Agenda Operating Committee June 6, 2007 1 p.m. to 5 p.m. June 7, 2007 8 a.m. to noon Toronto Marriott Downtown Eaton Centre 525 Bay Street, Toronto, Ontario, Canada 416-597-9200 Item Leader 1. Administration Secretary Action a. Quorum b. Procedures c. Introductions d. Agenda Chairman Approve 2. Consent Agenda Chairman Approve 3. FYI E-tag 1.8 Pat Doran Discuss 4. Committee Officer Elections Secretary Approve 5. NERC Compliance Filing on Reliability Enhancement Programs Dave Nevius Discuss Approve 6. Reliability Criteria and System Limit Concepts 7. Defining “Adequate Level of Reliability” Chairman Discuss 8. Standards BAL-007 through -011 Raymond Vice Discuss 9. Time Error Monitoring and Correction Terry Bilke a. Time Error Monitor Discuss b. Time Error and Inadvertent Management Procedures Discuss 10. Real-time Operations SAR Secretary Discuss 11. Demand Response Dave Nevius Discuss 12. Reliability Coordination Designate and Permit a. Reliability Coordination Information System b. Reliability Plan SaskPower Walter Omoth Approve Ross Wilkinson c. Reliability Plan WECC 13. Reliability Readiness Program Approve Richard Schneider Discuss 14. Next Meeting 116-390 Village Boulevard, Princeton, New Jersey 08540-5721 Phone: 609.452.8060 ▪ Fax: 609.452.9550 ▪ www.nerc.com Operating Committee Meeting June 67, 2007 Item 1. Administration Item 1.a Announcement of Quorum The secretary will announce whether a quorum (two-thirds of the voting members) is in place. NOTE: The committee cannot conduct business without a quorum. Please be prepared to stay for the entire meeting. Item 1.b Procedures The NERC Antitrust Compliance Guidelines, Operating Committee charter, and a summary of Parliamentary Procedures are attached for reference. The secretary will answer questions regarding these procedures. Attachments Antitrust Guidelines Operating Committee Charter Parliamentary Procedures Item 1.c Introduction of Members and Guests The chairman will ask the committee members and guests to introduce themselves. Attachment Operating Committee roster Item 1.d Approval of Agenda Action Approve meeting agenda. Background The chairman will review the agenda, ask for amendments, and then approval. Operating Committee Meeting June 67, 2007 Item 2. Consent Agenda The consent agenda allows the Operating Committee to approve routine items that would not normally need discussion. Any OC member may ask the chairman to remove an item from the consent agenda for formal discussion and action. Action Approve the attached document. Attachment Minutes of March 2122, 2007 Operating Committee meeting. Operating Committee Meeting June 67, 2007 Item 3. FYI – E-tag 1.8 The Interchange Subcommittee has been working on the E-tag revisions. Subcommittee member Pat Doran from the IESO will be available to answer questions about this project. Operating Committee Meeting June 67, 2007 Item 4. Committee Officer Elections Action Elect committee officers for July 1, 2007June 30, 2009. The Nominating Subcommittee recommends Gayle Mayo as chair and Sam Holeman as vice chair. Background and Procedure Section 4 of the Operating Committee charter explains the terms, conditions, and procedures for selecting the committee’s officers. The Operating Committee uses a nominating subcommittee to provide a slate of candidates for the committee’s consideration. (Secretary’s note: Members of the nominating subcommittee are eligible for nomination.) 1. The nominating subcommittee will present its candidate for chair. 2. The committee chairman will then open the floor for additional nominations, and 3. The committee will then vote on the candidates in the order they were nominated. 4. The first candidate to garner a majority (the charter states “majority” in this instance) of the votes is elected a. If there is only one nominee, that person is automatically elected. We will repeat this process for the vice chair candidate. Nominating Subcommittee Derek Cowbourne (chair) Bill Hatfield Sam Holeman Van Wardlaw John Powell Operating Committee Meeting June 67, 2007 Item 5. NERC Compliance Filing on Reliability Enhancement Programs Discussion Item Dave Nevius will lead the discussion of NERC’s draft filing on reliability enhancement programs. Attachment “Compliance Filing on Reliability Enhancement Programs,” in response to paragraph 468 of Order No. 672 Background The Commission requires the electric reliability organization (pursuant to Section 215 of the Federal Power Act) to make a compliance filing no later than one year from the date of certification “proposing reliability enhancement programs that would improve Bulk-Power System