1.2
Each Balancing Authority and each Reserve Sharing Group will have dated
documentation that demonstrates compliance with Requirement R1, Part 1.2.
Evidence may include, but is not limited to, documentation that reserves were
comprised of the types listed in Requirement R1, Part 1.2 for purposes of meeting the
Contingency Reserve obligation of Requirement R1. Additionally, for purposes of the
last bullet of Requirement R1, Part 1.2, evidence of compliance may include, but is not
limited to, documentation that the reliability coordinator had issued an energy
emergency alert, indicating that firm Load interruption was imminent or was in
progress.
Part 1.3
Each Balancing Authority and each Reserve Sharing Group will have dated
documentation that demonstrates compliance with Requirement R1, Part 1.3.
Evidence of compliance with Requirement R1, Part 1.3 may include, but is not limited
BAL-002-WECC-3
Page 3 of 18
WECC Standard BAL-002-WECC-2a — 3—Contingency Reserve
to, documentation that Contingency Reserve amounts are based upon load and
generating data averaged over each Clock Hour and excludes Qualifying Facilities
covered in 18 C.F.R.§ 292.101, as addressed in FERC Order 464.
Part 1.4
Evidence of compliance with Requirement R1, Part 1.4 may include, but is not limited
to, documentation that the reserves maintained to comply with Requirement R1, Part
1.4 are fully deployable within ten minutes.
R2.
M2.
Each Balancing Authority and each Reserve Sharing Group shall maintain at least half
of its minimum amount of Contingency Reserve identified in Requirement R1, as
Operating Reserve – Spinning that meets both of the following reserve characteristics.
[Violation Risk Factor: High] [Time Horizon: Real-time operations]
2.1
Reserve that is immediately and automatically responsive to frequency
deviations through the action of a governor or other control system;
2.2
Reserve that is capable of fully responding within ten minutes.
Each Balancing Authority and each Reserve Sharing Group will have dated
documentation that demonstrates it maintained at least half of the Contingency
Reserve identified in Requirement R1 as Operating Reserve – Spinning, averaged over
each Clock Hour, that met both of the reserve characteristics identified in
Requirement R2, Part 2.1 and Requirement R2, Part 2.2.
R2. R3. Reserved.
M2. Reserved.
R3.
Each Sink Balancing Authority and each sink Reserve Sharing Group shall maintain an
amount of Operating Reserve, in addition to the minimum Contingency Reserve in
Requirement R1, equal to the amount of Operating Reserve–Supplemental for any
Interchange Transaction designated as part of the Source Balancing Authority’s
Operating Reserve–Supplemental or source Reserve Sharing Group’s Operating
Reserve–Supplemental, except within the first sixty minutes following an event
requiring the activation of Contingency Reserve. [Violation Risk Factor: High] [Time
Horizon: Real-time operations]
M3. M3. Each Sink Balancing Authority and each sink Reserve Sharing Group will have
dated documentation demonstrating it maintained an amount of Operating Reserve,
in addition to the Contingency Reserve identified in Requirement R1, equal to the
amount of Operating Reserve–Supplemental for any Interchange Transaction
BAL-002-WECC-3
Page 4 of 18
WECC Standard BAL-002-WECC-2a — 3—Contingency Reserve
designated as part of the Source Balancing Authority’s Operating Reserve–
Supplemental or source Reserve Sharing Group’s Operating Reserve–Supplemental,
for the entire period of the transaction, except within the first sixty minutes following
an event requiring the activation of Contingency Reserves, in accordance with
Requirement 3.
R4.
R4. Each Source Balancing Authority and each source Reserve Sharing Group shall
maintain an amount of Operating Reserve, in addition to the minimum Contingency
Reserve amounts identified in Requirement R1, equal to the amount and type of
Operating Reserves for any Operating Reserve transactions for which it is the Source
Balancing Authority or source Reserve Sharing Group. [Violation Risk Factor: High]
[Time Horizon: Real-time operations]
M4. M4. Each Source Balancing Authority and each source Reserve Sharing Group will
have dated documentation that demonstrates it maintained an amount of additional
Operating Reserves identified in Requirement R1, greater than or equal to the amount
and type of that identified in Requirement 4, for the entire period of the transaction.
C. Compliance
1.
1. Compliance Monitoring Process
1.1. Compliance Enforcement Authority:
For entities that do not work for the Regional Entity, the Regional Entity shall
serve as the Compliance Enforcement Authority.
For Reliability Coordinators and other functional entities that work for their
Regional Entity, the ERO or a Regional Entity approved by the ERO and FERC or
other applicable governmental authorities shall serve as the Compliance
Enforcement Authority.
For responsible entities that are also Regional Entities, the ERO or a Regional
Entity approved by the ERO and FERC or other applicable governmental
authorities shall serve as the Compliance Enforcement Authority.
1.2. 1.2
Compliance Monitoring and Assessment Processes:
Compliance Audit
BAL-002-WECC-3
Page 5 of 18
WECC Standard BAL-002-WECC-2a — 3—Contingency Reserve
Self-Certification
Spot-Checking
Compliance Investigation
Self-Reporting
Complaint
1.3.
1.3
Evidence Retention:
The following evidence retention periods identify the period of time an entity is
required to retain specific evidence to demonstrate compliance. For instances
where the evidence retention period specified below is shorter than the time
since the last audit, the Compliance Enforcement Authority may ask an entity to
provide other evidence to show that it was compliant for the full-time period
since the last audit.
Each Balancing Authority and each Reserve Sharing Group shall keep evidence
for Requirement R1 through R4 for three years plus calendar current.
1.4. 1.4.
Additional Compliance Information:
1.4.1 1.4.1. This Standard shall apply to each Balancing Authority and each
Reserve Sharing Group that has registered with WECC as provided in Part
1.4.2 of Section C.
Each Balancing Authority identified in the registration with WECC as
provided in Part 1.4.2 of Section C shall be responsible for compliance with
this Standard through its participation in the Reserve Sharing Group and
not on an individual basis.
1.4.2 1.4.2. A Reserve Sharing Group may register as the Responsible Entity
for purposes of compliance with this Standard by providing written notice
to the WECC: 1) indicating that the Reserve Sharing Group is registering as
the Responsible Entity for purposes of compliance with this Standard, 2)
identifying each Balancing Authority that is a member of the Reserve
Sharing Group, and 3) identifying the person or organization that will serve
as agent on behalf of the Reserve Sharing Group for purposes of
communications and data submissions related to or required by this
Standard.
BAL-002-WECC-3
Page 6 of 18
WECC Standard BAL-002-WECC-2a — 3—Contingency Reserve
1.4.3 1.4.3. If an agent properly designated in accordance with Part 1.4.2 of
Section C identifies individual Balancing Authorities within the Reserve
Sharing Group responsible for noncompliance at the time of data
submission, together with the percentage of responsibility attributable to
each identified Balancing Authority, then, except as may otherwise be
finally determined through a duly conducted review or appeal of the initial
finding of noncompliance: 1) any penalties assessed for noncompliance by
the Reserve Sharing Group shall be allocated to the individual Balancing
Authorities identified in the applicable data submission in proportion to
their respective percentages of responsibility as specified in the data
submission, 2) each Balancing Authority shall be solely responsible for all
penalties allocated to it according to its percentage of responsibility as
provided in subsection 1) of this Part 1.4.3 of Section C, and 3) neither the
Reserve Sharing Group nor any member of the Reserve Sharing Group shall
be responsible for any portion of a penalty assessed against another
member of the Reserve Sharing Group in accordance with subsection 1) of
this Part 1.4.3 of Section C (even if the member of Reserve Sharing Group
against which the penalty is assessed is not subject to or otherwise fails to
pay its allocated share of the penalty).
1.4.4 1.4.4. If an agent properly designated in accordance with Part 1.4.2 of
Section C fails to identify individual Balancing Authorities within the
Reserve Sharing Group responsible for noncompliance at the time of data
submission or fails to specify percentages of responsibility attributable to
each identified Balancing Authority, any penalties for noncompliance shall
be assessed against the agent on behalf of the Reserve Sharing Group, and
it shall be the responsibility of the members of the Reserve Sharing Group
to allocate responsibility for such noncompliance.
1.4.5 1.4.5. Any Balancing Authority that is a member of a Reserve Sharing
Group that has failed to register as provided in Part 1.4.2 of Section C shall
be subject to this Standard on an individual basis.
Table of Compliance Elements
BAL-002-WECC-3
Page 7 of 18
WECC Standard BAL-002-WECC-2a — 3—Contingency Reserve
Violation Severity Levels
2.
R#
R1. 4.
Time
Horizon
3.
VRF
Violation Severity Levels
Lower VSL
Real-time
5.
Operations
High The Balancing
Authority or
the Reserve
Sharing Group
that incurs
one Clock
Hour, during a
calendar
month, in
which
Contingency
Reserve is less
than 100%
but greater
than or equal
to 90% of the
required
Contingency
Reserve
amount, with
the
characteristics
specified in
Moderate
VSL
High VSL
Severe VSL
The Balancing
Authority or
the Reserve
Sharing Group
that incurs
one Clock
Hour, during a
calendar
month, in
which
Contingency
Reserve is less
than 90% but
greater than
or equal to
80% of the
required
Contingency
Reserve
amount, with
the
characteristics
specified in
The Balancing
Authority or
the Reserve
Sharing Group
that incurs
one Clock
Hour, during a
calendar
month, in
which
Contingency
Reserve is less
than 80% but
greater than
or equal to
70% of the
required
Contingency
Reserve
amount, with
the
characteristics
specified in
The Balancing Authority or the Reserve Sharing Group
that incurs one Clock Hour, during a calendar month,
in which Contingency Reserve is less than 70% of the
required Contingency Reserve amount, with the
characteristics specified in Requirement R1.
1
BAL-002-WECC-3
Page 8 of 18
WECC Standard BAL-002-WECC-2a — 3—Contingency Reserve
R2.
Requirement
R1.
Requirement
R1.
Requirement
R1.
Real-time
Operations
Reserved.
High
The Balancing
Authority or
the Reserve
Sharing Group
that incurs
one Clock
Hour, during a
calendar
month, in
which
Contingency
Reserve
Operating
Reserve Spinning is
less than
100% but
greater than
or equal to
90% of the
required
Operating
Reserve–
Spinning
amount
specified in
Requirement
R2, and both
The Balancing
Authority or
the Reserve
Sharing Group
that incurs
one Clock
Hour, during a
calendar
month, in
which
Contingency
Reserve
Operating
Reserve Spinning is
less than 90%
but greater
than or equal
to 80% of the
required
Operating
Reserve–
Spinning
amount
specified in
Requirement
R2, and both
The Balancing 6.
Authority or
the Reserve
Sharing Group
that incurs
one Clock
Hour, during a
calendar
month, in
which
Contingency
Reserve
Operating
Reserve Spinning is
less than 80%
but greater
than or equal
to 70% of the
required
Operating
Reserve–
Spinning
amount
specified in
Requirement
R2, and both
characteristics
The Balancing
Authority or
the Reserve
Sharing Group
that incurs
one Clock
Hour, during a
calendar
month, in
which
Contingency
Reserve
Operating
Reserve Spinning is
less than 70%
of the
required
Operating
Reserve–
Spinning
amount
specified in
Requirement
R2, and both
characteristics
were met.
1
BAL-002-WECC-3
Page 9 of 18
WECC Standard BAL-002-WECC-2a — 3—Contingency Reserve
characteristics characteristics
were met.
were met.
R3.
Real-time
Operations
7.
R4.
Real-time
Operations
8.
High The Balancing The Balancing
Authority or
Authority or
the Reserve
the Reserve
Sharing
Sharing
Group that
Group that
incurs one
incurs one
hour, during a hour, during a
calendar
calendar
month, in
month, in
which
which
Contingency
Contingency
Reserve is
Reserve is less
less than
than 90% but
100% but
greater than
greater than
or equal to
or equal to
80% of the
90% of the
required
required
Operating
Operating
Reserve
Reserve
amount
amount
specified in
specified in
Requirement
Requirement R3.
R3.
High The Balancing The Balancing
Authority or
Authority or
the Reserve
the Reserve
Sharing
Sharing
The Balancing
Authority or
the Reserve
Sharing
Group that
incurs one
hour, during
a calendar
month, in
which
Contingency
Reserve is
less than
80% but
greater than
or equal to
70% of the
required
Operating
Reserve
amount
specified in
Requirement
R3.
The Balancing
Authority or
the Reserve
Sharing
were met.
The Balancing Authority or the Reserve Sharing Group
that incurs one hour, during a calendar month, in
which Contingency Reserve is less than 70% of the
required Operating Reserve amount specified in
Requirement R3.
The Balancing Authority or the Reserve Sharing Group
that incurs one hour, during a calendar month, in
which Contingency Reserve Operating Reserve is less
1
BAL-002-WECC-3
Page 10 of 18
WECC Standard BAL-002-WECC-2a — 3—Contingency Reserve
Group that
incurs one
hour, during a
calendar
month, in
which
Contingency
Reserve
Operating
Reserve is
less than
100% but
greater than
or equal to
90% of the
required
Operating
Reserve
amount
specified in
Requirement
R4.
Group that
incurs one
hour, during a
calendar
month, in
which
Contingency
Reserve
Operating
Reserve is less
than 90% but
greater than
or equal to
80% of the
required
Operating
Reserve
amount
specified in
Requirement
R4.
Group that
incurs one
hour, during
a calendar
month, in
which
Contingency
Reserve
Operating
Reserve is
less than
80% but
greater than
or equal to
70% of the
required
Operating
Reserve
amount
specified in
Requirement
R4.
than 70% of the required Operating Reserve amount
specified in Requirement R4.
D. D. Regional Variances
None.
1
BAL-002-WECC-3
Page 11 of 18
WECC Standard BAL-002-WECC-2a — 3—Contingency Reserve
E. E. Interpretations
Interpretation Requested
Arizona Public Service (APS) sought clarification that for purposes of BAL-002-WECC-2, Requirement R2, APS and other Balancing
Authorities and/or Reserve Sharing Groups can include “technologies, such as batteries, both contemplated and not yet
contemplated…as potential resources [to meet the Operating Reserve – Spinning requirement of BAL-002-WECC-2, Requirement R2]
– so long as the…resource can meet the response characteristics described in the standard.”
A standards interpretation team comprised of members of the original BAL drafting team concluded that APS’ understanding was
correct.
“[N]on-traditional resources, including electric storage facilities, may qualify as “Operating Reserve – Spinning” so long as they meet
the technical and performance requirements in Requirement R2 (i.e., that the resources must be immediately and automatically
responsive to frequency deviations through the action of a control system and capable of fully responding within ten minutes). 1
In Order 789, Paragraph 48, the Federal Energy Regulatory Commission (Commission) responded to the California Independent
System Operator that:
Commission Determination
1
FERC Order 789, P47. July 18, 2013.
See also FERC Order 740, Section E, Demand-Side Management as a Resource, at P 50:
“The Commission clarified that the purpose of this directive was to ensure comparable treatment of demand-side management with conventional generation
or any other technology and to allow demand-side management to be considered as a resource for contingency reserves on this basis without requiring the
use of any particular contingency reserve option.”
1
BAL-002-WECC-3
Page 12 of 18
WECC Standard BAL-002-WECC-2a — 3—Contingency Reserve
48. The Commission determines that non-traditional resources, including electric storage facilities, may qualify as “Operating
Reserve – Spinning” provided those resources satisfy the technical and performance requirements in Requirement R2. Our
determination is supported by the standard drafting team’s response to a comment during the standard drafting process
where the standard drafting team stated that “technologies, such as batteries, both contemplated and not yet contemplated
are included in the standard as potential resources – so long as the undefined resource can meet the response characteristics
described in the standard …The language does not preclude any specific technology; rather, the language delineates how
that technology must [] respond.” 2 We also note that non-traditional resources could contribute to contingency reserve
under the regional Reliability Standard if they are resources, “other than generation or load, that can provide energy or
reduce energy consumption.”
2
“Fn 44 Petition, Exhibit C at 20.”
1
BAL-002-WECC-3
Page 13 of 18
WECC Standard BAL-002-WECC-2a — 3—Contingency Reserve
F. None.
F. Associated Documents
None.
1
BAL-002-WECC-3
Page 14 of 18
WECC Standard BAL-002-WECC-2a — 3—Contingency Reserve
Version History
Version
1
1
2
Date
October 29, 2008
October 21, 2010
November 7, 2012
2
November 21, 2013
2a
Action
Adopted by NERC Board
of Trustees
Order issued remanding
BAL-002-WECC-1
Adopted by NERC Board
of Trustees
FERC Order issued
approving BAL-002WECC-2. (Order becomes
effective 1/28/14.)
December 1, 2015
Approved by WECC Board
of Directors
January 24, 2017
FERC approved
2a
3
TBD
TBD
Change Tracking
Clarified resources
available for use in
Requirement R2
The Interpretation
provides clarification
regarding the types of
resources that may be
used to satisfy
Contingency Reserve.
The Interpretation was
removed. Requirement
R2 was deleted.
Template and
formatting were
updated. Syntax and
verb tense in Guideline
section were
corrected.
1
BAL-002-WECC-3
Page 15 of 18
WECC Standard BAL-002-WECC-2a — 3—Contingency Reserve
Standard Attachments
Attachment A
Attachment A is illustrative only; it is not a requirement. Requirement R1 calls for an amount of
Contingency Reserve to be maintained, predicated on an amount of generation and load
required in Requirement R1, Part 1.1., specifically:
“1.1
The greater of either:
•
The amount of Contingency Reserve equal to the loss of the most severe
single contingency;
•
The amount of Contingency Reserve equal to the sum of three percent of
hourly integrated Load plus three percent of hourly integrated generation.”
Attachment A illustrates one possible way to account for and calculate the amount of
generation upon which the Contingency Reserve amount is predicated.
Below is a practical illustration showing how the generation amount may be calculated under
Requirement R1 for Balancing Authorities (BA) and Reserve Sharing Groups (RSG).
BA1 / RSG 1
Generator 1
Generator 2
Generator 3 (Pseudo-Tied out to BA2)
Generator 4 QF (has backup contract)
Generator 5 QF in EMS
Generator 6
Generation
300 MWs online
200 MWs online
100 MWs online
10 MWs online
10 MWs online
0 MWs online
Dynamic Schedule to BA2 from BA1 3
(50 MWs)
Generation
BA generation (EMS)
Generation to use Under BAL-002-WECC-1
620 MWs
510 MWs
460 MWs**
Part of Generator
Yes
Yes
No
No
Yes
Yes
(The sum of gen 1-–6)
(The sum of gen 1, 2, and 5)
(The sum of gen 1, 2, and 5
minus Dynamic Schedule)
** Assumes BA1 and BA2 agree on Dynamic Schedule treatment. If no agreement, BA1 would
maintain reserves based on 510 MWs Generation.
BA2 / RSG2
Generator 11
Generator 12
Generator 3 (Pseudo-Tied in from BA1)
Dynamic Schedule from BA1 to BA2
Generation
3
Generation
Part of Generator
100 MWs
100 MWs
100 MWs
Yes
Yes
Yes
50 MWs
Yes
300 MWs
(The sum of gen 11, 12 and 3.)
Note: This Dynamic Schedule is not the same as the Generator 3 Pseudo-Tie.
1
BAL-002-WECC-3
Page 16 of 18
WECC Standard BAL-002-WECC-2a — 3—Contingency Reserve
BA generation (EMS)
Generation to use Under BAL-002-WECC-1
300 MWs
350 MWs**
(The sum of gen 11, 12 and 3)
(The sum of gen 11, 12 and 3
plus Dynamic Schedule)
** Assumes BA1 and BA2 agree on Dynamic Schedule treatment. If no agreement, BA1 would
have to maintain reserves based on 510MWs Generation and BA2 would determine its
generation to be 300 MWs.
1
BAL-002-WECC-3
Page 17 of 18
WECC Standard BAL-002-WECC-3—Contingency Reserve (Attachment C)—Supplemental Material
Guideline and Technical Basis
A Guidance Document addressing implementation of this standard has beenwas filed with this
standard. Version 2.
Version History
Version
1
1
Date
October 29, 2008
October 21, 2010
2
November 7, 2012
2
November 21, 2013
2a
2a
BAL-002-WECC-3
December 1, 2015
January 24, 2017
Action
Change Tracking
Adopted by NERC Board
of Trustees
Order issued remanding
002-WECC-1
Adopted by NERC Board
of Trustees
FERC Order issued
approving BAL-002WECC-2. (Order becomes
effective 1/28/14.)
Approved by WECC Board
of Directors
FERC approved
BAL-
Clarified resources
available for use in
Requirement R2
The interpretation
provides
clarification
regarding the types
of resources that
may be used to
satisfy Contingency
Reserve.
Page 18 of 18
Exhibit B
Implementation Plan
Exhibit B
Implementation Plan
WECC-0115 BAL-002-WECC-3
Contingency Reserve
Request to Retire R2
Implementation Plan
Standards Authorization Request
The original Standards Authorization Request (SAR) is located here. 1 Documentation templates have
been updated for final filing.
Approvals Required
•
WECC Board of Directors .................. June 19, 2019
•
NERC Board of Trustees..................... August 15, 2019
•
FERC ...................................................... Pending
Effective Date
The WECC-0115 project asserts that BAL-002-WECC-2a, 2 Contingency Reserve, Requirement R2
became redundant to BAL-003-1.1, Frequency Response and Frequency Bias Setting, Requirement R1
effective April 1, 2016. Because that date has passed, retirement of BAL-002-WECC-2a, Contingency
Reserve, Requirement R2 can be effective immediately on receipt of regulatory approval.
Justification of Effective Date
The reliability-related substance of WECC-0115 BAL-002-WECC-2a Contingency Reserve, Requirement
R2 is contained in BAL-003-1.1 Frequency Response and Frequency Bias, Requirement R1. (See
Technical Justification, Exhibit C and Response to Comments for Posting 2, Attachment E9.)
Because BAL-003-1.1 Requirement R1 addresses the reliability task, BAL-002-WECC-2a Requirement
R2 is redundant and can be retired.
Attachment E1 of this filing reflects the SAR in an updated template. The original is located at
https://www.wecc.org/Reliability/WECC-0115%20BAL-002-WECC2%20Contingency%20Reserve%20SAR%20to%20Retire%20Requirement%20R2.pdf
2 The naming nomenclature changed during development from BAL-002-WECC-2, BAL-002-WECC-2a, and will
change to BAL-002-WECC-3 if approved.
1
155 Nort h 400 West | Suit e 200 | Salt Lake Cit y, Ut ah 84103
www. we cc.org
Exhibit B
Impact on Other Standards
As to other existing and proposed standards, the drafting team (DT) notes that some confusion may
arise as to how the retirement of WECC-0115 BAL-002-WECC-2a, Requirement R2 may interplay with
the existing BAL-002-1, Disturbance Control Performance standard. BAL-002-1, Requirement R2.3
requires the applicable entity (the Regional Reliability Organization or the Reserve Sharing Group) to
“specify its Contingency Reserve policies, including … (R2.3) … the permissible mix of Operating
Reserve—Spinning and Operating Reserve—Supplemental that may be included in Contingency
Reserve.” Arguably, BAL-002-WECC-2a Requirement R2 meets this requirement.
The DT disagrees that retention of BAL-002-WECC-2a Requirement R2 is the only way to comply with
BAL-002-1. At a high level, since BAL-002-1 has no Measure for the associated Requirement R2, it is
unclear how compliance might be met. Further, since the only Measure provided requires that the
Balancing Authority or the Reserve Sharing Group “shall calculate and report compliance with the
Disturbance Control Standard,” there is a disconnect between the required performance (have a policy)
and the required Measure (perform a calculation).
Consideration of Early Compliance
The DT sees no concerns with early compliance.
Action Plan
On June 19, 2019, the WECC Board of Directors approved the project for further regulatory disposition.
The full project is available for review on the WECC website at the WECC-0115 homepage. 3
3
https://www.wecc.org/Standards/Pages/WECC-0115.aspx
2
Exhibit C
Field Test Results, WECC-0115 BAL-002-WECC-2a
Request to Retire Requirement R2
Field Test Results
WECC-0115 BAL-002-WECC-2a
Request to Retire Requirement R2
Standard Drafting Team
March 5, 2019
Exhibit C
Executive Summary
After doing a field test from May 1, 2017, through April 30, 2018, the WECC-0115 BAL-002-WECC-2a,
Contingency Reserve, Request to Retire Requirement R2 Drafting Team (DT) concluded that if
Requirement R2 is retired, it is unlikely to adversely affect reliability.
On May 6, 2015, WECC received Standard Authorization Request (SAR) WECC-0115 BAL-002-WECC2a Contingency Reserve, Request to Retire Requirement R2 (R2), requesting retirement of R2 and its
compliance elements. The SAR stated that on April 1, 2016, BAL-003-1.1 Frequency Response and
Frequency Bias Settings, Requirement R1 would make R2 redundant.
From May 1, 2017, through April 30, 2018, WECC conducted a NERC-approved field test to find out the
effect on reliability if R2 was retired. 1 A compliance waiver for R2 was granted beginning on May 1,
2017 and ending on May 1, 2019.
WECC required U.S. entities to provide data on the quantity of reserve carried during the field test
period. This was done to enable WECC to see the effects of the field test, as a condition to take part in
the field test, and to meet conditions from NERC in approving WECC’s request for a field test. The data
showed no adverse effect to reliability if R2 is retired.
Project WECC-0115 will not be balloted until this report is presented for review to the WECC Ballot
Pool and NERC meets the requirements of the NERC Rules of Procedure, 6.3 Communication and
Coordination for All Types of Field Tests and Data Analyses.
NERC approved the field test in late March 2017 and WECC conducted it per NERC Standards Processes Manual,
Section 6.2, Field Tests and Data Analysis for Validation of Requirement.
1
2
Exhibit C
Table of Contents
Introduction .............................................................................................................................................................4
Field Test Description ...........................................................................................................................................4
Data Source and Description .............................................................................................................................4
Field Test Analysis and Results...........................................................................................................................5
Data Description ..................................................................................................................................................6
DCS Event Field Test Data ........................................................................ Error! Bookmark not defined.
Figures
Table 1—DCS Event Field Test Data .................................................................................................................... 6
Figure 1—Table 2.1 from NERC 2018 State of Reliability Report, June 2018 ................................................ 10
Figure 2—A to B IFRM.......................................................................................................................................... 11
Figure 3—A to C IFRM ......................................................................................................................................... 12
Figure 4—Cn to C Ratio ........................................................................................................................................ 13
Figure 5—Table 2.2 from NERC 2018 Frequency Response Annual Analysis, November 2018 ............... 14
Figure 6—Cn to UFLS margin ............................................................................................................................. 14
3
Exhibit C
Introduction
On May 6, 2015, WECC received SAR WECC-0115 BAL-002-WECC-2a, Contingency Reserve
requesting retirement of Requirement R2. The SAR was deemed complete the same day. The SAR
asserted that on April 1, 2016, BAL-003-1.1, Frequency Response and Frequency Bias Setting,
Requirement R1 would make R2 redundant.
