WECC 0083 BAL 002 WECC 1 Order 740 Remand Version 1 Comment Response final

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WECC 0083 BAL 002 WECC 1 Order 740 Remand Version 1 Comment Response final Powered By Docstoc
					WECC-0083 BAL-002 Order 740 Remand

Version 1 Comments
Open:        January 17, 2011
Closed:      March 7, 2011




The WECC-0083 BAL-002-WECC-1 Order 740 Remand Drafting Team thanks
everyone who submitted comments on the WECC Regional Standard. This standard
was posted for a 45-day public comment period from January 17, 2011 through March
3, 20111 with an extension of time to March 7, 2011. 2 WECC distributed the initial
notice for this posting on January 17, 2011 with a notice of extension distributed on
March 3, 2011. NERC was noticed of this posting on January 17, 2011. 3

WECC received comments from 18 entities representing 6 industry segments.

The Standard Drafting Team asked stakeholders to provide feedback on the Regional
Standard through a special Standard Comment Form (Survey).

All comments received on the Regional Standard can be viewed in their original format
at:
      1
       Notice 1:
      http://www.wecc.biz/Standards/Development/WECC-
      0083/Shared%20Documents/Posting%201/WECC-0083%20BAL-002-WECC-
      1%20Order%20740%20Remand%20posted%20for%2045-day%20Comment.htm



      2
       Notice 2:
      http://www.wecc.biz/Standards/Development/WECC-
      0083/Shared%20Documents/Posting%201/WECC-0083%20BAL-002-WECC-
      1%20Order%20740%20Remand%20posted%20for%2045-day%20Comment%20-Extended.htm



      3
       Notice 3:
      http://www.wecc.biz/Standards/Development/WECC-
      0083/Shared%20Documents/Posting%201/WECC-0083%20BAL-002-WECC-
      1%20Order%20740%20Remand%20posted%20for%2045-day%20Comment%20-
      %20NERC%20Notice.htm




                                           1
http://www.wecc.biz/Standards/Development/WECC-
0083/Lists/StandardCriterion%2045%20and%2030%20Day%20Comment%20Solicitati/
AllItems.aspx

If you feel that your comment has been overlooked, please let WECC know
immediately. WECC’s goal is to give every comment serious consideration in this
process. If you feel there has been an error or omission, please contact the W. Shannon
Black, Manager of Standards Processes, at sblack@wecc.biz. In addition, there is a
WECC Reliability Standards Appeals Process.4




4
 The appeals process is described in the Process for Developing and Approving WECC Standards:
http://www.wecc.biz/Standards/Documents/WECC%20Standards%20Development%20Process.pdf


                                                2
      The Industry Segments are:

         1 — Transmission Owners
         2 — RTOs, ISOs

         3 — Load-serving Entities

         4 — Transmission-dependent Utilities
         5 — Electric Generators
         6 — Electricity Brokers, Aggregators, and Marketers
         7 — Large Electricity End Users
         8 — Small Electricity End Users
         9 — Federal, State, Provincial Regulatory or other Government Entities
         10 – Regional Reliability Organizations, Regional Entities

                          Commenter       Organization           Industry Segment
                                                          1   2 3 4 5 6 7 8 9 10

1.    Mark Thompson, in    AESO                                √
      consultation with
      Neil Curtis and
      Lane Belsher
2.    Denise Koehn on      Bonneville Power               √        √        √     √
      behalf of Brenda     Administration
      Anderson, Bart
      McManus, Jamie
      Murphy, Kieran
      Connolly, Fran
      Halpin, and Don
      Watkins
3.    Mark J. Smith        Calpine                                          √

4.    Brian Theaker        Dynegy                                           √

5.    Lisa Wildes          Gila River Power                        √

6.    Unknown              Iberdrola Renewables                             √

7.    Oscar Alvarez and    Los Angeles Department of      √        √        √     √
      John Giese           Water and Power
8.    Sandeep Arora        LS Power Development,                            √
                           LLC
9.    John Stout           Mariner Consulting                      √
                           Services, Inc
10.   Rich Salgo           NV Energy                                              √
11.   JJ Jamieson          Portland General Electric                              √

                                               3
                               Merchant
12.   Unknown                  Powerex                                                         √
13.   John Cummings            PPL Energy Plus/PPL                                       √
                               Montana
14.   Unknown                  Salt River Project                   √                   √      √
15.   Pawel Krupa              SCL                                  √
16.   Unknown                  Sempra Generation                                         √
17.   Mike Evans               Shell Energy North America                                      √
                               (US), L.P. ("Shell Energy")
18.   Dan Walter               Tri-State Generation and             √          √        √
                               Transmission Association,
                               Inc.


                                                                                               Graphical
        Respond to this Survey Actions   Settings                                      View:
                                                                                               Summary


      1. Name/Organization/Telephone:

      (Multiple names can be listed here. Other identifying information will be asked in later fields.)


          John Stout

          Mariner Consulting Services, Inc.

          713-252-0535
           Number Of
           Responses1 Percentage
           Of Responses (6%)

          Lisa Wildes/Gila River Power/813-301-4921
           Number Of
           Responses1 Percentage
           Of Responses (6%)

          Dan Walter

          Tri-State Generation and Transmission Association, Inc.

          303-254-3513
           Number Of
           Responses1 Percentage
           Of Responses (6%)

          Salt River Project
           Number Of
           Responses1 Percentage
           Of Responses (6%)


                                                       4
Mike Evans

Shell Energy North America (US), L.P. ("Shell Energy")

858-526-2103
 Number Of
 Responses1 Percentage
 Of Responses (6%)

Brian Theaker

Dynegy

530-295-3305
 Number Of
 Responses1 Percentage
 Of Responses (6%)

Mark J Smith

Calpine

925 557-2231
 Number Of
 Responses1 Percentage
 Of Responses (6%)

Rich Salgo/ NV Energy
 Number Of
 Responses1 Percentage
 Of Responses (6%)

Sempra Generation
 Number Of
 Responses1 Percentage
 Of Responses (6%)

Sandeep Arora

LS Power Development, LLC

925.201.5252
 Number Of
 Responses1 Percentage
 Of Responses (6%)

Powerex
 Number Of
 Responses1 Percentage
 Of Responses (6%)


                                             5
Oscar A. Alvarez, Los Angeles Department of Water and Power, Manager of Regulatory
Standards and Compliance, (213) 367-0677

John Giese, Los Angeles Department of Water and Power, Manager of Marketing Analysis and
Planning, (818) 771-6558
 Number Of
 Responses1 Percentage
 Of Responses (6%)

Bonneville Power Administration

Denise Koehn, 360-418-2533




Submitted on behalf of the following SMEs: Brenda Anderson, Bart McManus, Jamie Murphy,
Kieran Connolly, Fran Halpin, and Don Watkins.
 Number Of
 Responses1 Percentage
 Of Responses (6%)

John Cummings

PPL Energy Plus/PPL Montana

406-533-3568
 Number Of
 Responses1 Percentage
 Of Responses (6%)

Iberdrola Renewables
 Number Of
 Responses1 Percentage
 Of Responses (6%)

JJ Jamieson Portland General Electric Merchant 503 464 7399
 Number Of
 Responses1 Percentage
 Of Responses (6%)

Pawel Krupa, SCL, (206)706-0242
 Number Of
 Responses1 Percentage
 Of Responses (6%)

The AESO appreciates the opportunity to comment on BAL-002-WECC-1. These comments are
submitted by Mark Thompson, in consultation with Neil Curtis and Lane Belsher.
 Number Of
 Responses1 Percentage
 Of Responses (6%)


                                           6
   Total: 18




2. Email Address of Person Submitting the Comments:


   jstout@marinerconsult.com
     Number Of
     Responses1 Percentage
     Of Responses (6%)

   lwildes@entegrapower.com
    Number Of
    Responses1 Percentage
    Of Responses (6%)

   dwalter@tristategt.org
    Number Of
    Responses1 Percentage
    Of Responses (6%)

   david.frederick@srpnet.com
    Number Of
    Responses1 Percentage
    Of Responses (6%)

   michael.evans@shell.com
    Number Of
    Responses1 Percentage
    Of Responses (6%)

   brian.theaker@dynegy.com
    Number Of
    Responses1 Percentage
    Of Responses (6%)

   smithmj@calpine.com
    Number Of
    Responses1 Percentage
    Of Responses (6%)

   rsalgo@nvenergy.com
    Number Of
    Responses1 Percentage
    Of Responses (6%)

   rcurtin@semprageneration.com
    Number Of


                                            7
 Responses1 Percentage
 Of Responses (6%)

sarora@lspower.com
 Number Of
 Responses1 Percentage
 Of Responses (6%)

demetrios.fotiou@powerex.com
 Number Of
 Responses1 Percentage
 Of Responses (6%)

Oscar.Alvarez@ladwp.com; John.Giese@ladwp.com
 Number Of
 Responses1 Percentage
 Of Responses (6%)

dekoehn@bpa.gov
 Number Of
 Responses1 Percentage
 Of Responses (6%)

jmcummings@pplweb.com
 Number Of
 Responses1 Percentage
 Of Responses (6%)

laura.beane@iberdrolaren.com
  Number Of
  Responses1 Percentage
  Of Responses (6%)

john.jamieson@pgn.com
 Number Of
 Responses1 Percentage
 Of Responses (6%)

pawel.krupa@seattle.gov
 Number Of
 Responses1 Percentage
 Of Responses (6%)

mark.thompson@aeso.ca
 Number Of
 Responses1 Percentage
 Of Responses (6%)


Total: 18




                                       8
3. FERC Order 740 states:

“P. 22 On remand, we direct WECC to develop a modification to the reserve restoration period
or provide evidence demonstrating that extending the reserve restoration period to 90 minutes
and adding a disturbance recovery period of 15 minutes would not increase the risk of a major
disturbance in the Western Interconnection.” FERC’s Order 740, page 22, P. 28 /////

The drafting team has posted a revised standard that contains a reserve restoration period of
105 minutes and is developing the necessary justification to support moving from 60 minutes
to 105 minutes. In the alternative, the drafting team believes that a standard with the 60 minutes
reserve restoration period will move more swiftly through the NERC/FERC approval process.

