1 2 3 • Organizations are required to register (with NERC) and to comply with approved reliability standards, to the extent that they are owners, operators, and users of the bulk power system. • Coordinated Functional Registration is a NERC approved written agreement between two or more entities agreeing to split NERC Reliability Standards compliance responsibilities. This allows MISO and the LBAs to split NERC compliance activities. The activities are usually listed in a spreadsheet-style matrix (thus the “CFR Matrix”) • Technically, MISO Reliability Coordinator and MISO Balancing Authority have not delegated any RC or BA tasks. However, Local Balancing Authorities (LBAs) within the MISO Balancing Authority are responsible for and thus will perform tasks per the NERC approved MISO BA/LBA Coordinated Functional Registration and the MISO Amended BA Agreement. • MISO has established a Coordinated Functional Registration for BA functions only • “LBA” is a MISO term, not a NERC term. • This presentation touches on NERC standards, but the main point is that some things will be done as they’ve always been done, some things will be done differently, and some things MISO will perform. 4 • The LBAs and the MISO BA will file a Coordinated Functional Registration (“CFR”) with NERC under the NERC Rules of Procedure, Section 508 and Appendix 5A. • CFR registration will be reviewed on at least an annual basis and revisions will be approved by the Balancing Authorities Committee prior to submittal by the MISO BA. 5 • CFR Matrix • Excel spreadsheet with all standards, requirements, and sub-requirements applicable to the BA Function (this supports the process and is not a specific format that is required by NERC) • Delineates responsibilities to requirement and/or sub-requirement level • Responsibilities can be whole (MISO or LBA), shared (LBA amongst LBAs or LBA and MISO), split (between MISO and LBAs) • Whole means that each entity is wholly responsible for their compliance • Shared means that each entity is fully accountable for their compliance • Split means that each entity has an identified, delineated part of the requirement for which they are accountable • The Amended BAA is the contractual agreement underlying the Coordinated Functional Registration • It is executed upon becoming a MISO Member/Transmission Owner/establishment of a Local BA (“LBA”) • Updated signatures are filed with FERC during the Electric Quarterly Reporting Process 6 • CFR Matrix Process Document • Describes the overall process for updating the BA Matrix • Internal to MISO and its Stakeholders 7 MISO’s only existing CFR is for the Balancing Authority Function (JRO00001) • Addresses all requirements applicable to Balancing Authorities (“BAs”) • Approved in the following regions: MRO, SERC, RFC • Consists of the following documents: • Amended BA Agreement (Rate Schedule 3 to the MISO Tariff) (“Amended BAA”) • Matrix delineating responsibilities by standard and requirement/subrequirement (“Matrix” or “CFR”) • NERC Standards • Governed by a Matrix Process Document • All modifications require approval by the BA Task Team (“BATT”) • Once approved by the BATT, changes are routed to the BA Committee (“BAC”) for approval 8 9 • The bubble diagram used in the document Overview section is for reference when reviewing this document only. This diagram is updated as part of the CFR matrix efforts and is not necessarily updated as NERC or Regional compliance registries are modified. • Under the provisions of the BA Agreement, 28 LBAs operate within the MISO BAA. Though many LBAs share the same “footprint” as the associated Transmission Operator, there are also examples of multiple LBAs operating within a single Transmission Operator footprint, and multiple Transmission Operators operating within a single LBA Area. The requirements placed upon the LBAs in this Operating Protocol apply under any configuration. 10 MISO Balancing Authority • Calculate the Area Control Error (ACE) for the footprint using: • Net Actual Interchange (NAI) from all the First Tier Balancing Areas • Collect Frequency bias from all Local Balancing Areas • Maintain the ability to run Automatic Generation Control (AGC) • Comply with Control Performance and Disturbance Control Standards • Repay its Inadvertent Interchange balance with the Eastern Interconnection • • • • • • • • Maintains balance between loads and resources Keeps actual interchange equal to its scheduled interchange Controls generators capable of providing regulation Performs generator commitment and economic dispatch Receives Interchange Schedules from one or more Interchange Authorities (IA) Provides commitment and dispatch schedule to the Reliability Coordinator (RC) Approves bilateral transactions with respect to the ramping requirements Implements emergency procedures in concert with RC 11 Local Balancing Authorities • • • • • Maintain interconnection telemetry, metering and associated accounting Send the area Net Actual Interchange (NAI) to the MISO Balancing Authority Establish equipment ratings and monitor their local system in Real-Time Send Dispatch signals from MISO BA to generation plants in area (in some cases) Implement Emergency Procedures including load shedding 12 Local Balancing Authorities • Provide Load Forecast • Each LBA within the Market Footprint must send an hourly, rolling seven-day Load forecast to the MISO. This forecast must be at an hourly granularity and reflects the amount of Load in the BAA that is served by the generation that is modeled by the MISO. • LBAs submit the actual BAA Load via ICCP and may submit a short-term forecast of Non-conforming Load, exclusive of any Non-conforming Load associated with DRRs-Type II, via ICCP if desired. If Non-conforming Load forecast data is not submitted, the MISO assumes all load is conforming in its short-term load forecast for the Real-Time Energy and Operating Reserve Market. • When it is necessary to indicate the expected performance of a Non-conforming Load or to make a correction to the MISO’s Real-Time Load forecast, the LBA may indicate a Load forecast adjustment through the ICCP. • The LBAs will submit the load forecast over the ICCP and should account for any non conforming load (Non conforming load is load that is not affected by temperature). • Corrections can be made to load forecasts over ICCP 13 • The following section provides a more detailed description of the obligations and responsibilities for both LBAs and MISO, within the MISO BA Area • Note: As stated on slide two of this presentation, this is not a governing document. This presentation does not relieve any entities from any requirements prescribed in the NERC Standards. In addition, this does not provide legal advice. This is provided simply to reference applicable polices and procedures about which MISO has received notable questions in the past. 14 BAL-003 Frequency Response and Bias • Frequency bias is an approximation of the frequency response (actual MW contribution to stabilize frequency) used in the ACE equation (prevents AGC withdrawal of frequency response). MISO calculates this by taking 1% of the forecasted footprint yearly peakload • On an annual basis, the MISO will provide a review of the MISO Frequency Bias calculation including actual and estimated responses to the BA Committee. • MISO is required by NERC Standard BAL-003 to report the frequency bias to the NERC Operating Committee 15 BAL-005 Automatic Generation Control • In order for MISO to accurately calculate ACE for Real Time Operations and compliance under BAL-001 and BAL-002, the LBAs are responsible for providing the MISO BA with real-time Actual Interchange with External Balancing Authorities as part of the LBA requirements specified in Appendix A for BAL-005. LBAs with metered points of interconnection with BAs adjacent to the MISO BA Area are responsible for providing Tie Line MW metering as agreed through ICCP. • Though not required for NERC compliance, the LBAs are responsible for providing the MISO BA with real-time interchange associated with adjacent LBAs consistent with information provided for External Balancing Authorities. • The MISO will provide its Real Time ACE to the LBAs at all times and upon request provide analysis of events impacting its compliance performance to the Resource and Demand Balancing Standards to the BA committee. • The LBAs shall ensure that megawatt-hour Actual Interchange data for each hour is telemetered or reported at the end of each hour to the MISO BA. 16 BAL-006 Inadvertent Interchange • In order for MISO to accurately report Inadvertent Interchange, the LBAs, as part of the LBA requirements specified in Appendix A for BAL-006, are responsible for providing the MISO BA with after-the-fact Actual Interchange data as coordinated with External Balancing Authorities. The LBAs are responsible for providing interchange data with adjacent LBAs consistent with information provided for External Balancing Authorities. • On a monthly basis, the MISO will report its Inadvertent Interchange for the prior month along with its accumulated Inadvertent Interchange. • MISO will perform all NSI and NAI NERC reporting 17 CIP-001 thru CIP-009 Critical Infrastructure Protection • The MISO in determining its scope of responsibility for assessment and identification of Critical Assets will have the responsibility for the infrastructure necessary to facilitate data exchange and communication links up to the LBAs asset boundary. The MISO will identify the Critical Assets within its operational purview. • The responsibility for Critical Infrastructure Protection standards related to the assets owned or within the operational purview of the LBA will solely be the responsibility of the LBA. The LBA will identify the Critical Assets within its operational purview. • Critical Infrastructure Protection standards are new and deal with the physical security of the system components. The LBA along with MISO BA will be responsible for all of these requirements. LBA is still responsible for determining which assets are critical assets. 18 MISO & LBAs are individually responsible for compliance COM-001 and COM-002 Communications • The MISO BA and the LBAs are individually responsible for compliance to the requirements under COM-001 and COM-002. In addition, the LBAs will continue to maintain reliable communications with neighboring LBAs and neighboring External BA’s. • The MISO will establish communication protocols with all External BA’s. The MISO will establish communication protocols, including provisions for loss of communications, between the MISO and the LBAs. The MISO will coordinate its communication protocols with the LBAs and test procedures for loss of communications with the LBAs on an annual basis. 