Stakeholder Comparison Comment Rationale Matrix 2012-10-16 AESO AUTHORITATIVE DOCUMENT PROCESS Alberta Reliability Standard – BAL-005-AB-0.2b Automatic Generation Control NOTE: The AESO is asking market participants to give an initial indication of their support for, or opposition to, the specific Alberta Reliability Standard variances to the NERC requirements referenced below. Such an initial indication assists in the AESO’s practical understanding of the receptivity of the industry to the proposed changes, and in that regard the AESO thanks, in advance, all market participants who choose to respond. With regard to the specific standard changes and their implications, such responses are without prejudice to the rights of market participants under the Act, any regulations, or related decisions of the Commission. Date of Request for Comment [yyyy/mm/dd]: Period of Consultation [yyyy/mm/dd]: 2012/10/16 2012/10/16 Comments From: through 2012/11/16 Contact: Phone: E-mail: ars_comments@aeso.ca Date [yyyy/mm/dd]: Listed below is the summary of changes for the proposed new, removed or amended sections of the standard. Please refer back to the Letter of Notice under the “Attachments to Letter of Notice” section to view the proposed content changes to the standard. Issued for stakeholder consultation: 2012-10-16 1 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b Purpose This standard establishes requirements for Balancing Authority Automatic Generation Control (AGC) necessary to calculate Area Control Error (ACE) and to routinely deploy the Regulating Reserve. The standard also ensures that all facilities and load electrically synchronized to the Interconnection are included within the metered boundary of a Balancing Area so that balancing of resources and demand can be achieved. Purpose Applicability 4.1. Balancing Authorities 4.2. Generator Operators 4.3. Transmission Operators 4.4. Load Serving Entities Applicability 1 The purpose of this reliability standard is to establish the necessary related requirements for the ISO`s automatic generation control. This reliability standard applies to: (a) the legal owner of a transmission facility that provides frequency data the ISO uses for automatic generation control which AESO Reason for Difference Stakeholder Comments AESO Replies New Amended Deleted Alberta Variance1: The AESO interprets that NERC BAL-005-0.2b R1 applies to market participants receiving service under Rate DTS of the ISO tariff and all generating units, transmission facilities and load connected to the interconnected electric system. These entities are subject to the ISO tariff and are already required to be within the metered boundaries of the Alberta balancing area. Consequently, it is not necessary to include the metered boundary of a balancing authority in proposed BAL-005-AB-0.2b. New Amended Deleted The terms used to describe applicable entities in proposed BAL005-AB-0.2b have been amended from the NERC version in order to correctly identify the applicable An Alberta variance is a change from the US Reliability Standard that the AESO has determined is material. Issued for stakeholder consultation: 2012-10-16 2 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b such frequency data is collected from the source the ISO identifies and publishes on the AESO website and may amend from time to time in accordance with the process set out in Appendix 1; (b) the legal owner of a generating unit that provides frequency data the ISO uses for automatic generation control which such frequency data is collected from the source the ISO identifies and publishes on the AESO website and may amend from time to time in accordance with the process set out in Appendix 1; and AESO Reason for Difference entities in Alberta and to align with terms included in the AESO's Consolidated Authoritative Documents Glossary. In addition, the legal owner has been assigned as the applicable entity type rather than the operator as the requirements pertain to metering equipment, devices and their accuracy. Stakeholder Comments AESO Replies (c) the ISO. (i) Effective Date Effective Date Janaury 1, 2014 R1. All generation, transmission, and load operating within an Interconnection must be included within the metered boundaries of a Balancing Authority Area. Issued for stakeholder consultation: 2012-10-16 New Amended Deleted Alberta Variance1: The AESO 3 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b R1.1. Each Generator Operator with generation facilities operating in an Interconnection shall ensure that those generation facilities are included within the metered boundaries of a Balancing Authority Area. R1.2. Each Transmission Operator with transmission facilities operating in an Interconnection shall ensure that those transmission facilities are included within the metered boundaries of a Balancing Authority Area. AESO Reason for Difference interprets that NERC BAL-005-0.2b applies to market participants receiving service under Rate DTS of the ISO tariff and all generating units, transmission facilities