Do you support the proposed 105 minutes? Please answer yes or no.


    Yes
     Number Of
     Responses5 Percentage
     Of Responses (31%)

    No
     Number Of
     Responses11 Percentage
     Of Responses (69%)


    Total: 16




4. If you answered yes to the question above, please explain your reasoning providing specific
empirical details, data and examples to support your position.




     Number Of
     Responses1 Percentage
     Of Responses (6%)


     Number Of
     Responses1 Percentage
     Of Responses (6%)

    Tri-State believe that under a 60 minutes restoration standard, the current market place based on
    hourly scheduling cannot readily be utilized on to help restore a resource lost to a contingency,
    particularly if the contingency occurs after 30 minutes past the hour. Due to this, we often have to
    keep our operating reserves activated for over an hour. This forces us to often carry/hold up to
    twice our operating reserve requirement to ensure that we can "recover" our reserves in 60


                                                   9
minutes. It also often forces us to run expensive turbines an extra hour rather than backing them
down or taking them off-line and putting them back into a reportable reserve mode. The cost of
holding these excess operating reserves is significant.




While it could be argued that this in to some small extent "increases" reliability, we don't believe
that this mode of operation is the intent of the language in the NERC or WECC standards. In
addition, it limits the amount of capacity we can make available to other utilities when they are in
need, as we have capacity being held back for potential reserve restoration needs.




If the current market place moves to a shorter scheduling window, this issue could become mute,
but we're not there yet today and the move to a shorter scheduling window, if it occurs at all, could
take several years.




           RESPONSE: After review of the comments to this question in this survey, the drafting
           team has revised the draft standard to include the current 60 minute time period. The
           drafting team interprets the responses as supporting the 60 minute restoration period
           due to the expectation that it would clear the regulatory process in a timely manner.
           The drafting team will also post documents that provide technical justification showing
           that an adequate level of reliability is maintained with the 105 minute version. In the
           second posting process, the drafting team will survey WECC voters for their opinion on
           whether or not the supporting documentation is sufficient for the Operating Committee
           to support the 105 minutes. If the survey results indicate that the supporting
           documentation is insufficient, the drafting team will recommend that the OC approve
           the standard with the 60 minutes restoration period.




 Number Of
 Responses1 Percentage
 Of Responses (6%)


 Number Of
 Responses1 Percentage
 Of Responses (6%)

In Order No. 740, paragraphs 26-30, FERC noted that some major WECC transfer paths are
stability-limited. In so noting, FERC rejected the use of the continent-wide 105 minute reserve
restoration period, as increasing the reserve restoration period from 60 minutes to 105 minutes,
despite the fact that doing so would align WECC's restoration period with the rest of the continent,
would result in increased exposure to a second contingency during the restoration period. In this
case, FERC clearly believes that WECC IS different from the rest of the continent, and is requiring
different treatment. I believe the only way to address FERC's concern about the reserve
restoration period is to somehow demonstrate that major WECC paths are NOT stability-limited,
which I believe would be impossible to do. I therefore do not support trying to justify the 105




                                               10
minute restoration period.


           RESPONSE: After review of the comments to this question in this survey, the drafting
           team has revised the draft standard to include the current 60 minute time period. The
           drafting team interprets the responses as supporting the 60 minute restoration period
           due to the expectation that it would clear the regulatory process in a timely manner.
           The drafting team will also post documents that provide technical justification showing
           that an adequate level of reliability is maintained with the 105 minute version. In the
           second posting process, the drafting team will survey WECC voters for their opinion on
           whether or not the supporting documentation is sufficient for the Operating Committee
           to support the 105 minutes. If the survey results indicate that the supporting
           documentation is insufficient, the drafting team will recommend that the OC approve
           the standard with the 60 minutes restoration period.

           Please review the documentation related to the justification of the 105 minutes to
           determine if the drafting team has addressed your concern related to demonstrating an
           adequate level of reliability.


I agree with the sense of the SDT that a standard with the 60 minute reserve restoration period will
move through the approval process more expeditiously. Re-visit the extension of the period to 105
in a subsequent phase of development, and after technical data is collected to justify the change.




           RESPONSE: After review of the comments to this question in this survey, the drafting
           team has revised the draft standard to include the current 60 minute time period. The
           drafting team interprets the responses as supporting the 60 minute restoration period
           due to the expectation that it would clear the regulatory process in a timely manner.
           The drafting team will also post documents that provide technical justification showing
           that an adequate level of reliability is maintained with the 105 minute version. In the
           second posting process, the drafting team will survey WECC voters for their opinion on
           whether or not the supporting documentation is sufficient for the Operating Committee
           to support the 105 minutes. If the survey results indicate that the supporting
           documentation is insufficient, the drafting team will recommend that the OC approve
           the standard with the 60 minutes restoration period.


LS Power does not believe it is necessary to prepare justification to increase the reserve
restoration period to 105 minutes from 60. In fact doing this could prevent FERC from approving
BAL-002 even if they completely agree with rest of the language in the revised standard.




LS Power agrees with Mariner Consulting that a better strategy is to segregate the increased
reserve restoration window provision into a separate revision of BAL-002. That would reduce the
risk of FERC rejecting other important elements of this version of BAL-002 standard.


           RESPONSE: After review of the comments to this question in this survey, the drafting


                                              11
            team has revised the draft standard to include the current 60 minute time period. The
            drafting team interprets the responses as supporting the 60 minute restoration period
            due to the expectation that it would clear the regulatory process in a timely manner.
            The drafting team will also post documents that provide technical justification showing
            that an adequate level of reliability is maintained with the 105 minute version. In the
            second posting process, the drafting team will survey WECC voters for their opinion on
            whether or not the supporting documentation is sufficient for the Operating Committee
            to support the 105 minutes. If the survey results indicate that the supporting
            documentation is insufficient, the drafting team will recommend that the OC approve
            the standard with the 60 minutes restoration period.

Powerex believes that the current 60 minute reserve restoration period poses more of a reliability
risk due to the potential loss of Firm schedules if a contingency event occurs in the latter half of an
hour. Under the current rules within WECC, a 75 minute reserve restoration period with a 15
minute disturbance recovery period would more than suffice. In the future, if/when we have
universal intra-hour scheduling throughout all of WECC, a 60 minute reserve restoration period
would suffice, but not currently.


            RESPONSE: After review of the comments to this question in this survey, the drafting
            team has revised the draft standard to include the current 60 minute time period. The
            drafting team interprets the responses as supporting the 60 minute restoration period
            due to the expectation that it would clear the regulatory process in a timely manner.
            The drafting team will also post documents that provide technical justification showing
            that an adequate level of reliability is maintained with the 105 minute version. In the
            second posting process, the drafting team will survey WECC voters for their opinion on
            whether or not the supporting documentation is sufficient for the Operating Committee
            to support the 105 minutes. If the survey results indicate that the supporting
            documentation is insufficient, the drafting team will recommend that the OC approve
            the standard with the 60 minutes restoration period.

            The drafting team does not wish to further expand options of restoration times by
            looking at the 90 minutes as proposed. We feel that the technical justification for the
            105 is the same as that to justify a restoration period of 90 minutes.


There have been very few second contingencies within 105 minutes of significant contingent
events. The data will be forthcoming on four of these in the NWPP over the past decade. When
looking at all significant contingencies in WECC, it has been found that the statistical risk of having
a second large contingency (both contingencies greater than or equal to 800 MW) within 105
minutes of an initial one is once in 10 years. The risk of a second large contingency in the 60
minute timeframe is once in 30 years. The studies conducted on this have been provided to the
WECC tech staff. Those studies were for data from January 1994 through June 2004. These
studies do not distinguish between reserve sharing groups, therefore, the risk of having a second
contingency in the same RSG within 105 minutes is much smaller than the risk in WECC as a
whole.


            RESPONSE: After review of the comments to this question in this survey, the drafting
            team has revised the draft standard to include the current 60 minute time period. The
            drafting team interprets the responses as supporting the 60 minute restoration period
            due to the expectation that it would clear the regulatory process in a timely manner.
            The drafting team will also post documents that provide technical justification showing



                                                12
           that an adequate level of reliability is maintained with the 105 minute version. In the
           second posting process, the drafting team will survey WECC voters for their opinion on
           whether or not the supporting documentation is sufficient for the Operating Committee
           to support the 105 minutes. If the survey results indicate that the supporting
           documentation is insufficient, the drafting team will recommend that the OC approve
           the standard with the 60 minutes restoration period.