reliability, along with a program implementation schedule.” In this filing (attached), NERC describes a number of programs and initiatives it has implemented or is in the process of implementing that have the objective of improving the reliability of the bulk power system. We invite the Operating Committee to review this filing and provide comments to Dave Nevius. Operating Committee Meeting June 67, 2007 Item 6. Reliability Criteria and System Limit Concepts Action Approve posting the Reliability Concepts document for industry comment. This is a follow-up to the morning’s joint meeting. Attachments Letter from Al Miller to the Planning Committee and Operating Committee, May 2, 2007 We will post the lastest “Reliability Criteria and Operating Limit Concepts” document in the joint OC/PC meeting agenda next week. Background We will start with an overview at the joint OC/PC meeting, and then provide time for each committee to discuss the reliability concepts at their own meetings. These are very important discussions because the concepts and ideas before us will, we hope, guide drafting teams as they prepare revisions to our reliability standards in the future. These concepts are also key to the Federal Energy Regulatory Commission’s judgment of our standards as providing an “adequate level of reliability,” a term the Commission has asked NERC to define (see following agenda item). The letter from Al Miller (attached) provides the background for the concepts document. Operating Committee Meeting June 67, 2007 Item 7. Defining “Adequate Level of Reliability” Discussion Item This is a follow-up to the joint OC/PC meeting on this topic. Background In its January 18, 2007 order on compliance filing, FERC directed NERC to file a plan for defining “adequate level of reliability.” The Commission will use that definition when judging the merits of NERC’s reliability standards against the requirements of Section 215 (c) of the Federal Power Act. At this meeting, the Planning Committee and Operating Committee will discuss a draft of this definition offered by the committee officers, and review the plan for presenting the definition to the NERC Board of Trustees in February 2008 and then filing this definition with the Commission. The Operating Committee and Planning Committee officers drafted the following definition of “adequate level of reliability” for the committees to discuss at this meeting. (The NERC staff was not involved in their deliberations.) “An adequate level of bulk power system reliability is required to support the economy, the environment and public health and safety. Adequate reliability is a targeted level of performance, as simulated or in real-time, whereby the bulk power system has been planned with enough reserve, or operated in such manner, so as to supply the anticipated aggregate demand for electricity, including reasonable forecasting error, while operating within equipment and electric system thermal, voltage, and stability limits such that instability, uncontrolled separation, or cascading failures of the bulk power system will not occur as a result of the planned, or unplanned, loss of bulk power system facilities as described in the NERC Transmission Planning (TPL) standards. Adequate reliability also includes the capability to respond to circumstances outside the TPL standards and restore the bulk power system to normal operation to effectively mitigate the impact on public health and safety.” Discussion Points As the committees discuss this definition, we need to keep the following points in mind: 1. Definition of adequate level of reliability in the context of Section 215 (c) of the Federal Power Act: (c) CERTIFICATION—Following the issuance of a Commission rule under subsection (b)(2), any person may submit an application to the Commission for certification as the Electric Reliability Organization. Operating Committee Meeting June 67, 2007 The Commission may certify 1 such ERO if the Commission determines that such ERO— (1) has the ability to develop and enforce, subject to subsection (e)(2), reliability standards that provide for an adequate level of reliability of the bulk-power system; and…. (Emphasis added) The Commission is asking NERC to provide this definition so it can judge our standards according to this provision in the act. 2. State savings provisions of the Act: (i) SAVINGS PROVISIONS.