On June 23, 2015, the WECC Standards Committee (WSC) approved the SAR after vetting by the
WECC Operating Committee Steering Committee (OC; June 9, 2015) and the Joint Guidance Committee
(JGC; May 27, 2015).
From October 22 through December 8, 2015, the project was posted once for comment, during which
stakeholders were asked a question:
Do you agree that WECC Regional Standard BAL-002-WECC-2, 2 Contingency Reserve,
Requirement R2 should be retired as of the effective date of NERC Standard BAL-003-1 3 (BAL003), Frequency Response and Frequency Bias Setting, Requirement R1?
Three entities responded to the posting and were in favor of retirement. 4 After discussion, the DT and
WECC staff 5 agreed that a field test should be done to gauge the effect of retiring R2.
A NERC-approved field test was done from May 1, 2017, through April 30, 2018. The field test data is
the foundation of this paper and was posted for comment as Posting 2 of this project. Posting 2
received three comments, one for retirement and two suggesting caution.
Field Test Description
Data Source and Description
The field test data was requested from each Balancing Authority (BA) and each Reserve Sharing Group
(RSG) subject to R2. WECC received data through an online WECC portal.
The data request included the following information:
During this project, the BAL-002-WECC-2 designation changed to BAL-002-WECC-2a on January 24, 2017, in FERC
Docket No. RD17-3-000. The BAL-003-1 designation changed to BAL-003-1.1 on November 13, 2015, in FERC Docket
RD15-6-000.
2
BAL-003-1, Frequency Response and Frequency Bias Setting was approved by FERC on March 24, 2014, and has an
enforcement date of April 1, 2016.
3
4
Xcel Energy, Bonneville Power Administration, and WECC.
Steven Rueckert, WECC Director of Standards, and Phil O’Donnell, WECC Manager, Operations and Planning Audits
and Investigations.
5
4
Exhibit C
1. For any reportable Disturbance Control Standard (DCS) event, the date and time of the event,
the required amount of Contingency Reserves at the time of the event, the actual amount of
Operating Reserves-Spinning at the time of the event, and the actual DCS performance. 6
2. For all instances of a loss of resources 700 MW or greater, whether it is a reportable DCS event
or not, the date and time of the event, the name of the resource(s), and the total MW loss.
Objective
The field test was designed to determine whether retirement of R2 would have any adverse effect on
grid reliability. The test examined the effect on Disturbance Control Standard (DCS 7) performance and
frequency response in the Western Interconnection.
Overview
The first metric, DCS performance, monitored the performance of each RSG, and each BA that was not
a member of an RSG, for every reportable DCS event, to see whether any were unable to meet the DCS
recovery period for a DCS event. WECC asked for more information from the participants to calculate
the ratio for required contingency reserve to Operating Reserve-Spinning for each qualified event.
The second metric watched system performance for any loss of resources greater than 700 MW and for
any adverse effects on frequency response. 8 Data for this metric was collected using the same method
NERC uses to collect information to analyze interconnection frequency response for its State of
Reliability and Frequency Response Annual Analysis reports.
Field Test Analysis and Results
R2 was intended to do two things: 1) to aid in frequency recovery (through governor action) for large
generation loss events across the Western Interconnection, and 2) to provide a part of the Contingency
Reserves (on-line generation minus 10-minute response) for generation trip events within the BA or
RSG if the party is an RSG member. With new standards being applied and generation resources
changing in the Western Interconnection, the SAR was based on the presumptions that R2 became
During the field test, only the DCS responsible entity was asked to provide data during DCS events. Entities that did
not have a reportable DCS event were not requested to provide data.
6
“The reliability standard that sets the time limit following a Disturbance within which a BA must return its Area
Control Error to within a specified range.” NERC Glossary of Terms Used in Reliability Standards (Glossary).
7
The DT noted that the WECC Interconnection Frequency Response Obligation (IFRO) is roughly -840 MW per 0.1 HZ.
The 700-MW loss was chosen as a more conservative number than the IFRO and represents a value large enough to
cause a significant frequency excursion. For an example, see Frequency Response Analysis Tool, Dmitry Kosterev,
Bonneville Power Administration, 2014. https://www.wecc.org/Reliability/Frequency%20Response%20Analysis%20%20Dmitry%20Kosterev.pdf
8
5
Exhibit C
redundant on April 1, 2016—the effective date of BAL-003-1.1—and that, with R2’s retirement, neither
metrics for the interconnection’s frequency performance nor DCS performance would degrade.
With BAL-003-01.1 in effect, frequency response became measurable, and the field test gave entities a
compliance waiver for R2, thus splitting DCS and frequency response. Entities were responsible for
ensuring both reliability performance metrics were met. On that basis, WECC used the data captured
from the field test with interconnection frequency response performance data to assess any effect to
individual DCS performance, as well as the overall frequency performance of the interconnection.
Data Description
Data from the field test covered 66 DCS events. During each of those events, entities provided data to
help assess DCS performance. This data included Contingency Reserve Obligation, Required Spin
(assuming no compliance waiver), Actual Spin, and whether Area Control Error (ACE) recovery was
met to successfully pass the DCS event. See Table 1 for the data set collected.
Table 1—DCS Event Field Test Data
Entity #
Reported
MW Loss
DCS
Event
Contingency (Cont)
Reserve Obligation
Required
Spin
Actual
Spin
Pass(x)
Cont/Spin (PreContingency Value)
Entity 3
Entity 3
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 2
Entity 5
Entity 5
Entity 2
Entity 5
Entity 5
Entity 5
Entity 5
Entity 2
530
480
341
309
310
294
480
375
393
587
628
388
838
353
655
356
619
430
513
519
748
630
442
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
585
585
2624
2528
2830
2992
2349
3068
3106
2373
3124
3211
2988
3234
656
3646
3732
468
3514
2823
3688
3024
538
293
293
1312
1264
1415
1496
1174.5
1534
1553
1187
1562
1606
1494
1617
328
1823
1866
234
1757
1412
1844
1512
269
878
1165
5595
4095
4428
4010
4360
4986
3989
4483
4201
4217
4223
4658
552
5956
6193
417
6063
6001
6271
6680
231
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
150.09%
199.15%
213.22%
161.99%
156.47%
134.02%
185.61%
162.52%
128.43%
188.92%
134.48%
131.33%
141.33%
144.03%
84.26%
163.36%
165.94%
89.11%
172.54%
212.58%
170.04%
220.90%
42.97%
6
Exhibit C
Entity #
Reported
MW Loss
DCS
Event
Contingency (Cont)
Reserve Obligation
Required
Spin
Actual
Spin
Pass(x)
Cont/Spin (PreContingency Value)
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 3
Entity 5
Entity 5
Entity 5
Entity 3
Entity 2
Entity 5
Entity 5
Entity 5
Entity 1
Entity 4
Entity 1
Entity 4
Entity 3
Entity 2
Entity 1
Entity 1
Entity 4
Entity 5
Entity 5
Entity 5
Entity 1
506
760
522
1061
411
1882
486
475
723
796
492
460
398
1150
1699
786
479
538
714
656
760
790
496
1046
493
651
388
851
970
1059
582
800
471
699
817
1026
850
660
500
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
3610
3742
3612
3791
2964
2497
3536
3422
3006
3293
3174
5129
5614
5231
6028
5874
5155
585
5869
6090
5517
790
573
8090
7099
3351
1040
2181
1037
1175
790
565
1040
1041
1543
2832
2741
2691
1040
1805
1871
1806
1896
1482
1249
1768
1711
1503
1647
1587
2565
2807
2616
3014
2937
2578
293
2935
3045
2759
395
286
4045
3550
1676
520
1091
519
588
395
283
520
521
772
1416
1371
1346
520
6703
6133
5698
6799
5358
4952
5855
6647
8401
5844
5111
9318
11920
13142
9288
9350
14798
1329
11056
14291
8679
1607
379
12613
12659
5962
979
1091
1151
600
924
234
1359
1426
768
6038
6543
5911
1589
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
185.68%
163.90%
157.75%
179.35%
180.77%
198.32%
165.58%
194.24%
279.47%
177.47%
161.03%
181.67%
212.33%
251.23%
154.08%
159.18%
287.06%
227.23%
188.38%
234.66%
157.31%
203.42%
66.15%
155.91%
178.32%
177.92%
94.13%
50.02%
110.99%
51.06%
116.96%
41.44%
130.67%
136.98%
49.77%
213.21%
238.71%
219.66%
152.79%
7
Exhibit C
Entity #
Reported
MW Loss
DCS
Event
Contingency (Cont)
Reserve Obligation
Required
Spin
Actual
Spin
Pass(x)
Cont/Spin (PreContingency Value)
Entity 5
Entity 5
Entity 1
Entity 4
506
707
322
866
Yes
Yes
Yes
Yes
3206
3056
1020
1186
1603
1528
510
593
5893
5952
1454
672
x
x
x
x
183.81%
194.76%
142.55%
56.66%
All 66 events had a 100-percent pass rate showing no degradation to DCS performance. With the R2
compliance waiver in effect, entities carried and deployed enough reserves for post-disturbance ACE
recovery. Also, Spinning Reserve more than the required 50 percent was carried during all but three
events. Of the remaining 63, on average, the entity was carrying 166.38 percent Spinning Reserve as
opposed to 50 percent Spinning Reserve required by the standard. In the remaining three events, the
entities carried an average of 5.3 percent less Spinning Reserve than mandated. 9
WECC assessed Western Interconnection frequency performance to further determine the effect of the
field test on the Interconnection. Frequency performance data was collected for the 32 events having a
verified resource loss of more than 700 MW.
According to NERC, Essential Reliability Services (ERS) Measure 4 10 is a comprehensive set of
Frequency Response measures capturing speed of Frequency Response and response withdrawal at all
relevant time frames:
•
Point A to C frequency response in MW/0.1 Hz;
•
Point A to B frequency response in MW/0.1 Hz (similar to Adequate Level of Reliability (ALR)12);
•
C:B Ratio;
•
C:C’ Ratio; and
•
Three time-based measures: t0 to tC, tC to tC’, and t0 to tC’.
Figure 1 shows a frequency deviation due to a loss of generation resource and the methodology for
calculating frequency response. The event starts at time t0. Value A is the average frequency from t-16
to t-2 seconds, Point C is the lowest frequency point observed in the first 12 seconds, and Value B is the
average from t+20 to t+52 seconds. Point C’ occurs when the frequency after 52 seconds falls below
either the Point C (12 seconds) or average Value B (20–52 seconds), as illustrated below.
This analysis does not speculate on why reporting entities carried more reserve than required. It only notes that excess
reserves were carried.
9
Please note that, although similar in title, NERC’s Essential Reliability Services (ERS) Measure 4 (page 8) is different from
NERC’s State of Reliability Report, Metric M-4 (page 9).
10
8
Exhibit C
Figure 1—Frequency Deviation due to Loss of Generation Resource
Per the NERC State of Reliability Report, Metric M-4 has two parts of interest: 1) performance of the
Western Interconnection to arrest the frequency decline after a loss-of-generation event to prevent
activation of underfrequency load shedding (UFLS), and 2) performance of the Western
Interconnection to stabilize quickly at a high enough frequency to successfully respond to a second
frequency event, should one occur. 11
•
Arresting Period: In 2017, the Western Interconnection experienced an event in which the Point
C nadir was 59.697 Hz, resulting in a Point C to UFLS margin of 0.197 Hz, the smallest margin
since a 0.171-Hz event in 2014. The resource MW losses for these two events were 2,685 MW
and 2,826 MW, respectively. This is more than double the mean resource MW loss for each year
and larger than the Resource Contingency Criteria of 2,626 MW, which is defined in the 2016
Frequency Response Annual Analysis and used to calculate 2017 IFRO. Over the 2013–2017
operating years, the Western Interconnection trend was neither statistically improving nor
NERC State of Reliability, June 2018, Appendix E: Frequency Response Statistics and Essential Reliability Services,
DADS Metric 4: Performance—Demand Response Events by Month—Dispatched vs. Realized, page 112.
https://www.nerc.com/pa/RAPA/PA/Performance%20Analysis%20DL/NERC_2018_SOR_06202018_Final.pdf
11
9
Exhibit C
declining. This indicates that the BAL-002-WECC-2a field test did not adversely affect Western
Interconnection arresting period frequency performance.
•
Stabilizing Period: The mean frequency response in 2017 of 1,836 MW/0.1 Hz was the highest of
all years evaluated in this report. The Western Interconnection had no events in 2017 in which
its interconnection frequency response measure (IFRM) was below its IFRO, including the event
noted above, wherein the Point C nadir to UFLS margin was less than 0.200 Hz. Frequency
response over the 2013–2017 operating years indicated that the Western Interconnection
experienced significant improvement during the stabilizing period. This indicates that the BAL002-WECC-2a field test did not adversely affect Western Interconnection stabilizing period
frequency performance.
Figure 2—Table 2.1 from NERC 2018 State of Reliability Report, June 2018
Below is a summary of Western Interconnection frequency performance metrics:
1. A to B frequency response shows the effectiveness of primary frequency response in stabilizing
frequency after a large frequency excursion. This measure is the conventional means of
calculating Frequency Response as the ratio of net MW lost to the difference between Point A
and Point B frequency values.
10
Exhibit C
Figure 3—A to B IFRM
Western A to B IFRM
7000.00
y = 0.0353x + 125.21
6000.00
5000.00
4000.00
3000.00
2000.00
1000.00
0.00
1/1/16
4/10/16
7/19/16
10/27/16
2/4/17
5/15/17
8/23/17
12/1/17
3/11/18
6/19/18
9/27/18
An increasing trend indicates that frequency response is improving. The Western
Interconnection A to C metric shows no degradation.
For example:
•
60.0 Hz pre-event (A frequency), Loss of 1,000 MW, 59.9 Hz primary frequency response
(B frequency)
o
•
A to B Measure = 1,000 MW/0.1 HZ
60.0 Hz pre-event (A frequency), Loss of 1,500 MW, 59.9 Hz primary frequency response
(B frequency)
o
A to B Measure = 1,500 MW/0.1 HZ
o
A to B measure increases, showing that larger loss of resource results in same
post-event disturbance
•
60.0 Hz pre-event (A frequency), Loss of 1,000 MW, 59.92 Hz primary frequency
response (B frequency)
o
A to B Measure = 1,250 MW/0.1 HZ
o
A to B measure increases, showing that the same loss in resource results in higher
post-event (primary frequency response measure)
11
Exhibit C
2. A to C frequency response shows the effects of inertial response, load response (load damping),
and initial governor response. Governor response is triggered immediately after frequency
exceeds a preset deadband; however, depending on generator technology, full governor
response may take up to 30 seconds to fully deploy. This measure is calculated as the ratio of
net megawatts lost to the difference between Point A and Point C frequency values.
Figure 4—A to C IFRM
Western A to C IFRM
5,000
4,500
y = -0.0412x + 2603.2
4,000
3,500
3,000
2,500
2,000
1,500
1,000
500
0
1/1/16
4/10/16
7/19/16
10/27/16
2/4/17
5/15/17
8/23/17
12/1/17
3/11/18
6/19/18
9/27/18
An increasing trend indicates that frequency response is improving. The Western
Interconnection A to C metric shows no degradation.
For example:
•
60.0 Hz pre-event (A frequency), Loss of 1000 MW, 59.85 Hz lowest frequency (C
frequency)
o
•
A to C Measure = 667 MW/0.1 HZ
60.0 Hz pre-event (A frequency), Loss of 1500 MW, 59.85 Hz lowest frequency (C
frequency)
o
A to C Measure = 1000 MW/0.1 HZ
o
A to C measure increases, representing that larger loss of resource results in same
post event disturbance
12
Exhibit C
•
60.0 Hz pre-event (A frequency), Loss of 1000 MW, 59.90 Hz lowest frequency (C
frequency)
o
A to C Measure = 1000 MW/0.1 HZ
o
A to C measure increases, representing that the same loss in resource results in
higher post event (primary frequency response measure)
3. Cn to C is the ratio between the absolute frequency minimum (Point Cn) caused by governor
withdrawal and the initial nadir (Point C). This metric measures withdrawal of primary
frequency response. A response greater than 1.0 indicates withdrawal. A declining trend is an
indication of improving primary frequency response. The Western Interconnection has shown
no indications of response withdrawal.
Figure 5—Cn to C Ratio
Western Cn to C Ratio
y = -2E-05x + 1.7112
16.0
14.0
12.0
10.0
8.0
6.0
4.0
2.0
0.0
10/23/15
1/31/16
5/10/16
8/18/16
11/26/16
3/6/17
6/14/17
9/22/17
When the DT drafted this white paper, Cn data was only publicly available through August
2017. However, in addition to trended data, the NERC Frequency Response Annual Analysis,
published November 2018, also shows that the Western Interconnection continues to experience
no frequency response withdrawal during the BAL-002-WECC-2a field test.
13
Exhibit C
Figure 6—Table 2.2 from NERC 2018 Frequency Response Annual Analysis, November 2018
4. Cn to UFLS ratio measures the margin between the frequency nadir and the first step in UFLS.
Figure 7—Cn to UFLS margin
Western Cn to UFLS Margin
y = 5E-05x - 1.7346
0.600
0.550
0.500
0.450
Hz
0.400
0.350
0.300
0.250
0.200
0.150
1/1/16
4/10/16
7/19/16 10/27/16
2/4/17
5/15/17
8/23/17
12/1/17
3/11/18
6/19/18
9/27/18
The trend does show a statistical increase in UFLS margin. Also note that the magnitude of the resource
loss directly affects Interconnection performance calculation as measured by IFRMs and Point C to
UFLS margins. During 2017 and 2018, there were three events in which the resource loss was 2,776
14
Exhibit C
MW, 2,685 MW, and 2741 MW; more than double the mean resource MW loss for each year and larger
than the defined Resource Contingency Criteria of 2,626 MW. 12
One event occurred on April 6, 2017, 11:00 p.m. PDT when the field test was not in effect and the other
two events on June 16, 2017, at 5:14 a.m. PDT and July 18, 2018, at 5:30 p.m. PDT when the field test
was in effect. All events, however, had comparable results and significant UFLS margin before and
after the field test. Also, all three events had an IFRM that exceeded the IFRO.
Per the WECC Off-Nominal Frequency Load Shedding Plan (UFLSP), load shedding occurs
sequentially in five blocks with a minimum separation of 0.1 Hz between steps. UFLS entities taking
part in the UFLS plan (aka, Coordinated Plan) must shed their first block of load as soon as frequency
has declined to 59.5 Hz. 13
12 See the 2017 Frequency Response Annual Analysis
https://www.nerc.com/comm/OC/BAL0031_Supporting_Documents_2017_DL/2017_FRAA_Final_20171113.pdf
“UFLS Entities participating in the Coordinated Plan are required to shed their first block of load as soon as frequency
has declined to 59.5 Hz, with additional minimum requirements for further load shedding steps” (as set forth in the
accompanying table).” WECC Off-Nominal Frequency Load Shedding Plan, Coordinated Plans, P. 1a, page 8,
December 5, 2012.
13
15
Exhibit C
WECC receives data used in its analyses from a wide variety of sources. WECC strives to source its data from reliable
entities and undertakes reasonable efforts to validate the accuracy of the data used. WECC believes the data contained herein
and used in its analyses is accurate and reliable. However, WECC disclaims any and all representations, guarantees,
warranties, and liability for the information contained herein and any use thereof. Persons who use and rely on the
information contained herein do so at their own risk.
16
Exhibit D
Order No. 672 Criteria
Exhibit D
Order 672 Criteria
WECC-0115 Contingency Reserve
Request to Retire R2
Introduction
The North American Electric Reliability Corporation (NERC) is responsible for ensuring that
the Reliability Standards, Violation Risk Factors (VRF), Violation Severity Levels (VSL),
definitions, Variances, and Interpretations developed by drafting teams are developed in
accordance with NERC processes. These standards must also meet NERC’s benchmarks for
Reliability Standards, as well as criteria for governmental approval.
In Federal Energy Regulatory Commission (FERC) Order No. 672, 1 FERC identified criteria
that it will use to analyze proposed Reliability Standards for approval to ensure they are just,
reasonable, not unduly discriminatory or preferential, and in the public interest. The
discussion below identifies these factors, and explains how the proposed Reliability Standard
meets or exceeds the criteria.
Designed for a Specific Goal
Proposed Reliability Standards must be designed to achieve a specified reliability goal.
The proposed Reliability Standard must address a reliability concern that falls within the requirements
of Section 215 of the Federal Power Act. That is, it must provide for the reliable operation of BulkPower System facilities. It may not extend beyond reliable operation of such facilities or apply to other
facilities. Such facilities include all those necessary for operating an interconnected electric energy
transmission network, or any portion of that network, including control systems. The proposed
Reliability Standard may apply to any design of planned additions or modifications of such facilities
that is necessary to provide for reliable operation. It may also apply to Cybersecurity protection. Order
No. 672 at P 321.
Further, NERC Reliability Standards are based on certain reliability principles that define the
foundation of reliability for North American bulk power systems. Each Reliability Standard shall
enable or support one or more of the reliability principles, thereby ensuring that each standard serves a
1
FERC Order 672
155 Nort h 400 West | Suit e 200 | Salt Lake Cit y, Ut ah 84103
www. we cc.org
Exhibit D
purpose in support of reliability of the North American bulk power systems. Each Reliability Standard
shall also be consistent with all of the reliability principles, thereby ensuring that no standard
undermines reliability through an unintended consequence. NERC Reliability Principles 2
The Purpose of BAL-002-WECC-2a Contingency Reserve is:
“To specify the quantity and types of Contingency Reserve required to ensure reliability under normal
and abnormal conditions.”
Of the eight NERC Reliability Principles, this standard addresses Reliability Principle 1, which states:
“Interconnected bulk power systems shall be planned and operated in a coordinated manner to
perform reliably under normal and abnormal conditions as defined in the NERC Standards.”
Technically Sound
Proposed Reliability Standards must contain a technically sound method to achieve the goal.
The proposed Reliability Standard must be designed to achieve a specified reliability goal and must
contain a technically sound means to achieve this goal. Although any person may propose a topic for a
Reliability Standard to the Electric Reliability Organization (ERO), in the ERO’s process, the specific
proposed Reliability Standard should be developed initially by persons within the electric power
industry and community with a high level of technical expertise and be based on sound technical and
engineering criteria. It should be based on actual data and lessons learned from past operating
incidents, where appropriate. The process for ERO approval of a proposed Reliability Standard should
be fair and open to all interested persons. Order No. 672 at P 324.
Standard Development
This proposed Reliability Standard was developed using the NERC and Western Electricity
Coordinating Council (WECC) Reliability Standards Development Procedures (Procedures) approved
by FERC and in effect at each point in the process. Among other things, these processes include
drafting of the standard by a drafting team composed of subject matter experts (SME); biographies of
those SMEs are provided with this filing.
These processes also include repeated public iterative comment/response cycles whereby comments are
received from the industry, and responses to those comments are provided by the drafting team.
Technically Sound
On May 6, 2015, WECC received Standard Authorization Request (SAR) WECC-0115 BAL-002-WECC-2
Contingency Reserve, Request to Retire Requirement R2 (R2) requesting retirement of R2 and its
2
https://www.nerc.com/files/Reliability_Principles.pdf
2
Exhibit D
compliance elements. 3 The SAR stated that, on April 1, 2016, BAL-003-1.1 Frequency Response and
Frequency Bias Settings, Requirement R1 would make R2 redundant.
To assess the potential risk of retiring R2, WECC conducted a NERC-approved field test from May 1,
2017, through April 30, 2018. 4 WECC required U.S. entities to provide data on the quantity of reserve
carried during the field test period. Between October 18, 2018, and January 10, 2019, the WECC-0115
BAL-002-WECC-2a drafting team (DT) reviewed the test data and concluded that, if BAL-002-WECC-2a
Requirement R2 is retired, it is unlikely to have an adverse effect on reliability.
To enable WECC to monitor the reliability effects of the field test, as a condition to participate in the
field test, and to meet NERC’s conditions in approving the field test, WECC required U.S. entities to
provide the following information for any reportable Disturbance Control Standard (DCS) event:
•
The date and time of the event;
•
The required amount of Contingency Reserve at the time of the event;
•
The actual amount of Operating Reserve—Spinning at the time of the event;
•
The actual DSC performance.
Additionally, whether or not an incident was a reportable DCS event, for all instances of a loss of
resources 700 MW or greater, entities were to report:
•
The date and time of the event;
•
The name of the resource(s);
•
The total MW loss; and
•
Any other relevant information.
Entities gave this information to WECC staff for each incident.
Applicability
Proposed Reliability Standards must be applicable to users, owners, and operators of the bulk
power system, and not others.
The proposed Reliability Standard may impose a requirement on any user, owner, or operator of such
facilities, but not on others. Order No. 672 at P 322.
The Applicability section of BAL-002-WECC-2a, Contingency Reserve is as follows:
The naming nomenclature changed during development from BAL-002-WECC-2, BAL-002-WECC-2a, and will
change to BAL-002-WECC-3 if approved.
4 NERC approved the field test in late March 2017 and WECC conducted it per NERC Standards Processes
Manual, Section 6.2, Field Tests and Data Analysis for Validation of Requirement. A compliance waiver for R2
was granted beginning on May 1, 2017, and ending on May 1, 2019.
3
3
Exhibit D
4. Applicability:
4.1
Balancing Authority
4.1.1.
The Balancing Authority is the responsible entity unless the Balancing Authority
is a member of a Reserve Sharing Group, in which case, the Reserve Sharing
Group becomes the responsible entity.
4.2
Reserve Sharing Group
4.2.1.
The Reserve Sharing Group when comprised of a Source Balancing Authority
becomes the source Reserve Sharing Group
4.2.2.
The Reserve Sharing Group when comprised of a Sink Balancing Authority
becomes the sink Reserve Sharing Group.
Clear and Unambiguous
Proposed Reliability Standards must be clear and unambiguous as to what is required and who is
required to comply.
The proposed Reliability Standard should be clear and unambiguous regarding what is required and
who is required to comply. Users, owners, and operators of the Bulk-Power System must know what
they are required to do to maintain reliability. Order No. 672 at P 325.
Understandable Consequence
Proposed Reliability Standards must include clear and understandable consequences and a range of
penalties (monetary and/or non-monetary) for a violation.
The possible consequences, including range of possible penalties, for violating a proposed Reliability
Standard should be clear and understandable by those who must comply. Order No. 672 at P 326.