See PPL reply to final question


           RESPONSE: We respond to issues raised in the reply to the last question.

The 60 minute reserve restoration period can place entities in a must fail position due to
scheduling timeline conflicts. Standards should be developed to support the requirements of the
WECC and supported by full analysis of all relevant data. PGE recommends that the drafting team
look to the entities responsible for maintaining contingency reserves, e.g.: Reserve Sharing
Groups, for the empirical details necessary for analysis. PGE is concerned that a proposed
standard is being modified to "move more swiftly through the NERC/ FERC approval process"
rather then written in a way that supports the regions requirements.


           RESPONSE: The drafting team disagrees with the assertion that there is a must fail
           position in the existing standard since the scheduling rules allow for emergency
           transfer of energy. After review of the comments to this question in this survey, the
           drafting team has revised the draft standard to include the current 60 minute time
           period. The drafting team interprets the responses as supporting the 60 minute
           restoration period due to the expectation that it would clear the regulatory process in a
           timely manner. The drafting team will also post documents that provide technical
           justification showing that an adequate level of reliability is maintained with the 105
           minute version. In the second posting process, the drafting team will survey WECC
           voters for their opinion on whether or not the supporting documentation is sufficient for
           the Operating Committee to support the 105 minutes. If the survey results indicate that
           the supporting documentation is insufficient, the drafting team will recommend that the
           OC approve the standard with the 60 minutes restoration period.

The AESO supports the proposed 105 minutes provided that the STD can develop the necessary
justification to support moving from 60 minutes to 105 minutes.


           RESPONSE: After review of the comments to this question in this survey, the drafting
           team has revised the draft standard to include the current 60 minute time period. The
           drafting team interprets the responses as supporting the 60 minute restoration period
           due to the expectation that it would clear the regulatory process in a timely manner.
           The drafting team will also post documents that provide technical justification showing
           that an adequate level of reliability is maintained with the 105 minute version. In the
           second posting process, the drafting team will survey WECC voters for their opinion on
           whether or not the supporting documentation is sufficient for the Operating Committee
           to support the 105 minutes. If the survey results indicate that the supporting
           documentation is insufficient, the drafting team will recommend that the OC approve
           the standard with the 60 minutes restoration period.




                                              13
    Total: 18




5. If the drafting team determines that there is insufficient empirical data to demonstrate that
the change from 60 minutes to 105 minutes for the reserve restoration period will maintain
adequate reliability of the Bulk Electric System, the Board has urged the drafting team to
submit the standard with a 60 minute reserve restoration period. ////

In the absence of empirical data to support the 105 minutes, would you support the posted
standard with a 60 minute reserve restoration period? Please answer yes or no.


    Yes
     Number Of
     Responses12 Percentage
     Of Responses (75%)

    No
     Number Of
     Responses4 Percentage
     Of Responses (25%)


    Total: 16




6. If you answered no to the question above, explain your reasoning providing specific
empirical details, data and examples to support your position.




     Number Of
     Responses1 Percentage
     Of Responses (6%)


     Number Of
     Responses1 Percentage
     Of Responses (6%)

    We believe the standard should be posted one more time with the extended reserve restoration
    period. The extended reserve restoration period was a key piece to Tri-State supporting the
    original submittal of the revised standard.




                                                14
           RESPONSE: After review of the comments to this question in this survey, the drafting
           team has revised the draft standard to include the current 60 minute time period. The
           drafting team interprets the responses as supporting the 60 minute restoration period
           due to the expectation that it would clear the regulatory process in a timely manner.
           The drafting team will also post documents that provide technical justification showing
           that an adequate level of reliability is maintained with the 105 minute version. In the
           second posting process, the drafting team will survey WECC voters for their opinion on
           whether or not the supporting documentation is sufficient for the Operating Committee
           to support the 105 minutes. If the survey results indicate that the supporting
           documentation is insufficient, the drafting team will recommend that the OC approve
           the standard with the 60 minutes restoration period.


 Number Of
 Responses1 Percentage
 Of Responses (6%)


 Number Of
 Responses1 Percentage
 Of Responses (6%)


 Number Of
 Responses1 Percentage
 Of Responses (6%)


 Number Of
 Responses1 Percentage
 Of Responses (6%)


 Number Of
 Responses1 Percentage
 Of Responses (6%)


 Number Of
 Responses1 Percentage
 Of Responses (6%)


 Number Of
 Responses1 Percentage
 Of Responses (6%)

As noted above, also, we feel that the current 60 minute reserve restoration period is a glaring
issue that needs to be addressed.


           RESPONSE: After review of the comments to this question in this survey, the drafting


                                              15
           team has revised the draft standard to include the current 60 minute time period. The
           drafting team interprets the responses as supporting the 60 minute restoration period
           due to the expectation that it would clear the regulatory process in a timely manner.
           The drafting team will also post documents that provide technical justification showing
           that an adequate level of reliability is maintained with the 105 minute version. In the
           second posting process, the drafting team will survey WECC voters for their opinion on
           whether or not the supporting documentation is sufficient for the Operating Committee
           to support the 105 minutes. If the survey results indicate that the supporting
           documentation is insufficient, the drafting team will recommend that the OC approve
           the standard with the 60 minutes restoration period.




 Number Of
 Responses1 Percentage
 Of Responses (6%)

Please see the response to the question above. Studies have been performed showing that
increasing the recovery period to 90 minutes (105 minutes from time of contingency) does not
increase the risk of reliable interconnection operation by a significant margin. The data provided
for NWPP shows that there is significant reserve available even after two contingencies have been
responded to in the same timeframe.


           RESPONSE: After review of the comments to this question in this survey, the drafting
           team has revised the draft standard to include the current 60 minute time period. The
           drafting team interprets the responses as supporting the 60 minute restoration period
           due to the expectation that it would clear the regulatory process in a timely manner.
           The drafting team will also post documents that provide technical justification showing
           that an adequate level of reliability is maintained with the 105 minute version. In the
           second posting process, the drafting team will survey WECC voters for their opinion on
           whether or not the supporting documentation is sufficient for the Operating Committee
           to support the 105 minutes. If the survey results indicate that the supporting
           documentation is insufficient, the drafting team will recommend that the OC approve
           the standard with the 60 minutes restoration period.



See PPL reply to final question
 Number Of
 Responses1 Percentage
 Of Responses (6%)


 Number Of
 Responses1 Percentage
 Of Responses (6%)

PGE believes that the 105 minute language is important and must be included in the proposed
standard. PGE urges the drafting team to continue their work on preparing data that will support
the 105 minutes reserve restoration period.



                                              16
                RESPONSE: After review of the comments to this question in this survey, the drafting
                team has revised the draft standard to include the current 60 minute time period. The
                drafting team interprets the responses as supporting the 60 minute restoration period
                due to the expectation that it would clear the regulatory process in a timely manner.
                The drafting team will also post documents that provide technical justification showing
                that an adequate level of reliability is maintained with the 105 minute version. In the
                second posting process, the drafting team will survey WECC voters for their opinion on
                whether or not the supporting documentation is sufficient for the Operating Committee
                to support the 105 minutes. If the survey results indicate that the supporting
                documentation is insufficient, the drafting team will recommend that the OC approve
                the standard with the 60 minutes restoration period.


     Number Of
     Responses1 Percentage
     Of Responses (6%)


     Number Of
     Responses1 Percentage
     Of Responses (6%)


    Total: 18




7. Order 740 states:

“61. On remand, the Commission hereby adopts its NOPR proposal and directs the WECC to
develop modifications to the proposed regional Reliability Standard that explicitly provide that
demand-side management technically capable of providing this service may be used as a
resource for both spinning and non-spinning contingency reserves. Consistent with the
Commission’s directive in Order No. 693, the modification should list the types of resources,
including demand-side management, which can be used to meet contingency reserves. The
modification also should ensure comparable treatment of demand-side management with
conventional generation or any other technology and allow demand-side management to be
considered as a resource for contingency reserves on this basis without requiring the use of
any particular contingency reserve option. For example, consistent with our determinations in
Order No. 693, the modification could replace the term Spinning Reserve with Operating
Reserve-Spinning and Non-Spinning Reserve with Operating Reserve-Supplemental, since
these glossary definitions are inclusive of demand-side management, including controllable
load, in contrast to the current terms used in the proposed regional Reliability Standard.”////

Based on the above excerpt and the proposed modifications, the drafting team is asking for
comments from the WECC participants on the following questions:

In response to the above FERC language, the drafting team modified the proposed standard. Do
you believe that the drafting team met the mandate required by FERC related to utilization of
demand side resources as a supplier of reserve response? Please answer yes or no.