and load connected to the interconnected electric system. These entities are subject to the ISO tariff and are already required to be within the metered boundaries of the Alberta balancing area. Consequently, it is not necessary to include NERC requirement R1 and its subsections in the Alberta reliability standard. Stakeholder Comments AESO Replies R1.3. Each Load-Serving Entity with load operating in an Interconnection shall ensure that those loads are included within the metered boundaries of a Balancing Authority Area. R2. Each Balancing Authority shall R1 The ISO must maintain maintain Regulating Reserve that can regulating reserve to meet the control performance standard. be controlled by AGC to meet the Control Performance Standard. New Amended Deleted Clarified requirement R1 to remove reference to automatic generation control as the AESO definition of regulating reserve contains this term. For greater certainty, regulating reserve is defined as follows: “the Issued for stakeholder consultation: 2012-10-16 4 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b R3. A Balancing Authority providing Regulation Service shall ensure that adequate metering, communications, and control equipment are employed to prevent such service from becoming a Burden on the Interconnection or other Balancing Authority Areas. Alberta BAL-005-AB-0.2b R2 The ISO must, when providing regulation service, have adequate metering, communications, and control equipment employed to prevent such regulation service from becoming a burden on the interconnection or other balancing authority areas. AESO Reason for Difference amount of spinning reserve responsive to automatic generation control that is sufficient to provide normal regulating margin.” Stakeholder Comments AESO Replies New Amended Deleted Amended NERC requirement R3 when drafting Alberta requirement R2 in accordance with the reliability standard drafting principles to add clarity to the requirements. NERC requirement R3 has been retained for possible future use in Alberta, as currently “regulation service” does not exist in Alberta. R4. A Balancing Authority providing Regulation Service shall notify the Host Balancing Authority for whom it is controlling if it is unable to provide the service, as well as any Intermediate Balancing Authorities. R3 The ISO must, when providing regulation service, notify the host balancing authority for which it is controlling if it is unable to provide the regulation service and must also notify any intermediate balancing authorities. Issued for stakeholder consultation: 2012-10-16 New Amended Deleted Amended NERC requirement R4 when drafting Alberta requirement R3 in accordance with the reliability standard drafting principles to add 5 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b AESO Reason for Difference clarity to the requirements. Stakeholder Comments AESO Replies NERC requirement R4 has been retained for possible future use in Alberta, as currently “regulation service” does not exist in Alberta. R5. A Balancing Authority receiving Regulation Service shall ensure that backup plans are in place to provide replacement Regulation Service should the supplying Balancing Authority no longer be able to provide this service. R4 The ISO must, when receiving regulation service, have backup plans in place to provide replacement regulation service should the supplying balancing authority no longer be able to provide this service. New Amended Deleted Amended NERC requirements R5 when drafting Alberta requirement R4 in accordance with the reliability standard drafting principles to add clarity to the requirements. NERC requirement R5 has been retained for possible future use in Alberta, as currently “regulation service” does not exist in Alberta. R6. The Balancing Authority’s AGC shall compare total Net Actual Interchange to total Net Scheduled Interchange plus Frequency Bias obligation to determine the Balancing Authority’s ACE. Single Balancing Authorities operating asynchronously R5 The ISO must use area control error calculations in its automatic generation control that compare total net actual interchange to total net scheduled interchange plus frequency bias obligation except that the ISO’s automatic generation Issued for stakeholder consultation: 2012-10-16 New Amended Deleted NERC requirement R6 contains two requirements that have been divided 6 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b may employ alternative ACE calculations such as (but not limited to) flat frequency control. If a Balancing Authority is unable to calculate ACE for more than 30 minutes it shall notify its Reliability Coordinator. Alberta BAL-005-AB-0.2b control may use alternative area control error calculations when the ISO is operating the interconnected electric system asynchronously. R7. The Balancing Authority shall operate AGC continuously unless such operation adversely impacts the reliability of the Interconnection. If AGC has become inoperative, the Balancing Authority shall use manual control to adjust generation to maintain