This filing does not propose changes to the FERC-approved VSLs or VRFs. This filing proposes only a
formatting change to the VRF.
Measurability for Compliance
Proposed Reliability Standards must identify a clear and objective criterion or measure for
compliance, so that it can be enforced in a consistent and non-preferential manner.
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. Order No. 672 at P 327.
4
Exhibit D
This filing proposes retirement of BAL-002-WECC-2a, Requirement R2 with no further substantive
changes to the existing FERC-approved standard.
Effective and Efficient
Proposed Reliability Standards should achieve a reliability goal effectively and efficiently - but does not
necessarily have to reflect “best practices” without regard to implementation cost.
The proposed Reliability Standard does not necessarily have to reflect the optimal method, or “best
practice,” for achieving its reliability goal without regard to implementation cost or historical regional
infrastructure design. It should however achieve its reliability goal effectively and efficiently. Order
No. 672 at P 328.
During the two posting periods, no concerns were raised about implementation costs or regional
infrastructure.
Lowest Common Denominator
Proposed Reliability Standards cannot be “lowest common denominator,” i.e., cannot reflect a
compromise that does not adequately protect bulk power system reliability.
The proposed Reliability Standard must not simply reflect a compromise in the ERO’s Reliability
Standard development process based on the least effective North American practice — the so-called
“lowest common denominator” — if such practice does not adequately protect Bulk-Power System
reliability. Although the Commission will give due weight to the technical expertise of the ERO, we
will not hesitate to remand a proposed Reliability Standard if we are convinced it is not adequate to
protect reliability. Order No. 672 at P 329.
The filing proposes retirement of BAL-002-WECC-2a, Requirement R2 because it is redundant to BAL003-1.1 Frequency Response and Frequency Bias Settings, Requirement R1.
Costs
Proposed Reliability Standards may consider costs to implement for smaller entities but not at
consequence of less than excellence in operating system reliability.
A proposed Reliability Standard may take into account the size of the entity that must comply with the
Reliability Standard and the cost to those entities of implementing the proposed Reliability Standard.
However, the ERO should not propose a “lowest common denominator” Reliability Standard that
would achieve less than excellence in operating system reliability solely to protect against reasonable
expenses for supporting this vital national infrastructure. For example, a small owner or operator of the
Bulk-Power System must bear the cost of complying with each Reliability Standard that applies to it.
Order No. 672 at P 330.
5
Exhibit D
During the development of the project, the industry raised no such concerns.
Continent-wide and Regional Variations
Proposed Reliability Standards must be designed to apply throughout North America to the
maximum extent achievable with a single reliability standard while not favoring one area or
approach.
A proposed Reliability Standard should be designed to apply throughout the interconnected North
American Bulk-Power System, to the maximum extent this is achievable with a single Reliability
Standard. The proposed Reliability Standard should not be based on a single geographic or regional
model but should take into account geographic variations in grid characteristics, terrain, weather, and
other such factors; it should also take into account regional variations in the organizational and
corporate structures of transmission owners and operators, variations in generation fuel type and
ownership patterns, and regional variations in market design if these affect the proposed Reliability
Standard. Order No. 672 at P 331.
In the Order 740 Remand at P4, the Commission states that:
“Reliability Standards that the ERO proposes to the Commission may include Reliability Standards that
are proposed to the ERO by a Regional Entity… When the ERO reviews a regional Reliability Standard
that would be applicable on an interconnection-wide basis and that has been proposed by a Regional
Entity organized on an interconnection-wide basis, the ERO must rebuttably presume that the regional
Reliability Standard is just, reasonable, not unduly discriminatory or preferential, and in the public
interest. In turn, the Commission must give “due weight” to the technical expertise of the ERO and of a
Regional Entity organized on an interconnection-wide basis.”
Further, regional entities may propose Regional Reliability Standards that set more stringent reliability
requirements than the NERC Reliability Standard or cover matters not covered by an existing NERC
Reliability Standard. NERC Rules of Procedure, Section 312, Regional Reliability Standards.
The filing requests retirement of BAL-002-WECC-2a Contingency Reserve, Requirement R2. If
approved, the reliability-related tasks will default to the continent-wide requirement of BAL-003-1.1
Frequency Response and Frequency Bias Settings, Requirement R1.
No Undue Negative Effect
Proposed reliability standards should cause no undue negative effect on competition or restriction
of the grid.
As directed by section 215 of the FPA, the Commission itself will give special attention to the effect of a
proposed Reliability Standard on competition. The ERO should attempt to develop a proposed
Reliability Standard that has no undue negative effect on competition. Among other possible
6
Exhibit D
considerations, a proposed Reliability Standard should not unreasonably restrict available transmission
capability on the Bulk-Power System beyond any restriction necessary for reliability and should not
limit use of the Bulk-Power System in an unduly preferential manner. It should not create an undue
advantage for one competitor over another. Order No. 672 at P 332
The DT does not foresee any negative effects on competition resulting from the proposed retirement.
During the development phase of this project, the industry raised no concerns about competition or
restrictive use of the grid.
Implementation of New Requirements (Effective Date)
The implementation time for the proposed Reliability Standards must be reasonable.
In considering whether a proposed Reliability Standard is just and reasonable, the Commission will
consider also the timetable for implementation of the new requirements, including how the proposal
balances any urgency in the need to implement it against the reasonableness of the time allowed for
those who must comply to develop the necessary procedures, software, facilities, staffing or other
relevant capability. Order No. 672 at P 333
Per the WECC Reliability Standards Development Procedures, Posting 1 (Attachment E4) of this project
included an implementation plan for the proposed retirement. The Implementation Plan is included as
Exhibit B of this filing.
When the DT published Posting 1 in October 2015, it proposed a retirement date coincident with the
then-future effective date of BAL-003-1.1 Frequency Response and Frequency Bias Settings,
Requirement R1. Because BAL-003-1.1, Requirement R1 is now effective, and while the reliabilityrelated tasks of BAL-002-WECC-2a are addressed in BAL-003-1.1, Requirement R1, retirement of BAL002-WECC-2a, Requirement R2 can be effective immediately upon receipt of regulatory approval.
Fair and Open Process
The Reliability Standard development process must be open and fair.
Further, in considering whether a proposed Reliability Standard meets the legal standard of review, we
will entertain comments about whether the ERO implemented its Commission-approved Reliability
Standard development process for the development of the particular proposed Reliability Standard in a
proper manner, especially whether the process was open and fair. However, we caution that we will
not be sympathetic to arguments by interested parties that choose, for whatever reason, not to
participate in the ERO’s Reliability Standard development process if it is conducted in good faith in
accordance with the procedures approved by the Commission. Order No. 672 at P 334
WECC followed the WECC Reliability Standards Development Procedures (Procedures) approved by
FERC in effect at the time of each step in the process.
7
Exhibit D
In accordance with the Procedures, all drafting team meetings are open to the public.
All drafting team meetings were announced via the WECC Standards Email List for the period
prescribed in the Procedures. Notice of the meetings was provided to NERC and posted on the WECC
Calendar along with meeting minutes.
All meetings were supported by a telephone conference bridge associated with an on-line internet
visual capability allowing all participants to see the document(s) as they were being developed.
Further, this team held an open-mic Standards Briefing prior to balloting affording the industry an
additional opportunity to have its questions addressed.
This project was posted twice for public comment at WECC.
Comments and the associated responses are currently posted on the WECC website at the WECC-0115
project page on the Submitt and Review accordion. 5 Response to Comments forms were provided with
this filing.
In addition to posting under the WECC Procedures, this project was also posted by NERC for 45-days
in accordance with NERC’s Rules of Procedure and NERC’s internal business practices.
All comments received in that posting indicated WECC’s development processes were: 1) open, 2)
inclusive, 3) balanced, 4) transparent, and 5) provided due process.
Balanced with Other Vital Interests
Proposed Reliability Standards must balance with other vital public interests.
Finally, we understand that at times development of a proposed Reliability Standard may require that
a particular reliability goal must be balanced against other vital public interests, such as environmental,
social and other goals. We expect the ERO to explain any such balancing in its application for approval
of a proposed Reliability Standard. Order No. 672 at P 335
WECC is not aware of any other vital public interests. No such balancing concerns were raised or
noted.
Consideration of Other Facts
Proposed Reliability Standards must consider any other relevant factors.
In considering whether a proposed Reliability Standard is just and reasonable, [FERC] will consider
[several] general factors, as well as other factors that are appropriate for the particular Reliability
Standard proposed. Order No. 672 at P 323
5
https://www.wecc.org/Standards/Pages/WECC-0115.aspx
8
Exhibit D
WECC is not aware of any other general factors in need of consideration.
9
Exhibit E
Summary of Development History and
Complete Record of Development
Summary of Development History
The development record for proposed Regional Reliability Standard BAL-002-WECC-3 is
summarized below.
I.
Overview of the Standard Drafting Team
When evaluating a proposed Reliability Standard, the Commission is expected to give “due
weight” to the technical expertise of the ERO. 1 The technical expertise of the ERO is derived from
the standard drafting team (“SDT”) selected by the WECC Standards Committee (“WSC”) to lead
each project in accordance with Step 3 of the WECC Reliability Standards Development
Procedures. 2 For this project, the SDT consisted of industry experts, all with a diverse set of
experiences. A roster of the BAL-002-WECC-3 SDT members is included in Exhibit F.
II.
Standard Development History
A. Standard Authorization Request Development
On May 6, 2015, WECC received Standard Authorization Request (“SAR”) WECC-0115
to examine whether to retire BAL-002-WECC-2 Requirement R2. 3 After an affirmative review by
the WECC Operating Committee, the SAR was approved by the WSC on June 23, 2015.
Nominations for the drafting team were open from June 23, 2015 through July 31, 2015. The WSC
approved the drafting team roster on August 12, 2015.
B. First Posting – Comment Period 4
The project’s first posting opened October 22, 2015, closing on December 8, 2015. After
considering all comments received, on December 17, 2015, the SDT agreed to conduct a field test
1
Section 25(d)(2) of the Federal Power Act; 16 U.S.C. 824(d)(2) (2012).
The currently effective WECC RSDP is located at
https://www.wecc.org/Reliability/WECC%20Reliability%20Standards%20Development%20Procedures%20%20FERC%20Approved%20October%2027%202017%20-%202019%20Template.pdf.
3
The currently-effective version, BAL-002-WECC-2a, came into effect during the development of
proposed BAL-002-WECC-3.
4
Posting materials for all postings are located on the WECC project page:
https://www.wecc.org/Standards/Pages/WECC-0115.aspx. An implementation plan was filed as part of Posting 1.
2
to examine the ramifications of retiring Requirement R2. 5 On January 7, 2016, the SDT concluded
a one-year data set would be sufficient to determine the impacts of retirement. The one-year data
set began on May 1, 2017 and terminated on April 30, 2018.
C. Field Test
In late March 2017, NERC approved WECC’s request for the field test. The test allowed
WECC to waive compliance with BAL-002-WECC-2a Requirement 2 for all Reserve Sharing
Groups (“RSG”), and all Balancing Authorities (“BA”) that were not members of an RSG, that
opted to participate in the field test. Participants were required to notify WECC of their intent to
participate in the field test prior to receiving the waiver.
In late March 2017, NERC approved WECC’s request for the field test. 6 The test allowed
WECC to waive compliance with BAL-002-WECC-2a Requirement 2 for all Reserve Sharing
Groups (“RSG”) and all Balancing Authorities (“BA”) which were not members of an RSG and
who opted to participate in the field test. Participants were required to notify WECC of their intent
to participate in the field test prior to receiving the waiver.
To enable WECC to monitor the reliability impacts of the field test, as a condition to
participation in the field test, and to meet conditions specified by NERC in approving WECC’s
request for a field test, WECC required U.S. entities to provide the following information for any
reportable Disturbance Control Standard (“DCS”) event:
•
•
•
5
The date and time of the event;
The required amount of Contingency Reserves at the time of the event;
The actual amount of Operating Reserves – Spinning at the time of the event; and
“WECC-0115 Notice of Field Test” (2017), available at https://www.wecc.org/Reliability/WECC0115%20Notice%20of%20Field%20Test.pdf.
•
The actual DCS performance.
Additionally, whether or not an incident was a reportable DCS event, for all instances of a
loss of resources 700 MW or greater, entities were to report:
•
•
•
•
The date and time of the event;
The name of the resource(s);
The total MW loss; and
Any other relevant information.
This information was provided to WECC staff for each incident.
Between October 18, 2018 and January 10, 2019, the SDT reviewed the test data and
concluded that if Requirement R2 is retired, it is unlikely to have an adverse impact on reliability.
D. Second Posting – Comment Period
From January 18, 2019 through February 18, 2019, the SDT posted Posting 2 of the project
(a technical white paper) in support of the retirement. 7 Posting 2 received three comments. After
considering all comments, the SDT made editorial changes to its technical findings and provided
additional footnotes to clarify data and language; however, the SDT did not change its conclusion
that Requirement R2 should be retired. On February 28, 2019, the SDT agreed by majority vote to
forward the project to the WSC with a request for ballot.
E. Ballot
On March 5, 2019, the WSC approved the project for ballot. Balloting was open from
March 28, 2019 through April 11, 2019. It received 100% affirmative ballot in favor of retirement
of Requirement R2, supported by an 89.5 percent quorum. On June 18, 2019, the WSC approved
“Field Test Results, WECC-0115 BAL-002-WECC-2a Request to Retire Requirement R2,” Standard
Drafting Team, March 5, 2019, Executive Summary, https://www.wecc.org/Reliability/WECC0115%20Posting%202%20BAL-002-WECC-2%20Request%20to%20Retire%20R2%20%20From%20Tech%20Editor.docx.
7
the ballot results and forwarded the project to the WECC Board of Directors (“Board”) with a
request for approval and subsequent disposition.
F. WECC Board of Directors Approval
On June 19, 2019, the WECC Board approved BAL-002-WECC-3 with the following
resolution:
Resolved, that the WECC Board of Directors (Board), acting upon the
recommendation of the WECC Standards Committee (WSC) at the meeting of the
Board on June 19, 2019, hereby approves the June 19, 2019 Board Voting Record
2 retirement of BAL-002-WECC-2a, Contingency Reserve, Requirement R2, the
associated Measure M2, and the associated violation risk factor and violation
severity levels, as presented and attached hereunto. 8
G. NERC Comment Period and Board of Trustees Adoption
NERC posted proposed Regional Reliability Standard BAL-002-WECC-3 for a 45-day
public comment period from June 20, 2019 through August 5, 2019. The NERC Board of Trustees
adopted the proposed Regional Reliability Standard on August 15, 2019.
8
Voting Record, WECC Board of Directors, June 19, 2019, Item 6. “Retire BAL-002-WECC-2a,
Requirement,” https://www.wecc.org/_layouts/15/WopiFrame.aspx?sourcedoc=/Administrative/2019-0619%20Board%20Voting%20Record.pdf.
Complete Record of Development
Steven Rueckert
WECC Director of Standards
August 14, 2019
Ms. Nasheema Santos
NERC Reliability Standards Department
North American Electric Reliability Corporation
3353 Peachtree Rd. NE, North Tower—Suite 600
Atlanta, GA 30326
Subject:
WECC-0115 BAL-002-WECC-3
Request to Retire Requirement R2
Dear Nasheema,
WECC is seeking approval from the NERC Board of Trustees, with subsequent disposition by the
Federal Energy Regulatory Commission (FERC), to approve retirement of WECC Regional Reliability
Standard, BAL-002-WECC-2a, Contingency Reserve, Requirement R2.
This project proposes retirement of R2 on the premise that R2 is redundant to BAL-003-1.1 Frequency
Response and Frequency Bias Setting. The drafting team’s conclusion is supported by technical
justification (Exhibit C) premised on a NERC-approved field test. 1 Results of the field test indicate that
adverse impact on reliability is unlikely.
When considering retirement of R2 it should be noted that BAL-003-1.1 represents a measurable
performance calculated as an entity’s known contribution to frequency response. By contrast, R2 has
no technical foundation; rather, it represents a negotiated threshold established circa 1998 prior to
mandatory standards. 2
The request to retire R2 was approved by a WECC Ballot Pool with a 100 percent weighted approval.
Sincerely,
Steven Rueckert
WECC Director of Standards
A NERC-approved field test was conducted from May 1, 2017, through April 30, 2018 examining the impact of
retirement.
2 Western System Coordinating Council, Reliability Criteria Agreement, 2. WSCC Criterion, (a.) Minimum
Operating Reserve, (ii) Contingency reserve. Circa November 1998.
1
155 North 400 West | Suite 200 | Salt Lake City, Utah 84103
WECC-0115 BAL-002-WECC-3 Contingency Reserve
Request to Retire Requirement R2
For documentation support please contact W. Shannon Black, at (503) 307-5782.
WECC-0115 BAL-002-WECC-3, Contingency Reserve 3
Request to Retire Requirement R2
QR
BOT
Gov’t
Auth.*
Exhibit A – Final Standard - Clean
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Exhibit A - Final Standard - Clean
Exhibit A1 - Final Standard – Redline
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Exhibit A1 - Final Standard –
Redline
Exhibit B – Final Implementation Plan
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Exhibit B – Final Implementation
Plan
Exhibit C – Final Technical Justification
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Exhibit C – Final Technical
Justification
Exhibit D - Order 672 Criteria
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Exhibit D – Order 672 Criteria
Exhibit E - Summary of Development and WECC’s Record of
Development - NERC Provided Template
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve – Exhibit E - Summary of Development
– NERC Provided
Attachment E1 – WECC Standard Authorization Request
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Attachment E1 – WECC SAR
Attachment E2 – Project Roadmap
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Attachment E2 – Project Roadmap
The naming nomenclature changed during development from BAL-002-WECC-2, BAL-002-WECC-2a, and will
change to BAL-002-WECC-3 if approved.
3
2
WECC-0115 BAL-002-WECC-3 Contingency Reserve
Request to Retire Requirement R2
Attachment E3 – NERC Submittal Request
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Attachment E3 – NERC Submittal
Request
Attachment E4 – Posting 1 Clean
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Attachment E4 – Posting 1 Clean
Attachment E5 – Posting 1 Redline
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Attachment E5 – Posting 1 Redline
– Not Used
Attachment E6 – Posting 2 Clean
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Attachment E6 – Posting 2 Clean
Attachment E7 – Posting 2 Redline
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Attachment E7 – Posting 2 Redline
Attachment E8 – Posting 1 WECC Response to Comments
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Attachment E8 – Posting 1 Response
to Comments
Attachment E9 – Posting 2 WECC Response to Comments
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Attachment E9 – Posting 2 Response
to Comments
Attachment E10 – Minority Issues
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Attachment E10 – Minority Issues
Attachment E11 – Ballot Pool Members
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Attachment E11 – Ballot Pool
Members
Attachment E12 – Ballot Pool Results
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Attachment E12 – Ballot Pool
Results
Attachment E13 – Posting 1 NERC Response to Comments
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Attachment E13 – NERC Posting 1
Response to Comments
3
WECC-0115 BAL-002-WECC-3 Contingency Reserve
Request to Retire Requirement R2
Attachment E14 – WECC Standards Committee Roster
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Attachment E14 – WECC Standards
Committee Roster
Exhibit F - WECC-0115 Drafting Team Roster
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Exhibit F – WECC Drafting Team
Roster
Exhibit G - VRF & VSL Justification
File Name: WECC-0115 BAL-002-WECC-3 – Contingency Reserve —Exhibit G - VRF & VSL Justification
Exhibit H - Issue Table and Mapping Document – Optional
Not Used
Exhibit I - Guidance Document - Optional
Not Used
Exhibit J - Additional Supporting Documentation – Optional
Not Used
The above documents have been provided to NERC in MS Word format.
4
Attachment E1
WECC Standard Authorization Request
WECC-0115 BAL-002-WECC-3
Contingency Reserve
Request to Retire R2
Introduction
This Standard Authorization Request (SAR) was assigned WECC Tracking Number WECC-0115.
On May 6, 2015, WECC received Standard Authorization Request (SAR) WECC-0115 to examine
whether to retire BAL-002-WECC-2 Requirement R2. 1 After an affirmative review by the WECC
Operating Committee, the SAR was approved by the WECC Standards Committee (WSC) on June 23,
2015. Nominations for the drafting team were received from June 23, 2015 through July 31, 2015. The
WSC approved the drafting team roster on August 12, 2015. 2
Requester Information
Provide your contact information and your alternate’s contact information:
Primary contact
•
First name:
James
•
Last name:
Wells
•
Email:
[email protected]
•
Phone:
(818) 77-6701
•
Organization name:
Los Angeles Department of Water and Power
Alternate
•
First name:
W. Shannon
•
Last name:
Black
•
Email:
[email protected]
•
Phone:
(503) 307-5782
The naming nomenclature changed during development from BAL-002-WECC-2, BAL-002-WECC-2a, and will
change to BAL-002-WECC-3 if approved.
2 This document was added to the WECC Intranet on August 12, 2019, after being updated to WECC’s newest
document templates. The SAR in its original format is available upon request from the WECC Standards
Department.
1
155 Nort h 400 West | Suit e 200 | Salt Lake Cit y, Ut ah 84103
www. we cc.org
Attachment E1
Type of Request
Specify the type of request: (Select one)
•
Request to Modify a Regional Reliability Standard (RRS)
Create, Modify, Retire, or Review a Document
Provide information for your request to create, modify, retire, or review the document.
Pick from the dropdown provided in the online form.
Requested Action (Select one)
•
Request to Retire BAL-002-WECC-2, Requirement R2 3
Document Type (Select one)
•
Regional Reliability Standard
Issue
Specify what industry problem this request is trying to resolve.
BAL-003-1, Frequency Response and Frequency Bias Setting
On January 16, 2014, FERC approved BAL-003-1, Frequency Response and Frequency Bias Setting,
Requirement R1, with an effective date of April 1, 2016. The text of BAL-003-1, Requirement R1 states:
R1.
Each Frequency Response Sharing Group (FRSG) or Balancing Authority that is not a member
of a FRSG shall achieve an annual Frequency Response Measure (FRM) that is equal to or more
negative than its Frequency Response Obligation (FRO) to ensure that sufficient Frequency
Response is provided by each FRSG or BA that is not a member of a FRSG to maintain
Interconnection Frequency Response equal to or more negative than the Interconnection
Frequency Response Obligation.
BAL-003-1, Requirement R1 is an annual measure requiring a full 12 months of performance
measurements, collected through Frequency Response Forms (FRS) 1 and 2, summarizing frequency
response settings for participating Balancing Authorities (BA), for a period of December through
November of the following year, in accordance with BAL-003-1 and its Attachment A.
On January 24, 2017, the Federal Energy Regulatory Commission (FERC) approved interpretation of BAL-002WECC-2, which clarified the types of resources that may be used to satisfy Contingency Reserve. The standard’s
name was changed to BAL-002-WECC-2a.
3
2
Attachment E1
BAL-003-1, Requirement R1 will become enforceable for frequency events occurring December 2016
through November 2017. Frequency Response Measures for compliance with BAL-003-1, Requirement
R1 will be submitted no later than March 7, 2018.
Compliance will be judged against Balancing Authority Frequency Response Obligations (BA FRO)
calculated annually based on the Interconnection Frequency Response Obligations (IFROs) calculated
and approved by the NERC Operating Committee.
With the implementation of BAL-003-1, standards now exist that define requirements for acceptable
Frequency Response from the BA to maintain Interconnection Frequency within predefined bounds by
arresting frequency deviations and supporting frequency until the frequency is restored to its
scheduled value. Additionally, [BAL-003-1] provides consistent methods for measuring Frequency
Response and determining the Frequency Bias Setting.
BAL-002-WECC-2, Contingency Reserve
BAL-002-WECC-2, Requirement R2 becomes redundant as of the April 1, 2016, effective date of BAL003-1. Further, there is no technical support or reason for retaining BAL-002-WECC-2, Requirement R2
once BAL-003-1 becomes effective.
Leaving BAL-002-WECC-2 in place would require the BA or Reserve Sharing Group to carry additional
spinning reserve with the intended purpose of supporting the frequency of the Western
Interconnection. The 50 percent spinning reserve requirement has no measurable performance metric
with respect to interconnection frequency support.
Proposed Remedy
Specify how this request will address the issue you stated above.
•
Retire BAL-002-WECC-2, Contingency Reserve, Requirement R2.
Purpose:
The purpose of this Standard Authorization Request (SAR) is to delete BAL-002-WECC-2, Contingency
Reserve, Requirement R2 and Measurement M2. The modification should be coincident with
implementation of BAL-003-1, Requirement R1 that specifies BA frequency response obligation and
performance measurement. The text of BAL-002-WECC-2, Requirement R2 is as follows:
R2.
Each Balancing Authority and each Reserve Sharing Group shall maintain at least half of its
minimum amount of Contingency Reserve identified in Requirement R1, as Operating Reserve
– Spinning that meets both of the following reserve characteristics. [Violation Risk Factor: High]
[Time Horizon: Real-time operations]
2.1
Reserve that is immediately and automatically responsive to frequency deviations
through the action of a governor or other control system;
3
Attachment E1
2.2
Reserve that is capable of fully responding within ten minutes.
Removing BAL-002-WECC- 2, Requirement R2 does not change the amount of a BA’s contingency
reserve requirement specified in BAL-002-WECC-2, Requirement R1.
Operating Reserve will only require reserve fully capable of responding within ten minutes to support
the Disturbance Control Standard (DCS).
Applicable Entities
•
Balancing Authority
•
Reserve Sharing Groups
•
Frequency Response Sharing Group
Detailed Description
See above.
Affected Reliability Principles
Which of the NERC Reliability Principles is most affected by this request?
•
Reliability Principle 1 — Interconnected bulk electric systems shall be planned and operated in
a coordinated manner to perform reliably under normal and abnormal conditions as defined in
the NERC Standards.
Reference Uploads
Specify the document title, document number, and affected section regarding the request.
•
BAL-002-WECC-2, Contingency Reserve, Requirement R2
Additional Comments
Please reference or upload any affected standards, regional business practices, criteria, policies, white
papers, technical reports, or other relevant documents. If this request is based on a conflict of law,
please include a copy of—or accessible reference to—the specific law or regulatory mandate in conflict.
•
None
4
Attachment E2
Project Roadmap
WECC-0115 BAL-002-WECC-3
Contingency Reserve
Request to Retire R2
Description of Current Draft
Per the WECC Reliability Standards Development Procedures (Procedures) this is a request to retire
Requirement R2 of BAL-002-WECC-2, Contingency Reserve.