                                                  17
    Yes
     Number Of
     Responses11 Percentage
     Of Responses (100%)

    No
     Number Of
     Responses0 Percentage
     Of Responses (0%)


    Total: 11




8. If you answered no to the above question, please explain your answer.




     Number Of
     Responses1 Percentage
     Of Responses (6%)


     Number Of
     Responses1 Percentage
     Of Responses (6%)


     Number Of
     Responses1 Percentage
     Of Responses (6%)


     Number Of
     Responses1 Percentage
     Of Responses (6%)


     Number Of
     Responses1 Percentage
     Of Responses (6%)


     Number Of
     Responses1 Percentage
     Of Responses (6%)


     Number Of
     Responses1 Percentage


                                              18
 Of Responses (6%)


 Number Of
 Responses1 Percentage
 Of Responses (6%)


 Number Of
 Responses1 Percentage
 Of Responses (6%)


 Number Of
 Responses1 Percentage
 Of Responses (6%)

Powerex believes that "an amount of reserve equal to the sum of three percent of the load and
three percent of net generation" has no proven or studied validity and thus poses a reliability risk
without extensive studies. This proposal will cause confusion in certain situations as noted by NV
Energy. What is missing from this Standard is a detailed explanation of who is responsible for
carrying reserves for each situation and energy product type (i.e. G-FC, G-NF, etc...). Can the
source BA contract their obligation to the sink BA (and vice versa)? How would you show this on
an etag? These sorts of details need to be worked out and detailed before finalizing this Standard.


           RESPONSE: The point of this standard is to help clarify the level of reserve needed by
           a Balancing Authority or Reserve Sharing Group. The determination of the amount of
           reserves is based on physical load and physical generation regardless of product type.
           FERC did not point to the 3 plus 3 as unreasonable nor unreliable in the order
           remanding the proposed standard. In fact, FERC stated that they could accept this
           method.


 Number Of
 Responses1 Percentage
 Of Responses (6%)

Did not answer no, but would still like to point out a couple of things. First, the Commission may
not believe that we have fulfilled its request to deem demand-side management as spinning
reserve since we did not explicitly state that it could be used for that purpose as long as it
exhibited the same response characteristics as a conventional generator (36 MHz dead band, 5%
droop [whatever that would mean with load], increasing response on the 5% droop line as
frequency declines or recovers, etc.). However, we are not stating that it cannot be used; we just
did not explain how it could be. WECC should also point out that there is a difference between
demand side management and demand response for reserve activation.


           RESPONSE: The drafting team believes that we have clarified that load can act as
           Operating Reserve – Spinning since the definition of the term clearly states that load is
           part of Operating Reserve – Spinning. R2.1 and R2.2 states that anything utilized as
           Operating Reserve – Spinning must meet certain criteria, although not the specific
           requirements in this comment. The proposed standard also does not require

                                              19
                generators to meet the respondent’s specific requirements.



    See PPL reply to final question
     Number Of
     Responses1 Percentage
     Of Responses (6%)


     Number Of
     Responses1 Percentage
     Of Responses (6%)


     Number Of
     Responses1 Percentage
     Of Responses (6%)


     Number Of
     Responses1 Percentage
     Of Responses (6%)


    Total: 17




9. Order 740 states:

“48. We will accept WECC’s proposal on this issue. The Commission finds that, similar to the
current continent-wide Reliability Standard, the proposed regional Reliability Standard does not
allow balancing authorities or reserve sharing groups to curtail firm load except in compliance
with NERC’s Reliability Standard EOP-002-2.1.

49. The continent-wide Reliability Standard, BAL-002 does not contemplate the use of firm load
as contingency reserve. In fact, it would be a violation of EOP-002-2.1 if balancing authorities or
reserve sharing groups outside of WECC planned to shed firm load before the reliability
coordinator issued a level 3 energy emergency alert. Similarly, although Requirement R3.6 of
Reliability Standard BAL-002-WECC-1 would allow balancing authorities and reserve sharing
groups to use “Load, other than Interruptible Load, once the Reliability Coordinator has
declared a capacity or energy emergency,” these entities would not be authorized to shed firm
load unless the applicable reliability coordinator had issued a level 3 energy emergency alert
pursuant to EOP-002-2.1. Thus, balancing authorities and reserve sharing groups within WECC
are subject to the same restrictions regarding the use of firm load as contingency reserve as
balancing authorities elsewhere operating under the continent-wide Reliability Standard. On
remand, we direct WECC to develop revised language to clarify this point.” P. 48 and P. 49./////

Based on the proposed modifications, the drafting team is asking for comments from the
WECC participants on the following questions:

Do you believe that the drafting team captured the mandate of FERC’s concerns related to


                                                 20
utilization of load as reserve? Please answer yes or no.


    Yes
     Number Of
     Responses11 Percentage
     Of Responses(92%)

    No
     Number Of
     Responses1 Percentage
     Of Responses(8%)


    Total: 12




10. If you answered no to the above question, explain your answer




     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)



                                               21
 Number Of
 Responses1 Percentage
 Of Responses(6%)


 Number Of
 Responses1 Percentage
 Of Responses(6%)


 Number Of
 Responses1 Percentage
 Of Responses(6%)


 Number Of
 Responses1 Percentage
 Of Responses(6%)

Powerex believes that "an amount of reserve equal to the sum of three percent of the load and
three percent of net generation" has no proven or studied validity and thus poses a reliability risk
without extensive studies. This proposal will cause confusion in certain situations as noted by NV
Energy. What is missing from this Standard is a detailed explanation of who is responsible for
carrying reserves for each situation and energy product type (i.e. G-FC, G-NF, etc..). Can the
source BA contract their obligation to the sink BA (and vice versa)? How would you show this on
an etag? These sorts of details need to be worked out and detailed before finalizing this Standard.


           RESPONSE: Please see the response above to this comment.


 Number Of
 Responses1 Percentage
 Of Responses(6%)


 Number Of
 Responses1 Percentage
 Of Responses(6%)

See PPL reply to final question
 Number Of
 Responses1 Percentage
 Of Responses(6%)


 Number Of
 Responses1 Percentage
 Of Responses(6%)

SCL believes that R3.6 conflicts with EOP-002-2.1. Specifically, EOP-002-2.1-R6 requires a


                                              22
    Balancing Authority (BA) to deploy all available operating reserves before it can request a
    Reliability Coordinator to declare an Energy Emergency (EE). However, under BAL-002-WECC-
    R3.6, the BA may only deploy load (other than load defined in R3.2) as a reserve after it has
    requested an Energy Emergency Alert (EEA) Level 3. Thus, the BA violates the BAL-002-WECC
    by following EOP-006, because it deployed load as a reserve without seeking an EEA Level 3.
    And the BA violates EOP-006 R6 (and possible R7) by following BAL-002-WECC because it did
    not deploy all reserve before it requested an EE.




    Finally, BAL-002-WECC R3 may also conflict with TOP-005-2. Attachment 1 to TOP-005-2
    requires BAs and Transmission Operators (TOP) to update at least every ten minutes the MW
    amount of operating reserves available within ten minutes. If the amount of operating reserves is
    contingent on declaration of an EEA level 3, then BAs and TOPs will be unable to determine that
    amount until the EEA level 3 is declared.




    SCL recommends the SDT conform BAL-002 to be consistent with EOP-002 and TOP-005.


                RESPONSE: The drafting team believes that the standards discussed in this comment
                work together in those instances when an entity has declared an emergency. When an
                entity has requested an EEA Level 1, it still is able to meet all reserve requirements
                and serve its firm loads. Therefore, it is not utilizing its firm load as reserves at this
                point. When an entity moves into a EEA Level 3, the circumstances are such that firm
                load shed is either occurring or imminent. If an entity has requested an EEA Level 3,
                the proposed BAL-002-WECC-1 standard would allow that entity to start using firm
                load as reserve when it restores its reserve requirement rather than curtailing firm load
                to allow generation to back down and provide reserve.

    R3.6 implies load shedding will take place after an EEA Level 3 has been requested. The AESO
    may shed load and request an EEA Level 3 concurrently.


                RESPONSE: The drafting team agrees that may be the case. In that instance, the
                WECC standard would state that you were unable to claim that load as meeting your
                reserve requirement under BAL-002-WECC-1. After the request to move to an EEA
                Level 3, an entity would be able to count firm load as part of it reserve requirement if it
                is ready and willing to curtail the load.


    Total: 17




11. Do you agree with the determination of the drafting team as to how load may be counted as
it pertains to deployment of reserves? Please answer yes or no.


    Yes



                                                    23
     Number Of
     Responses11 Percentage
     Of Responses(92%)

    No
     Number Of
     Responses1 Percentage
     Of Responses(8%)


    Total: 12




12. If you answered no to the question above, please explain your answer.




     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)


                                              24
 Number Of
 Responses1 Percentage
 Of Responses(6%)


 Number Of
 Responses1 Percentage
 Of Responses(6%)


 Number Of
 Responses1 Percentage
 Of Responses(6%)

Powerex believes that "an amount of reserve equal to the sum of three percent of the load and
three percent of net generation" has no proven or studied validity and thus poses a reliability risk
without extensive studies. This proposal will cause confusion in certain situations as noted by NV
Energy. What is missing from this Standard is a detailed explanation of who is responsible for
carrying reserves for each situation and energy product type (i.e. G-FC, G-NF, etc..). Can the
source BA contract their obligation to the sink BA (and vice versa)? How would you show this on
an etag? These sorts of details need to be worked out and detailed before finalizing this Standard.




           RESPONSE: Please see the response above to this comment.