19 20 EOP-001 Emergency Operations Planning • Emergency Operations Planning is the standard that forces Balancing Authorities and Transmission Operators to build a plan to handle the system during emergency conditions. The plan has to be updated annually for NERC and there are some specific elements that have to be included from Attachment 1. • The MISO is responsible for overall Emergency Operations planning and coordination of such plans. (EOP-001) In accordance with EOP-001 R3.3 and R3.4, the LBAs will provide the MISO with local restoration (as developed under EOP-005) and load shed plans (as developed under EOP-003). The local restoration and load shed plans will include coordination with Transmission Operators in the applicable LBAA. The MISO emergency plans will include the overall coordination, as necessary, with the LBAs and Transmission Operators in its BAA. Such plans will consider the elements listed in Attachment 1-EOP001-0, so that the MISO can coordinate plans throughout the region and develop overall MISO plans for emergency operations. The overall MISO plans will consider the elements numbered 5, 9, 10, 11, 13, 14 and 15 listed in Attachment 1-EOP-001-0. (EOP001 R5) EOP-001 Emergency Operations Planning • The MISO will use the stakeholder process, as well as internal review, to update all of the Emergency Operations Procedures annually. (EOP-001 R6) The LBAs will update their plans in coordination with the MISO annual process. The MISO will also facilitate 21 training and simulation to support the proficiency of LBA operators for restoration, load shedding and emergencies, including training for communication protocols for emergencies. The MISO will provide neighboring External BA’s and TOPs with the overall MISO emergency plans. To the extent that an LBA may need to be involved for situations of cross-boundary islanding and restoration, the MISO plan will consider such situations in the development of its emergency plans. The LBAs shall be responsible for their coordination of emergency plans with the MISO RC and LBA’s TOP(s). The MISO is responsible for coordination of emergency plans with neighboring BAs and TOPs. EOP-001 Emergency Operations Planning • When the MISO determines that load shed is necessary within the MISO BAA or portions of the MISO BAA, the MISO shall determine the appropriate amount of load to shed and direct the applicable LBA(s) to shed such load. The LBA(s) shall implement the load shedding within their LBAA, in accordance with Section 8 of these NERC Standards. 21 Capacity and Energy Emergencies is where the Balancing Authorities are given the specific authority to do whatever is necessary to correct system emergencies. This includes the shedding of firm system load if necessary. Firm system load can be carried down to the residential customer if needed. Also in this standard the BAs have to supply reliability information as need by other reliability entities for them to perform the studies needed for the system. EOP-002 Capacity and Energy Emergencies • Each LBA shall provide the MISO BA with current available information on the behindthe-meter generation, interruptible loads and demand-side management resources within the LBA area. The LBA operator shall coordinate emergency operations with the MISO BA operator as required by the MISO emergency operating procedures. • The MISO BA shall provide the LBAs and TOPs projections of Operating Reserves for MISO BAA wide or specific sub-area (s) as appropriate. A sub-area may consist of a single Local Balancing Authority Area, a group of Local Balancing Authorities Areas, or portions of a Local Balancing Authority Area (s). • The MISO BA shall issue alerts, warnings, and event notifications to keep all affected system personnel aware of the forecast and/or actual status of the MISO BAA. The MISO BA operator shall communicate and coordinate operations necessary during energy or capacity emergencies with the other affected BAs, LBAs, and TOPs as appropriate. 22 Load Shedding Plans are a requirement by NERC. Most companies have either an under frequency load shed plan or an under voltage load shed plan. These plans are set up to be triggered by predetermined levels and to operate automatically. This is where the LBA has to keep MISO apprised of their plans and the performance of those plans. EOP-003 Load Shedding Plans • Each LBA, in conjunction with its Transmission Operator where applicable, shall be responsible for the development of its Load Shedding Plan, including plans for automatic load shedding for under-frequency or under-voltage conditions. Such plans shall be shared and coordinated with the MISO. • Upon implementation of its Load Shedding Plan, the LBA shall confirm with the MISO the amount of load that has been directed off, the actual amount of load that has been removed from the system, and any amount of load that has been restored. The LBA shall be responsible for keeping the MISO current in regard to this information. • The MISO shall communicate and coordinate the implementation of any Load Shedding plan with the LBA, as well all affected LBAs, interconnected Transmission Operators and Balancing Authorities. 