the Net Scheduled Interchange. R7 Subject to requirement R8, the ISO must operate its automatic generation control continuously. R8. The Balancing Authority shall ensure that data acquisition for and AESO Reason for Difference into Alberta requirements R5 and R6 to separate the responsibilities of the AESO. Stakeholder Comments AESO Replies R6 The ISO must notify the WECC Reliability Coordinator if the ISO is unable to calculate the area control error for more than thirty (30) minutes consecutively. R8 The ISO must, if automatic generation control has become inoperative or operation of automatic generation control could adversely impact the reliability of the interconnection, use manual controls to adjust generation to maintain the net scheduled interchange. R9 The ISO must acquire data for, and calculate, the area control error Issued for stakeholder consultation: 2012-10-16 New Amended Deleted NERC requirement R7 contains two requirements that have been divided into Alberta requirements R7 and R8 to separate the responsibilities of the AESO. Alberta requirement R8 was amended to include the use of manual controls to adjust generation to maintain the net scheduled interchange if the operation of automatic generation control could adversely impact the reliability of the interconnection. New Amended 7 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b calculation of ACE occur at least every six seconds. Alberta BAL-005-AB-0.2b at least every nine (9) seconds. R8.1. Each Balancing Authority shall provide redundant and independent frequency metering equipment that shall automatically activate upon detection of failure of the primary source. This overall installation shall provide a minimum availability of 99.95%. R9. The Balancing Authority shall include all Interchange Schedules with Adjacent Balancing Authorities in the calculation of Net Scheduled Interchange for the ACE equation. R9.1 The ISO must use frequency data from redundant and independent frequency metering equipment that automatically activates upon detection of failure of the primary source; and R9.2 The ISO must provide frequency metering data to its automatic generation control with a minimum availability of 99.95%. R10 Subject to requirement R10.1 the ISO must include all interchange schedules with adjacent balancing authorities in the ISO’s calculation of net scheduled interchange for Issued for stakeholder consultation: 2012-10-16 AESO Reason for Difference Stakeholder Comments AESO Replies Deleted Alberta Variance1: The time allotted for data acquisition and calculation of ACE was changed from six (6) seconds to nine (9) seconds due to communications latency with the extra link between facility owners and the AESO. The Alberta interconnected electric system has been operating reliably under this condition for quite some time. Amended NERC requirement R8.1 when drafting Alberta requirements R9.1and R9.2 in accordance with the reliability standard drafting principles to add clarity to the requirements. NERC requirement R8.1 has been divided into Alberta requirements R9.1 and R9.2 to separate the requirements for acquiring frequency data and the availability of frequency metering data. New Amended Deleted 8 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b the area control error calculation. R9.1. Balancing Authorities with a high voltage direct current (HVDC) link to another Balancing Authority connected asynchronously to their Interconnection may choose to omit the Interchange Schedule related to the HVDC link from the ACE equation if it is modeled as internal generation or load. R10.1 The ISO may omit the interchange schedule for a high voltage direct current link to another balancing authority from the area control error calculation if such interchange schedule is modeled by the ISO as internal generation or load. R10. The Balancing Authority shall include all Dynamic Schedules in the calculation of Net Scheduled Interchange for the ACE equation. R11 The ISO must include all dynamic schedules in the calculation of net scheduled interchange for the area control error calculation. AESO Reason for Difference Amended NERC requirements R9 and R9.1 when drafting Alberta requirements R10 and R10.1 in accordance with the reliability standard drafting principles to add clarity to the requirements. Stakeholder Comments AESO Replies New Amended Deleted Amended NERC requirement R10 when drafting Alberta requirement R11 in accordance with the reliability standard drafting principles to add clarity to the requirement. R11. Balancing Authorities shall include the effect of ramp rates, which shall be identical and agreed to between affected Balancing Authorities, in the Scheduled Interchange values to calculate ACE. R12 The ISO must include the effect of ramp rates, which must be identical and agreed to between affected balancing authorities, in the scheduled interchange values to calculate the area control error. Issued for stakeholder consultation: 2012-10-16 New Amended Deleted Amended NERC requirement R11 when drafting Alberta