 Number Of
 Responses1 Percentage
 Of Responses(6%)


 Number Of
 Responses1 Percentage
 Of Responses(6%)


 Number Of
 Responses1 Percentage
 Of Responses(6%)

See PPL reply to final question
 Number Of
 Responses1 Percentage
 Of Responses(6%)


 Number Of
 Responses1 Percentage
 Of Responses(6%)


                                              25
    See above.
     Number Of
     Responses1 Percentage
     Of Responses(6%)

    R3.6 implies load shedding will take place after an EEA Level 3 has been requested. The AESO
    may shed load and request an EEA Level 3 concurrently.


                RESPONSE: The drafting team agrees that may be the case. In that instance, the
                WECC standard would state that you were unable to claim that load as meeting your
                reserve requirement under BAL-002-WECC-1. After the request to move to an EEA
                Level 3, an entity would be able to count firm load as part of it reserve requirement if it
                is ready and willing to curtail the load.


    Total: 17




13. FERC directed WECC to consider the concerns in Paragraphs 63, 64 and 65 of the Order
related to net generation. The drafting team has revised the definition of net generation to
address the mandate contained in Paragraph 66 below.

FERC Order 740 states:

66. The proposed regional Reliability Standard offers certain improvements over the current
regional Reliability Standard as commenters point out. Nevertheless, for the reasons discussed
above, we must remand the proposed regional Reliability Standard to the ERO. On remand, we
direct WECC to consider the concerns raised by the QF Parties and NV Energy.

Do you agree with the proposed definition of net generation as used in the draft document at
R1.1.2?


    Yes
     Number Of
     Responses6 Percentage
     Of Responses(46%)

    No
     Number Of
     Responses7 Percentage
     Of Responses(54%)


    Total: 13




14. If you answered no to the above question, please explain your answer providing an example


                                                    26
of your concerns.


    Included in my response to the final question
     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)

    See comments below.
     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage


                                                    27
 Of Responses(6%)

This proposal is open to interpretation and can easily be used by some to avoid carrying a proper
proportion of reserves for both load and generation that they link together through a contract. We
believe that the intent is to cover small solar (and such) located on site directly feeding a
residential or commercial load, but the wording is not restrictive enough to prevent misuse and
allowing some to carry less reserves than actually required.

           RESPONSE: The drafting team agrees with the concern raised here although the
           intent was to cover larger installations than just residential or commercial solar
           installations. With that said, the Balancing Authority is ultimately responsible for
           ensuring resources and loads balance. This issue should be addressed on a case-by-
           case review by the Balancing Authority.

 Number Of
 Responses1 Percentage
 Of Responses(6%)

Although, BPA would suggest amending the language and including "behind the meter
generation" along with "self supplied load" in the terms being defined.


           RESPONSE: A modification to the proposed standard has been made.

See PPL reply to final question
 Number Of
 Responses1 Percentage
 Of Responses(6%)

Please see comments in final question.
 Number Of
 Responses1 Percentage
 Of Responses(6%)

PGE does not support moving from the current reserve obligations to three percent of the load and
three percent of net generation. PGE finds that the definition of net generation is adequate.
RESPONSE: The point of this standard is to help clarify the level of reserve needed by a
Balancing Authority or Reserve Sharing Group. FERC did not point to the 3 plus 3 as
unreasonable nor unreliable in the order remanding the proposed standard. In fact, FERC stated
that they could accept this method.




Thank you for your comment in support of the definition of net generation.

As currently written, the standard will allow Self-Provided load to stay on line and use
Interconnection resources up to 10 minutes following generation trip until the standby service is
deployed. We suggest that if the Self-Provided load is not curtailed concurrently with an outage of
the generator serving this load then the BA should be carrying reserves for that load.


            RESPONSE: The drafting team agrees with the comment that there could be a 10


                                              28
                 minute lag for the standby service. This is an issue that the Balancing Authority
                 should address with the generator and standby service provider.

    Does “curtail concurrently” in the part “b” of the sub-bullet in R1.1.2, mean by relay, manually or
    both?


                RESPONSE: The drafting team has decided not to address the means by which to
                effect the curtailment.


    Total: 18




15. FERC directed WECC to consider the concerns suggesting that the host BA may not be
responsible for all generation within its boundaries. The drafting team has revised the language
concerning generation within a BA to attempt to address this issue.

Do you agree with the proposal as shown in R1.1.2? Please answer yes or no.


    Yes
     Number Of
     Responses4 Percentage
     Of Responses(27%)

    No
     Number Of
     Responses11 Percentage
     Of Responses(73%)


    Total: 15




16. If you answered no to the above question, kindly explains your answer.


    Included in my response to the final question
     Number Of
     Responses1 Percentage
     Of Responses(6%)


     Number Of
     Responses1 Percentage
     Of Responses(6%)




                                                    29
 Number Of
 Responses1 Percentage
 Of Responses(6%)


 Number Of
 Responses1 Percentage
 Of Responses(6%)

The revised standard includes the following text under R1.1.2 on page 4 of the redline:

“For purposes of R1.1.2, sink Balancing Authority net generation reserve calculations include
generation located in a separate source Balancing Authority where both the sink and the source
Balancing Authorities have agreed to that counting mechanism.” (Emphasis added.)




Shell Energy is pleased that WECC is proceeding to make revisions to BAL-002 as suggested by
FERC. This standard will clarify the responsibility for the provision of reserves. However, Shell
Energy is concerned that the revisions to R1.1.2 introduce ambiguity over the responsibility of
procurement of reserves, which is contrary to the original intent of BAL-002. Does this election
obligate the source BA to then procure reserves for ALL the generation? Can the sink BA
selectively choose which generation for which it supplies reserves? In the latter case, where a
sink BA can selectively choose generation, will the sink BA choose to not provide reserves for IPP
generation in its BA, thus inhibiting the ability of the IPP to procure reserves and supply energy?
We believe that the revised language above is beyond the scope of the FERC remand order. It is
necessary that the reserve responsibility be clear, and we suggest that paragraph in italics could
be removed from the draft and still maintain the timeline to produce and approve the draft, while
being compliant with the FERC remand order.
            RESPONSE: Based on comments, the drafting team has removed this language.
            Please refer to the revised standard posted for comment. The drafting team points out
            that a pseudo-tie can be used to move generation and load from one BA to another.
            The drafting team asks for comments on this revised language.

I believe that the language added to R1.1.2 - "For the purposes of R1.1.2, Sink Balancing
Authority net generation reserve calculations that include generation located in a separate Source
Balancing Authority where both the Sink and the Source Balancing Authorities have agreed to that
counting mechanism." - runs counter to the original intent of revised BAL-002, namely, to de-link a
BAA's reserve obligation from its interchange transactions. I believe that allowing for source and
sink BAAs to decide how generation in each others' BAA will or won't count towards their reserve
obligations invites mischief and discriminatory treatment of PSEs. As the WECC Board member
who moved that BAL-002 be revised to address FERC's concerns, I find this new language, which
purportedly addresses FERC's concerns, to do so in a way that undermines the original intent of
the revised BAL-002.


           RESPONSE: Based on comments, the drafting team has removed this language.
           Please refer to the revised standard posted for comment. The drafting team points out
           that a pseudo-tie can be used to move generation and load from one BA to another.
           The drafting team asks for comments on this revised language.

           The revised language reads as follows:



                                              30
            For purposes of R1.1.2, sink Balancing Authority net generation reserve calculations
            include generation located in a separate source Balancing Authority where both the
            sink and the source Balancing Authorities have agreed to that counting mechanism.




Calpine believes that this modification defeats the noble goals of the original revisions included in
BAL-002 -- goals of reliability and equal treatment. In this regard, we whole-heartedly agree with
the comments of John Stout.




Allowing two BA's to agree to unsupervised counting mechanisms would allow differentiated, non-
transparent and possibly, grossly-discriminatory, treatment of non-utility generation. Such actions
would further confuse contingency reserve calculations and frustrate commercial confidence.


            RESPONSE: Based on comments, the drafting team has removed this language.
            Please refer to the revised standard posted for comment. The drafting team points out
            that a pseudo-tie can be used to move generation and load from one BA to another.
            The drafting team asks for comments on this revised language.

While the language in R1.1.2 was developed in consultation with me (NV Energy) in an attempt to
address the NV Energy NOPR comments, I am persuaded by the comments of others within
WECC that this modification will serve to confuse the issue of what party is responsible for
carrying reserves. It also somewhat defeats the original premise of the standard development - to
separate reserve requirements from energy transactions. So, with that, I no longer believe the
suggested language meets the intent of the Western Interconnection as a whole.




That said, I still cannot support the original "3% BA Generation plus 3% Load" requirement,
because it unjustly obligates the BA to carry reserve for generation that is sited within the sending
BA, in contradiction to the transmission tariff obligations of the host transmission service provider.
Example of difficulty will be variable/intermittent resources located in a host source BA and
expecting that source BA to be obligated to provide all reserves and keep the transactions from
the variable generation party whole after the source output vanishes. Another common example is
a single unit located in a host BA selling "unit contingent" to a receiving BA. In both these cases,
the host BA (under the BAL-002-WECC-1 remand proposal) considers that generation in
determining its contingency reserve obligation, strongly implying that the reserves will be
activated upon loss of those resources. Thus, there exists no link between the reserves that a
host BA must carry under BAL-002-WECC-1 and the reserves that it would deploy during a
generation loss event. This is problematic.