Completed Actions
Date Completed
WECC-0115 Standard Authorization Request (SAR)—Request to Retire
May 6, 2015
Requirement R2 of BAL-002-WECC-2 received and deemed complete
WECC Joint Guidance Committee approved the SAR approach
May 27, 2015
WECC Operating Committee approved the SAR approach
June 9, 2015
WECC Standards Committee (WSC) approved the SAR
June 23, 2015
Notice of Solicitation—WECC-0115 Drafting Team
June 29, 2015
Notice of Solicitation—WECC-0115 Drafting Team—Extended
July 14, 2015
Nominations closed
July 31, 2015
WSC approved the team roster
August 12, 2015
Drafting Team (DT) meeting
October 1, 2015
DT Meeting
October 22, 2015
Posting 1—opened
October 22, 2015
Posting 1—closed
December 8, 2015
DT meeting 1
December 17, 2015
DT meeting—DT approved field test parameters (Exhibit C)
January 7, 2016
WSC updated
September 6, 2016
Field test approval under development by WECC and NERC. The NERC vice president of Standards
and Compliance had to approve the test.
NERC approved WECC request for field test to examine retirement of R2
March 2017
Notice of field test dispatched
April 11, 2017
Field test begins
May 1, 2017
The DT agreed by majority vote to pursue a field trial to determine the potential effects of retiring BAL-002WECC-2, Requirement R2.
1
155 Nort h 400 West | Suit e 200 | Salt Lake Cit y, Ut ah 84103
www. we cc.org
Attachment E2
Field test ends
April 30, 2018
DT meeting
October 18, 2018
2
DT meeting
November 1, 2018
DT meeting
November 29, 2018
DT meeting
January 10, 2019
Posting 2—open
January 18, 2019
Posting 2—closed
February 18, 2019
DT meeting
February 21, 2019
DT meeting
February 28, 2019
Field test ends (originally proposed end date)
March 30, 2019
Initial compliance waiver ends
May 1, 2019
WSC approved for ballot
March 5, 2019
Notice of Ballot Pool forming / Notice of Ballot
March 7, 2019
Ballot Pool opened
March 11, 2019
Notice of Standards Briefing
March 12, 2019
Ballot Pool closed
March 26, 2019
Standards Briefing
March 27, 2019
Ballot opened
March 28, 2019
Ballot closed
April 11, 2019
WSC approves sending to WECC Board of Directors (Board)
June 18, 2019
Board approves for NERC/FERC disposition
June 19, 2019
NERC 45-day comment open
June 20, 2019
NERC 45-day comment closed
August 5, 2019
NERC Board of Trustees approved
August 15, 2019
Filed with FERC
Pending
Analysis of the field test data indicated that sufficient reserves were being carried even though a compliance
waiver was in effect. The threshold conclusion was that retirement of Requirement R2 would have no detrimental
effect on the grid.
2
2
Regional Reliability Standard Submittal Request
Attachment E3
Region:
Western Electricity Coordinating Council
Regional Standard Number:
BAL-002-WECC-3 1
Regional Standard Title:
Contingency Reserve
Date Submitted:
August 30, 2019
Regional Contact Name:
Steven Rueckert
Regional Contact Title:
Director of Standards
Regional Contact Telephone
Number:
(801) 883-6878
Request (check all that apply):
Retirement of WECC Regional Reliability Standard Requirement BAL-002-WECC-2a (R2)
Interpret an existing standard
Approval of a new standard
Revision of an existing standard: BAL-002-WECC-2a
Withdrawal of an existing standard
Urgent action
Has this action been approved by your Board of Directors:
Yes
No
(If no please indicate date standard action is expected along with the current status (e.g., third
comment period with anticipated board approval on mm/dd/year)):
On June 19, 2019, the WECC Board of Directors (Board) approved BAL-002-WECC-3 with the
following resolution:
1
The naming nomenclature changed during development from BAL-002-WECC-2, BAL-002-WECC-2a, and will change to
BAL-002-WECC-3 if approved.
1
Regional Reliability Standard Submittal Request
“Resolved, that the WECC Board of Directors (Board), acting upon the recommendation of
the WECC Standards Committee (WSC) at the meeting of the Board on June 19, 2019,
hereby approves the retirement of BAL-002-WECC-2a, Contingency Reserve, Requirement
R2, the associated Measure M2, and the associated violation risk factor and violation
severity levels, as presented and attached hereunto.”
[Note: The purpose of the remaining questions is to provide NERC with the information needed
to file the regional standard(s) with FERC. The information provided may to a large degree be
used verbatim. It is extremely important for the entity submitting this form to provide sufficient
detail that clearly delineates the scope and justification of the request.]
Concise statement of the This project proposes retirement of BAL-002-WECC-3 Contingency
basis and purpose (scope) Reserve, Requirement R2 on the premise that R2 is redundant to
of request:
BAL-003-1.1 Frequency Response and Frequency Bias Setting.
Concise statement of the
justification of the
request:
The project drafting team recommendation to retire
Requirement R2 is supported by technical justification (Exhibit
C) premised on a NERC-approved field test. Results of the
field test indicate that adverse impact on reliability is unlikely.
When considering retirement of Requirement R2 it should be
noted that BAL-003-1.1 Frequency Response and Frequency
Bias Setting represents a measurable performance calculated
as an entity’s known contribution to frequency response. By
contrast, BAL-002-WECC-2a, Requirement R2 has no technical
foundation; rather, it represents a negotiated threshold
established circa 1998 prior to mandatory standards.
2
Regional Reliability Standard Submittal Request
Attachment E4
Posting 1
WECC-0115 BAL-002-WECC-3,
Contingency Reserve
Request to Retire R2
Memo
Date:
October 23, 2019
To:
WECC Standards Email List
Subject:
WECC-0115 BAL-002-WECC-2—Contingency Reserve
Request to Retire Requirement R2
Question for Survey 1
Do you agree that WECC Regional Standard BAL-002-WECC-2, Contingency Reserve, Requirement R2
should be retired as of the effective date of NERC Standard BAL-003-1 2 (BAL-003), Frequency Response
and Frequency Bias Setting, Requirement R1?
If you answered no to the above question, please explain your answer.
Recommendation
The WECC-0115, BAL Drafting Team is recommending retirement of BAL-002-WECC-2, Contingency
Reserve, Requirement R2 as of the effective date of BAL-003-1, Frequency Response and Frequency Bias
Setting, Requirement R1.
BAL Requirement R1 is not impacted by this project.
Language for Retirement
The language proposed for retirement is as follows:
R2.
Each Balancing Authority and each Reserve Sharing Group shall maintain at least half of
its minimum amount of Contingency Reserve identified in Requirement R1, as
This document has been updated to reflect the most recent WECC template. The document in its original format
is located on the WECC-0115 project page: https://www.wecc.org/Reliability/WECC0115%20Posting%201%20BAL-002-WECC-2%20Request%20to%20Retire%20R2%20-%2010-232015%20through%2012-8-2015.docx
2 BAL-003-1, Frequency Response and Frequency Bias Setting is approved by the Federal Energy Regulatory
Commission (March 24, 2014) and has an enforcement date of April 1, 2016.
1
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www. we cc.org
WECC-0115 BAL-002-WECC-2—Contingency Reserve—Request to Retire Requirement R2
Operating Reserve – Spinning that meets both of the following reserve characteristics.
[Violation Risk Factor: High] [Time Horizon: Real-time operations]
2.1
Reserve that is immediately and automatically responsive to frequency
deviations through the action of a governor or other control system;
2.2
Reserve that is capable of fully responding within ten minutes.
Background
On November 21, 2013 in Order 789, the Federal Energy Regulatory Commission (FERC) approved
WECC Regional Standard BAL-002-WECC-2 (the WECC BAL) with an Effective Date of October 1,
2014.
The WECC BAL applies to Balancing Authorities and Reserve Sharing Groups in the WECC Region
and is meant to specify the quantity (Requirement R1) and types (Requirement R2) of contingency
reserve required to ensure reliability under normal and disturbance conditions.
Requirement R1 requires the applicable entity to “maintain a minimum amount of Contingency
Reserve” whereas Requirement R2 requires that “at least half of [an entity’s] minimum amount of
Contingency Reserve identified in Requirement R1, as Operating Reserve – Spinning [must meet
specific] reserve characteristics.”
To qualify as Operating Reserve—Spinning, 3 the reserve maintained in accordance with Requirement
R2 must be:
•
Generation synchronized to the system and fully available to serve load [automatically] within
the Disturbance Recovery Period following the contingency event; or
•
Load fully removable from the system within the Disturbance Recovery Period following the
contingency event.
Intent of BAL-002-WECC-2, Requirement R2
The intent of Requirement R2 was to delineate “how” a reserve type must respond without creating a
definitive list of the types of reserve that might be used to meet the requirement. This intent was made
clear in the WECC-0115, BAL Drafting Team’s (DT) Guidance Document that included Frequently
Asked Questions (FAQ) regarding the development of the WECC BAL. There the drafting team noted
that in the absence of a frequency response standard the original WECC Minimum Operating
Reliability Criteria 4 (MORC) needed to have an element that was capable of arresting a frequency
excursion and supporting frequency during the recovery period.
See the definition of Operating Reserve contained in the NERC Glossary of Terms Used in NERC Reliability
Standards.
4 WECC Minimum Operating Reliability Criteria, April 6, 2005 (MORC).
3
2
WECC-0115 BAL-002-WECC-2—Contingency Reserve—Request to Retire Requirement R2
The drafting team noted at FAQ 11 5:
When the drafting team incorporated the FERC mandated [glossary] terms, it
determined that the definition for Contingency Reserve – Spinning did not require that
it be automatically responsive to frequency. To fill that void, the drafting team included
in the current version [of the WECC BAL] the historical WECC requirement that
spinning reserve must be automatically responsive proportionally to frequency
deviations. Parenthetically, this approach should also assuage some concerns that the
frequency component of the earlier Purpose statement is no longer offered.
The intent of Requirement R2 was to ensure that the right type of reserve was available specifically to
address frequency response.
Subsequent to the approval of the WECC BAL, FERC has approved BAL-003 specifically addressing
frequency response. The Purpose of BAL-003 is “to require sufficient Frequency Response” from
Balancing Authorities and Frequency Response Sharing Groups as specified in the Applicability section
of BAL-003. The frequency response component of the WECC BAL’s Requirement R2 is now covered in
BAL-003; the specific content of BAL-003 directly addresses the indirect and general content of the
WECC BAL, and the historical 6 premise for the WECC BAL no longer reflects the present-day granular
visibility from one Balancing Authority to another; therefore, the language of the WECC BAL’s
Requirement R2 should be retired. The reliability-related substance of the WECC BAL is provided for
by the frequency response performance components of BAL-003.
Requirement R2—Main Body
BAL-003 is a superior standard to the WECC BAL because BAL-003 is a result-based standard that
achieves the WECC BAL’s Requirement R2 reliability goal by requiring the applicable entity to perform
in accordance with a specified performance metric. By contrast, the WECC BAL has no stated
performance requirement or compliance metric associated with requirement2 and is measured solely
on documentation presented after-the-fact.
Retention of both WECC BAL Requirement R2 as well as BAL-003 Requirement R1 could lead to
confusion and the needless procurement of additional reserve, thereby increasing costs without benefit.
The WECC BAL’s Requirement R2 specifies procurement of Contingency Reserve, at least one half of
WECC-00083 BAL-002-WECC-1 (and 2), Guidance Document, presented to the industry in Posting 5 of the BAL
project and also provided as Attachment S as part of WECC’s filing to NERC/FERC that sought approval of the
BAL.
6 The language of the existing BAL is premised on the MORC that was originally drafted to address a 1970s-era
paradigm in which visibility, data exchange, and understanding of other Balancing Areas was minimal. During
that pre-standards era, frequency deviation was largely addressed by manual and analogue intervention, and
interaction between control areas was based on the premise of mutual cooperation not supported by regulatory
mandates.
5
3
WECC-0115 BAL-002-WECC-2—Contingency Reserve—Request to Retire Requirement R2
which must be comprised of Operating Reserve—Spinning. The intent of Requirement R2 is to have
reserve resources that both arrest and support frequency. BAL-003 meets the same reliability-related
goal without specifying the type of resource from which the outcome can be produced. If kept in
tandem the result could be that an entity procures a specific amount and type of reserve to meet the
WECC BAL and also procures a different and possibly superior resource to meet the separate
requirement of BAL-003. As a result, retirement of R2 will not create a reliability gap because BAL-003,
Requirement R1 meets the same need. Further, retirement of R2 could actually lower the cost of
reliability by eliminating the potential for redundant reserve procurement. 7
As illustrated in BAL-003, “how” frequency support is achieved need not be prescribed like it is in the
WECC BAL. Under the WECC BAL, the response must result from Operating Reserve – Spinning
provided in a specific quantity. As pointed out in the supporting documentation for BAL-003, the same
reliability-related goal can be met by any of the following: 1) Regulation services, 2) contract services, 3)
tariff arrangements, or 4) generator/load agreements. Since the goal of BAL-003, Requirement R1 is to
meet a Frequency Response Measure, by definition, Frequency Response can be obtained by either a
system or more discrete sub-elements of the system. There is no need to prescribe the specific stockpile
of resources as has been done in the WECC BAL’s Requirement R2. This position is in accord with that
of the BAL-003 drafting team. 8
Section 2.1
Requirement R2, Section 2.1 can be retired because it is already addressed in BAL-003. Requirement
R2.1 requires use of resources that are immediately and automatically responsive to frequency
deviations through the action of a governor or other control system. BAL-003, without specifying the
stockpile of resources, requires the applicable entity to meet a specific Frequency Response Measure
equal to or more negative than its Frequency Response Obligation.
Section 2.2
Requirement R2, Section 2.2 can be retired because it is already addressed in Requirement R2, Section
2.1. Section 2.1 requires the applicable entity to carry reserve “that is immediately and automatically
responsive to frequency.” Section 2.2 requires the applicable entity to carry reserves “capable of fully
responding within ten minutes.” Section 2.1’s immediate response-time renders the Section 2.2 ten-
A good contract for the acquisition of Frequency Response will provide “a method to evaluate the least cost mix
of resources necessary to provide the minimum required Frequency Response for maintain reliability. Finally, it
will provide the least complex method of evaluation considering the complexity and efficient of the acquisition
process.” NERC Frequency Response Standard Background Document, Frequency Response Costs – Supply Side,
page 20, November 2012.
8 NERC Frequency Response Standard Background Document, Methods of Obtaining Frequency Response, page
37, November 2012.
7
4
WECC-0115 BAL-002-WECC-2—Contingency Reserve—Request to Retire Requirement R2
minute response time moot. The drafting team notes the language is a carryover from the MORC and
should be updated through retirement.
Implementation Plan
In accordance with the Reliability Standards Development Procedures (Procedures), Step 5- Post for
Comment, “[a]n implementation plan shall be included in at least one iterative posting during the
development of the [Regional Reliability Standard] and shall be a part of the final record for
consideration prior to ballot.”
On May 6, 2015, WECC accepted a Standards Authorization Request (SAR) requesting retirement of
BAL-002-WECC-02, Contingency Reserve, Requirement R2.
The SAR is located at the Standards Authorization Request accordion of the WECC-0115 BAL-002WECC-2, Request to Retire Requirement R2 project page.
Procedural approvals are required from:
•
The WECC Standards Committee
•
The Ballot Pool
•
The WECC Board of Directors
•
The NERC Board of Trustees
•
The Federal Energy Regulation Commission
•
Other regulatory bodies as applicable
Proposed Effective Date
The WECC-0115, BAL Drafting Team is recommending retirement of BAL-002-WECC-2, Contingency
Reserve, Requirement R2 as of the effective date of BAL-003, Frequency Response and Frequency Bias
Setting, Requirement R1.
Justification of Effective Date
The reliability-related substance of WECC BAL’s Requirement R2 is contained in BAL-003. Because the
reliability task is addressed in BAL-003, once BAL-003 Requirement R1 is effective there will no longer
be a need for WECC BAL Requirement R2.
Impact on Other Standards
As to other existing and proposed standards, the drafting team notes that some confusion may arise as
to how the retirement of WECC BAL Requirement R2 may interplay with the existing BAL-002-1,
Disturbance Control Performance standard. BAL-002-1, Requirement R2.3 requires the applicable entity
(the Regional Reliability Organization “or” the Reserve Sharing group) to “specify its Contingency
Reserve policies, including…(R2.3.)…the permissible mix of Operating Reserve—Spinning and
5
WECC-0115 BAL-002-WECC-2—Contingency Reserve—Request to Retire Requirement R2
Operating Reserve—Supplemental that may be included in Contingency Reserve.” Arguably, BAL-002WECC-2, Requirement R2 meets this requirement.
The drafting team disagrees that retention of BAL-002-WECC-2, Requirement R2 is the only means of
compliance with BAL-002-1. At a high level, since BAL-002-1 has no Measure for the associated
Requirement R2, how compliance might be met is ethereal. Further, since the only Measure provided
requires that the Balancing Authority “or” the Reserve Sharing group “shall calculate and report
compliance with the Disturbance Control Standard” there is a decided disconnect between the required
performance (have a policy) and the required Measure (perform a calculation).
Consideration of Early Compliance
Retirement of WECC BAL Requirement R2 should not take place until the industry mandate to comply
with BAL-003-1 goes into place. Early retirement could create a reliability gap resulting from
insufficient reserves.
6
Attachment E5
Posting 1—Redline
WECC-0115 BAL-002-WECC-3
Contingency Reserve
Request to Retire R2
Not Used
Posting 1 asks only whether BAL-002-WECC-2a Contingency Reserve, Requirement R2 should be
deleted. No other language changes were proposed.
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www. we cc.org
Attachment E6
Posting 2—Clean
WECC-0115 BAL-002-WECC-3
Contingency Reserve
Request to Retire R2
Field Test Results
WECC-0115 BAL-002-WECC-2a
Request to Retire Requirement R2
Standard Drafting Team
March 5, 2019
Attachment E6
Executive Summary
After doing a field test from May 1, 2017, through April 30, 2018, the WECC-0115 BAL-002-WECC-2a,
Contingency Reserve, Request to Retire Requirement R2 Drafting Team (DT) concluded that if
Requirement R2 is retired, it is unlikely to have an adverse impact on reliability.
On May 6, 2015, WECC received Standard Authorization Request (SAR) WECC -0115 BAL-002-WECC 2a Contingency Reserve, Request to Retire Requirement R2 (R2) requesting retirement of R2 and its
compliance elements. The SAR stated that on April 1, 2016, R2 would become redundant to BAL-0031.1 Frequency Response and Frequency Bias Settings, Requirement R1.
From May 1, 2017, through April 30, 2018, WECC did a NERC-approved field test to find out the
impact on reliability if R2 was retired. 1 A compliance waiver for R2 was granted beginning on May 1,
2017 and ending on May 1, 2019.
WECC required U.S. entities to provide data on the quantity of reserve carried during the field test
period. This was done to enable WECC to see the impacts of the field test, as a condition to take part in
the field test, and to meet conditions from NERC in approving WECC’s request for a field test. The data
showed no adverse impact to reliability if R2 is retired.
Project WECC-0115 will not be balloted until this report is presented for review to the WECC Ballot
Pool and the requirements of the NERC Rules of Procedure, 6.3 Communication and Coordination for
All Types of Field Tests and Data Analyses have been met by NERC.
The field test was approved by NERC in late March 2017 and conducted per NERC Standards Processes Manual,
Section 6.2, Field Tests and Data Analysis for Validation of Requirement.
1
2
Attachment E6
Table of Contents
Introduction .............................................................................................................................................................4
Field Test Description ...........................................................................................................................................4
Data Source and Description .............................................................................................................................4
Field Test Analysis and Results...........................................................................................................................5
Data Description ..................................................................................................................................................6
DCS Event Field Test Data ........................................................................ Error! Bookmark not defined.
Figures
Table 1—DCS Event Field Test Data .................................................................................................................... 6
Figure 1—Table 2.1 from NERC 2018 State of Reliability Report, June 2018 ................................................ 10
Figure 2—A to B IFRM.......................................................................................................................................... 11
Figure 3—A to C IFRM ......................................................................................................................................... 12
Figure 4—Cn to C Ratio ........................................................................................................................................ 13
Figure 5—Table 2.2 from NERC 2018 Frequency Response Annual Analysis, November 2018 ............... 14
Figure 6—Cn to UFLS margin ............................................................................................................................. 14
3
Attachment E6
Introduction
On May 6, 2015, WECC received Standard Authorization Request (SAR) WECC-0115 BAL-002-WECC2a, Contingency Reserve requesting retirement of Requirement R2 (R2). The SAR was deemed
complete the same day. The SAR asserted that, on April 1, 2016, Requirement R2 would become
redundant to BAL-003-1.1, Requirement R1, Frequency Response and Frequency Bias Setting.
On June 23, 2015, the WECC Standards Committee (WSC) approved the SAR after vetting by the
WECC Operating Committee Steering Committee (OC; June 9, 2015) and the Joint Guidance Committee
(JGC; May 27, 2015).
From October 22 through December 8, 2015, the project was posted once for comment, during which
stakeholders were asked a question:
Do you agree that WECC Regional Standard BAL-002-WECC-2, 2 Contingency Reserve,
Requirement R2 should be retired as of the effective date of NERC Standard BAL-003-1 3 (BAL003), Frequency Response and Frequency Bias Setting, Requirement R1?
Three entities responded to the posting and were in favor of retirement. 4 After discussion with staff, the
DT and WECC staff 5 agreed that a field test should be done to gauge the impact of retiring R2.
A NERC-approved field test was done from May 1, 2017, through April 30, 2018. The field test data is
the foundation of this paper and was posted for comment as Posting 2 of this project. Posting 2
received three comments, one for retirement and two suggesting caution.
Field Test Description
Data Source and Description
The field test data was requested from each Balancing Authority (BA) and each Reserve Sharing Group
(RSG) subject to R2. Data was received by WECC through an online WECC portal.
The data request included the following information:
During this project, the BAL-002-WECC-2 designation changed to BAL-002-WECC-2a on January 24, 2017, in FERC
Docket No. RD17-3-000. The BAL-003-1 designation changed to BAL-003-1.1 on November 13, 2015, in FERC Docket
RD15-6-000.
2
BAL-003-1, Frequency Response and Frequency Bias Setting is approved by the FERC on March 24, 2014 and has an
enforcement date of April 1, 2016.
3
4
Xcel Energy, Bonneville Power Administration, and WECC.
Steven Rueckert, WECC Director of Standards, and Phil O’Donnell, WECC Manager, Operations and Planning Audits
and Investigations.
5
4
Attachment E6
1. For any reportable Disturbance Control Standard (DCS) event, the date and time of the event,
the required amount of Contingency Reserves at the time of the event, the actual amount of
Operating Reserves-Spinning at the time of the event, and the actual DCS performance. 6
2. For all instances of a loss of resources 700 MW or greater, whether it is a reportable DCS event
or not, the date and time of the event, the name of the resource(s), and the total MW loss.
Objective
The field test was designed to determine whether retirement of R2 would have any adverse impact on
grid reliability. The test examined the impact on Disturbance Control Standard (DCS7) performance
and frequency response in the Western Interconnection.
Overview
The first metric, DCS performance, monitored the performance of each RSG and each BA that was not a
member of an RSG, for every reportable DCS event, to see whether any were unable to meet the DCS
recovery period for a DCS event. More information was requested from the participants to calculate the
ratio for required contingency reserve to Operating Reserve-Spinning for each qualified event.
The second metric watched system performance for any loss of resources greater than 700 MW and for
any adverse impact on frequency response. 8 Data for this metric was collected using the same
information used by NERC to collect information to perform analysis on interconnection frequency
response analysis for the NERC State of Reliability and Frequency Response Annual Analysis reports.
Field Test Analysis and Results
BAL-002-WECC-2a, Requirement R2 was intended to do two things: 1) to aid in frequency recovery
(through governor action) for large generation loss events across the Western Interconnection, and 2) to
provide a part of the Contingency Reserves (on-line generation minus 10-minute response) for
generation trip events within the BA or RSG, if the party is an RSG member. With the implementation
of new standards and a change of generation resources in the Western Interconnection, the SAR was
based on the presumptions that BAL-002-WECC-2a, Requirement R2 became redundant as of the April
During the field test, only the DCS responsible entity was asked to provide data during DCS events. Entities that did
not have a reportable DCS event were not requested to provide data.
6
“The reliability standard that sets the time limit following a Disturbance within which a BA must return its Area
Control Error to within a specified range.” NERC Glossary of Terms Used in Reliability Standards (Glossary).
7
The DT noted that the WECC Interconnection Frequency Response Obligation (IFRO) is roughly -840 MW per 0.1 HZ.
The 700-MW loss was chosen as a more conservative number than the IFRO and represents a value large enough to
cause a significant frequency excursion. For an example, see Frequency Response Analysis Tool, Dmitry Kosterev,
Bonneville Power Administration, 2014. https://www.wecc.org/Reliability/Frequency%20Response%20Analysis%20%20Dmitry%20Kosterev.pdf
8
5
Attachment E6
1, 2016, effective date of BAL-003-1.1 Frequency Response and Frequency Bias Setting, and that, with its
retirement, neither interconnection frequency performance metrics nor DCS performance would
degrade.
With the implementation of BAL-003-01.1, frequency response became measurable, and the field test
gave entities a compliance waiver for WECC BAL-002-WECC-2a Requirement R2, thus splitting DCS
and frequency response. Entities were responsible for ensuring both reliability performance metrics
were met. On that basis, the data captured from the field test was used with interconnection frequency
response performance data to assess any impact to individual DCS performance as well as overall
interconnection frequency performance.
Data Description
Data from the field test covered 66 DCS events. During each of those events, entities provided data to
help assess DCS performance. This data included Contingency Reserve Obligation, Required Spin
(assuming no compliance waiver), Actual Spin, and whether Area Control Error recovery was met to
successfully pass the DCS event. See Table 1 for the data set collected.