requirement R12 in accordance with the reliability standard drafting principles to add 9 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b R12. Each Balancing Authority shall include all Tie Line flows with Adjacent Balancing Authority Areas in the ACE calculation. Alberta BAL-005-AB-0.2b R13 The ISO must include all synchronous interconnection flows of real power in the area control error calculation. AESO Reason for Difference clarity to the requirement. Stakeholder Comments AESO Replies New Amended Deleted Amended NERC requirement R12 to clarify that the area control error calculation only includes synchronous interconnection flows of real power. R12.1. Balancing Authorities that share a tie shall ensure Tie Line MW metering is telemetered to both control centers, and emanates from a common, agreed-upon source using common primary metering equipment. Balancing Authorities shall ensure that megawatt-hour data is telemetered or reported at the end of each hour. R13.1 The ISO must use MW metering data for each synchronous interconnection that: Issued for stakeholder consultation: 2012-10-16 (a) emanates from a common, agreed-upon source using common primary metering equipment; and (b) is telemetered to its system coordination centre and the control centre of the adjacent balancing authority; New Amended Deleted NERC requirement R12.1 contains two requirements. The first requirement has been amended into Alberta requirement R13.1. the second is already in effect under BAL-006-AB-1 requirement R3 “The ISO must ensure all of the AIES’s interconnection points are equipped with common megawatt hour meters, with readings provided hourly to the control centers of adjacent balancing authorities.” 10 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b R12.2. Balancing Authorities shall ensure the power flow and ACE signals that are utilized for calculating Balancing Authority performance or that are transmitted for Regulation Service are not filtered prior to transmission, except for the Antialiasing Filters of Tie Lines. R13.2 The legal owner of a transmission facility must not filter: (a) MW metering data for synchronous interconnections; or (b) area control error signals transmitted to the ISO, except for the anti-aliasing filters of interconnections; R13.3 The ISO must use unfiltered: (a) MW metering data for synchronous interconnections; or AESO Reason for Difference Stakeholder Comments AESO Replies New Amended Deleted NERC requirement R12.2 has been divided into Alberta requirements R13.2 and R13.3 to separate the responsibilities of the AESO and the legal owners of transmission facilities. . (b) area control error signals; provided by the legal owner of a transmission facility for calculating the ISO’s performance under the control performance standard, except for the anti-aliasing filters of interconnections; and Issued for stakeholder consultation: 2012-10-16 11 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b R12.3. Balancing Authorities shall install common metering equipment where Dynamic Schedules or Pseudo-Ties are implemented between two or more Balancing Authorities to deliver the output of Jointly Owned Units or to serve remote load. Alberta BAL-005-AB-0.2b R13.4 The ISO must ensure that common metering equipment is installed where dynamic schedules or pseudo-ties are implemented between two (2) or more balancing authorities to deliver the output of jointly owned generating units or to serve remote load. R13. Each Balancing Authority shall perform hourly error checks using Tie Line megawatt-hour meters with common time synchronization to determine the accuracy of its control equipment. The Balancing Authority shall adjust the component (e.g., Tie Line meter) of ACE that is in error (if known) or use the interchange meter error (IME) term of the ACE equation to compensate for any equipment error until repairs can be made. R14 The ISO must perform hourly error checks using intertie MWh meters with common time synchronization to determine the accuracy of its control equipment. R14. The Balancing Authority shall provide its operating personnel with sufficient instrumentation and data recording equipment to facilitate R16 The ISO must provide its operating personnel with real-time values for the area control error, interconnection frequency and net R15 The ISO must adjust the component of the area control error that is in error, if known, or use the interchange meter error (IME) term of the area control error equation, to compensate for any metering equipment error until repairs can be made. Issued for stakeholder consultation: 2012-10-16 AESO Reason for Difference Stakeholder Comments AESO Replies New Amended Deleted Amended NERC requirement R12.3 when drafting Alberta requirement R13.4 in accordance with the reliability standard drafting principles to add clarity to the requirement. New Amended Deleted NERC requirement R13 contains two requirements that have been divided into Alberta requirements R14 and R15 to separate the responsibilities of the AESO. New Amended