My suggestion is to simply defer to the continent-wide standard, and base all contingency reserve
obligation on the MSSC.




                                               31
            RESPONSE: Based on comments, the drafting team has removed this language.
            Please refer to the revised standard posted for comment. The drafting team points out
            that a pseudo-tie can be used to move generation and load from one BA to another.
            The drafting team asks for comments on this revised language.




            In previous FERC filings, WECC has stated that the existing standard and therefore a
            higher level of reserves than just each entity’s MSSC was needed for reliable
            operation of the interconnection. We would need to provide documentation to FERC
            showing how that level of reserve would continue to provide an acceptable level of
            reliability to the interconnection.

Sempra Generation concurs with the responses from Mariner Consulting (John Stout), Shell
Energy and Dynegy. We have concerns with the additional language included under R1.1.2 - "For
the purposes of R1.1.2, Sink Balancing Authority net generation reserve calculations that include
generation located in a separate Source Balancing Authority where both the Sink and the Source
Balancing Authorities have agreed to that counting mechanism." We believe this additional
language undermines the original intent of the revised BAL-002.


            RESPONSE: Based on comments, the drafting team has removed this language.
            Please refer to the revised standard posted for comment. The drafting team points out
            that a pseudo-tie can be used to move generation and load from one BA to another.
            The drafting team asks for comments on this revised language.

LS Power agrees with John Stout (Mariner Consulting) that addition of the counting
mechanism provision in R.1.1.2 undermines the original intent of the revised standard, which was
to make it clear how much contingency reserve each BA in WECC is required to carry by
disconnecting contingency reserve calculations from individual energy transactions. If any entities
exercise this proposed option, it will return WECC to the situation of linking contingency reserves
back to the specific nature of each individual energy transaction. In addition we believe that this
new provision could make the contingency reserve procurement process non transparent and
discriminatory. Therefore, LS Power recommends deletion of this new provision.


           RESPONSE: Based on comments, the drafting team has removed this language.
           Please refer to the revised standard posted for comment. The drafting team points out
           that a pseudo-tie can be used to move generation and load from one BA to another.
           The drafting team asks for comments on this revised language.

This proposal is open to interpretation and can easily be used by some to avoid carrying a proper
proportion of reserves for both load and generation that they link together through a contract. We
believe that the intent is to cover small solar (and such) located on site directly feeding a
residential or commercial load, but the wording is not restrictive enough to prevent misuse and
allowing some to carry less reserves than actually required.


           RESPONSE: Based on comments, the drafting team has removed this language.
           Please refer to the revised standard posted for comment. The drafting team points out
           that a pseudo-tie can be used to move generation and load from one BA to another.
           The drafting team asks for comments on this revised language. The drafting team was
           attempting to address issues with potentially large generation, not just small,


                                              32
           residential type generation.


 Number Of
 Responses1 Percentage
 Of Responses(6%)


 Number Of
 Responses1 Percentage
 Of Responses(6%)

See PPL reply to final question
 Number Of
 Responses1 Percentage
 Of Responses(6%)

Please see comments in final question.
 Number Of
 Responses1 Percentage
 Of Responses(6%)

PGE is concerned that R 1.2 will be difficult to monitor for compliance and operational
requirements on a bilateral basis. R 1.2 should include language that would support
communication between the source and sink BAs. The sink BA has no ability to determine the
source BA's reserve obligations and vice versa.
The drafting team considered the comments and determined that tagging tools are in place to
allow these transactions. Additionally, the measurement section related to R1 identifies what
would be needed to prove compliance. No modification was made to section 1.2.

Current proposal assumes that sink and source BAs will be able to agree on the correct
accounting mechanism. What if they are not able to reach an agreement?


           RESPONSE: Based on comments, the drafting team has removed this language.
           Please refer to the revised standard posted for comment. The drafting team points out
           that a pseudo-tie can be used to move generation and load from one BA to another.
           The drafting team asks for comments on this revised language.

We assume WECC is referring to the bullet in R1.1.2 that begins with "Self-Provided Load….." We
agree that the proposed wording addresses the issue, however a close review of the AESO tariff
and market rules to ensure there is no conflict between the proposed "Self Provided Load"
definition and those authoritative documents is required.


           RESPONSE: Based on comments, the drafting team has removed the language
           related to the BAs agreeing to move generation from one BA to another. Please refer
           to the revised standard posted for comment. The drafting team points out that a
           pseudo-tie can be used to move generation and load from one BA to another. The
           drafting team asks for comments on this revised language. The drafting team agrees
           that the appropriate place to address the issue of Self-Provided Load is an entity’s
           tariff. Thank you for your comment.


                                             33
    Total: 18




17. The Drafting Team welcomes comments on any other aspects of this document not covered
in the previous questions.

This is the last question in this survey.


    Comments of Mariner Consulting Services on the proposed modifications of WECC BAL-
    002




        1. R1.1.2 includes the following new provision…

    For purposes of R1.1.2, sink Balancing Authority net generation reserve calculations include
    generation located in a separate source Balancing Authority where both the sink and the source
    Balancing Authorities have agreed to that counting mechanism.




    I believe that the addition of this provision undermines the original intent of the revised standard…
    to make it crystal clear how much contingency reserve each BA in WECC is required to carry by
    disconnecting contingency reserve calculations from individual energy transactions. If any entities
    exercise this proposed option, it will return WECC to the situation of linking contingency reserves
    back to the specific nature of each individual energy transaction.




    For example, assume that BA1 has such an agreement with BA2:




                ·     Why does the drafting team believe that BA2 would be inclined to enter into such
                    an agreement with BA1?

                ·     Is the drafting team aware of any reasons that this contingency reserve transfer
                    could not have been accomplished through existing WECC Business Practices?

                ·      Is it the drafting team’s intent that the transfer of contingency reserve responsibility
                    apply to all generation in BA1, or is it the drafting team’s intent that the BA’s be able
                    to specify specific generation units to which such an agreement applies?

                ·     Is it the drafting team’s intent that a BA be able to enter into such an agreement for
                    merchant generation within its boundary, but exclude utility owned generation from
                    the agreement?



                                                       34
·     Is it the drafting team’s intent that the generation owners have no control over
    whether or not their units are included under such an agreement?

·      Is it the drafting team’s intent that this provision apply between BA’s which are
    members of the same Reserve Sharing Group? If so, why does the drafting team
    believe that such could not be accomplished simply by the RSG changing its own
    rules, rather than modifying WECC BAL-002?

·     Is it the drafting team’s intent that this provision apply between BA’s which are
    members of different Reserve Sharing Groups? If so, would the RSG’s be parties to
    the agreement or have any control over such agreements?

·     Assume Generator A, located in BA1 sells a block of energy to a PSE for delivery
    within BA2. Under the agreement, BA2 is obligated to count Generator A in its
    contingency reserve calculations.

           Is it the drafting team’s intent that the agreement be provided to the
             Reliability Coordinators so that they can incorporate it into their reserve
             verification procedures?

           If not, how does the drafting team propose that the RC’s be able to verify
             whether BA’s are properly calculating and carrying the right reserves, and
             who would they hold accountable if the provisions of the agreement do not
             match the reported reserves.

           Is it the drafting team’s intent that BA2 provide AGC driven frequency
             response to cover the loss of this generation in BA1? If so, how would such
             be accomplished and verified?

           If frequency is not returned to normal within the required restoration period,
             which BA would be required to self report a violation?

·     That same block of energy is now resold for delivery into BA3.

           Does BA1 now have to include Generator A into its contingency reserve
             calculations or does BA2 continue to include Generator A into its contingency
             reserve calculations?

           Is it the drafting team’s intent that the Etag could be split into two transactions
             to preserve the obligation of BA2 to carry the contingency reserves for
             Generator A?

·     Now assume that BA2 purchases a block of energy from a PSE for delivery within
    BA2. BA2 values the purchase with the expectation that it will not be expected to
    include the generation supporting the transaction in its contingency reserve
    calculation. The PSE then purchases supply for the transaction from a third party.
    When the e-Tag is generated for the delivery, the PSE and BA2 learn for the first time
    that the generation to support the transaction is in BA1, triggering the transfer of the
    3% generation reserve obligation to BA2.

           Is it the drafting team’s expectation that under this scenario BA2 would be



                                       35
                       allowed to reject the Etag when the transaction is scheduled?

                     Is it the drafting team’s expectation that BA2 could or would be able to
                       restrict the supply for this transaction from being located in BA1?

                  O How does the drafting team intend that the PSE be made aware that
                    purchasing from Generator A triggers the transfer of contingency reserve
                    responsibility? Does the drafting team intend that such agreements be
                    publicly posted so that PSE’s be aware of such?

                     NERC Principles regarding reliability standards include the following
                       statement: In addition to providing for an Adequate Level of Reliability,
                       NERC Reliability Standards shall be written such that they achieve their
                       reliability objective without causing undue restrictions or adverse impacts on
                       competitive electricity markets by adhering to the following: A reliability
                       standard shall not give any market participant an unfair competitive
                       advantage. It would seem that triggering a transfer of reserve obligation for
                       some, but not all generators in WECC would give an “unfair competitive
                       advantage” to some generators. Why does the drafting team believe that this
                       proposed provision would not be a violation of the aforementioned NERC
                       principle?