—(1) The ERO shall have authority to develop and enforce compliance with reliability standards for only the bulk-power system. (2) This section does not authorize the ERO or the Commission to order the construction of additional generation or transmission capacity or to set and enforce compliance with standards for adequacy or safety of electric facilities or services. (3) Nothing in this section shall be construed to preempt any authority of any State to take action to ensure the safety, adequacy, and reliability of electric service within that State, as long as such action is not inconsistent with any reliability standard,…. (Emphasis added) The savings provisions mean that NERC cannot compel any entity to construct facilities. In other words, we cannot write standards that require specific levels of generation reserves or ensure that all customer demand is served. 3. Applicability of the definition. The definition must be applicable to all NERC reliability standards. When we submit a standard to the board and Commission for approval, we will need to make sure that standard supports the definition of adequate level of reliability. This includes standards on planning, operations planning, and real-time operations. The Standards Committee will revise the standards process by adding a reference to this definition. Procedure NERC, through the PC and OC, committed to 1) develop a “straw man” definition, 2) seek industry-wide comment, 3) request Commission staff’s direct participation in these technical discussions, and 4) otherwise coordinate with Commission staff at periodic intervals throughout this process to obtain input and gauge conformance to Commission expectations. Key PC/OC milestones: December 31, 2007: After industry review and comment, propose a definition to the NERC Board of Trustees. Operating Committee Meeting June 67, 2007 February 2008 Board of Trustees meeting: Present a recommendation for board approval. The definition, as approved, will be subsequently filed with the Commission and applicable regulatory authorities in Canada. Operating Committee Meeting June 67, 2007 Item 8. Standards – BAL-007 through -011 Discussion Item Raymond Vice, a member of the Balance Resources and Demand Standard Drafting Team, will solicit the Operating Committee’s thoughts and suggestions on how to proceed with these standards. Attachments Ballot Results BAL-007 through -011 Revised SAR, “Reliability-Based Control” Letter – Gerry Adamski to Regional Managers – Extending the Field Test, May 17, 2007 Summary The ballot body did not approve these standards, and the Board of Trustees would like the Operating Committee to provide its insight on the outcome of the ballot and possible next steps for this standard. The drafting team has fully explained the concept of these standards to the Operating Committee over the past three years, focusing on the Balancing Area ACE Limit (BAAL) concepts, and then on the results of the field test. Mr. Vice, who is a member of the standard drafting team, will review the ballot results and discuss the new SAR, which the Standards Committee has already approved. The Standards Committee is also forming a new standard drafting team. Background Proposed standards BAL-007 through -011 were not approved (the ballot results are attached). At its May 2 meeting, the NERC Board of Trustees discussed the results of the ballot, and some board members asked for additional insight into the reasons the standard was not approved. What were the reliability arguments? Would the standard have been approved if more utilities had participated in the field trial? (See list at right.) The standard drafting team regularly visited the Operating Committee over the past few years as the team developed and tested the standard. The field trial showed that interconnection frequency had not deteriorated, though it did exhibit frequency excursions around the time of the on-to-off peak periods that were attributed to the end of the 16-hour on-peak energy sales. Items 8 10 deal with NERC standards. Operating Committee Meeting June 67, 2007 Just before the first ballot of the standard last fall, the Operating Committee provided its opinion on the merits of the standard (see following page). While the committee generally supported and recommended the standard be approved, it also pointed out two concerns: 1) The retirement of the Disturbance Control Standard at the same time the new standards became effective, and 2) the effects of the new Balancing Area ACE Limits on transmission line flow. (Several OC members suggested keeping the DCS for 18 months, or until the new BAAL standard proved to successfully deal with ACE recovery after large generation failures.) The standard was not approved, and several ballot body members cited the retirement of the DCS as the reason for their negative vote. Others noted their concern about