23 Disturbance Reporting has to be done for certain events that take place on the system. There are several requirements and thresholds that dictate the reporting that has to be done. The form OE-417 is the most stringent of the reporting requirements and has to be sent to the Department of Energy. There are two attachments in the Standards that dictate the which report must be used. They are Attachment 1-EOP-004 NERC Disturbance Report Form and Attachment 2-EOP-004 U.S. Department of Energy Disturbance Reporting Requirements. EOP-004 Disturbance Reporting • As Balancing Authority for the MISO BAA, the MISO has the primary responsibility for reporting Bulk Electric System related disturbances, events or unusual occurrences to NERC, DOE, Regional Entities or other industry or governmental entities with jurisdictional authority. • LBAs shall be responsible for local event reporting to NERC, DOE, Regional Entities, and state or local government reporting requirements. • For incidents of cyber and/or physical security, sabotage, vandalism or suspected terrorist actions, the MISO and all affected LBAs shall each report directly to the appropriate government and industry agencies. • Under any reporting situation, the MISO and LBAs shall provide the other with data and information necessary to complete the report. • The MISO and the LBAs will follow the reporting requirements and procedures described in the MISO OP-023 Disturbance Reporting procedure. 24 System Restoration Plans are required by NERC in the event the system should become islanded or blacked out. All Balancing Authorities and Transmission Operators and the Regional Reliability Organizations are required to have system restoration plans and share them as needed. This applies to both the LBA and the MISO BA. EOP-005 System Restoration Plans Joint Responsibilities: • The MISO BA and LBAs shall be responsible for coordinating regional generation plans with the Reliability Coordinator during restoration events involving restoration of islands and interconnection of LBAs. • The MISO BA and LBAs shall periodically test the telecommunication facilities needed to implement the restoration plans to ensure that proper capabilities are maintained. • The MISO BA and LBAs shall train their operating personnel in the implementation of the restoration plan(s), and ensure they understand their roles and responsibilities during a restoration event. Such training shall include simulated exercises, if practical. • The MISO BA and LBAs shall verify the restoration procedures by actual testing or by simulation. • The MISO Balancing Authority and the Local Balancing Areas shall share information regarding their roles and responsibilities under all system restoration plans. • Post Disturbance: The LBAs and MISO BA shall work in conjunction with the Reliability Coordinators to determine the extent and condition of the isolated areas. The LBAs shall keep the MISO BA apprised of local conditions. 25 • Post Disturbance: The MISO BA and LBAs shall take the necessary actions to restore Bulk Electric System frequency to normal, including adjusting generation, placing additional generators on line, or load shedding. • Post Disturbance: The MISO BA and LBAs shall make all attempts to maintain the adjusted Interchange Schedules, whether generation control is manual or automatic. 25 System Restoration Plans are required by NERC in the event the system should become islanded or blacked out. All Balancing Authorities and Transmission Operators and the Regional Reliability Organizations are required to have system restoration plans and share them as needed. This applies to both the LBA and the MISO BA. EOP-005 System Restoration Plans LBA Unique Responsibilities: • The LBAs are responsible for participation in the coordination of local restoration plans with the Transmission Operators (TOPs) in their areas. These plans will ensure the viability of restoring the local areas to the point of interconnecting with adjacent LBAs or external entities. • Post Disturbance: As a minimum, LBAs shall maintain the capability to control an adequate amount of generation necessary for operating under Constant Frequency & Constant Net Interchange modes in order to facilitate interconnection of islands during a restoration event. MISO Unique Responsibilities: • The MISO BA shall be aware of all LBA restoration plans, and be responsible for coordinating these plans with the TOPs, Generator Operators, and Reliability Coordinator to ensure workable plans which will allow for the interconnection of islands within the MISO BAA and interconnection with external entities. • Post Disturbance: The MISO BA shall be responsible for working with their Reliability 26 Coordinator(s) to review the Interchange Schedules between LBAs, or fragments of LBAs to facilitate the restoration. 