It is my understanding that this provision was added to address the concern of NVEnergy that they
did not think it was appropriate for the obligation to carry reserves to rest solely on BA’s/RSG’s
rather than including generators. If so, the proposed provision is off target… under paragraph 4
of the proposed standard the obligation to carry reserves still rests solely on BA’s/RSG’s, even
with these proposed modifications. This fundamental allocation issue was debated and decided
by the original drafting team. The appropriate response to the FERC NOPR is to simply include in
the filing package the reasons the drafting team rejected this argument originally. If their reasons
haven’t changed, neither should the wording of this standard. If two BA’s wish to transfer their
contingency reserves, they can do so simply by entering into a contingency reserve transaction
under existing WECC business practices.




All said, this proposed option is not needed, will be difficult to monitor/verify compliance, violates
NERC principles regarding reliability standards, and should be removed.




More importantly, it is my understanding that NVEnergy’s two utility affiliates are members of
Reserve Sharing Groups. Allocation of reserve obligations to individual BA’s within an RSG is
defined by the RSG agreements, not by BAL-002. If NVEnergy wishes to redefine their reserve
obligation as an individual BA, the appropriate forum to do so is the RSG, not WECC BAL-002.




       Measure M1 still includes the provision that the reserve restoration period be
         increased to 90 minutes rather than the 60 minutes FERC indicated it would accept



                                                36
         in the NOPR…

It is my understanding that the drafting team wants to take another shot at providing justification to
FERC, and resubmit the standard with the original provision. This is a fatally flawed strategy for
several reasons…




First, it is technically impossible to demonstrate that the contingency risk during a 90 minute
exposure window is no greater than the contingency risk of a 60 minute exposure window. The
longer the exposure window, the greater the risk, irrespective of anecdotal evidence provided by
historical data.




Second, feedback from WECC staff suggests that FERC would like to see the current NERC
restoration period reduced to the 60 minutes currently used by WECC. If this feedback is
accurate, there should be no expectation that FERC would approve a proposed standard which
moves in the opposite direction.




Third, if we include the 90 minute provision, we are effectively including a poison pill in WECC
BAL-002, one which could prevent FERC from approving BAL-002 even if they completely agree
with every other word in the revised standard. A better strategy is to segregate the increased
reserve restoration window provision into a separate revision of BAL-002. That way, there is still a
shot at convincing FERC to change its mind about the increased reserve restoration period,
without risking the rejection of the other important elements of BAL-002.




       R1.1.2 has also been modified to include the following provisions to clarify the
         treatment of behind the meter generation in the calculation of contingency reserve
         obligations by the BA…

·     For purposes of R1.1.2, net generation is gross generation minus station service minus Self-
    Provided Load.

·      For purposes of R.1.1.2, Self-Provided Load is that portion of the load of an individual retail
    customer that is served by generation: (a) located on the customer’s site or provides service
    to the customer’s site through arrangements as authorized by law and (b) secures standby
    service deployable within 10 minutes and under terms approved by regulatory authority, or is
    curtailed concurrently with an outage of the generation serving the load.




The first half of item (b) within the second bullet seems to have two fatal flaws. First, Standby
service deployable within 10 minutes and contingency reserves are not equivalent. If the self
provided load secures standby service for the loss of their on-site generation, but it takes up to 10



                                               37
minutes to deploy that service, WECC contingency reserves are clearly providing contingency
reserve to that load until the standby service is initiated. Since WECC contingency reserves are
being used to protect the load, BA’s should include that load in their calculations, regardless of the
retail standby service arrangements they have made with the customer.




Second, even if the standby service supplied by retail service provider begins instantaneously,
where does the drafting team believe that the service come from? The answer is defined by the
laws of physics, not the provisions of a standby contract… it comes from WECC wide contingency
reserves. Once again, if WECC contingency reserves are being used to protect that load, BA’s
need to include that load in their calculations. WECC reliability standard requirements do not need
to be reconciled with retail cost allocation issues.




The provision “or is curtailed concurrently with an outage of the generation serving the load” is
fine because under those arrangements WECC contingency reserves are not called on to protect
the load.




             RESPONSE:

             Item 1 - BA Agreement Issue: Based on comments, the drafting team has removed
             this language. Please refer to the revised standard posted for comment. The drafting
             team points out that a pseudo-tie can be used to move generation and load from one
             BA to another. The drafting team asks for comments on this revised language. The
             drafting team expects that the existing WECC business practice related to tagging
             reserve responsibility would be retired upon implementation of this standard and there
             would be no means to transfer reserve responsibility other than a pseudo-tie. The
             process would allow a reserve transaction but not a transfer of reserve obligation.




             Item 2 – Reserve Restoration Period: After review of the comments in this survey, the
             drafting team has revised the draft standard to include the current 60 minute time
             period. The drafting team interprets the responses as supporting the 60 minute
             restoration period due to the expectation that it would clear the regulatory process in a
             timely manner. The drafting team will also post documents that provide technical
             justification showing that an adequate level of reliability is maintained with the 105
             minute version. In the second posting process, the drafting team will survey WECC
             voters for their opinion on whether or not the supporting documentation is sufficient
             for the Operating Committee to support the 105 minutes. If the survey results indicate
             that the supporting documentation is insufficient, the drafting team will recommend
             that the OC approve the standard with the 60 minutes restoration period.




             Item 3 – Self-Provided Load: The drafting team revised the language related to this
             issue. In answer to your concern related to automatic response, it is very likely that


                                               38
            the Balancing Authority (or other entity responsible for providing the standby service)
            will have to respond to the loss of the behind the meter generator. However, that
            Balancing Authority will not be able to claim that the loss of the behind the meter
            generator creates conditions under which they no longer have to maintain their
            minimum contingency reserve. In other words, the Balancing Authority would not be
            allowed to call upon its reserve and or allow its reserve level to fall below the
            minimum amount required by this standard. Since the behind the meter generators
            are typically small, it is entirely likely that the Balancing Authority will utilize the
            regulating reserve component of the Balancing Authority’s operating reserve rather
            than contingency reserve to rebalance. This is similar to the need for a Balancing
            Authority to respond to a load such as an arc furnace as it comes on. The drafting
            team agrees that there could be events such as the loss of a behind the meter
            generation which cause one Balancing Authority to lean on the interconnection’s
            reserves.

I would encourage the drafting team to explore contacting FERC staff to further discuss the
reserve restoration issue, and what might suffice for acceptable evidence. Our company has had
success in direct conversations with FERC staff and found it helpful in several instances. While
this may not bear fruit, it could be worth a try.




Good luck, and thank you for issuing the survey.


            RESPONSE: The drafting team will attempt to discuss this issue with FERC staff.

WECC should focus on developing a standard that will be accepted by FERC in a reasonable
timeframe. We risk pushing the process back another 4 years by insisting on 105 minutes during
this round.

A draft with the 60 minute reserve restoration period would still contain improvements over the
MORC-based standard.

    ·     it gives fair treatment to BAs hosting joint-owned generation by allowing them to share
        reserve responsibility with joint owners

    ·    it cleans up unclear or contradictory definitions and matched them with their use in
        NERC’s updated glossary

    ·     it accommodates demand response products, increasing reserves without new
        generation

    ·     it settles the use of firm load for reserves in energy emergencies, enhancing operators’
        understanding of low-spin situations
            RESPONSE: After review of the comments in this survey, the drafting team has
            revised the draft standard to include the current 60 minute time period. The drafting
            team interprets the responses as supporting the 60 minute restoration period due to
            the expectation that it would clear the regulatory process in a timely manner. The
            drafting team will also post documents that provide technical justification showing that
            an adequate level of reliability is maintained with the 105 minute version. In the second
            posting process, the drafting team will survey WECC voters for their opinion on
            whether or not the supporting documentation is sufficient for the Operating Committee

                                              39
            to support the 105 minutes. If the survey results indicate that the supporting
            documentation is insufficient, the drafting team will recommend that the OC approve
            the standard with the 60 minutes restoration period.

Final Comments:

Shell Energy supports the comments by John Stout, Mariner Consulting Services.

Shell Energy makes the two following suggestions:

    1.     The last paragraph under the second bullet of R1.1.2 should be deleted - “For purposes
         of R1.1.2, sink Balancing Authority net generation reserve calculations include generation
         located in a separate source Balancing Authority where both the sink and the source
         Balancing Authorities have agreed to that counting mechanism.”

    2.      Submit 2 versions, 105 min. and 60 min. - WECC should focus on revisions that will be
         acceptable to FERC in a reasonable timeframe. We risk pushing this process back by
         insisting on 105 minutes. Please consider submitting two drafts for approval, one with the
         105 minute and one with the 60 minute reserve restoration standard, if the drafting team
         justifies the 105 minutes. If FERC agrees with the arguments with the 105 minute
         submittal, then they have the ability to approve. Should we submit only 1 version, we may
         risk a similar delay to the 3-4 year delay we are currently experiencing.
             RESPONSE:

            Item 1 - BA Agreement Issue: Based on comments, the drafting team has removed this
            language. Please refer to the revised standard posted for comment. The drafting team
            points out that a pseudo-tie can be used to move generation and load from one BA to
            another. The drafting team asks for comments on this revised language.