Deleted 12 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b monitoring of control performance, generation response, and after-thefact analysis of area performance. As a minimum, the Balancing Authority shall provide its operating personnel with real-time values for ACE, Interconnection frequency and Net Actual Interchange with each Adjacent Balancing Authority Area. Alberta BAL-005-AB-0.2b actual interchange with each adjacent balancing authority. R15. The Balancing Authority shall provide adequate and reliable backup power supplies and shall periodically test these supplies at the Balancing Authority’s control center and other critical locations to ensure continuous operation of AGC and vital data recording equipment during loss of the normal power supply. R18 The ISO must have adequate and reliable backup power supplies at the ISO’s coordination centre and at the ISO’s backup coordination centre, which must be periodically tested, to maintain continuous operation of the automatic generation control and vital data recording equipment during loss of the normal power supply. New Amended Deleted R19 The ISO must: New Amended Deleted R16. The Balancing Authority shall sample data at least at the same periodicity with which ACE is calculated. The Balancing Authority shall flag missing or bad data for operator display and archival R17 The ISO must provide its operating personnel with sufficient instrumentation and data recording equipment to facilitate the monitoring of the control performance standard, generation response and after-the-fact analysis of area performance. Issued for stakeholder consultation: 2012-10-16 (a) sample area control errorrelated data at least at the same periodicity with which the area control error is calculated; AESO Reason for Difference Stakeholder Comments AESO Replies NERC requirement R14 contains two requirements that have been divided into Alberta requirements R16 and R17 to separate the responsibilities of the AESO. Amended NERC requirement R15 when drafting Alberta requirement R18 to align with reliability standard drafting principles. Provided clarity that “other critical locations” only applies to the ISO’s backup coordination centre. Amended NERC requirement R16 when drafting Alberta requirement 13 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b purposes. The Balancing Authority shall collect coincident data to the greatest practical extent, i.e., ACE, Interconnection frequency, Net Actual Interchange, and other data shall all be sampled at the same time. R17. Each Balancing Authority shall at least annually check and calibrate its time error and frequency devices against a common reference. The Balancing Authority shall adhere to the minimum values for measuring devices as listed below: Device Accuracy Digital 0.001 Hz frequency transducer MW, MVAR, 0.25 % of full and voltage scale transducer Remote 0.25 % of full terminal unit scale Potential 0.30 % of full transformer scale Current 0.50 % of full transformer scale Alberta BAL-005-AB-0.2b (b) flag missing or bad area control error-related data for operator display and archival purposes; and AESO Reason for Difference R19 to align with reliability standard drafting principles. Stakeholder Comments AESO Replies (c) collect coincident area control error-related data to the greatest extent practical. R20 Each legal owner of a transmission facility, legal owner of a generating unit, and the ISO must: (a) at least once every calendar year, check and calibrate its time error and frequency devices used for automatic generation control against a common reference; but if these devices cannot be calibrated, (b) cross-check its time error and frequency devices used for automatic generation control against other properly calibrated equipment at least once every calendar year; and replace them if they do not meet the required level of accuracy as specified in requirements R21. Issued for stakeholder consultation: 2012-10-16 New Amended Deleted Note: The AESO will post a list of time error and frequency devices, used for automatic generation control on the AESO website. Requirements R20 and R21 have been revised to align with the NERC interpretation as included in Appendix 2 at the end of this document. Please note that the NERC interpretation will not be included in proposed BAL-005-AB0.2b. NERC requirement R17 contains requirements that have been divided into Alberta requirements R20 and R21. 14 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b R21 Each legal owner of a transmission facility, legal owner of a generating unit, and the ISO must adhere to the following accuracy values for measuring devices used for automatic generation control data as identified in requirement R20: Device Digital frequency transducer Stakeholder Comments AESO Replies Accuracy 0.001 Hz MR1 Evidence of maintaining regulating reserve as required in requirement R1 exists. Evidence may include data files showing the control performance standard was met. Issued for stakeholder consultation: 2012-10-16 AESO Reason for Difference Alberta Variance: Requirements R20 and R21 apply to legal owners of transmission facilities and legal owners of generating units as specified in the Applicability section of this standard in addition to the AESO. New Amended Deleted Added to align with Alberta requirement R1. 