the effects of the BAAL standard on line flows. The drafting team revised the implementation of the BAAL standard to keep the DCS in place, and submitted the standard for a second ballot this spring. Analysis of Ballot Results We can draw at least two conclusions from the ballot results: 1. Most of the negative ballots were from ballot body members in WECC, NPCC, and FRCC. Most of them expressed their concern about the potential for transmission line overloads caused by the wider BAAL limits when the balancing authority was helping interconnection frequency, and 2. The 14 field test participants represented about one-half of the NERC-wide load, but only a small percentage of the 214 ballot body members. Therefore, even though the field test results have not linked transmission line overloads to the BAAL standard, sufficient ballot body members remained skeptical that this link would not materialize. What’s Next The Balance Resources and Demand standard drafting team has proposed a new SAR (also attached) that adds transmission line reliability to the BAAL standards. The drafting team is also actively soliciting other utilities to participate in the field trial so they can see first-hand whether the BAAL standards adversely affect transmission system loading. The Standards Committee is forming a new drafting team. Operating Committee Meeting June 67, 2007 Topics to Discuss In addition to the proposed SAR, the Operating Committee should consider these questions: 1. Does the revised SAR address the reliability issues that the Operating Committee discussed last fall? 2. What role does field testing play when balloting a standard? 3. Does the OC have specific comments it would like to send the drafting team? Excerpt from September 1314, 2006 OC Meeting Minutes: Opinion on BAL-007 through -011 Balance Resources and Demand Discussion Standard drafting team member Doug Hils presented the latest results of the field trial in which many utilities in the Eastern Interconnection have been participating. This evoked considerable discussion within the committee. Most of the comments focused on the planned retirement of standard BAL-002, also known as the Disturbance Control Standard (DCS), within 18 months of the implementation of new Balancing Area ACE Limits (BAAL) standards. Retiring the DCS effectively extends the recovery time for generation loss to 30 minutes because the BAAL standards do not distinguish generation loss from other events that result in a large area control error. Some committee members were concerned that allowing balancing authorities more leeway in controlling their ACE when the Interconnection frequency error was low could result in more unscheduled interchange, and increased line loading. Mr. Hils noted that, so far, the field trial has not turned up this problem. Opinion “The Operating Committee believes BAL-007 through -011 should be approved. Eastern Interconnection frequency performance has been consistent with previous years or improved since the field trials began. The standard considers Interconnection frequency error and requires balancing authorities to take action as the frequency approaches specified high or low limits. “The committee believes the Disturbance Control Standard should remain in effect and be eliminated only after satisfactory field trials.” Approved by show of hands: 23 in favor and 4 opposed. Operating Committee Meeting June 67, 2007 Item 9. Time Error Monitoring and Correction Item 9.a Time Error Monitor Discussion Item The OC needs to discuss its expectations of the interconnection time error monitors, considering they perform this task voluntarily. Resources Subcommittee Chairman Terry Bilke will lead this discussion. Attachments Memo – Roger Harszy to Dave Whiteley Letter Dave Whiteley to Roger Harszy, “Standard BAL-004, ‘Time Error Correction,’” May 11, 2007 NAESB Time Error Correction Business Practice Background Mr. Harszy’s memo requests a waiver for the Midwest Independent System Operator (MISO) from BAL-004, requirement 2, considering that MISO performs the time monitoring tasks voluntarily: As Mr. Whiteley explained in his response, NERC cannot waive compliance with its standards. We also explained that NERC would not assess a penalty for non-compliance with requirement 2, and asked MISO to continue serving voluntarily as the interconnection’s time monitor until the Operating Committee resolved the issue. Operating Committee Meeting June 67, 2007 Ideas for Resolving Issue Should we remove requirement 2 from BAL-004? (We would initiate this with a SAR.) requirement 1 requires the time monitor to be a reliability coordinator designated by the Operating Committee. Do we need any other guidelines? For example, the Operating Committee could establish this procedure: Time Error Monitors and Correction Approved by the Operating Committee: dd/mm/yyyy Designated time monitors: 1. 