BAL-002 is a no with comments (yes to Paragraph 321 directive, but no to others):
The use of Demand Side Management for spinning reserves needs an additional requirement
and a further description of "adequate" . Based on the use of Demand Side Management in
the Spinning Reserve Requirement, Demand Side Management could act like Non-spin.
“same response characteristics of the resources it is replacing”. If load is going to be
allowed to be used for spin, it should be responding to all frequency deviations, just like
generators do with a droop setting. It shouldn’t be allowed to only respond to large
deviations or only internal contingencies. If allowed to only respond to contingencies, there
will be a definite delay for contingencies external to their BA.
BAL-005 is yes to all directives
EOP-001 is yes to all directives
EOP-002 is yes to all directives
EOP-003 is no with comments (believe it is no to both directives - but Jim is not
here to confirm which one) see page 10 of comment form:
Requires test every 2 years with TOP/BA/LSE/DP and deployment of personnel (that's a ton
of work for a large TOP). Requires annual simulation of load shedding plans (with the other
revisions UF moves to Planning Coordinator not TOP/BA but does leave UVLS with the
TOP). Adds - coordinate load shedding plans with RC, Regional Entity (and GO as
appropriate?).
EOP-004 is yes to all directives with comments:
Should RRO be changed to RE ? What is promptly? The Preliminary Disturbance form
requires RC/BA/TOP/GOP/LSE to report within 1 day to NERC and RRO. Sometimes events
are complicated and analysis takes time - no simple solution.
FAC-002 is yes to all directives
MOD-017 is no with comments (no to first two directives, yes to last three directives):
In the directives in Paragraph 1250 Alcoa’s proposal was rejected because it appears
to provide a broad exemption to the Reliability Standard due to the subjective nature
of determining whether a load varies with temperature and/or humidity. Regardless
of the variability of load with these weather elements, providing the weather data
with the loads allows all who are trying to assess or validate past events and
databases with the data to make sound mathematical or statistical determinations.
Not having the data does not ensure this capability which is the purpose of the
Standard. Thus the words “that vary” should be removed from Requirement R1.1.
Further, entities do not want to be penalized for not being able to provide the data
from a weather station that is near the load if it is not available, nor do entities want
to establish weather capturing capabilities. Thus, Requirement R1.1. should be
changed to read something like “Integrated hourly demands in megawatts(MW) for
the prior year along with coincident hourly temperature from weather station(s) in
proximity to the load center(s) and if available hourly humidity from the same
weather stations.”
Because monthly loads may experience heating and cooling impacts in the same
month, using monthly temperature is not the best method to approach analyzing
temperature impacts on monthly date. Further, by having already provided hourly
weather data in Requirement 1.1 make the request for the monthly temperature
data in Requirement 1.2 redundant and really worthless. Typically, the monthly
analysis of energy and temperature is done using Heating and Cooling Degree
Days(HDD/CDD). Any analyst should be able to calculate the necessary HDD and or
CDD using the hourly data provided in Requirement 1.1 for the analysis.
Requirement 1.2 should be changed to read something similar to this “Monthly and
annual peak hour actual demands in MW and Net Energy for Load in gigawatthours
(GWh) for the prior year. If hourly temperatures were not provided in Requirement
1.1 provide Heating and Cooling degree days base 65, and humidity data for the
prior year from weather station(s) in proximity to the load center(s)”.
MOD -019 is yes to all directives
MOD-020 is yes to all directives
MOD-021 is yes to all directives
PRC-004-2 is yes to all directives with comments:
The addition of LSE’s and TO’s was to be considered, but not necessarily accepted. The
changes are acceptable but leave a little confusion about which misoperations each entity is
required to address. See our proposed modification: Suggested wording for R1: The
Transmission Owner and any entity listed below that individually or jointly owns a
transmission Protection System shall analyze Misoperations of the transmission Protection
Systems that it owns and shall develop and implement a Corrective Action Plan for those
Misoperations according to the Regional Entity’s procedures to avoid future Misoperations of
a similar nature.
VAR-001-2 is yes to all directives
Thanks to all of you for your quick turn around on this and for your patience while I
pestered you to make sure I understood the comments. I'll be out of the office for the
remainder of today and tomorrow, returning Monday morning.