15 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b AESO Reason for Difference Stakeholder Comments AESO Replies MR2 Evidence of having adequate metering, communications, and control equipment employed as required in requirement R2 exists. Evidence may include regulation reserve service agreements or other documentation confirming that metering, communications and control equipment employed are adequate to prevent such service from becoming a burden. MR3 Evidence of notifying the host balancing authority and any intermediate balancing authorities as required in requirement R3 exists. Evidence may include voice recordings or operator logs. MR4 Evidence of having backup plans in place as required in requirement R4 exists, Evidence may include a dated and in effect backup plans. Issued for stakeholder consultation: 2012-10-16 16 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b MR5 Evidence of using area control error calculations in the automatic generation control of the ISO as required in requirement R5 exist. Evidence may include the algorithm or codes of the calculation of the area control error. AESO Reason for Difference Stakeholder Comments AESO Replies New Amended Deleted Added to align with Alberta requirements R5, R6, and R7. MR6 Evidence of notifying the WECC Reliability Coordinator as required in requirement R6 exists. Evidence may include operator logs or voice recordings. MR7 Evidence of operating automatic generation control continuously as required in requirement R7 exists. Evidence may include: (a) data files showing the automatic generation control was operated continuously; (b) where the automatic generation control was not operated continuously documentation of the rationale of not operating automatic generation control continuously; and (c) operator logs and voice Issued for stakeholder consultation: 2012-10-16 17 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b recordings. MR8 Evidence of using manual controls to adjust generation as required in requirement R8 exists. Evidence may include operator logs or voice recordings. MR9 Evidence of acquiring data for, and calculating area control error as required in requirement R9 exists. Evidence may include documentation of data acquisition and calculation rate. AESO Reason for Difference Stakeholder Comments AESO Replies New Amended Deleted Added to align with Alberta requirements R8 and R9 as well as sub-requirements R9.1and R9.2. MR9.1 Evidence of using frequency data as required in requirement R9.1 exists. Evidence may include a list of independent and redundant frequency metering equipment. MR9.2 Evidence of providing frequency metering data as required in requirement R9.2 exists. Evidence may include records of frequency metering data availability to its automatic generation Issued for stakeholder consultation: 2012-10-16 18 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b control. MR10 Evidence of including all interchange schedules with adjacent balancing authorities in the ISO’s calculation as required in R10 exists. Evidence may include the algorithm or codes of the calculation of the area control error MR10.1 Evidence of omitting the interchange schedule for a high voltage direct current link as allowed in requirement R10.1 exists. Evidence may include modeling data documentation showing that the omitted interchange schedule for a high voltage direct current link was modeled as internal generation or load. MR11 Evidence of including dynamic schedules in the calculation of net scheduled interchange as required in R11 exists. Evidence may include modeling data documentation showing dynamic schedules, if they exist, are included in the area control error equation. Issued for stakeholder consultation: 2012-10-16 AESO Reason for Difference Stakeholder Comments AESO Replies New Amended Deleted Added to align with Alberta requirement R10 and its subrequirements R10.1. New Amended Deleted Added to align with Alberta requirement R11. 19 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b MR12 Evidence of including the effect of ramp rates in the scheduled interchange values as required in requirement R12 exists. Evidence may include: a) documentation showing the effect of ramp rates was included in the calculation of the area control error; and AESO Reason for Difference Stakeholder Comments AESO Replies New Amended Deleted Added to align with Alberta requirement R12. b) documentation showing the ramp rates were identical and agreed to between affected balancing authorities. MR13 Evidence of including all synchronous interconnection flows of real power in the calculation as required in requirement R13 exists. Evidence may include the algorithm or codes of the calculation of the area control error. MR13.1 Evidence of using MW metering values for synchronous interconnections as required in requirement R13.1 exists. Evidence may include measurement definition records and Issued for stakeholder consultation: 2012-10-16 New Amended Deleted Added to align with Alberta requirement R13 and its subrequirements R13.1 through to R13.4. 