2. 3. 4. Correction procedures 1. Monitor time error. 2. Initiate or terminate time correction actions according to NAESB Time Error Correction Business Practice or at the request of a reliability coordinator or balancing authority. We could place this in the Operating Manual. Operating Committee Meeting June 67, 2007 Item 9.b Time Error and Inadvertent Management Procedures Discussion Item Terry Bilke will seek the Operating Committee’s opinions on a Time and Inadvertent Management Procedure SAR for the Eastern Interconnection. Attachments Standards Authorization Request, “Time and Inadvertent Management Procedures (Eastern Interconnection)” NAESB Inadvertent Interchange Payback Business Practice Background Here are the features of the SAR (excepted): Change in Time Error Procedures: Expand the time window and reduce the frequency offset such that TECs are implemented if Time Error exceeds ±20 seconds (East) at 22:00 Central Prevailing Time. If this threshold is reached, a TEC is implemented at midnight (2 hours later) with a scheduled frequency offset of +0.01Hz (rather than the present +0.02Hz)and run for a full clock day (unless stopped for reliability reasons. Unilateral Payback Correcting Time Error: In addition to current procedures, allow unilateral payback via one of the following two methods whenever the BA Inadvertent Interchange Balance and Time Error have the same sign: ACE ( I A I S ) B( f A f S ) An offset of scheduled frequency of +0.02 Hz, or If the scheduled frequency setting cannot be offset, a Net Interchange Schedule (MW) equal to 20% of the BA Bias. This unilateral Inadvertent payback ends when the time error is zero or has changed signs, the accumulation of inadvertent interchange has been corrected to zero, or a scheduled time error correction begins, which takes precedence over offsetting frequency schedule to pay back inadvertent. Financial Settlement: Allowing financial settlement of Inadvertent Interchange prevents a second flow of energy to correct an unscheduled flow of energy in previous hours. The terms of the financial inadvertent settlement remain private, the parties and amount of Inadvertent Interchange would be reported to NERC. NAESB, at its discretion, may enact standards on terms and mechanisms for settlement. To provide assurance to the industry, the SAR proposes a field-trial of at least 6 months to be followed by a performance report prior to a standard being presented for ballot. This standard would also require changes in the NAESB Time Error and Inadvertent Interchange Payback Business Practices. The Eastern Interconnection time error limits are now ± 10 seconds, and unilateral payback limit is L10. Operating Committee Meeting June 67, 2007 Item 10. Real-time Operations SAR Discussion Item Don Benjamin will introduce this item. This SAR has been posted for a 30-day comment period that ends on June 13. So this would be an ideal time for the Operating Committee to discuss the SAR and provide comments to the drafting team. Attachment Standards Authorization Request, “Real-time Operations” Background The SAR proposes changes to number of standards, including all the TOP standards. The changes are generally aimed at reducing redundant requirements (where the same language shows up in two different standards) and tidying up the language. (Of course, “tidy” to some is a major revision to others.) SAR drafting team included several questions in the SAR comment form, and the Operating Committee may wish to discuss the first two: The first question asks, in essence, whether we need “best practices,” or “guides.” The OC has discussed this in the past, and believes there is merit in listing “good things to do.” The risk is they become de-facto standards even though we would add warning labels that they are not. If the OC still supports the idea of listing a set of guides, this is something the OC subcommittees should pursue. The second question asks whether NERC needs standards for mitigating SOLs. SOLs are “local,” so to speak, and generally deal with equipment protection, though mostly by inference (as in “you Operating Committee Meeting June 67, 2007 must operate within limits” as opposed to “you must not allow equipment to exceed its short-term rating”). Do we need standards for protecting equipment? Do we need standards that require transmission operators to take