Table 1—DCS Event Field Test Data
Entity #
Reported
MW Loss
DCS
Event
Contingency (Cont)
Reserve Obligation
Required
Spin
Actual
Spin
Pass(x)
Cont/Spin (PreContingency Value)
Entity 3
Entity 3
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 2
Entity 5
Entity 5
Entity 2
Entity 5
Entity 5
Entity 5
530
480
341
309
310
294
480
375
393
587
628
388
838
353
655
356
619
430
513
519
748
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
585
585
2624
2528
2830
2992
2349
3068
3106
2373
3124
3211
2988
3234
656
3646
3732
468
3514
2823
3688
293
293
1312
1264
1415
1496
1174.5
1534
1553
1187
1562
1606
1494
1617
328
1823
1866
234
1757
1412
1844
878
1165
5595
4095
4428
4010
4360
4986
3989
4483
4201
4217
4223
4658
552
5956
6193
417
6063
6001
6271
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
150.09%
199.15%
213.22%
161.99%
156.47%
134.02%
185.61%
162.52%
128.43%
188.92%
134.48%
131.33%
141.33%
144.03%
84.26%
163.36%
165.94%
89.11%
172.54%
212.58%
170.04%
6
Attachment E6
Entity #
Reported
MW Loss
DCS
Event
Contingency (Cont)
Reserve Obligation
Required
Spin
Actual
Spin
Pass(x)
Cont/Spin (PreContingency Value)
Entity 5
Entity 2
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 3
Entity 5
Entity 5
Entity 5
Entity 3
Entity 2
Entity 5
Entity 5
Entity 5
Entity 1
Entity 4
Entity 1
Entity 4
Entity 3
Entity 2
Entity 1
Entity 1
Entity 4
Entity 5
Entity 5
630
442
506
760
522
1061
411
1882
486
475
723
796
492
460
398
1150
1699
786
479
538
714
656
760
790
496
1046
493
651
388
851
970
1059
582
800
471
699
817
1026
850
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
3024
538
3610
3742
3612
3791
2964
2497
3536
3422
3006
3293
3174
5129
5614
5231
6028
5874
5155
585
5869
6090
5517
790
573
8090
7099
3351
1040
2181
1037
1175
790
565
1040
1041
1543
2832
2741
1512
269
1805
1871
1806
1896
1482
1249
1768
1711
1503
1647
1587
2565
2807
2616
3014
2937
2578
293
2935
3045
2759
395
286
4045
3550
1676
520
1091
519
588
395
283
520
521
772
1416
1371
6680
231
6703
6133
5698
6799
5358
4952
5855
6647
8401
5844
5111
9318
11920
13142
9288
9350
14798
1329
11056
14291
8679
1607
379
12613
12659
5962
979
1091
1151
600
924
234
1359
1426
768
6038
6543
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
220.90%
42.97%
185.68%
163.90%
157.75%
179.35%
180.77%
198.32%
165.58%
194.24%
279.47%
177.47%
161.03%
181.67%
212.33%
251.23%
154.08%
159.18%
287.06%
227.23%
188.38%
234.66%
157.31%
203.42%
66.15%
155.91%
178.32%
177.92%
94.13%
50.02%
110.99%
51.06%
116.96%
41.44%
130.67%
136.98%
49.77%
213.21%
238.71%
7
Attachment E6
Entity #
Reported
MW Loss
DCS
Event
Contingency (Cont)
Reserve Obligation
Required
Spin
Actual
Spin
Pass(x)
Cont/Spin (PreContingency Value)
Entity 5
Entity 1
Entity 5
Entity 5
Entity 1
Entity 4
660
500
506
707
322
866
Yes
Yes
Yes
Yes
Yes
Yes
2691
1040
3206
3056
1020
1186
1346
520
1603
1528
510
593
5911
1589
5893
5952
1454
672
x
x
x
x
x
x
219.66%
152.79%
183.81%
194.76%
142.55%
56.66%
All 66 events had a 100-percent pass rate showing no degradation to DCS performance. With the BAL002-WECC-2a R2 compliance waiver in effect, entities carried and deployed enough reserves for post
disturbance ACE recovery. Also, Spinning Reserve more than the required 50 percent was carried
during all but three events. Of the remaining 63, on average the entity was carrying 166.38 percent
Spinning Reserve as opposed to 50 percent Spinning Reserve required by the standard. In the
remaining three events, the entities carried an average of 5.3 percent less Spinning Reserve than
mandated. 9
Western Interconnection frequency performance was assessed to further determine the impact of the
field test on the Interconnection. Frequency performance data was collected for the 32 events having a
verified resource loss of more than 700 MW.
According to NERC, Essential Reliability Services (ERS) Measure 4 10 is a comprehensive set of
Frequency Response measures capturing speed of Frequency Response and response withdrawal at all
relevant time frames:
•
Point A to C frequency response in MW/0.1 Hz;
•
Point A to B frequency response in MW/0.1 Hz (similar to Adequate Level of Reliability (ALR)12);
•
C:B Ratio;
•
C:C’ Ratio; and
•
Three time-based measures: t0 to tC, tC to tC’, and t0 to tC’.
Figure 1 shows a frequency deviation due to a loss of generation resource and the methodology for
calculating frequency response. The event starts at time t0. Value A is the average frequency from t-16
to t-2 seconds, Point C is the lowest frequency point observed in the first 12 seconds, and Value B is the
This analysis does not speculate on why reporting entities carried more reserve than required. It only notes that excess
reserves were carried.
9
Please note that, although similar in title, NERC’s Essential Reliability Services (ERS) Measure 4 (page 8) is different from
NERC’s State of Reliability Report, Metric M-4 (page 9).
10
8
Attachment E6
average from t+20 to t+52 seconds. Point C’ occurs when the frequency after 52 seconds falls below
either the Point C (12 seconds) or average Value B (20–52 seconds), as illustrated below.
Figure 1—Frequency Deviation due to Loss of Generation Resource
Per the NERC State of Reliability Report, Metric M-4 has two parts of interest: 1) performance of the
Western Interconnection to arrest the frequency decline after a loss of generation event to prevent
activation of underfrequency load shedding (UFLS), and 2) performance of the Western
Interconnection to stabilize quickly at a high enough frequency to successfully respond to a second
frequency event, should one occur. 11
•
Arresting Period: In 2017, the Western Interconnection experienced an event in which the Point
C nadir was 59.697 Hz, resulting in a Point C to UFLS margin of 0.197 Hz, the smallest margin
since a 0.171-Hz event in 2014. The resource MW losses for these two events were 2,685 MW
and 2,826 MW, respectively. This is more than double the mean resource MW loss for each year
and larger than the Resource Contingency Criteria of 2,626 MW, which is defined in the 2016
NERC State of Reliability, June 2018, Appendix E: Frequency Response Statistics and Essential Reliability Services,
DADS Metric 4: Performance—Demand Response Events by Month—Dispatched vs. Realized, page 112.
https://www.nerc.com/pa/RAPA/PA/Performance%20Analysis%20DL/NERC_2018_SOR_06202018_Final.pdf
11
9
Attachment E6
Frequency Response Annual Analysis and used to calculate 2017 IFRO. Over the 2013–2017
operating years, the Western Interconnection trend was neither statistically improving nor
declining. This indicates that the BAL-002-WECC-2a field test did not adversely impact Western
Interconnection arresting period frequency performance.
•
Stabilizing Period: The mean frequency response in 2017 of 1,836 MW/0.1 Hz was the highest of
all years evaluated in this report. The Western Interconnection had no events in 2017 in which
its interconnection frequency response measure (IFRM) was below its IFRO, including the event
noted above, wherein the Point C nadir to UFLS margin was less than 0.200 Hz. Frequency
response over the 2013–2017 operating years indicated that the Western Interconnection
experienced significant improvement during the stabilizing period. This indicates that the BAL002-WECC-2a field test did not adversely impact Western Interconnection stabilizing period
frequency performance.
Figure 2—Table 2.1 from NERC 2018 State of Reliability Report, June 2018
Below is a summary of Western Interconnection frequency performance metrics:
1. A to B frequency response shows the effectiveness of primary frequency response in stabilizing
frequency after a large frequency excursion. This measure is the conventional means of
calculating Frequency Response as the ratio of net MW lost to the difference between Point A
and Point B frequency values.
10
Attachment E6
Figure 3—A to B IFRM
Western A to B IFRM
7000.00
y = 0.0353x + 125.21
6000.00
5000.00
4000.00
3000.00
2000.00
1000.00
0.00
1/1/16
4/10/16
7/19/16
10/27/16
2/4/17
5/15/17
8/23/17
12/1/17
3/11/18
6/19/18
9/27/18
An increasing trend indicates that frequency response is improving. The Western
Interconnection A to C metric shows no degradation.
For Example:
•
60.0 Hz pre-event (A frequency), Loss of 1,000 MW, 59.9 Hz primary frequency response
(B frequency)
o
•
A to B Measure = 1,000 MW/0.1 HZ
60.0 Hz pre-event (A frequency), Loss of 1,500 MW, 59.9 Hz primary frequency response
(B frequency)
o
A to B Measure = 1,500 MW/0.1 HZ
o
A to B measure increases, showing that larger loss of resource results in same
post-event disturbance
•
60.0 Hz pre-event (A frequency), Loss of 1,000 MW, 59.92 Hz primary frequency
response (B frequency)
o
A to B Measure = 1,250 MW/0.1 HZ
o
A to B measure increases, showing that the same loss in resource results in higher
post-event (primary frequency response measure)
11
Attachment E6
2. A to C frequency response shows the impacts of inertial response, load response (load
damping), and initial governor response. Governor response is triggered immediately after
frequency exceeds a pre-set deadband; however, depending on generator technology, full
governor response may require up to 30 seconds to be fully deployed. This measure is
calculated as the ratio of net megawatts lost to the difference between Point A and Point C
frequency values.
Figure 4—A to C IFRM
Western A to C IFRM
5,000
4,500
y = -0.0412x + 2603.2
4,000
3,500
3,000
2,500
2,000
1,500
1,000
500
0
1/1/16
4/10/16
7/19/16
10/27/16
2/4/17
5/15/17
8/23/17
12/1/17
3/11/18
6/19/18
9/27/18
An increasing trend indicates that frequency response is improving. The Western
Interconnection A to C metric shows no degradation.
For Example:
•
60.0 Hz pre-event (A frequency), Loss of 1000 MW, 59.85 Hz lowest frequency (C
frequency)
o
•
A to C Measure = 667 MW/0.1 HZ
60.0 Hz pre-event (A frequency), Loss of 1500 MW, 59.85 Hz lowest frequency (C
frequency)
o
A to C Measure = 1000 MW/0.1 HZ
o
A to C measure increases, representing that larger loss of resource results in same
post event disturbance
12
Attachment E6
•
60.0 Hz pre-event (A frequency), Loss of 1000 MW, 59.90 Hz lowest frequency (C
frequency)
o
A to C Measure = 1000 MW/0.1 HZ
o
A to C measure increases, representing that the same loss in resource results in
higher post event (primary frequency response measure)
3. Cn to C is the ratio between the absolute frequency minimum (Point Cn) caused by governor
withdrawal and the initial nadir (Point C). This metric measures withdrawal of primary
frequency response. A response greater than 1.0 indicates withdrawal. A declining trend is an
indication of improving primary frequency response. The Western Interconnection has shown
no indications of response withdrawal.
Figure 5—Cn to C Ratio
Western Cn to C Ratio
y = -2E-05x + 1.7112
16.0
14.0
12.0
10.0
8.0
6.0
4.0
2.0
0.0
10/23/15
1/31/16
5/10/16
8/18/16
11/26/16
3/6/17
6/14/17
9/22/17
When this white paper was drafted, Cn data was only publicly available through August 2017.
However, in addition to trended data, the NERC Frequency Response Annual Analysis,
published November 2018, also shows that the Western Interconnection continues to experience
no frequency response withdrawal during the BAL-002-WECC-2a field test.
13
Attachment E6
Figure 6—Table 2.2 from NERC 2018 Frequency Response Annual Analysis, November 2018
4. Cn to UFLS ratio measures the margin between the frequency nadir and the first step in UFLS.
Figure 7—Cn to UFLS margin
Western Cn to UFLS Margin
y = 5E-05x - 1.7346
0.600
0.550
0.500
0.450
Hz
0.400
0.350
0.300
0.250
0.200
0.150
1/1/16
4/10/16
7/19/16 10/27/16
2/4/17
5/15/17
8/23/17
12/1/17
3/11/18
6/19/18
9/27/18
The trend does show a statistical increase in UFLS margin. It should also be noted that the magnitude
of the resource loss has a direct impact on Interconnection performance calculation as measured by
IFRMs and Point C to UFLS margins. During 2017 and 2018, there were three events in which the
14
Attachment E6
resource loss was 2,776 MW, 2,685 MW, and 2741 MW; more than double the mean resource MW loss
for each year and larger than the defined Resource Contingency Criteria of 2,626 MW. 12
One event occurred on April 6, 2017, 11:00 p.m. PDT when the field test was not in effect and the other
two events on June 16, 2017, at 5:14 a.m. PDT and July 18, 2018, at 5:30 p.m. PDT when the field test
was in effect. All events, however, had comparable results and significant UFLS margin before and
after the field test. Also, all three events had an IFRM that exceeded the IFRO.
Per the WECC Off-Nominal Frequency Load Shedding Plan (UFLSP), load shedding occurs
sequentially in five blocks with a minimum separation of 0.1 Hz between steps. UFLS entities taking
part in the UFLS plan (aka, Coordinated Plan) are required to shed their first block of load as soon as
frequency has declined to 59.5 Hz. 13
See the 2017 Frequency Response Annual Analysis
https://www.nerc.com/comm/OC/Documents/2017_FRAA_Final_20171113.pdf#search=2017%20Frequency%20Respons
e%20Annual%20Analysis
12
“UFLS Entities participating in the Coordinated Plan are required to shed their first block of load as soon as frequency
has declined to 59.5 Hz, with additional minimum requirements for further load shedding steps” (as set forth in the
accompanying table).” WECC Off-Nominal Frequency Load Shedding Plan, Coordinated Plans, P. 1a, page 8,
December 5, 2012.
13
15
Attachment E6
WECC receives data used in its analyses from a wide variety of sources. WECC strives to source its data from reliable
entities and undertakes reasonable efforts to validate the accuracy of the data used. WECC believes the data contained herein
and used in its analyses is accurate and reliable. However, WECC disclaims any and all representations, guarantees,
warranties, and liability for the information contained herein and any use thereof. Persons who use and rely on the
information contained herein do so at their own risk.
16
Attachment E7
Posting 2 - Redline
WECC-0115 Contingency Reserve
Request to Retire Requirement R2
Field Test Results
BAL-002-WECC-22a
Retirement of Requirement R2
WECC-0115 BAL-002-WECC-22a
Request to Retire Requirement R2
Standard Drafting Team
January 14March 5, 2019
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114
Executive Summary1
After conducting a field test from May 1, 2017 through April 30, 2018, the WECC concluded there
would be no detrimental impact to the reliability of the Western Interconnection if -0115 BAL-002WECC-22a, Contingency Reserve, Request to Retire Requirement R2 were to beDrafting Team (DT)
concluded that if Requirement R2 is retired. , it is unlikely to result in any detrimental impact to
reliability.
On May 6, 2015, WECC received Standard Authorization Request (SAR) WECC -0115 BAL-002-WECC 22a Contingency Reserve, Request to Retire Requirement R2 (R2) requesting retirement of R2 and its
associated compliance elements (WECC BAL).. The SAR asserted that on April 1, 2016, R2 would become
redundant to BAL-003-1.1 Frequency Response and Frequency Bias Settings, Requirement R1 (NERC
BAL)..
From May 1, 2017 through April 30, 2018, WECC conducted a NERC-approved field test to determine
the impact on reliability in the event R2 was retired. 2 A compliance waiver for R2 was granted
beginning on May 1, 2017 and concluding on May 1, 2019.
To enable WECC to monitor the reliability impacts of the field test, as a condition to participation in the
field test, and to meet conditions specified by NERC in approving WECC’s request for a field test, WECC
required United States entities to provide specified information regarding the quantity of reserve
carried during the field test period. As seen in the following sections, that data showed no detrimental
impact to reliability in the event R2 is retired.
Project WECC-0115 will not be balloted until this report is presented for review to the appropriate
WECC Ballot Pool and the NERC requirements of the NERC Rules of Procedure, 6.3 Communication and
Coordination for All Types of Field Tests and Data Analyses have been met by NERC.
1
This document was updated to WECC’s newest template when Posting 2 was finalized. This document can be reviewed in
its original format at https://www.wecc.org/Reliability/WECC-0115%20Posting%202%20BAL-002-WECC2%20Request%20to%20Retire%20R2%20-%20Redlined%20in%20Response%20to%20Comments%203-1-2019.docx. Its
updated format is presented with this filing as WECC-0115 BAL-002-WECC3 – Contingency Reserve – Attachment E6 –
Posting 2 Clean.
2
The field test was approved by NERC in late March 2017 and conducted per NERC Standards Processes Manual, Section
6.2, Field Tests and Data Analysis for Validation of Requirement.
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Table of Contents
Introduction...................................................................................................................................... 1
Field Test Description ........................................................................................................................ 1
Field Test Analysis and Results .......................................................................................................... 3
DCS Event Field Test Data ....................................................................................................................... 3
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Introduction
On May 6, 2015, WECC received Standard Authorization Request (SAR) WECC-0115 BAL-002-WECC22a, Contingency Reserve requesting retirement of Requirement R2 (R2) of that standard. The SAR
was deemed complete the same day. The SAR asserted that on April 1, 2016, Requirement R2 would
become redundant to NERC BAL-003-1.1, Requirement R1, Frequency Response and Frequency Bias
Setting (NERC BAL)..
On June 23, 2015, the WECC Standards Committee (WSC) approved the SAR after a favorable vetting
by the WECC Operating Committee Steering Committee (OC; June 9, 2015) and the Joint Guidance
Committee (JGC; May 27, 2015).
From October 22 through December 8, 2015, the project was posted once for comment, during which
stakeholders were asked a single question:
Do you agree that WECC Regional Standard BAL-002-WECC-2 3, Contingency Reserve,
Requirement R2 should be retired as of the effective date of NERC Standard BAL-003-1 4 (BAL003), Frequency Response and Frequency Bias Setting, Requirement R1?
Three entities responded to the Posting and were in favor of retirement. 5 After discussion with WECC
staff 6, the DT and WECC staff were in accord that a field trial should be pursued to evaluate the impact
of retiring R2.
A NERC-approved field test was conducted from May 1, 2017 through April 30, 2018. The data from
that field test formed the foundation of this paper and was posted for comment, appearing as Posting
2 of this project. Posting 2 received three comments, one in favor of retirement and two suggesting
caution.
Field Test Description
Data Source and Description
3
Over the course of this project, the BAL-002-WECC-2 designation changed to BAL-002-WECC-2a on January 24, 2017 (FERC
Docket No. RD17-3-000. The BAL-003-1 designation changed to BAL-003-1.1 on November 13, 2015, in FERC Docket RD156-000.
4
BAL-003-1, Frequency Response and Frequency Bias Setting is approved by the Federal Energy Regulatory Commission
(March 24, 2014) and has an enforcement date of April 1, 2016.
5
Xcel Energy, Bonneville Power Administration, and the Western Electricity Coordinating Council (WECC)
6
Mr. Steven Rueckert, WECC Director of Standards and Mr. Phil O’Donnell, WECC Manager, Operations and Planning Audits
and Investigations
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The field test data was requested from each Balancing Authority and each Reserve Sharing Group
subject to Requirement R2 of the BAL. Data was received by WECC through an existing online WECC
portal for receipt of such reports.
The data requestedrequest included the following information:
1) For any reportable Disturbance Control Standard (DCS) event, the date and time of the event, the
required amount of Contingency Reserves at the time of the event, the actual amount of Operating
Reserves – Spinning at the time of the event, and the actual DCS performance. 7
2) For all instances of a loss of resources 700 MW or greater, whether it is a reportable DCS event or not,
the date and time of the event, the name of the resource(s), and the total MW loss.
Objective
The field test was designed to determine whether retirement of R2 would have any negative impact on
grid reliability. To make that determination, the test examined the impact on Disturbance Control
Standard (DCS 8) performance and frequency response within the Western Interconnection.
Overview
The first metric, DCS performance, monitored the performance of each Reserve Sharing Group (RSG)
and each Balancing Authority (BA) that was not a member of an RSG, for every reportable DCS event,
to determine whether any of the participants were unable to meet the DCS recovery period for a DCS
event. Additional information was requested from the participants to provide information to calculate
the ratio for required contingency reserve to Operating Reserve-Spinning for each qualified event.
The second metric watched system performance for any loss of resources greater than 700 MW and
watched for any negative impact on frequency response.9 Information for this metric was collected by
using the same information that is used by NERC to collect information to perform analysis on
interconnection frequency response analysis for the NERC State of Reliability and Frequency Response
Annual Analysis reports.
7
During the field test, data collection only the DCS responsible entity was required to provide data during DCS events.
Entities that did not have a reportable DCS event were not requested to provide data.
8
“The reliability standard that sets the time limit following a Disturbance within which a Balancing Authority must return its
Area Control Error to within a specified range.” NERC Glossary of Terms Used in Reliability Standards (Glossary)
9
The DT noted that the WECC Interconnection Frequency Response Obligation (IFRO) is roughly -840 MW per 0.1 HZ. The
700 MW loss was chosen as a more conservative number than the IFRO and represents a value suitably large to cause a
significant frequency excursion. For illustrative purposes only see Frequency Response Analysis Tool, Dmitry Kosterev,
Bonneville Power Administration, 2014. https://www.wecc.org/Reliability/Frequency%20Response%20Analysis%20%20Dmitry%20Kosterev.pdf
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Field Test Analysis and Results
BAL-002-WECC-22a, Requirement R2 was originally intended to accomplish two purposes: 1) aid in
frequency recovery (through governor action) for large generation loss events across the Western
Interconnection, and 2) provide a part of the Contingency Reserves (on -line generation minus 10minute response) for generation trip events within the BA or RSG, if the party is an RSG member. With
the implementation of new standards and an evolution of generation resources in the Western
Interconnection the rational of the Standards Authorization RequestSAR was based on the
presumptions that BAL-002-WECC-22a, Requirement R2 became redundant as of the April 1, 2016
effective date of BAL-003-1.1 Frequency Response and Frequency Bias Setting, and that with its
retirement neither interconnection frequency performance metrics nor Disturbance Control Standards
(DCS) performance would degrade.
With the implementation of NERC BAL-003-01.1, frequency responsive reserveresponse became a
measurable quantity, and the field test provided entities a compliance waiver for WECC BAL-002WECC-22a Requirement R2, thus decoupling DCS and frequency response. Entities were ultimately
responsible to ensure both reliability performance metrics were met. Based on thethat rational, the
data captured from the field test will iswas used in conjunction with interconnection frequency
response performance data to assess any impact to individual DCS performance as well as overall
interconnection frequency performance.
Data Description
Data received as part of the field test covered sixty-six66 DCS events. During each of those events,
entities were required to provide data to help assess DCS performance including: Contingency Reserve
Obligation, Required Spin (assuming no compliance waiver), Actual Spin, and whether ACEArea Control
Error recovery was met to successfully pass the DCS event. Reference “DCS Event Field Test Data”
below for the data set collected.
DCS Event Field Test Data
Entity #
Reported
MW Loss
DCS
Event
Entity 3
Entity 3
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
530
480
341
309
310
294
480
375
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
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Contingency
(Cont) Reserve
Obligation
585
585
2624
2528
2830
2992
2349
3068
L E C T R I C I T Y
Required
Spin
Actual
Spin
Pass(x)
Cont/Spin (PreContingency Value)
293
293
1312
1264
1415
1496
1174.5
1534
878
1165
5595
4095
4428
4010
4360
4986
x
x
x
x
x
x
x
x
150.09%
199.15%
213.22%
161.99%
156.47%
134.02%
185.61%
162.52%
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Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 2
Entity 5
Entity 5
Entity 2
Entity 5
Entity 5
Entity 5
Entity 5
Entity 2
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 5
Entity 3
Entity 5
Entity 5
Entity 5
Entity 3
Entity 2
Entity 5
Entity 5
Entity 5
Entity 1
Entity 4
W
393
587
628
388
838
353
655
356
619
430
513
519
748
630
442
506
760
522
1061
411
1882
486
475
723
796
492
460
398
1150
1699
786
479
538
714
656
760
790
496
1046
493
651
388
851
E S T E R N
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
E
3106
2373
3124
3211
2988
3234
656
3646
3732
468
3514
2823
3688
3024
538
3610
3742
3612
3791
2964
2497
3536
3422
3006
3293
3174
5129
5614
5231
6028
5874
5155
585
5869
6090
5517
790
573
8090
7099
3351
1040
2181
L E C T R I C I T Y
1553
1187
1562
1606
1494
1617
328
1823
1866
234
1757
1412
1844
1512
269
1805
1871
1806
1896
1482
1249
1768
1711
1503
1647
1587
2565
2807
2616
3014
2937
2578
293
2935
3045
2759
395
286
4045
3550
1676
520
1091
C
3989
4483
4201
4217
4223
4658
552
5956
6193
417
6063
6001
6271
6680
231
6703
6133
5698
6799
5358
4952
5855
6647
8401
5844
5111
9318
11920
13142
9288
9350
14798
1329
11056
14291
8679
1607
379
12613
12659
5962
979
1091
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
O O R D I N A T I N G
128.43%
188.92%
134.48%
131.33%
141.33%
144.03%
84.26%
163.36%
165.94%
89.11%
172.54%
212.58%
170.04%
220.90%
42.97%
185.68%
163.90%
157.75%
179.35%
180.77%
198.32%
165.58%
194.24%
279.47%
177.47%
161.03%
181.67%
212.33%
251.23%
154.08%
159.18%
287.06%
227.23%
188.38%
234.66%
157.31%
203.42%
66.15%
155.91%
178.32%
177.92%
94.13%
50.02%
C
O U N C I L
Entity 1
Entity 4
Entity 3
Entity 2
Entity 1
Entity 1
Entity 4
Entity 5
Entity 5
Entity 5
Entity 1
Entity 5
Entity 5
Entity 1
Entity 4
970
1059
582
800
471
699
817
1026
850
660
500
506
707
322
866
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
1037
1175
790
565
1040
1041
1543
2832
2741
2691
1040
3206
3056
1020
1186
519
588
395
283
520
521
772
1416
1371
1346
520
1603
1528
510
593
1151
600
924
234
1359
1426
768
6038
6543
5911
1589
5893
5952
1454
672
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
110.99%
51.06%
116.96%
41.44%
130.67%
136.98%
49.77%
213.21%
238.71%
219.66%
152.79%
183.81%
194.76%
142.55%
56.66%
All sixty-six66 events were passed successfully demonstrating a 100% percent pass rate and signaling
no degradation to DCS performance. With the BAL-002-WECC-22a R2 compliance waiver in effect,
entities carried and deployed sufficient reserves necessary for post disturbance ACE recovery.
Additionally, Spinning Reserve exceeding the required 50% percent was carried during all but three
events. Of the remaining 63 events, on average the entity was carrying 166.38% percent Spinning
Reserve as opposed 50% percent Spinning Reserve required by the standard. In the remaining three
events, the entities carried an average of 5.3% percent less Spinning Reserve than mandated. It can
only be speculation as to why entities were carrying greater than 50% Spinning Reserve during events
(Regulation, load ramping, renewable generation variability, Frequency Response). 10
Western Interconnection frequency performance was assessed to further determine the impact of the
field test on the Interconnection. Frequency performance data was collected for the 32 events having
a verified resource loss of more than 700 MW.