20 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b documentation showing the agreement on the source and metering equipment with the adjacent balancing authority. AESO Reason for Difference Stakeholder Comments AESO Replies MR13.2 Evidence of not filtering metering data or area control error signals as required in requirement R13.2 exists. Evidence may include data files showing that the MW metering data for synchronous interconnections or area control error signals transmitted to the ISO are not filtered prior to transmission. MR13.3 Evidence of using unfiltered metering data or area control error signals as required in requirement R13.3 exists. Evidence may include data files showing that the unfiltered data received by the ISO is the same data used in the area control error calculation. MR13.4 Evidence of ensuring that common metering Issued for stakeholder consultation: 2012-10-16 21 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b equipment is installed as required in requirement R13.4 exists. Evidence may include documentation showing the agreement on the common metering equipment with the other balancing authority. AESO Reason for Difference MR14 Evidence of performing MWh hourly error checks as required in requirement R14 exists. Evidence may include records of hourly error checks and records of adjustments made for each discrepancy, if any, identified in the hourly error checks. New Amended Deleted MR15 Evidence of adjusting the component of the area control error that is in error as required in requirement R15 exists. Evidence may include files or data showing the error was included in the area control error. New Amended Deleted MR16 Evidence of providing real-time New Issued for stakeholder consultation: 2012-10-16 Stakeholder Comments AESO Replies Added to align with Alberta requirement R14. Added to align with Alberta requirement R15. 22 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b values for area control error, interconnection frequency and net actual interchange, as required in requirement R16 exists. Evidence may include screen shots of the interface displaying the real-time data. MR17 Evidence of providing sufficient instrumentation and data recording equipment as required in requirement R17 exists. Evidence may include a list of instrumentation, data and recording equipment and screen shots of the interface displaying the control performance standard generation response and after-the fact analysis of area performance. AESO Reason for Difference Stakeholder Comments AESO Replies Amended Deleted Added to align with Alberta requirement R16. New Amended Deleted Added to align with Alberta requirements R17 and R18. MR18 Evidence of having adequate and reliable backup power supplies and of periodically testing these supplies as required in requirement R18 exists. Evidence may include a list of backup power supplies, a periodic testing plan for these backup power supplies and records of the tests. MR19 Evidence of sampling, flagging Issued for stakeholder consultation: 2012-10-16 New 23 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b and collecting area control errorrelated data as required in requirement R19 exists. Evidence may include: (a) algorithms of the sampling area control error-related data; AESO Reason for Difference Stakeholder Comments AESO Replies Amended Deleted Added to align with Alberta requirement R19. (b) screenshots of the operator display; (c) archived files for missing or bad area control error related data; and (d) archived files for coincident area control error data. MR20 Evidence of checking, calibrating and replacing time error and frequency devices as required in requirement R20 exists. Evidence may include: (a) a list of time error and frequency devices used for automatic generation control ; New Amended Deleted Added to align with Alberta requirement R20. (b) records of check and calibration against a common reference; Issued for stakeholder consultation: 2012-10-16 24 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b AESO Reason for Difference Stakeholder Comments AESO Replies (c) where the manufacturer’s specification does not require calibration of these devices, records of check and cross-checking against a properly calibrated equipment. MR21 Evidence of adhering to the minimum values for measuring devices as identified in requirement R21 exists. Evidence may include: (a) records of calibration against a common reference showing the accuracy values of these devices; and New Amended Deleted Added to align with Alberta requirements R21. (b) where these devices cannot be calibrated, records of cross-checking against a properly calibrated equipment showing the accuracy values of these devices. Issued for stakeholder consultation: 