26 NERC requires all BAs to have Plans for Loss of Control Center Functionality. Basically if the control center has to be shut down for any reason there has to be a backup and plans on how the backup will be put into service. EOP-008 Plans for Loss of Control Center Functionality • The MISO BA and LBAs are each individually responsible for having a plan to continue reliability operations in the event its control center becomes inoperable. (EOP-008 R1) The associated entity shall be responsible for annual review (EOP-003 R1.7), testing (EOP-008 R1.5) and training (EOP-008 R1.6) of its plan. Each LBA shall coordinate its plan and the review of such plan with the MISO BA, and the MISO BA shall coordinate its plan and the review of such plan with all of the LBAs. Each LBA shall include needed communication with the MISO BA, neighboring LBAs and neighboring External BAs in its plan. The MISO shall include needed communication with neighboring External BAs and all LBAs in its plan. (EOP-008 R1.4) 27 28 Nuclear Plant Coordination • In the event that the MISO BA and/or an LBA has been provided an NPIR per the current version of NUC-001 , its scope of responsibility as a Balancing Authority for the NUC standards is defined in the Coordinated Functional Registration JRO-00001 document under the BAL, CIP, COM, EOP, INT, IRO, MOD, PER, PRC and TOP requirements. • MISO BA and LBAs will be responsible individually for each requirement based on the NPIRs each receives and the applicable agreements reached with a particular nuclear plant. The MISO BA and LBAs will cooperate and support each other to provide the necessary NPIR/Agreement service should assistance be required by either the MISO or the LBAs. In addition, the MISO BA and LBAs will each notify the other when an NPIR is received by one party that may potentially impact the other party. 29 All operators are required to be NERC certified and to receive a certain amount of continuing education hours a year. Each LBA has the responsibility to provide the adequate training for those operators. PER-001 through PER-003 Personnel Performance, Training, and Qualifications • Each LBA and the MISO shall individually staff adequately trained operating personnel. • Each LBA and the MISO shall be individually responsible for personnel performance, training, and qualifications its own employees in accordance with NERC Standards. In addition, the MISO will facilitate and conduct annual joint training for the LBA and MISO BA system operators for coordinated normal and emergency operations. 30 The Protection and Control standard is to ensure system protection is coordinated among operating entities. The LBA has the responsibility to provide the MISO with the information as needed to accomplish this. PRC-001 Protection and Control • Each LBA will provide the MISO with the purpose and limitations of the protection system schemes applicable to its LBAA. (PRC-001 R1) Each LBA will notify other LBAs, External BAs and the MISO of any status change that affects such entity. (PRC-001 R6) • MISO will coordinate special protection schemes of adjacent systems with the impacted LBAs. 31 The purpose of the Reliability Responsibilities and Authorities standards are to ensure reliability entities have clear decision-making authority and capabilities to take the appropriate actions or direct the actions of others to return the transmission system to normal conditions during an emergency. This is where the LBAs also have to follow directives from the Reliability Coordinator or the Transmission Operator unless such directives would violate safety, equipment, regulatory or statutory requirements. Reliability Responsibilities and Authorities also states that if there is a conflict between the directives from the RC and the TOP the RC will always prevail. The Reliability Responsibilities and Authorities standards states that BAs have to render emergency assistance as needed. In this case, LBAs follow directives by MISO. TOP-001 Reliability Responsibilities and Authorities • Each LBA shall, in coordination with the MISO BA, comply with all reliability directives of the Reliability Coordinator and Transmission Operators unless such directives would violate safety, equipment, regulatory or statutory requirements. If a directive violates such requirements, the LBA shall immediately inform the Reliability Coordinator or Transmission Operator of the violation. If there is a conflict between directives to the LBA from the Reliability Coordinator and the Transmission Operator, the Reliability Coordinator’s directive shall prevail. The LBA shall be responsible for communicating the actions taken to the Reliability Coordinator, the Transmission Operator, the MISO BA and any affected LBAs. 32 • Each LBA, in coordination with the MISO BA, shall render all emergency assistance to others as directed by the MISO Reliability Coordinator unless such assistance would violate safety, equipment, regulatory or statutory requirements. If requested assistance violates such requirements, the LBA shall immediately inform the Reliability Coordinator or MISO BA of the violation. 