According to NERC, Essential Reliability Services (ERS) Measure 4 is a comprehensive set of frequency
response measures at all relevant time frames: Point A to C frequency response in MW/0.1 Hz, Point A
to B frequency response in MW/0.1 Hz (similar to Adequate levelLevel of Reliability (ALR) -12), C:B
Ratio, C:C’ Ratio as well as three time-based measures (t0 to tC, tC to tC’, t0 to tC’), capturing speed of
frequency response and response withdrawal. 11 The figure illustrates a frequency deviation due to a
loss of generation resource and the methodology for calculating frequency response. The event starts
at time t0. Value A is the average frequency from t-16 to t-2 seconds, Point C is the lowest frequency
10
This analysis does not speculate on why reporting entities carried more reserve than required. It only notes the empirical
fact that reserves in excess were indeed carried.
11
Please note that although similar in title, NERC’s Essential Reliability Services (ERS) Measure 4 (white paper page 5) is not
the same as NERC’s State of Reliability Report, Metric M-4 (page 6).
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C
O O R D I N A T I N G
C
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point observed in the first 12 seconds and Value B is the average from t+20 to t+52 seconds. Point C’
occurs when the frequency after 52 seconds falls below either the Point C (12 seconds) or average
Value B (20 – 52 seconds), as illustrated below.
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E S T E R N
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L E C T R I C I T Y
C
O O R D I N A T I N G
C
O U N C I L
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E S T E R N
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L E C T R I C I T Y
C
O O R D I N A T I N G
C
O U N C I L
Per the NERC State of Reliability Report, Metric M-4 has two components of primary interest: 1)
performance of the Western Interconnection to arrest the frequency decline after a loss of generation
event to prevent activation of Under Frequency Load Shedding, and 2) performance of the Western
Interconnection to stabilize quickly at a high enough frequency to successfully respond to a second
frequency event, should one occur. 12
•
Arresting Period: In 2017, the Western Interconnection experienced an event where the Point C
nadir was 59.697 Hz, resulting in a Point C to UFLS margin of 0.197 Hz, the smallest margin since
a 0.171 Hz event in 2014. The resource MW loss for these two events were 2,685 MW and
2,826 MW, respectively, more than double the mean resource MW loss for each year and larger
Resource Contingency Criteria of 2,626 MW defined in the 2016 Frequency Response Annual
Analysis and used to calculate 2017 Interconnection Frequency Response Obligation (IFRO).
Over the 2013–2017 operating years, the Western Interconnection trend was neither
12
NERC Sate of Reliability, June 2018, Appendix E: Frequency Response Statistics and Essential Reliability Services, DADS
Metric 4: Performance—Demand Response Events by Month—Dispatched vs. Realized, page 112.
https://www.nerc.com/pa/RAPA/PA/Performance%20Analysis%20DL/NERC_2018_SOR_06202018_Final.pdf
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C
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•
statistically improving nor declining. This indicates that the BAL-002-WECC-22a field test did
not adversely impact Western Interconnection arresting period frequency performance.
Stabilizing period: The mean frequency response in 2017 of 1,836 MW / 0.1 Hz was the highest
of all years evaluated in this report. The WI had no events in 2017 where its IFRM was below its
IFRO, including the event noted above where the Point C nadir to UFLS margin was less than
0.200 Hz. Frequency response over the 2013–2017 operating years indicated that the Western
Interconnection experienced statistically significant improvement during the stabilizing period.
This indicates that the BAL-002-WECC-22a field test did not adversely impact western
interconnection stabilizing period frequency performance
*NERC 2018 State of Reliability Report published June 2018
Below is a summary of Western Interconnection frequency performance metrics:
1) A to B frequency response captures the effectiveness of primary frequency response in
stabilizing frequency following a large frequency excursion. This Measure is the conventional
means of calculating Frequency Response as the ratio of net MW lost to the difference between
Point A and Point B frequency values.
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O O R D I N A T I N G
C
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Western A to B IFRM
7000.00
y = 0.0353x + 125.21
6000.00
5000.00
4000.00
3000.00
2000.00
1000.00
0.00
1/1/16
4/10/16
7/19/16 10/27/16
2/4/17
5/15/17
8/23/17
12/1/17
3/11/18
6/19/18
9/27/18
An increasing trend over time indicates that frequency response is improving. The Western
Interconnection A to C metric shows no degradation.
For Example:
o 60.0 Hz pre-event (A frequency), Loss of 1000 MW, 59.9 Hz primary frequency response
(B frequency)
A to B Measure = 1000 MW/0.1 HZ
o 60.0 Hz pre-event (A frequency), Loss of 1500 MW, 59.9 Hz primary frequency response
(B frequency)
A to B Measure = 1500 MW/0.1 HZ
A to B measure increases, representing that larger loss of resource results in
same post event disturbance
o 60.0 Hz pre-event (A frequency), Loss of 1000 MW, 59.92 Hz primary frequency
response (B frequency)
A to B Measure = 1250 MW/0.1 HZ
A to B measure increases, representing that the same loss in resource results in
higher post event (primary frequency response measure)
2) A to C frequency response captures the impacts of inertial response, load response (load
damping) and initial governor response (governor response is triggered immediately after
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C
O O R D I N A T I N G
C
O U N C I L
frequency exceeds a pre-set deadband; however, depending on generator technology, full
governor response may require up to 30 seconds to be fully deployed). This Measure is
calculated as the ratio of net megawatts lost to the difference between Point A and Point C
frequency values.
Western A to C IFRM
5,000
4,500
y = -0.0412x + 2603.2
4,000
3,500
3,000
2,500
2,000
1,500
1,000
500
0
1/1/16
4/10/16
7/19/16 10/27/16
2/4/17
5/15/17
8/23/17
12/1/17
3/11/18
6/19/18
9/27/18
An increasing trend over time indicates that frequency response is improving. The Western
Interconnection A to C metric shows no degradation.
•
W
Generic Example:
o 60.0 Hz pre-event (A frequency), Loss of 1000 MW, 59.85 Hz lowest frequency (C
frequency)
A to C Measure = 667 MW/0.1 HZ
o 60.0 Hz pre-event (A frequency), Loss of 1500 MW, 59.85 Hz lowest frequency (C
frequency)
A to C Measure = 1000 MW/0.1 HZ
A to C measure increases, representing that larger loss of resource results in
same post event disturbance
o 60.0 Hz pre-event (A frequency), Loss of 1000 MW, 59.90 Hz lowest frequency (C
frequency)
A to C Measure = 1000 MW/0.1 HZ
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C
O O R D I N A T I N G
C
O U N C I L
A to C measure increases, representing that the same loss in resource results in
higher post event (primary frequency response measure)
3) Cn to C is the ratio between the absolute frequency minimum (Point Cn) caused by governor
withdrawal and the initial nadir (Point C). This metric measures withdrawal of primary
frequency response. A response greater than 1.0 indicates withdrawal. A declining trend is an
indication of improving primary frequency response. The Western Interconnection has shown
no indications of response withdrawal.
Western Cn to C Ratio
y = -2E-05x + 1.7112
16.0
14.0
12.0
10.0
8.0
6.0
4.0
2.0
0.0
10/23/15
1/31/16
5/10/16
8/18/16
11/26/16
3/6/17
6/14/17
9/22/17
At the time of the draftingWhen this white paper was drafted, Cn data was only publicly available
through August 2017. However, in addition to trended data, the NERC Frequency Response Annual
Analysis published November 2018 also demonstrates the Western Interconnection has
continuedcontinues to not experience no frequency response withdraw during the time of the BAL002-WECC-22a Field Test.
*NERC 2018 Frequency Response Annual Analysis published November 2018
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C
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4) Cn to USLF ratio measures the margin between the frequency nadir and the first step in Under
Frequency Load Shed (UFLS).
Western Cn to UFLS Margin
y = 5E-05x - 1.7346
0.600
0.550
0.500
0.450
Hz
0.400
0.350
0.300
0.250
0.200
0.150
1/1/16
4/10/16 7/19/16 10/27/16 2/4/17
5/15/17 8/23/17 12/1/17 3/11/18 6/19/18 9/27/18
The trend does show a statistical increase in UFLS margin. It should also be noted that the magnitude
of the resource loss has a direct impact on Interconnection performance calculation as measured by
IFRMs and Point C to UFLS margins. During 2017 and 2018, there were three events where the
resource loss was 2,776 MW, 2,685 MW and 2741 MW, more than double the mean resource MW loss
for each year and larger than the defined Resource Contingency Criteria of 2,626 MW.13
One event occurred on April 6, 2017, 11:00 p.m. (Pacific) when the field test was not in effect and the
other two events on June 16, 2017 at 5:14 a.m. (Pacific) and July 18, 2018 at 5:30 p.m. (Pacific) when
the field test was in effect; however, all events had comparable results and significant UFLS margin
before and after the field test. Additionally, all three events had an interconnection frequency
response measure (IFRM) that exceeded the interconnection frequency response obligation (IFRO)).
13
See The 2017 Frequency Response Annual Analysis.
https://www.nerc.com/comm/OC/Documents/2017_FRAA_Final_20171113.pdf#search=2017%20Frequency%20Response
%20Annual%20Analysis
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Per the WECC Off Nominal Frequency Load Shedding Plan (UFLSP), load shedding occurs sequentially in
five blocks with a minimum separation between steps of 0.1 Hz. UFLS entities participating in the UFLS
plan (AKA: Coordinated Plan) are required to shed their first block of load as soon as frequency has declined
to 59.5 Hz. 14
Disclaimer
WECC receives data used in its analyses from a wide variety of sources. WECC strives to source its data
from reliable entities and undertakes reasonable efforts to validate the accuracy of the data used.
WECC believes the data contained herein and used in its analyses is accurate and reliable. However,
WECC disclaims any and all representations, guarantees, warranties, and liability for the information
contained herein and any use thereof. Persons who use and rely on the information contained herein
do so at their own risk.
14
“UFLS Entities participating in the Coordinated Plan are required to shed their first block of load as soon as frequency has
declined to 59.5 Hz, with additional minimum requirements for further load shedding steps” (as set forth in the
accompanying table).” WECC Off-Nominal Frequency Load Shedding Plan, Coordinated Plans, P. 1a, page 8, December 5,
2012.
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Attachment E8
Posting 1 Response to Comments
WECC-0115 Contingency Reserve
Request to Retire Requirement R2
Posting 11
The WECC-0115 BAL-002-WECC-2, Request to Retire Requirement R2 Drafting Team (DT) thanks
everyone who submitted comments on the proposed documents.
Posting
This project was posted for a 45-day public comment period from October 22 through December 8,
2015.
WECC distributed the notice for the posting on October 22, 2015. The DT asked stakeholders to provide
feedback on the proposed document through a standardized electronic template. WECC received
comments from three companies as shown in the following table.
Location of Comments
All comments received on the project can be viewed in their original format on the WECC-0115 project
page under the “Submit and Review Comments” accordion.
Changes in Response to Comment
After consideration of comments received, the DT took the following action:
No changes were made to the Posting 1 document.
After direct discussion with WECC staff commenters (Mr. Steven Rueckert and Mr. Phil O’Donnell),
the drafting team and WECC staff were in accord that a field trial should be pursued to evaluate the
impact of retirement of BAL-002-WECC-2, Requirement R2.
Effective Date
The effective date for this project is to be coincident with the effective date of BAL-003-1, Frequency
Response and Frequency Bias Setting, Requirement R1.
This document has been updated to WECC’s most recent document template. It can be viewed in its original
format at https://www.wecc.org/Reliability/WECC-0115%20Posting%201%20BAL-002-WECC2%20Retire%20R2%20-%20Response%20to%20Comments%2010-22%20through%2012-8-2015.docx.
1
155 Nort h 400 West | Suit e 200 | Salt Lake Cit y, Ut ah 84103
www. we cc.org
Attachment E8
BAL-003-1, Frequency Response and Frequency Bias Setting is approved by the Federal Energy
Regulatory Commission (March 24, 2014) and has an enforcement date of April 1, 2016.
Action Plan
On December 17, 2015, the WECC-0115 DT agreed by majority vote to pursue a field trial to determine
the potential effects of retiring BAL-002-WECC-2, Requirement R2. Mr. W. Shannon Black, WECC
Consultant, will draft and circulate the proposed trial for internal comment by the drafting team as
well as WECC Standards, Operations, and Compliance departments. The team will reconvene on
January 7, 2016, from 10:00 a.m. to 12:00 p.m. with the goal of finalizing the field trial proposal for
presentation to the NERC.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC
Consultant, at (503) 307-5782. In addition, there is a WECC Reliability Standards appeals process.
Commenter
Organization
1
William Franklin
Xcel Energy
2
Aaron Paulson
On Behalf of the Bonneville Power Administration
3
Steven Ashbaker
Western Electricity Coordinating Council (WECC)
Steven Rueckert
Phil O’Donnell
2
Attachment E8
Index to Questions, Comments, and Responses
Question
1. The drafting team welcomes comments on all aspects of the document.
3
Attachment E8
1. The drafting team welcomes comments on all aspects of the document.
Summary Consideration: See summary in the preamble of this document.
Commenter
Comment
William Franklin, Xcel Energy
Public Service Company of Colorado supports retirement of
BAL-002-WECC-2, Contingency Reserve, Requirement R2 as of
the effective date of BAL-003, Frequency Response and
Frequency Bias Setting, Requirement R1.
Lacking a better approach R2 served the Region well over the
past years and decades but it is now time to retire it. R2 was
intended to accomplish two purposes; aid in frequency
recovery (through governor action) for large generation loss
events across the WECC, and provide a part of the contingency
reserves (on line generation-10-minute response) for
generation trip events within the BA or RSG if party is a
member. However spinning reserve in R2 is somewhat vague
and has no performance-based compliance metric. R2 is
functionally replaced by BAL-003 for frequency recovery.
BAL-003 will serve this first purpose in a more straight
forward manner; response time, responsibility and compliance
metric are each well-defined and geared specifically to help the
interconnection recover frequency in a reliable manner. With
regard to the second purpose, local loss of generation, BAL002-WECC-2, without R2, will not be diluted. It will continue
to require the same total amount of contingency reserves, only
the somewhat vague requirement of carrying a 10-minute, 50
percent spinning reserve as part of the overall contingency
reserve will have been appropriately removed. With no
reduction in reliability retirement of R2 will remove sources of
possible confusion, and unsupportable overlap between R2
and BAL-003.
Thanks for the opportunity to comment.
Response
The drafting team thanks Xcel for its comments and its continued support in the standards
development process.
4
Attachment E8
Summary Consideration: See summary in the preamble of this document.
Commenter
Comment
Bonneville Power Administration
Comments on retirement of WECC BAL-002 R2
Answer to Survey:
BPA strongly supports that the requirement of WECC
Regional Standard BAL-002-WECC-2, Contingency Reserve,
Requirement R2, should be retired as of the effective date of
NERC Standard BAL-003-1 (BAL-003), Requirement R1.
BAL-003-1, Frequency Response and Frequency Bias Setting is
approved by the Federal Energy Regulatory Commission
(March 24, 2014) and has an enforcement date of April 1, 2016.
Comments:
With the retirement of WECC BAL-002 R2, and the adoption of
NERC BAL-003-01, frequency responsive reserve becomes a
measurable quantity and no longer needs to be covered within
a 50% spinning reserve requirement. BAL-003-01 is a more
applicable standard for measuring frequency response and
meets the original intent of WECC BAL-002 R2, which was put
in place because; it was, "in the absence of a frequency
response standard…capable of arresting a frequency
excursion." (WECC-0115 Posting 1).
With this in mind, BPA would like to provide some further
thoughts on the decision to retire WECC BAL-002 R2.
1. Outside of the technical aspects of frequency response, a
key reason to have the BAL-002 R2 standard retired as of
the effective date of NERC Standard BAL-003-01 relates to
comments made in WECC-0115 Posting 1, that states
"Retention of both WECC BAL Requirement R2 as well as
BAL-003 Requirement R1 could lead to confusion and the
needless procurement of additional reserve, thereby
increasing costs without benefit." BPA agrees fully that
multiple requirements to hold spinning reserve and also
meet FRO requirements, double up on the BA requirement
to meet the same goal.
5
Attachment E8
Summary Consideration: See summary in the preamble of this document.
Commenter
Comment
2. BPA agrees that BAL-003-01 FRM is a better indicator of
frequency response than a 50% spin requirement. While
BAL-003-001 provides a measure for frequency response, it
places no requirement on capacity that needs to be held by
a BA in order to meet the standard. This needs to be
determined by the BA planners/operators themselves,
using their knowledge of equipment capability. Without
other operational changes (adjusting plant controls,
governor tuning), a BA would need to maintain its current
level of spinning reserves to statistically maintain its
historical measures of frequency response in the short term.
Without other changes (i.e. tuning to plant controls,
governors, additional units) the lessening of spinning
reserve amounts would likely lessen statistical measures of
frequency response in WECC. With this in mind, BPA sees
that NERC BAL-003-01 is a better driver for BA's to study
their actual online frequency response capability, than
WECC BAL-002 R2.
3. The WECC standard was a good stop-gap for frequency
response with the absence of a NERC frequency response
standard. However, spinning reserve does not have a oneto-one correlation to frequency response. A good example
of this is a situation where a BA is carrying spinning
reserves on only a few generating units. The spinning
reserve requirement is met; however, the BA does not have
as much frequency response as if the spinning reserve was
carried on a greater number of responsive units. In order to
create a more accurate estimate of frequency response
capacity online, BPA is studying: the number of units
online, the max capacity of those units, current generation
of those units, governor droop, actual tests of unit
performance, and how much of governor response is met in
the 20-52 second measurement window defined in NERC
BAL-003-01.
6
Attachment E8
Summary Consideration: See summary in the preamble of this document.
Commenter
Comment
4. One more point BPA would like to make regarding
comments in WECC-0115 Posting 1, is in regards to the
statement that, "Requirement R2, Section 2.2 can be retired
because it is already addressed in Requirement R2, Section 2.1.
Section 2.1 requires the applicable entity to carry reserve 'that is
immediately and automatically responsive to frequency.' Section
2.2 requires the applicable entity to carry reserves 'capable of
fully responding within ten minutes.' Section 2.1's immediate
response-time renders the Section 2.2 ten-minute response time
moot. The drafting team notes the language is a carryover from
the MORC and should be updated through retirement." BPA
would like to point out that it is not a strong argument to
say that "Requirement R2, Section 2.2 can be retired because
it is already addressed in Requirement R2, Section 2.1,"
because section 2.1 is going to be retired as well. BPA
suggests that since Section 2.2 is a sub-requirement of R2,
with R2 retired then 2.2 would stand by itself and would
make the statement that 'Reserve must be capable of fully
responding within 10 minutes.' This 10-minute response is
already covered in Requirement R1, 1.4.
Response
The DT appreciates BPA’s support in the retirement of the Requirement. The DT also appreciates
BPA’s continued involvement in the standards development process.
Summary Consideration: See summary in the preamble of this document.
Commenter
Comment
WECC Staff
Thank you for the opportunity to provide comments on the
Steve Ashbaker:
WECC, [email protected]
Phil O'Donnell:
WECC, [email protected]
proposed retirement of BAL-002-WECC-2, Requirement R2.
We are concerned that the project to retire BAL-002-WECC-2,
Requirement R2 may be moving forward too fast, without the
proper evaluations being made prior to retirement.
It is our understanding that BAL-003 and Frequency Response
are characteristics of the first few seconds after a disturbance
7
Attachment E8
Summary Consideration: See summary in the preamble of this document.
Commenter
Comment
Steve Rueckert:
and are based on available on-line reserves, the associated
WECC, [email protected]
inertia of the on-line generation and the frequency dependency
of the load on line at the time. Contrarily, BAL-002 and BAL002-WECC-2 address contingency reserves, which are used to
restore ACE within 15 minutes of a disturbance.
There is no indication that a Frequency Response Measure
(FRM) that complies with the Requirements of BAL-003 will
ensure ACE will be restored in accordance with the
requirements of BAL-002 unless the amount of Responsive
Reserves required to comply with BAL-003 was equal to or
greater than the disturbance. BAL-003 was required due to the
systematic retirement of heavy thermal and large hydro and
the replacement with various types of low inertia and no
inertia resources.
We recognize that BAL-002-WECC-2 requires only half of the
total amount of contingency reserves to be online and
responsive to frequency, so that alone is not enough to ensure
compliance with the DCS requirement, and that it requires
operator intervention to meet DCS. However, we suspect that
Requirement R2 of BAL-002-WECC-2 is one of the major
contributors to WECC's relatively good frequency response
when compared to the Eastern Interconnection.
We question at this point how a Frequency Response Sharing
Group (FRSG) or Balancing Authority that is not part of a
FRSG will know how much on-line, responsive resources they
will need to meet the Requirements of BAL-003. We have some
concern that due to the monitoring process for BAL-003 and
entity may find out too late that they are going to be noncompliant.
For the reasons above we suggest a more cautious approach to
the potential retirement of BAL-002-WECC-2, Requirement R2
and offer two options for consideration. The first option is that
we do not retire BAL-002-WECC-2, Requirement R2 until at
least one year beyond the effective date of BAL-003. This
8
Attachment E8
Summary Consideration: See summary in the preamble of this document.
Commenter
Comment
would allow us to determine if the requirement is too
demanding, which would be demonstrated by responsible
entities greatly exceeding FRM compliance. If that were the
case, we could feel comfortable retiring Requirement R2. The
second option would be for WECC to seek a waiver of BAL002-WECC-2, Requirement R2 for at least a year so that we can
conduct a field trial to ensure that not keeping BAL-002WECC-2, Requirement R2 effective will not lead to a
substantial decrease in frequency response in the West.
Thank you for your consideration.
Response
WECC commenters (Mr. Steven Rueckert and Mr. Phil O’Donnell) were in attendance at the drafting
team meeting during which these comments were addressed. After a thorough discussion of the
above issues both the drafting team and the commenters were in accord that the concerns raised
could be addressed by pursuing a field trial to examine system performance in the absence of BAL002-WECC-2, Requirement R2.
The drafting team discussed the outline for the proposed trial and will target finalization of the
proposal when they reconvene. The proposal will be vetted with WECC Standards (Rueckert),
Operations (Ashbaker), and Compliance (O’Donnell). The primary WECC liaison is proposed to be
Mr. Tim Reynolds in his role as WECC staff liaison for the WECC Performance Work Group under
the WECC Operating Committee.
Commenters agreed that each of the sub-issues raised in their comments need not be addressed in
lieu of pursuing the proposed field trial.
9
Attachment E9
Posting 2 Response to Comments
WECC-0115 Contingency Reserve
Request to Retire Requirement R2
Posting 21
The WECC-0115 BAL-002-WECC-2a, Contingency Reserve, Request to Retire Requirement R2 Drafting
Team (DT) thanks everyone who submitted comments on the proposed document.
Posting
This project was posted for a 30-day public comment period from January 18 through February 18,
2019.
WECC distributed the notice for the posting on January 14, 2019. The DT asked stakeholders to provide
feedback on the proposed document through a standardized electronic template. Three comments were
received on this posting.
Location of Comments
All comments received on the project can be viewed in their original format on the WECC-0115 project
page under the “Submit and Review” accordion.
Changes in Response to Comment
After considering all comments received, the DT opted for the following changes:
The opening sentence of the executive summary is to read as follows:
After conducting a field test from May 1, 2017, through April 30, 2018, the WECC-0115 BAL002-WECC-2a, Contingency Reserve, Request to Retire Requirement R2 Drafting Team (DT)
concluded that if Requirement R2 is retired, it is unlikely to result in any detrimental impact to
reliability. (Emphasis added.)
The following sentence was added to the closing comment of the Introduction:
This document can be reviewed in its original format at https://www.wecc.org/Reliability/WECC0115%20Posting%202%20BAL-002-WECC-2%20Request%20to%20Retire%20R2%20%20Tech%20Editor%20Approved.docx.
1
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www. we cc.org
Attachment E9
The data from that field test formed the foundation of this paper and was posted for comment,
appearing as Posting 2 of this project. Posting 2 received three comments, one in favor of
retirement and two suggesting caution.
The following footnote regarding why the 700-MW threshold was used was added to the Overview:
The DT noted that the WECC Interconnection Frequency Response Obligation (IFRO) is roughly
-840 MW per 0.1 HZ. The 700 MW loss was chosen as a more conservative number than the
IFRO and represents a value suitably large to cause a significant frequency excursion. For
illustrative purposes only see Frequency Response Analysis Tool, Dmitry Kosterev, Bonneville
Power Administration, 2014.
https://www.wecc.org/Reliability/Frequency%20Response%20Analysis%20%20Dmitry%20Kosterev.pdf
The following footnote was added to the DCS Field Test section to highlight the DT’s lack of
speculation as to why the field test showed additional reserves carried or whether future results will be
the same:
This analysis does not speculate on why reporting entities carried more reserve than required. It
only notes the empirical fact that reserves in excess were indeed carried.
The following footnote was added to the DCS Field Test section to highlight the difference between to
similar terms:
Please note that although similar in title, NERC’s Essential Reliability Services (ERS) Measure 4
(white paper page 5) is not the same as NERC’s State of Reliability Report, Metric M-4 (page 6).
Although the following style changes were made, this document is still pending full review by the
WECC technical editor. Changes made include:
•
References updated from BAL-002-WECC-2 to BAL-002-WECC-2a, along with use of the full
reference in lieu of abbreviation.
•
References updated from BAL-003-1 to BAL-003-1.1, along with use of the full reference in lieu
of abbreviation.
Minority View
The DT opted not to include speculation as to why more reserves were carried than anticipated nor to
speculate as to whether future performance would replicate those amounts.
The DT disagreed with Powerex that retirement of Requirement R2: 1) was premature given the
present status of BAL-003-1.1 and 2) would make BAL-002-WECC-2a less stringent.
2
Attachment E9
The DT maintains that retirement of Requirement R2 is warranted because the requirement is
redundant to BAL-003-1.1. In its Posting 1, Response to Comments, the DT provided a detailed
explanation regarding this issue.
Effective Date
The effective date for this project is to be coincident with the effective date of BAL-003-1.1, Frequency
Response and Frequency Bias Setting, Requirement R1.
BAL-003-1.1, Frequency Response and Frequency Bias Setting is approved by the Federal Energy
Regulatory Commission (March 24, 2014) and has an enforcement date of April 1, 2016.
Justification of Effective Date
The reliability-related substance of WECC-0115 BAL-002-WECC-2a Contingency Reserve, Requirement
R2 is contained in BAL-003-1.1 Frequency Response and Frequency Bias, Requirement R1.