2012-10-16 25 COMPARISON BETWEEN NERC BAL-005-0.2B AND ALBERTA BAL-005-AB-0.2B Automatic Generation Control NERC BAL-005-0.2b Alberta BAL-005-AB-0.2b Compliance To view the compliance section D of the NERC reliability standard follow this link: http://www.nerc.com/files/BAL-0050_2b.pdf Regional Differences None identified. AESO Reason for Difference Stakeholder Comments AESO Replies The Alberta reliability standards do not contain a compliance section. Compliance with all Alberta reliability standards is completed in accordance with the Alberta Reliability Standards Compliance Monitoring Program, available on the AESO website at: http://www.aeso.ca/loadsettlement/1 7189.html. None identified. Not applicable in Alberta Appendix 1 Amending Process for List of Frequency Data In order to amend the lists referenced in subsections (a) and (b) of section 2, Applicability, the ISO must: (a) upon determining that a source of frequency data is to be added to the list, notify each affected legal owner of a generating unit or legal owner of a transmission facility in writing and determine an effective date, which must be no less than thirty (30) days after the date of notice, for the legal owner to meet the applicable requirements; (b) upon determining that a source of frequency data is to be deleted, notify each affected legal owner of a generating unit or legal owner of a transmission facility in writing and determine an effective date for the legal owner to no longer be required to meet the applicable requirements; and (c) post the amended list with effective dates on the AESO website. Issued for stakeholder consultation: 2012-10-16 26 Appendix 22 NERC Interpretation Effective Date: August 27, 2008 (U.S.) Interpretation of BAL-005-0 Automatic Generation Control, R17 Request for Clarification received from PGE on July 31, 2007 PGE requests clarification regarding the measuring devices for which the requirement applies, specifically clarification if the requirement applies to the following measuring devices: • Only equipment within the operations control room • Only equipment that provides values used to calculate AGC ACE • Only equipment that provides values to its SCADA system • Only equipment owned or operated by the BA • Only to new or replacement equipment • To all equipment that a BA owns or operates BAL-005-0 R17. Each Balancing Authority shall at least annually check and calibrate its time error and frequency devices against a common reference. The Balancing Authority shall adhere to the minimum values for measuring devices as listed below: Device Accuracy Digital frequency transducer ≤ 0.001 Hz MW, MVAR, and voltage transducer ≤ 0.25% of full scale Remote terminal unit ≤ 0.25% of full scale Potential transformer ≤ 0.30% of full scale Current transformer ≤ 0.50% of full scale Existing Interpretation Approved by Board of Trustees May 2, 2007 BAL-005-0, Requirement 17 requires that the Balancing Authority check and calibrate its control room time error and frequency devices against a common reference at least annually. The requirement to “annually check and calibrate” does not address any devices outside of the operations control room. The table represents the design accuracy of the listed devices. There is no requirement within 2 The NERC interpretation in Appendix 2 will not be part of the Alberta reliability standard BAL-005-AB-0.2.b. The interpretation has been applied in the drafting of Alberta requirements R17, R18 and R19. Issued for stakeholder consultation: 2012-10-16 27 the standard to “annually check and calibrate” the devices listed in the table, unless they are included in the control center time error and frequency devices. Interpretation provided by NERC Frequency Task Force on September 7, 2007 and Revised on November 16, 2007 As noted in the existing interpretation, BAL-005-0 Requirement 17 applies only to the time error and frequency devices that provide, or in the case of back-up equipment may provide, input into the reporting or compliance ACE equation or provide real-time time error or frequency information to the system operator. Frequency inputs from other sources that are for reference only are excluded. The time error and frequency measurement devices may not necessarily be located in the system operations control room or owned by the Balancing Authority; however the Balancing Authority has the responsibility for the accuracy of the frequency and time error measurement devices. No other devices are included in R 17. The other devices listed in the table at the end of R17 are for reference only and do not have any mandatory calibration or accuracy requirements. New or replacement equipment that provides the same functions noted above requires the same calibrations. Some devices used for time error and frequency measurement cannot be calibrated as such. In this case, these devices should be cross-checked against other properly calibrated equipment and replaced if the devices do not meet the required level of accuracy. Issued for stakeholder consultation: 2012-10-16 28