32 TOP-002 Normal Operations Planning • The MISO BA shall provide each LBA with the operational planning information for the LBA Area on a day-ahead basis. This should include, but not limited to forecasted load, generator commitment results from the day-ahead process, and availability for the generators within the LBA area. The MISO BA shall provide projections of Operating Reserves for MISO BAA wide or reserve zones as appropriate. • Unless other provisions are arranged with the MISO BA, each LBA shall submit its MidTerm Load Forecast data to MISO. There are two standard times for LBAs to update and submit their Mid-Term Load Forecast data to MISO via ftp. The two standard times are 1:00am EST and 4:00pm EST each day. Each load forecast file submitted to MISO will consist of hourly integrated load forecast for the next 7 days, including the current day The 4:00pm load forecast data submitted by the LBA could include actual historical data for the previous 15 hours. The LBA may provide more frequent MTLF data updates than the two standard times each day. The Mid-Term Load Forecast data submitted by the LBA shall be consistent with the LBA metered boundary, as represented in the MISO network model. • The real-time LBA Area load is required to produce the MISO BA Short-Term Load Forecast (STLF) data. For this reason, each LBA shall submit its real-time LBA Area load to MISO via ICCP. The calculated LBA Area load shall be consistent with the LBA metered boundary, as represented in the MISO network model. • MISO shall coordinate a method of communicating line identifiers by the Reliability Coordinator, MISO BA, Transmission Operators and LBAs throughout the MISO 33 transmission footprint. 33 When it comes to Planned Outage Coordination the LBAs have to coordinate the scheduled outages of telemetering, control or communications equipment with the MISO BA if such equipment is used to provide information to MISO for operations of the MISO BAA and also anyone that is affected by the outage. TOP-003 Planned Outage Coordination • Each LBA shall coordinate scheduled outages of telemetering, control or communications equipment with the MISO BA if such equipment is used to provide information to the MISO for operations of the MISO Balancing Area. Each LBA shall also be responsible for coordinating scheduled outages of telemetering and communications equipment with neighboring LBAs and External BAs for tie lines with those neighboring LBAs and External BA’s. The MISO BA shall also coordinate and notify the LBAs of scheduled maintenance of MISO, Transmission Operator and generator telemetering, control or communications equipment which provides data or control signals to the LBAs. 34 The purpose of this standard is to ensure that Operational Reliability Information is given to reliability entities as needed to monitor system conditions within their areas. No Market Participant can see any of the Operational Reliability information! There is too much information to mention here. Basically it is anything that the Reliability Coordinator ask for including the financial information or market sensitive information if needed. Market Participants are not allowed to sign the NERC Confidentiality Agreement and that prohibits them from being able to see any Reliability information. TOP-005 Operational Reliability Information • Each LBA, in coordination with the MISO BA, shall provide operating data requested by the Reliability Coordinator for performing operational reliability assessments and to coordinate reliable operations within the Reliability Coordinator Area. The MISO BA shall provide operating data to the LBAs, as determined by the LBAs, needed to perform their reliability responsibilities under the BA Agreements. The MISO BA shall also be responsible for providing operating data requested by External BAs and receiving operating data from External BAs as needed for the MISO BA to perform its reliability responsibilities. LBAs may also request operating data directly from External BAs if needed to perform the LBA reliability responsibilities. 35 When it comes to Monitoring System Conditions the purpose of the standard is to ensure that critical reliability parameters are monitored in real-time. Each LBA is responsible for monitoring the frequency in its area and any other parameters need for emergency operations and restoration. While Monitoring System Conditions the LBA has to provide the MISO BA with this information so that the MISO BA can control the system in a reliable manner. TOP-006 Monitoring System Conditions • Each LBA shall be responsible for monitoring system frequency in the LBA Area. Each LBA shall also be responsible for monitoring other system parameters in the LBA Area that would be needed for emergency operations and system restoration. • Each LBA shall provide the MISO BA with information on load within the LBA area and other information required by the MISO BA to monitor the status of the MISO Balancing Authority Area. The MISO BA shall provide information necessary for the LBAs to continuously monitor the status of the LBA Area should the LBAs need to participate in emergency operations and system restoration. This information shall include load and Bulk Electric System status in the LBA area. • The MISO BA shall be responsible for providing information to neighboring External BAs as requested. The MISO shall be responsible for obtaining information from neighboring External BAs or Transmission Operators as needed for effective monitoring of system status. The MISO BA shall provide information from External entities to LBAs when needed by the LBAs for monitoring their LBA Area’s. 36