Because the reliability task is addressed in BAL-003-1.1 Requirement R1, BAL-002-WECC-2a
Requirement R2 is redundant and can be retired.
Impact on Other Standards
As to other existing and proposed standards, the drafting team notes that some confusion may arise as
to how the retirement of WECC-0115 BAL-002-WECC-2a, Requirement R2 may interplay with the
existing BAL-002-1, Disturbance Control Performance standard. BAL-002-1, Requirement R2.3 requires
the applicable entity (the Regional Reliability Organization or the Reserve Sharing group) to “specify its
Contingency Reserve policies, including … (R2.3) … the permissible mix of Operating Reserve –
Spinning and Operating Reserve—Supplemental that may be included in Contingency Reserve.”
Arguably, BAL-002-WECC-2a Requirement R2 meets this requirement.
The drafting team disagrees that retention of BAL-002-WECC-2a Requirement R2 is the only means of
compliance with BAL-002-1. At a high level, since BAL-002-1 has no Measure for the associated
Requirement R2, how compliance might be met is unclear. Further, since the only Measure provided
requires that the Balancing Authority or the Reserve Sharing group “shall calculate and report
compliance with the Disturbance Control Standard,” there is a disconnect between the required
performance (have a policy) and the required Measure (perform a calculation).
Consideration of Early Compliance
The DT sees no concerns with early compliance.
3
Attachment E9
Action Plan
On February 28, 2019, the WECC-0115 BAL-002-WECC-2a, Contingency Reserve, Request to Retire
Requirement R2 Drafting Team agreed by majority vote to forward the project to the WECC Standards
Committee (WSC) with a request for ballot. If approved, this project will retire Requirement R2 of that
standard on the premise that R2 is redundant to BAL-003-1.1 Frequency Response and Frequency Bias
Setting, Requirement R1.
A NERC-approved field test examining the potential impact on reliability if BAL-002-WECC-2a
Requirement R2 is retired was conducted from May 1, 2017, through April 30, 2018. The drafting team
examined the field test data including Disturbance Control Standard (DCS) performance and frequency
response within the Western Interconnection concluding that adequate reserve was available
throughout the period of the field test.
During the field test, a NERC-approved compliance waiver for Requirement R2 was in place. An
extension of that waiver has been requested to run through May 1, 2020. A response to that request is
pending.
The full project is available for review on the WECC website at the WECC-0115 homepage.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC
Consultant, at (503) 307-5782. In addition, there is a WECC Reliability Standards appeals process.
Commenter
Organization
1
Andrea Jessup
Bonneville Power Administration
2
Connor Curson
Powerex Corporation
3
Adrian Andreoiu
BC Hydro
4
Attachment E9
Index to Questions, Comments, and Responses
Question
1. The drafting team welcomes comments on all aspects of the document.
5
Attachment E9
1. The drafting team welcomes comments on all aspects of the document.
Summary Consideration: See summary in the preamble of this document.
Commenter
Comment
Andrea Jessup,
BPA supports the retirement of BAL-002-WECC-2. With the
Bonneville Power
implementation of BAL-003 the spinning reserve requirement of BAL-
Administration
002-WECC -2 has been shown to be an inappropriate and redundant
measure of frequency response. A frequency responsive resource
needs both capability and headroom to provide frequency response.
Although BAL-002-WECC -2 states that the spinning reserve must be
frequency responsive, it does not measure that frequency response nor
recognize that frequency response is measured in MW/tenths of a
Hertz, not MW's (e.g., a unit could say it provides a certain amount of
spin, but actually provides much less frequency response when
following governor droop).
Response
The drafting team appreciates Bonneville Power Administration’s longstanding commitment to the
WECC Standards and Criteria development process.
Commenter
Connor Curson, Powerex
Corp.
Comment
Powerex appreciates the opportunity to submit comments on WECC's
recently published White Paper, "Field Test Results BAL-002-WECC-2
Retirement of Requirement R2" (January 14, 2019).
The White Paper, and the field test reported within the White Paper,
was produced in response to a Standard Authorization Request (SAR)
for retirement of BAL-002-WECC-2 R2. The SAR asserted that BAL002-WECC-2 R2 would become redundant to BAL-003-1 Frequency
Response and Frequency Bias Settings, Requirement R1. In response,
the WECC conducted a NERC-approved field test to determine the
impact on reliability in the event BAL-002-WECC-2 R2 was retired.
The paper notes that the results of the field test indicate that "there
would be no detrimental impact to the reliability of the Western
Interconnection if BAL-002-WECC-2, Contingency Reserve,
Requirement R2 were to be retired." Powerex respectively submits
that the WECC should be cautious in making such an unequivocal
statement based on the field test results.
6
Attachment E9
Powerex does not dispute that the field test demonstrated that entities
carried and deployed sufficient reserves necessary for post
disturbance ACE recovery with the BAL-002-WECC-2 R2 compliance
waiver in effect across the field trial. However, in Powerex's view, the
field test does not demonstrate that BAL-003-1 R1, as currently
written, would render BAL-002-WECC-2 R2 redundant. This is due to
the differences in how the two requirements are drafted: BAL-002WECC-2 R2 is a prescriptive requirement that applies equally to all
entities and is applicable in all hours, whereas BAL-003-1 R1 is
an after-the-fact check that determines compliance based on an entity's
performance during its median event of the year. Under BAL-003-1 R1,
an entity could potentially carry less Frequency Response than its
Frequency Response Obligation ("FRO") for more than 40% of the
hours of the year, effectively leaning on other WECC entities, and still
be in compliance with the standard. If enough entities are acting in a
similar manner during a tail event (say, Q2, high wind), there may not
be sufficient Frequency Response to avoid Under-Frequency LoadShedding.
BAL-002-WECC-2 R2 provides a floor on the amount of unloaded,
synchronized generation (Spinning Reserve) that entities must carry in
every hour. The White Paper doesn't quantify the risk to Frequency
Response in the Western Interconnection of removing that floor. It
therefore seems premature to move forward with a plan to retire BAL002-WECC-2 R2 until a field test could demonstrate that the above
noted risk is insignificant, or, that BAL-003-1 can be revised to include
a focus on real-time Frequency Response such that having the extra
protection of a baseline Spinning Reserve requirement is no longer
required.
Finally, Powerex notes that NERC regularly seeks demonstration that
a replacement or retirement of a reliability standard results in a
more stringent standard, not a relaxation of standards. While Powerex
agrees in general that there should not be an unnecessary duplication
of standards or regulations, in this instance Powerex does not believe
unnecessary duplication exists.
Thank you for consideration of our comments and we look forward to
engaging on this topic in future meetings.
7
Attachment E9
Response
The drafting team appreciates Powerex’ observations and has changed the opening (and
corresponding) sentence of the executive summary as follows:
“After conducting a field test from May 1, 2017, through April 30, 2018, the WECC-0115 BAL002-WECC-2a, Contingency Reserve, Request to Retire Requirement R2 Drafting Team (DT)
concluded that if Requirement R2 is retired, it is unlikely to result in any detrimental impact to
reliability.” Emphasis added.
More Stringent
Generally, FERC will approve a Regional Reliability Standard (RRS) if the content of the RRS is
either more stringent than its NERC counterpart, or the RRS covers an area not addressed in the
NERC, continent-wide standard.
In June 2007, FERC approved WECC’s BAL-STD-002-0, Operating Reserves (BAL-002-WECC-2a’s
predecessor), noting two specific attributes that made that standard more stringent than its NERC
counterparts (NERC BAL-002 series of standards 2).
“The Commission stated that regional Reliability Standard BAL-STD-002-0 was more
stringent than the NERC Reliability Standard BAL-002-0 because the WECC regional
Reliability Standard required: (1) a more stringent minimum reserve requirement; and (2)
restoration of contingency reserves within 60 minutes, as opposed to the 90-minute
restoration period required by the NERC Reliability Standard BAL-002-0.1.” 3
More specifically, FERC found that WECC’s calculation of minimum contingency reserves and its 60minute restoration period were more stringent than that of NERC. 4 These two FERC-identified
Since the 2005 inception of the NERC BAL-002, Disturbance Control Performance series of standards, the
purpose of that NERC series has been to ensure that applicable entities could access and use sufficient
Contingency Reserves to balance resources and demand until Interconnection frequency returned to normal after
a disturbance. BAL-002-1, Disturbance Control Standard required applicable entities to have access to and operate
Contingency Reserves, specify reserve policies, activate sufficient reserves to meet Disturbance Control Standard
(DCS), and replace those reserves as needed. Successive versions of NERC’s BAL-002 series added the concept of
preparing for responding to Most Severe Single Contingency within a given period. BAL-002-2—Disturbance
Control Standard—Contingency Reserve for Recovery from a Balancing Contingency Event, Version 2 (FERC
Order approved BAL-002-2. Docket No. RM16-7-000) and Version 3 (Revisions to address two FERC directives
from Order No. 835, FERC Order approving BAL-002-3. Docket No. RD18-7-000).
2
3
FERC Order No. 789, C. WECC Regional Reliability Standard BAL-STD-002-0, Docket No. RM13-13-000.
Loc. Cit. See 1. Restoration Period for Contingency Reserve, paragraph 9 and 2. Calculation of Minimum Contingency
Reserve, paragraph 10.
4
8
Attachment E9
attributes are retained in BAL-002-WECC-2, Requirements R1, R3, and R4, wherein those
Requirements state:
•
“R1. Each [BA/RSG] shall maintain a minimum amount…”
•
“R3. Each [Sink BA/RSG] shall maintain an amount…”
•
“R4. Each [Source BA/RSG] shall maintain an amount…”
By contrast, Requirement R2 does not require maintenance of a specific amount of reserve; rather, R2
specifies the type or quality of reserve that must be carried. 5 This is a stated fraction of the amount of
reserve required in Requirement R1. Thus, retirement of Requirement R2 has no impact on the
calculation of the amount of reserves nor does it impact the 60-minute restoration period. As such,
Requirement R2 can be retired without BAL-002-WECC-2 becoming less stringent.
Redundancy
As to the issue of redundancy, the WECC-0115 DT addressed this issue in detail in its Posting 1
Response to Comments. 6 Further, the DT believes retirement of Requirement R2 meets the spirit of
FERC’s “P81 Order.” 7
In FERC’s November 2013 order approving BAL-002-WECC-2, Contingency Reserve, FERC noted “The regional
Reliability Standard applies to balancing authorities and reserve sharing groups in the WECC Region and is meant
to specify the quantity and types of contingency reserve required to ensure reliability under normal and abnormal
conditions.” FERC Order 789, Summary (Emphasis added).
5
WECC-0115 BAL-002-WECC-2, Contingency Reserve Drafting Team, Request to Retire Requirement R2, Posting
1 for 45-day Comment, October 23 through December 8, 2015, pages 2–4.
6
https://www.wecc.biz/Reliability/WECC-0115%20Posting%201%20BAL-002-WECC2%20Request%20to%20Retire%20R2%20-%2010-23-2015%20through%2012-8-2015.docx
7
Paragraph 81 (“P 81”) of the FFT Order reads:
“The Commission notes that NERC’s FFT initiative is predicated on the view that many violations of
requirements currently included in Reliability Standards pose lesser risk to the Bulk-Power System. If so, some
current requirements likely provide little protection for Bulk-Power System reliability or may be redundant. The
Commission is interested in obtaining views on whether such requirements could be removed from the
Reliability Standards with little effect on reliability and an increase in efficiency of the ERO compliance program.
If NERC believes that specific Reliability Standards or specific requirements within certain Standards should be
revised or removed, we invite NERC to make specific proposals to the Commission identifying the Standards or
requirements and setting forth in detail the technical basis for its belief. In addition, or in the alternative, we invite
NERC, the Regional Entities and other interested entities to propose appropriate mechanisms to identify and
remove from the Commission approved Reliability Standards unnecessary or redundant requirements. We will
not impose a deadline on when these comments should be submitted, but ask that to the extent such comments
are submitted NERC, the Regional Entities, and interested entities coordinate to submit their respective comments
concurrently.” North American Electric Reliability Corporation, 138 FERC ¶ 61,193 at P 81 (2012) (“FFT Order”).
9
Attachment E9
Retaining Requirement R2 offers little to no added benefit to reliability because the intent of R2 was
to ensure that reserve assets have specific response attributes. These are the same attributes called for
in BAL-003-1.1. 8
Commenter
Comment
Adrian Andreoiu and
BC Hydro greatly appreciates the drafting team's efforts to conduct
Tony Nguyen,
the field test and compile the results, and offers the following
BC Hydro
comments on the January 14, 2019 version of the "Field Test Results
BAL-002-WECC-2 Retirement of Requirement R2" report.
The first paragraph of the Executive Summary (page 1) states that
"WECC concluded there would be no detrimental impact to the
reliability of the Western Interconnection if BAL-002-WECC-2,
Contingency Reserve, Requirement R2 were to be retired." BC Hydro
recommends that this sentence be re-worded to account for the fact
that the observed DCS recovery performance was recorded where, for
63 out of 66 events, the actual Spinning Reserves carried by the
responsible entities were far greater than the 50% requirement.
Without a clear comparison with the status prior to the Field Test, in
terms of actual Spinning Reserves being carried, it seems that there is
not enough support for such an unequivocal statement. A well-placed
phrase such as "it appears that…" or "unlikely to cause…" might be
more appropriate.
In the Overview section (page 2) it may be helpful to clearly express
that data used for demonstrating impacts on Frequency Response
cover a period wider than the Field Test period for which the impacts
on DCS Recovery is observed. As drafted, readers will have to look
into details of each frequency response analysis graph to realize that
fact.
The statement in the last paragraph on page 2, "With the
implementation of NERC BAL-003-01, frequency responsive reserve
became a measurable quantity," should be clarified that only the
In its order remanding BAL-002-WECC-1, FERC called for WECC to broaden the specified criteria of the
equipment used to meet the requirement so that a broader range of reserve assets might be included. FERC Order
740, paragraphs 60–62, Docket No. RM09-15-000. FERC Order 789, paragraph 48.
8
10
Attachment E9
Frequency Response is measured for BAL-003-1, not Frequency
Responsive Reserve.
BC Hydro recommends expanding the last sentence of the first
paragraph on page 5 into a separate paragraph to further substantiate
whether the drafting team has reasons to believe that even after the
retirement of the requirement R2 of BAL-002-WECC-2 the entities will
continue to carry high level of Spinning Reserve, potentially by
operating their system in manners that satisfy other objectives, be it
environmental, economic or reliability standard compliance
(particularly if a direct link to BAL-003-1 R1 can be made).
BC Hydro suggests revising the last paragraph on page 5 to indicate
that the ALR-12 Metric has been renamed to Metric M-4. This Metric
M-4 is one of the metrics monitored by the NERC Performance
Analysis Subcommittee (PAS) and is different than ERS Measure 4. If
this paragraph about ERS Measure 4 is to be retained, some
background info should be included to explain the difference between
Metric M-4 and ERS Measure 4 to avoid confusion. It may not be
necessary to retain this paragraph since it appears that all of the
analysis that followed were extracted from the NERC Frequency
Response Annual Analysis and NERC State of Reliability Reports and
were performed for Metric M-4. If that is confirmed, BC Hydro
suggests removing this entire paragraph to avoid confusion.
Thank you for the opportunity to comment.
Response
The DT agrees that there are rarely certainties in future-looking analysis. As such, the tenor of the
conclusion has been redrafted. Please see the above response to Powerex.
As to adding an explanation regarding why excess reserves were carried during any specific period
or by any specific entity, or whether future results will be the same as the history field test, the DT
would only be speculating as to the past and future motives of each entity. Thus, the DT opted not to
venture a guess in its analysis. That said, there is a near certainty that some hydro-based entities will
always carry large amounts of reserve due to the nature of the asset, such as water behind the dam.
As to modification of the second full paragraph of page five regarding Essential Reliability Services
(ERS) Measure 4, the DT opted to retain the paragraph as it illuminates the analysis and illustrations
that follow thereafter. The following footnote was added to aid in clarity:
11
Attachment E9
“Please note that although similar in title, NERC’s Essential Reliability Services (ERS) Measure 4 (white
paper page 5) is not the same as NERC’s State of Reliability Report, Metric M-4 (page 6).”
As to editorial modification of the Overview section to include greater detail, the DT opted not to
adopt the suggestion, concluding the draft as presented sufficiently conveyed the message.
In the first sentence of page five, the word “reserve” was deleted from the phrase “frequency
response reserve.” The resulting sentence is as follows:
“With the implementation of NERC BAL-003-01.1, frequency response reserve became a measurable
quantity, and the field test provided entities a compliance waiver for WECC BAL-002-WECC-2a
Requirement R2, thus decoupling DCS and frequency response.”
12
Attachment E10
Minority Issues
WECC-0115 BAL-002-WECC-3
Contingency Reserve
Request to Retire R2
Minority Issues
Posting 1
In Posting 1, there were no minority issues; however, after direct discussion with WECC staff (Mr.
Steven Rueckert and Mr. Phil O’Donnell), the drafting team (DT) concluded that a field trial should be
pursued to evaluate the effects of retiring BAL-002-WECC-2a, Requirement R2. 1 After conducting the
field test, the drafting team concluded that retirement of BAL-002-WECC-2a Contingency Reserve,
Requirement R2 “is unlikely to result in any detrimental impact to reliability.” 2
Posting 2
In Posting 2, the DT opted not to include speculation as to why more reserves were carried than
anticipated, nor to speculate as to whether future performance would replicate those amounts.
The DT disagreed with Powerex that retirement of BAL-002-WECC-2a, Requirement R2 was premature
given the present status of BAL-003-1.1. The DT maintained that retirement of Requirement R2 is
warranted because the requirement is redundant to BAL-003-1.1. In its Posting 1, Response to
Comments, the DT gave a detailed explanation regarding this issue.
Balloting Comments
During balloting, British Columbia Hydro and Power Authority abstained from ballot but gave the
following narrative, echoing the Posting 2 minority position held by Powerex:
BAL-002-WECC-2 R2 requirement to carry spinning reserves in all hours could provide
improved frequency response. The retirement of this requirement may result in Western
The naming nomenclature changed during development from BAL-002-WECC-2, BAL-002-WECC-2a, and will
change to BAL-002-WECC-3 if approved.
1
Field Test Results, BAL-002-WECC-2 Retirement of Requirement R2, Executive Summary. See also Exhibit C and
Attachment E8. These documents can be reviewed in their original format on the WECC-0115 project page located
at https://www.wecc.org/Standards/Pages/WECC-0115.aspx.
2
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Attachment E11
entities’ diminished frequency response performance that may not be alleviated by the current
BAL-003-1.1 standard, which is under review and development under NERC Standards
Development Project 2017-01.
BC Hydro recommends that the retirement of this requirement be coordinated with the revision
of the BAL-003-1.1 Frequency Response and Frequency Bias Setting.
2
Attachment E11
Ballot Pool Members
WECC-0115 BAL-002-WECC-3
Contingency Reserve
Request to Retire R2
Ballot Pool Members
Project
Entity
Segment
Vote
Comment
Name
WECC-0115
British
Columbia
Hydro &
Power
Authority
Electric
Generators
Abstain
BAL-002-WECC-2 R2
requirement to carry spinning
reserves in all hours could
provide improved frequency
response. The retirement of
this requirement may result in
Western entities’ diminished
frequency response
performance that may not be
alleviated by the current BAL003-1.1 standard, which is
under review and
development under NERC
Standards Development
Project 2017-01.
Adrian
Andreoiu
BC Hydro recommends that
the retirement of this
requirement be coordinated
with the revision of the BAL003-1.1 Frequency Response
and Frequency Bias Setting.
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Attachment E11
Project
Entity
Segment
Vote
Comment
Name
WECC-0115
British
Columbia
Hydro &
Power
Authority
Transmission
Dependent
Utilities (TDU)
Abstain
BAL-002-WECC-2 R2
requirement to carry spinning
reserves in all hours could
provide improved frequency
response. The retirement of
this requirement may result in
Western entities’ diminished
frequency response
performance that may not be
alleviated by the current BAL003-1.1 standard, which is
under review and
development under NERC
Standards Development
Project 2017-01.
Adrian
Andreoiu
BC Hydro recommends that
the retirement of this
requirement be coordinated
with the revision of the BAL003-1.1 Frequency Response
and Frequency Bias Setting.
WECC-0115
British
Columbia
Hydro &
Power
Authority
Transmission
Owners
Abstain
BAL-002-WECC-2 R2
requirement to carry spinning
reserves in all hours could
provide improved frequency
response. The retirement of
this requirement may result in
Western entities’ diminished
frequency response
performance that may not be
alleviated by the current BAL003-1.1 standard, which is
under review and
development under NERC
Standards Development
Project 2017-01.
Adrian
Andreoiu
BC Hydro recommends that
the retirement of this
requirement be coordinated
with the revision of the BAL003-1.1 Frequency Response
and Frequency Bias Setting.
2
Attachment E11
Project
Entity
Segment
Vote
Comment
Name
WECC-0115
British
Columbia
Hydro &
Power
Authority
Load-Serving
Entities (LSE)
Abstain
BAL-002-WECC-2 R2
requirement to carry spinning
reserves in all hours could
provide improved frequency
response. The retirement of
this requirement may result in
Western entities’ diminished
frequency response
performance that may not be
alleviated by the current BAL003-1.1 standard, which is
under review and
development under NERC
Standards Development
Project 2017-01.
Adrian
Andreoiu
BC Hydro recommends that
the retirement of this
requirement be coordinated
with the revision of the BAL003-1.1 Frequency Response
and Frequency Bias Setting.
WECC-0115
Southern
California
Edison
Company
Load-Serving
Entities (LSE)
Abstain
No comments.
Romel
Aquino
WECC-0115
Tacoma Power
Transmission
Dependent
Utilities (TDU)
Yes
0
John
Nierenberg
WECC-0115
Seattle City
Light
Transmission
Dependent
Utilities (TDU)
Yes
0
Hao Li
WECC-0115
Tacoma Power
Electric
Generators
Yes
0
Karen
Hedlund
WECC-0115
Platte River
Power
Authority
Transmission
Owners
Yes
0
Matthew
Thompson
WECC-0115
Tacoma Power
Load-Serving
Entities (LSE)
Yes
0
Twila Hofer
WECC-0115
Bonneville
Power
Administration
Transmission
Owners
Yes
0
Kammy
RogersHolliday
3
Attachment E11
Project
Entity
Segment
Vote
Comment
Name
WECC-0115
Bonneville
Power
Administration
Load-Serving
Entities (LSE)
Yes
0
Rebecca
Berdahl
WECC-0115
Western Area
Power
Administration
Electricity
Brokers,
Aggregators,
and Marketers
Yes
0
Timothy
Vigil
WECC-0115
Bonneville
Power
Administration
Electricity
Brokers,
Aggregators,
and Marketers
Yes
0
Andrew
Meyers
WECC-0115
California
Independent
System
Operator
Regional
Transmission
Organizations
(RTOs) and
Independent
System
Operators
(ISO)
Yes
0
Richard
Vine
WECC-0115
Puget Sound
Energy, Inc.
Electric
Generators
Yes
0
Theresa
Rakowsky
WECC-0115
Puget Sound
Energy, Inc.
Load-Serving
Entities (LSE)
Yes
0
Theresa
Rakowsky
WECC-0115
Puget Sound
Energy, Inc.
Transmission
Owners
Yes
0
Theresa
Rakowsky
WECC-0115
Los Angeles
Department of
Water and
Power
Transmission
Owners
Yes
0
Pjoy Chua
WECC-0115
Los Angeles
Department of
Water and
Power
Load-Serving
Entities (LSE)
Yes
0
Pjoy Chua
WECC-0115
Los Angeles
Department of
Water and
Power
Electricity
Brokers,
Aggregators,
and Marketers
Yes
0
Pjoy Chua
4
Attachment E11
Project
Entity
Segment
Vote
Comment
Name
WECC-0115
Los Angeles
Department of
Water and
Power
Electric
Generators
Yes
0
Pjoy Chua
WECC-0115
Arizona Public
Service
Company
Load-Serving
Entities (LSE)
Yes
0
Vivian Vo
WECC-0115
Arizona Public
Service
Company
Electric
Generators
Yes
0
Kelsi Rigby
WECC-0115
Arizona Public
Service
Company
Electricity
Brokers,
Aggregators,
and Marketers
Yes
0
Chinedu
Ochonogor
WECC-0115
Arizona Public
Service
Company
Transmission
Owners
Yes
0
Michelle
Amarantos
WECC-0115
Public Utility
District No. 1
of Chelan
County
Electric
Generators
Yes
0
Meaghan
Connell
WECC-0115
Public Utility
District No. 1
of Chelan
County
Transmission
Owners
Yes
0
Meaghan
Connell
WECC-0115
Public Utility
District No. 1
of Chelan
County
Load-Serving
Entities (LSE)
Yes
0
Meaghan
Connell
WECC-0115
Public Utility
District No. 1
of Chelan
County
Electricity
Brokers,
Aggregators,
and Marketers
Yes
0
Meaghan
Connell
WECC-0115
Puget Sound
Energy, Inc.
Electric
Generators
Yes
0
Eleanor
Ewry
WECC-0115
Platte River
Power
Authority
Load-Serving
Entities (LSE)
Yes
0
Jeff Landis
5
Attachment E11
Project
Entity
Segment
Vote
Comment
Name
WECC-0115
Platte River
Power
Authority
Electricity
Brokers,
Aggregators,
and Marketers
Yes
support the retirement of
BAL-002-WECC-2a,
Requirement R2 on the
premise that R2 is redundant
to BAL-003-1.1 Frequency
Response and Frequency Bias
Setting. We are at the end of a
2 year field trial and have
found no degradation in
reliability in general and also
none specific to BAL-002 or
BAL-003 performance.
Sabrina
Martz
WECC-0115
Platte River
Power
Authority
Electric
Generators
Yes
0
Tyson
Archie
WECC-0115
Idaho Power
Company
Electricity
Brokers,
Aggregators,
and Marketers
0
0
Laura
Nelson
WECC-0115
Idaho Power
Company
Load-Serving
Entities (LSE)
0
0
Laura
Nelson
WECC-0115
Idaho Power
Company
Electric
Generators
0
0
Laura
Nelson
WECC-0115
Idaho Power
Company
Transmission
Owners
0
0
Laura
Nelson
6
Attachment E12
Ballot Pool Results
WECC-0115 BAL-002-WECC-3
Contingency Reserve
Request to Retire R2
Ballot Name:
WECC-0115 BAL-002-WECC-2a Contingency Reserve—Retirement of R2
Overview:
This project proposed to retire BAL-002-WECC-2a, Requirement R2 on the
premise that R2 is redundant to BAL-003-1.1 Frequency Response and Frequency
Bias Setting. The drafting team’s position is supported by a white paper located
on the WECC-0115 project page at the Posted for Comment accordion. A NERCapproved field test examining the potential impact on reliability if R2 is retired
was conducted from May 1, 2017, through April 30, 2018.