action, including load shedding, to protect equipment, or is that intuitively obvious? Given that SOLs can turn into IROLs, do we need SOL standards? The Reliability Concepts document suggests new definitions of SOL and IROL. Operating Committee Meeting June 67, 2007 Item 11. Demand Response Discussion Item Dave Nevius will lead this discussion. This is a follow-up to the presentations on demand response at the joint OC/PC meeting. Operating Committee Meeting June 67, 2007 Item 12. Reliability Coordination Item 12.a Reliability Coordination Information System Action 1. Designate the Reliability Coordinator Working Group (RCWG) as the grantor of access to the Reliability Coordinator Information System (RCIS), and, as part of this action, 2. Permit access (either read-only or read/write) to the RCIS only upon the approval of the RCWG and as specified in the reliability coordinators’ plans. Background NERC has maintained the Reliability Coordinator Information System for many years as a Web-based communications system specifically for the reliability coordinators. The NERC staff has been managing the RCIS with help from the RCWG, and allows reliability coordinators to participate in this system once the reliability coordinator’s plan is approved. Balancing Authority Access to RCIS When the RCIS was first implemented, the balancing authorities and transmission operators in the VACAR area were also provided access because it provided them a simple way to communicate with their reliability coordinator. This BA/TOP access is specified in VACAR’s reliability coordinator plan, which the Operating Reliability Subcommittee (ORS) and OC have approved. Recently, the RCWG has received requests from other balancing authorities, transmission operators, and regional council staff for either read-only, or full read/write access to the RCIS. The working group has discussed this issue but has not resolved it, deciding instead to seek the Operating Committee’s counsel. One of the underlying questions is “Who decides access rules for the RCIS?” Recommendations from the Operating Reliability Subcommittee The Operating Reliability Subcommittee chairman, Jim Castle, and NERC staff have discussed this, and we believe the Operating Committee should consider two actions that would help the RCWG address the RCIS access issue: First, recognizing that the Reliability Coordinator Information System is primarily intended for reliability coordinator communications, the Operating Committee should designate the RCWG as the grantor of RCIS access. This would allow the RCWG to allow access (either read-only or read/write as the working group sees fit) to balancing authorities and transmission Operating Committee Meeting June 67, 2007 operators once those organizations have signed the necessary confidentiality agreement, been listed in their respective reliability coordinator’s plan, and the plan approved by the ORS. It would be up to the RCWG to grant access to all other parties. Second, the OC should agree that RCIS access is permitted only to those organizations that are identified in the reliability coordinator’s plan. Item 12.b Reliability Plan – SaskPower Action Approve the SaskPower’s reliability coordination plan. Walter Omoth and Ross Wilkinson from SaskPower will be available to answer questions about this plan. Attachment “Reliability Coordinator Reliability Plan for the SaskPower Subregion of the Midwest Reliability Organization,” March 20, 2007 Background The Operating Reliability Subcommittee has approved the SaskPower reliability plan, subject to SaskPower successfully completing a reliability coordinator reliability readiness pre-operational evaluation scheduled for this fall. The ORS recommends the OC approve the plan (attached), with the understanding that 1.) the ORS will grant access to the RC “tools” once the subcommittee is satisfied with the results of the pre-operational evaluation, and 2.) the ORS will notify the OC of the results of the evaluation. The flowchart on the right shows where we are in approving this plan. Operating Committee Meeting June 67, 2007 Item 12.c Reliability Plan – WECC Action Approve WECC’s reliability plan. Attachment “Western Electricity Coordinating Council Reliability Coordinator Plan,” April 24, 2003 Background The ORS recommends the OC approve the WECC plan (attached). No pre-operational evaluation is necessary. Operating Committee Meeting June 67, 2007 Item 13. Reliability Readiness Program Discussion Item Richard Schneider will review the activities of the Reliability Readiness Program. Operating Committee Meeting June 67, 2007 Item 14. Next Meeting