Ballot Pool Open:
03/11/2019
Ballot Pool Closed:
03/26/2019
Ballot Opened:
03/28/2019
Ballot Closed:
04/11/2019
Total Ballot Pool:
38
Total Votes:
34
Quorum:
89.5%
Weighted Votes:
100%
Ballot Results:
Pass
Voting Sectors
Transmission Owners
Regional Transmission
Organizations (RTO) and
Independent System
Operators (ISO)
Load-Serving Entities (LSE)
Transmission Dependent
Utilities (TDU)
Electric Generators
Electricity Brokers,
Aggregators, and
Marketers
Large Electricity End Users
Small Electricity Users
Federal, State, Provincial
Regulatory, other Gov.
Entities
Regional Entities
Totals
Total in
Ballot
Pool
Votes
NonAbstain
Sector
Weight
Yes
Votes
Weighted
Segment
Vote
No
Votes
8
6
0.6
6
60.0%
1
10
1
7
0.1
0.7
1
7
3
9
2
7
0.2
0.7
7
0
0
6
0
0
0
0
38
In-Pool
Affiliates
Excluded
0
Abstain
Total
Votes for
Quorum
Did
Not
Vote
0
1
7
1
10.0%
70.0%
0
0
0
2
1
9
0
1
2
7
20.0%
70.0%
0
0
1
1
3
8
0
1
0.6
0
0
6
0
0
60.0%
0.0%
0.0%
0
0
0
0
0
0
6
0
0
1
0
0
0
0
0
0
0
0
0.0%
0.0%
0
0
0
0
0
0
0
0
29
2.9
29
100.0%
0
5
34
4
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Attachment E12
Project
Entity
Segment
Vote
Comment
Name
WECC-0115
British
Columbia
Hydro &
Power
Authority
Electric
Generators
Abstain
BAL-002-WECC-2 R2
requirement to carry spinning
reserves in all hours could
provide improved frequency
response. The retirement of
this requirement may result in
Western entities’ diminished
frequency response
performance that may not be
alleviated by the current BAL003-1.1 standard, which is
under review and
development under NERC
Standards Development
Project 2017-01.
Adrian
Andreoiu
BC Hydro recommends that
the retirement of this
requirement be coordinated
with the revision of the BAL003-1.1 Frequency Response
and Frequency Bias Setting.
WECC-0115
British
Columbia
Hydro &
Power
Authority
Transmission
Dependent
Utilities (TDU)
Abstain
BAL-002-WECC-2 R2
requirement to carry spinning
reserves in all hours could
provide improved frequency
response. The retirement of
this requirement may result in
Western entities’ diminished
frequency response
performance that may not be
alleviated by the current BAL003-1.1 standard, which is
under review and
development under NERC
Standards Development
Project 2017-01.
Adrian
Andreoiu
BC Hydro recommends that
the retirement of this
requirement be coordinated
with the revision of the BAL003-1.1 Frequency Response
and Frequency Bias Setting.
2
Attachment E12
Project
Entity
Segment
Vote
Comment
Name
WECC-0115
British
Columbia
Hydro &
Power
Authority
Transmission
Owners
Abstain
BAL-002-WECC-2 R2
requirement to carry spinning
reserves in all hours could
provide improved frequency
response. The retirement of
this requirement may result in
Western entities’ diminished
frequency response
performance that may not be
alleviated by the current BAL003-1.1 standard, which is
under review and
development under NERC
Standards Development
Project 2017-01.
Adrian
Andreoiu
BC Hydro recommends that
the retirement of this
requirement be coordinated
with the revision of the BAL003-1.1 Frequency Response
and Frequency Bias Setting.
WECC-0115
British
Columbia
Hydro &
Power
Authority
Load-Serving
Entities (LSE)
Abstain
BAL-002-WECC-2 R2
requirement to carry spinning
reserves in all hours could
provide improved frequency
response. The retirement of
this requirement may result in
Western entities’ diminished
frequency response
performance that may not be
alleviated by the current BAL003-1.1 standard, which is
under review and
development under NERC
Standards Development
Project 2017-01.
Adrian
Andreoiu
BC Hydro recommends that
the retirement of this
requirement be coordinated
with the revision of the BAL003-1.1 Frequency Response
and Frequency Bias Setting.
3
Attachment E12
Project
Entity
Segment
Vote
Comment
Name
WECC-0115
Southern
California
Edison
Company
Load-Serving
Entities (LSE)
Abstain
No comments.
Romel
Aquino
WECC-0115
Tacoma Power
Transmission
Dependent
Utilities (TDU)
Yes
0
John
Nierenberg
WECC-0115
Seattle City
Light
Transmission
Dependent
Utilities (TDU)
Yes
0
Hao Li
WECC-0115
Tacoma Power
Electric
Generators
Yes
0
Karen
Hedlund
WECC-0115
Platte River
Power
Authority
Transmission
Owners
Yes
0
Matthew
Thompson
WECC-0115
Tacoma Power
Load-Serving
Entities (LSE)
Yes
0
Twila Hofer
WECC-0115
Bonneville
Power
Administration
Transmission
Owners
Yes
0
Kammy
RogersHolliday
WECC-0115
Bonneville
Power
Administration
Load-Serving
Entities (LSE)
Yes
0
Rebecca
Berdahl
WECC-0115
Western Area
Power
Administration
Electricity
Brokers,
Aggregators,
and Marketers
Yes
0
Timothy
Vigil
WECC-0115
Bonneville
Power
Administration
Electricity
Brokers,
Aggregators,
and Marketers
Yes
0
Andrew
Meyers
WECC-0115
California
Independent
System
Operator
Regional
Transmission
Organizations
(RTOs) and
Independent
System
Operators
(ISO)
Yes
0
Richard
Vine
4
Attachment E12
Project
Entity
Segment
Vote
Comment
Name
WECC-0115
Puget Sound
Energy, Inc.
Electric
Generators
Yes
0
Theresa
Rakowsky
WECC-0115
Puget Sound
Energy, Inc.
Load-Serving
Entities (LSE)
Yes
0
Theresa
Rakowsky
WECC-0115
Puget Sound
Energy, Inc.
Transmission
Owners
Yes
0
Theresa
Rakowsky
WECC-0115
Los Angeles
Department of
Water and
Power
Transmission
Owners
Yes
0
Pjoy Chua
WECC-0115
Los Angeles
Department of
Water and
Power
Load-Serving
Entities (LSE)
Yes
0
Pjoy Chua
WECC-0115
Los Angeles
Department of
Water and
Power
Electricity
Brokers,
Aggregators,
and Marketers
Yes
0
Pjoy Chua
WECC-0115
Los Angeles
Department of
Water and
Power
Electric
Generators
Yes
0
Pjoy Chua
WECC-0115
Arizona Public
Service
Company
Load-Serving
Entities (LSE)
Yes
0
Vivian Vo
WECC-0115
Arizona Public
Service
Company
Electric
Generators
Yes
0
Kelsi Rigby
WECC-0115
Arizona Public
Service
Company
Electricity
Brokers,
Aggregators,
and Marketers
Yes
0
Chinedu
Ochonogor
WECC-0115
Arizona Public
Service
Company
Transmission
Owners
Yes
0
Michelle
Amarantos
WECC-0115
Public Utility
District No. 1
of Chelan
County
Electric
Generators
Yes
0
Meaghan
Connell
5
Attachment E12
Project
Entity
Segment
Vote
Comment
Name
WECC-0115
Public Utility
District No. 1
of Chelan
County
Transmission
Owners
Yes
0
Meaghan
Connell
WECC-0115
Public Utility
District No. 1
of Chelan
County
Load-Serving
Entities (LSE)
Yes
0
Meaghan
Connell
WECC-0115
Public Utility
District No. 1
of Chelan
County
Electricity
Brokers,
Aggregators,
and Marketers
Yes
0
Meaghan
Connell
WECC-0115
Puget Sound
Energy, Inc.
Electric
Generators
Yes
0
Eleanor
Ewry
WECC-0115
Platte River
Power
Authority
Load-Serving
Entities (LSE)
Yes
0
Jeff Landis
WECC-0115
Platte River
Power
Authority
Electricity
Brokers,
Aggregators,
and Marketers
Yes
support the retirement of
BAL-002-WECC-2a,
Requirement R2 on the
premise that R2 is redundant
to BAL-003-1.1 Frequency
Response and Frequency Bias
Setting. We are at the end of a
2 year field trial and have
found no degradation in
reliability in general and also
none specific to BAL-002 or
BAL-003 performance.
Sabrina
Martz
WECC-0115
Platte River
Power
Authority
Electric
Generators
Yes
0
Tyson
Archie
WECC-0115
Idaho Power
Company
Electricity
Brokers,
Aggregators,
and Marketers
0
0
Laura
Nelson
WECC-0115
Idaho Power
Company
Load-Serving
Entities (LSE)
0
0
Laura
Nelson
WECC-0115
Idaho Power
Company
Electric
Generators
0
0
Laura
Nelson
6
Attachment E12
Project
Entity
Segment
Vote
Comment
Name
WECC-0115
Idaho Power
Company
Transmission
Owners
0
0
Laura
Nelson
7
Attachment E13
Posting 1NERC Response to Comments
WECC-0115 BAL-002-WECC-3
Contingency Reserve
Request to Retire R2
Posting 1 NERC Response to Comments
The WECC-0115 BAL-002-WECC-2a, 1 Contingency Reserve Drafting Team (DT) thanks everyone who
submitted comments on the proposed document. As all comments were in support of the project, no
changes were made.
Posting
NERC posted the project for public comment from June 20, 2019, through August 5, 2019.
NERC distributed notice for the posting on June 20, 2019. NERC asked stakeholders to give feedback
on the proposed document through a standardized electronic template. Four sets of responses were
received, including comments from four different people from four companies representing five of the
industry Segments.
Location of Comments
All comments received on the project can be viewed in their original format on the WECC-0115 project
page under the “Submit and Review Comments” accordion.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC
Consultant, at (503) 307-5782. In addition, there is a WECC Reliability Standards appeals process.
The naming nomenclature changed during development from BAL-002-WECC-2, BAL-002-WECC-2a, and will
change to BAL-002-WECC-3 if approved.
1
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Attachment E13
Respondents
Respondent
Organization
1
Aaron Cavanaugh
Bonneville Power Administration
2
Laurie Williams
PNM Resources— Public Service Company of New Mexico
3
Sandra Shaffer
Berkshire Hathaway—PacifiCorp
4
Richard Vine
California Independent System Operator
Index to Questions, Comments, and Responses
Question
1. Do you agree the development of BAL-002-WECC-3 met the “Open” criteria as outlined above?
If “No,” please explain in the comment area below:
2. Do you agree the development of BAL-002-WECC-3 met the “Inclusive” criteria as outlined
above? If “No,” please explain in the comment area below:
3. Do you agree the development of BAL-002-WECC-3 met the “Balanced” criteria as outlined
above? If “No,” please explain in the comment area below:
4. Do you agree the development of BAL-002-WECC-3 met the “Due Process” criteria as outlined
above? If “No,” please explain in the comment area below:
5. Do you agree the development of BAL-002-WECC-3 met the “Transparent” criteria as outlined
above? If “No,” please explain in the comment area below:
Comments and Responses
All commenters responded “yes” to all questions asked. No changes were made.
Respondent
Comment
Bonneville Power Administration
Yes
PNM
Yes
Berkshire Hathaway
Yes
California Independent System Operator
Yes
2
Attachment E14
WECC Standards Committee Roster
WECC-0115 BAL-002-WECC-3
Contingency Reserve
Request to Retire R2
WECC Standards Committee Roster
The following individuals are those assigned to the WECC Standards Committee as of June 18, 2019.
Sunitha Kothapalli, Puget Sound Energy ........................................................................... SVS 1 Transmission
Vacant ............................................................................................................................................. SVS 2 RTO/ISO 1
Dana Cabbell, Southern California Edison ........................................................................................ SVS 3 LSE 2
Marty Hostler, Northern California Power Agency ........................................................................ SVS 4 TDU 3
Gary Nolan, Arizona Public Service ........................................................................................ SVS 5 Generators
Joe Tarantino, Sacramento Municipal Utility District .......................... SVS 6 Broker/Aggregator/Marketers
Caitlin Liotiris, Utah Association of Energy Users .................................... SVS 7 Large Electricity End Users
Crystal Musselman, Proven Compliance Solutions .......................................... SVS 8 Small Electricity Users
Davy Zhuang, British Columbia Utilities Commission ..................................................... SVS 9 Gov. Entities
Steven Rueckert, WECC ................................................................................................ SVS 10 Regional Entities
James Avery, Chair.......................................................................................................... Non-Affiliated Director
Regional Transmission Organization/Independent System Operator
Load-Serving Entity
3 Transmission Dependent Utilities
1
2
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Exhibit F
Drafting Team Roster
Exhibit F
Drafting Team Roster
WECC-0115 BAL-002-WECC-3
Contingency Reserve
Request to Retire R2
WECC-0115 Contingency Reserve Drafting Team Roster
On August 12, 2015, the WECC Standards Committee (WSC) appointed the initial WECC-0115 drafting
team. Thereafter, the WECC-0115 Field Test was initiated spanning a lengthy period.
On October23, 2018, the WSC adjusted the DT roster adding/deleting drafting team members as
indicated in the Candidate column. The action was taken per the WSC Charter, Section WSC Charter,
Section 4. Actions Without a Meeting.
On November 27, 2018, the WSC assigned Mr. James Wells to replace Mr. Don Badley as DT chair. That
action was taken per the November 27, 2018 Consent Agenda.
Candidate
Experience
Ali Miremadi
Ali Miremadi is the California Independent System Operator’s (CAISO) Senior
CAISO
Operations Policy Advisor. He has been with the CAISO for over 17 years and
was part of the CAISO start-up team back in 1997. Mr. Miremadi has held
various positions within CAISO including leading the Operator Training
program through transition to full compliance with NERC Standard PER-005,
and design/oversight of the real time and near miss Root Cause Analysis
Process. Mr. Miremadi designed the real-time Operations reliability metrics for
daily review of CAISO operator performance.
In his current assignment, Mr. Miremadi is responsible for the review and
evaluation of North American Electric Reliability Corporation (NERC) proposed
standards impacting CAISO Operations. He works directly with CAISO upper
management coordinating the formulation of CAISO Operations positions on
proposed NERC standards and prepares comments and filings at NERC or other
regulatory agencies.
Mr. Miremadi began his career at the California Public Utilities Commission
(CPUC) where he spent most of his tenure working on investor owned utility
Demand-side Management and Load Management programs. He was part of
the CPUC team that worked on the restructuring of the electric utility industry.
155 Nort h 400 West | Suit e 200 | Salt Lake Cit y, Ut ah 84103
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Exhibit F
Candidate
Experience
Mr. Miremadi has a Bachelor of Science degree in Engineering and a Master of
Arts degree in Management. He holds an active NERC System Operator
Certification.
Bart McManus
Bonneville Power
Administration
(Added October
23, 2018)
Mr. McManus received his Bachelor of Science degree in Electrical Engineering
from the University of Washington and has been at Bonneville Power Authority
Administration (BPA) since 1994. Mr. McManus was the lead programmer for
the Automatic Generation Control (AGC) system for multiple years then became
the lead for AGC and other Balancing Authority Area Operations in BPA. Mr.
McManus began working on wind integration issues in 2006 and was team lead
for AGC and wind integration for a few years. He is currently the AGC and
wind integration subject matter engineer and the wind integration lead for BPA
Transmission Operations. Mr. McManus was part of the North American
Electric Reliability (NERC) Performance Work group that drafted the original
Disturbance Control Performance Standard and was also on the drafting team
for the original WECC regional Reliability Standard addressing reserves.
David Frederick
Salt River Project
(Inactive October
23, 2018)
Mr. Frederick served as the drafting team chair for WECC-0114 BAL-002-WECC2, Contingency Reserve, Request for Interpretation Drafting Team and was a
member of the WECC-0103 BAL-STD-002-0, Operating Reserves Drafting Team
and the WECC-0083 BAL-002-WECC-1, Contingency Reserves Drafting Team.
Mr. Frederick is a Cost/Plant/Power Production Analyst for Salt River Project.
He has worked in merchant and reliability areas at SRP since 1999. Previously,
he served as the Administrator of the Southwest Reserve Sharing Group.
Mr. Frederick is a NERC-Certified Dispatcher in Balancing, Interchange, and
Transmission Operations and holds a Bachelor of Science degree in
Accountancy.
David Kirsch,
Bonneville Power
Administration
(Inactive as of
October 23, 2018)
Mr. Kirsch has 27 years of experience in the electric utility industry. He began
his career in 1988 at PacifiCorp, in the Major Equipment Specifications, and
Substation Design groups, which led to a Distribution Engineer position in
PacifiCorp's Portland district. Mr. Kirsch joined BPA's workforce in 2001 as a
Field Engineer in the Substation Protection and Control (SPC) group leading to
assignment as an SPC District Engineer. In 2009, Mr. Kirsch transitioned to
BPA's Transmission Technical Operations organization in the AGC workgroup
where he served as part of the maintenance committee with the United States
Army Corps of Engineers and the United States Bureau of Reclamation. In 2014,
Mr. Kirsch was named Chair of the Technical Operations and Implementation
2
Exhibit F
Candidate
Experience
Subcommittee (TOIS) which coordinates controls and signals with for hydro
projects. Mr. Kirsch is BPA's subject matter expert for several NERC Standards,
including BAL-002-WECC-2, Contingency Reserve and is a member WECC's
Performance Work Group.
Don Badley
The following is a listing of Mr. Don Badley’s experience related to NERC and
Northwest Power
WECC BAL standards:
Pool
•
Groups served on (past and present): North American Power Systems
(Inactive October
Interconnection Committee (NAPSIC) Performance Subcommittee,
23, 2018 - Retired)
WECC Control Work Group, WECC Operating Practices Subcommittee,
WECC Technical Operations Subcommittee, WECC Reserve Issues Task
Force, NERC Functional Model Task Force, NERC Resources
Subcommittee, NERC Frequency Task Force, NERC Frequency
Responsive Reserve Standard Drafting Team, Reserve Task Force, and
WECC Performance Work Group.
•
Groups chaired (past and present): NAPSIC Performance Subcommittee,
WECC Performance Work Group, WECC Reserve Issues Task Force,
NERC Control Criteria Task Force, NERC Resources Subcommittee.
•
Mr. Badley served on and chaired multiple groups within the Northwest
Power Pool related to the BALs.
Employment History
Mr. Badley started working for Pacific Power & Light in 1963 and began his
career with the Northwest Power Pool in 1975.
Professional history
Mr. Badley was affiliated with the IEEE and served in multiple positions
including Oregon Section Chair and twice as the Northwest Area Chair (Alaska,
Oregon, and Washington). Mr. Badley is a life member of IEEE.
James Wells
Los Angeles
Department of
Mr. Wells has a Bachelor of Science and a Master of Science in Electrical
Engineering from the University of Southern California, and is a licensed
Professional Electrical Engineer in the State of California.
Water and Power
Mr. Wells has nine years of utility work experience at Los Angeles Department
(LADWP)
of Water and Power, serving the first three years in Energy Reconciliation/Afterthe-Fact supporting developing and maintaining custom reporting tools and
3
Exhibit F
Candidate
Experience
(Appointed chair
database applications for energy scheduling, marketing transactions,
on November 27,
interchange control, transmission utilization, and loss accounting.
2018.)
Mr. Wells served six years in Operating Engineering/Grid Operations Support
providing outage coordination support by facilitating and studying complex
outages and providing real-time power system analysis in support of unplanned
or abnormal system conditions. Mr. Wells serves as a technical engineering
operations expert providing guidance and direction to multiple internal and
external stakeholders on power system operation issues.
Mr. Wells is the LADWP representative on multiple regional study groups
including the Operating Study Subcommittee and the Pacific Southwest
Interconnection Reliability Operating Limit Study group. Mr. Wells is a member
of the WECC Performance Work group and is the author of the WECC-0115
Standards Authorization Request. .
Ken Otto
Western Area
Power
Administration,
Golden, and
Loveland, CO
(Inactive October
23, 2018 - Retired)
Mr. Ken Otto began his Federal career as a student engineer with Bonneville
Power Administration in 1980, before joining Western Area Power
Administration (WAPA) as a system protection engineer in 1983. Many of the
policies and procedures he implemented during his tenure as the lead electrical
engineer became standard WAPA policy. These include substation
computerized controls, an electronic relay replacement program and
collaboration with the Supervisory Controls and Data Acquisition Division to
develop Supervisory Control And Data Acquisition standards. Mr. Otto was
involved with the installation and commissioning of phase shifting transformers
on the TOT2A Project, and the Kayenta Series Capacitor Project.
When he accepted last position in the Colorado River Storage Project
Management Center in October 2000, Mr. Otto took charge over the office's realtime merchant activities. Mr. Otto was instrumental in successfully integrating
the Loveland Area Projects and Basin Electric merchant activities into the
Energy Management & Marketing Office (Hoover). Mr. Otto developed software
tools and procedures for scheduling and marketing WAPA’s resources. Mr.
Otto’s last position was that of Supervisory Energy Management and Marketing
specialist at Western's Energy Management and Marketing Office, in Montrose,
Colorado.
Mr. Otto serves on the WECC Operating Committee, and both the Seams Issues
Subcommittee and Market Issues Subcommittee as well as various other
subcommittees, task forces and drafting teams. Mr. Otto also represents Western
4
Exhibit F
Candidate
Experience
on the Western Systems Power Pool (WSPP) Executive Committee and
Operating Committee.
Mr. Otto received his Bachelor of Science degree in Electrical Engineering from
the University of New Mexico and is a registered professional engineer.
Rick Lowther
Salt River Project
Mr. Lowther has 38 years of experience in the electric utility Industry. He began
his career at Houston Light & Power as a system planning engineer.
Mr. Lowther spent 14 years working for an Energy Management System vendor.
There, Mr. Lowther developed EMS applications and managed developers
responsible for EMS applications such as Automatic Generation control (AGC),
Interchange Scheduling, Thermal Unit Commitment, State Estimation, Optimal
Power Flow and Contingency Analysis.
For the last 19 years, Mr. Lowther has worked for Salt River Project (SRP).
Initially, he led a team that provided EMS support and developed operational
support applications. He was the lead designer and developer of the Southwest
Reserve Sharing Group’s first reserve sharing system and the Southwest Open
Access Same-Time Information System site that was used by eight desert
southwest utilities for transmission access sales until 2004. He was also the lead
designer and developer of SRP’s current interchange scheduling and accounting
system.
For the last seven years, Mr. Lowther worked in SRP’s Balancing Authority and
Transmission Operations area. In that role, he provides engineering support and
training for generation and transmission dispatchers. He is currently SRP’s
subject matter expert for most NERC BAL and INT Standards and well as some
TOP Standards.
Mr. Lowther participates in several WECC subcommittees (Interchange
Scheduling and Accounting Subcommittee), work groups (Performance Work
Group (PWG), Electronic Scheduling Work Group, Data Exchange Work Group,
EMS Work Group), and task forces (Unscheduled Flow Event Analysis Task
Force). He currently chairs the PWG.
Mr. Lowther received a Bachelor of Science in Electrical Engineering degree
from the University of Houston.
Robert Johnson
Mr. Johnson served as the Rocky Mountain Reserve Group (RMRG)
Rocky Mountain
Administrator for more than 15 years, 20 plus years as Senior Engineer for
WECC Members (PSColorado, WAPA), Member of numerous WECC and NERC
5
Exhibit F
Candidate
Experience
Reserve Sharing
technical committees over my career. Presently the WECC Operating Committee
Group
(Transmission) representative for PSColorado/Xcel. Also, on the Operating
Issues Work Group. Mr. Johnson has served on several drafting teams and is
presently on the TOP-007 retirement team.
Mr. Johnson has served as administrator for the Rocky Mountain Reserve Group
and Senior Operations Engineer for PSCo from 1998 to present.
He manages the generation reserve coordination, compliance monitoring and
reporting, software development, and training for the Rocky Mountain Reserve
Group and is involved in all aspects of administering the RMRG—10 Members
covering Colorado and Wyoming.
As senior Engineer for PSCo prepare advanced operational analysis to address
operational issues and concerns covering a broad spectrum.
Mr. Johnson is a voting Member of the:
•
WECC Operations Committee (OC) Colorado Coordinated Planning
Group
•
WECC Operating Procedures Review Group, Foothills Planning Group
•
Rocky Mountain Operations Study Group.
Mr. Johnson was previously a part of the NERC Compliance and Certification
Committee, WECC Operating Capability Studies Group and NERC Standards
Compliance Task Force.
Over the course of his career, he has drafted multiple technical papers for the
Institute of Electrical and Electronics Engineers.
Manager and Supervisor in Resource and Transmission Planning; 1988-1998
Western Area Power Administration, Golden, and Loveland, CO
Managed the operational, resource and transmission planning group for
Western’s RMR Region in the States of Colorado, Wyoming, and portions of
Utah, New Mexico, Nebraska, and Montana and in a separate position
supervised planning engineers evaluating projects for all of Western’s Regions.
Served on the NERC Planning Committee and numerous WECC technical
committees.
6
Exhibit F
Candidate
Experience
Mr. Johnson served as Power System Engineer for the Bureau of Reclamation
and Western Area Power (1971-1988) where he was involved in a wide variety
of technical assignments.
John Tolo
Tucson Electric
Power
Mr. Tolo is currently employed by Tucson Electric Power as the director of
system control and reliability. He has been in the utility business for 26 years.
Mr. Tolo has held positions in power production and distribution, transmission,
and generation operations. He has memberships in the NERC Resources
Subcommittee, the WECC Performance Work Group, serves as vice chair of the
WECC Operating Committee, chair of the WECC Joint Guidance Committee,
and is a member of the BAL-004-WECC-01 and WECC-0068 BAL-004-WECC-02,
Automatic Time Error Correction (ATEC) Drafting Team.
7
Exhibit G
VRF and VSL Justification
Exhibit G
VRF and VSL Justification
WECC-0115 BAL-002-WECC-3
Contingency Reserve
Request to Retire R2
Violation Risk Factors & Violation Severity Levels
Violation Risk Factors and Violation Severity Levels were previously approved by FERC. No changes
are proposed other than updating the format of the associated components.
155 Nort h 400 West | Suit e 200 | Salt Lake Cit y, Ut ah 84103
www. we cc.org
| File Type | application/pdf |
| Author | NERC Legal (ST) |
| File Modified | 2019-09-06 |
| File Created | 2019-09-06 |