            Item 2 – Reserve Restoration Period: After review of the comments in this survey, the
            drafting team has revised the draft standard to include the current 60 minute time
            period. The drafting team interprets the responses as supporting the 60 minute
            restoration period due to the expectation that it would clear the regulatory process in a
            timely manner. The drafting team will also post documents that provide technical
            justification showing that an adequate level of reliability is maintained with the 105
            minute version. In the second posting process, the drafting team will survey WECC
            voters for their opinion on whether or not the supporting documentation is sufficient for
            the Operating Committee to support the 105 minutes. If the survey results indicate that
            the supporting documentation is insufficient, the drafting team will recommend that the
            OC approve the standard with the 60 minutes restoration period.

I greatly appreciate the drafting team's timeliness in responding to the Board's direction to revise
BAL-002 to address FERC's concerns. However, as noted above, I have concerns about trying
to justify a 105 minute reserve restoration period in light of FERC's observations about WECC
stability-limited paths. I also believe the language added to R.1.1.2 confuses, if not negates, the
original intent of BAL-002. I encourage the drafting team to develop different language to try to
address FERC's concern about generation in other BAAs.




                                               40
            RESPONSE:

            Item 1 - BA Agreement Issue: Based on comments, the drafting team has removed this
            language. Please refer to the revised standard posted for comment. The drafting team
            points out that a pseudo-tie can be used to move generation and load from one BA to
            another. The drafting team asks for comments on this revised language.




            Item 2 – Reserve Restoration Period: After review of the comments in this survey, the
            drafting team has revised the draft standard to include the current 60 minute time
            period. The drafting team interprets the responses as supporting the 60 minute
            restoration period due to the expectation that it would clear the regulatory process in a
            timely manner. The drafting team will also post documents that provide technical
            justification showing that an adequate level of reliability is maintained with the 105
            minute version. In the second posting process, the drafting team will survey WECC
            voters for their opinion on whether or not the supporting documentation is sufficient for
            the Operating Committee to support the 105 minutes. If the survey results indicate that
            the supporting documentation is insufficient, the drafting team will recommend that the
            OC approve the standard with the 60 minutes restoration period.

I appreciate the SDT's efforts in the timely development of this draft.


            RESPONSE: Thank you for your comments.

Sempra Generation (SGEN) appreciates the opportunity to comment on the latest draft of the
Contingency Reserves Standard. SGEN commends the drafting team on the timely response to
revise BAL-002 in order to address FERC's concerns, but SGEN objects to some of the proposed
language. SGEN believes that the drafting team should delete the language added to R1.1.2 as it
makes the responsibility for the provision of reserves unclear and is a step backward from the
original intent of the revised BAL-002 to separate reserve requirements from energy transactions.
Sempra Generation also feels that the proposal for a 105 minute reserve restoration period should
be addressed in a separate process.


            RESPONSE:

            Item 1 - Reserve Restoration Period: After review of the comments in this survey, the
            drafting team has revised the draft standard to include the current 60 minute time
            period. The drafting team interprets the responses as supporting the 60 minute
            restoration period due to the expectation that it would clear the regulatory process in a
            timely manner. The drafting team will also post documents that provide technical
            justification showing that an adequate level of reliability is maintained with the 105
            minute version. In the second posting process, the drafting team will survey WECC
            voters for their opinion on whether or not the supporting documentation is sufficient for
            the Operating Committee to support the 105 minutes. If the survey results indicate that
            the supporting documentation is insufficient, the drafting team will recommend that the
            OC approve the standard with the 60 minutes restoration period.




            Item 2 - BA Agreement Issue: Based on comments, the drafting team has removed this

                                               41
           language. Please refer to the revised standard posted for comment. The drafting team
           points out that a pseudo-tie can be used to move generation and load from one BA to
           another. The drafting team asks for comments on this revised language.

LS Power commends WECC Standards Drafting Team for their efforts on this task.




LS Power recommends removal of the new language inserted in R.1.1.2 "..sink Balancing
Authority net generation reserve calculations include generation located in a separate source
Balancing Authority where both the sink and the source Balancing Authorities have agreed to that
counting mechanism..".




Also, LS Power recommends segregating the increased reserve restoration window provision into
a separate revision of BAL-002.




We appreciate the opportunity to comment on this draft standard.


           RESPONSE:

           Item 1 - Reserve Restoration Period: After review of the comments in this survey, the
           drafting team has revised the draft standard to include the current 60 minute time
           period. The drafting team interprets the responses as supporting the 60 minute
           restoration period due to the expectation that it would clear the regulatory process in a
           timely manner. The drafting team will also post documents that provide technical
           justification showing that an adequate level of reliability is maintained with the 105
           minute version. In the second posting process, the drafting team will survey WECC
           voters for their opinion on whether or not the supporting documentation is sufficient for
           the Operating Committee to support the 105 minutes. If the survey results indicate that
           the supporting documentation is insufficient, the drafting team will recommend that the
           OC approve the standard with the 60 minutes restoration period.




           Item 2 - BA Agreement Issue: Based on comments, the drafting team has removed this
           language. Please refer to the revised standard posted for comment. The drafting team
           points out that a pseudo-tie can be used to move generation and load from one BA to
           another. The drafting team asks for comments on this revised language.


 Number Of
 Responses1 Percentage
 Of Responses(6%)

Los Angeles Department of Water and Power (LADWP) agrees with FERC’s statement in
paragraph 62 in the RM09-15-000 NOPR (see below for paragraph 62) that it is unnecessary for
WECC to maintain its own definition of the term Spinning Reserve, and that WECC should remove


                                              42
the regional definition from the NERC Glossary and instead use the NERC definition of Spinning
Reserve for WECC Standard BAL-002-WECC-1.




LADWP suggests modifying requirements R2, R2.1 and R2.2 in the current draft of BAL-002-
WECC-1 to be consistent with the use of the NERC definition of Spinning Reserve. LADWP
suggests requirements R2, R2.1 and R2.2 to read as followed:




        R2.      Each Reserve Sharing Group, or Balancing Authority that is not a member of a
                 Reserve Sharing Group, shall maintain at least half of the Contingency Reserve in
                 R1.1 as Operating Reserve - Spinning. Any Operating Reserve - Spinning specified
                 in R1 shall meet the following requirements as specified in the NERC glossary of
                 terms. [Violation Risk Factor: Medium] [Time Horizon: Real time operations]

              R2.1.     Generation synchronized to the system and fully available to serve load
                        within the disturbance recovery period following the contingency event; or

              R2.2.     Load fully removable from the system within the Disturbance Recovery
                        Period following the contingency event




Paragraph 62. As commenters have pointed out, the term Spinning Reserve is used in the
definition of Operating Reserve and in service agreements by and among certain WECC entities.
Therefore, the Commission will not adopt its proposal to direct the ERO to remove the term from
the NERC Glossary. However, as NERC points out WECC has maintained its own definition of the
term Spinning Reserve. We find no substantial difference between the two terms. Both terms refer
to “unloaded generation that is synchronized and ready to serve additional demand.”71 In its order
approving WECC’s current regional Reliability Standard, the Commission determined that regional
definitions should conform to the definitions set forth in the NERC Glossary, unless a specific
deviation has been justified.72 WECC has not justified the need for a separate, regional definition
of Spinning Reserve. Accordingly, we direct WECC to remove this regional definition from the
NERC Glossary.


           RESPONSE: The drafting team has removed all terms not defined by NERC from the
           proposed standard. There is not a need to reference the NERC glossary since the
           terms are capitalized and defined in the glossary. The drafting team will recommend to
           the OC to remove the terms from the WECC glossary at NERC.


PPL Montana, LLC and PPL Energy Plus, LLC (PPL) encourage the WECC-BAL-002 SDT to
continue working to include all of the changes required by FERC in their remand of this standard.
PPL has concerns with a number of issues and recommends the following items for the SDT
consideration:




                                              43
1.    PPL encourages the SDT to re-draft the standard in the latest NERC standard format.

2.    PPL encourages the SDT to re-write the VSLs based on both the percent of shortage in reserves
     in one hour and also the number of hours violation each month.

3.    Measure 3.1: Please add “Energy Emergency Alert Level 3” to the measure to indicate when this
     is appropriate.

4.    Please revise the second bullet under R1.1.2, to delete “and” under (b). Also, the indented
     paragraph under this same section should be bulleted and for clarity, replace “counting
     mechanism” with “agreed to that reserve accounting mechanism”.

5.    Finally, the redrafted of BAL-002-WECC-1 does not appear to address FERC NOPR paragraphs
     65 and 66 with respect to the BA allocating reserves. FERC recognized in paragraph 65 of the
     Order, the NV Energy request for FERC to give specific instructions to the WECC on how to
     assign reserve responsibility within a BA. In paragraph 66, FERC issues that instruction to the
     WECC. PPL would like the SDT to please propose wording in the standard to address the FERC
     and NV Energy’s concerns about how a BAA must allocate reserve obligations.


                RESPONSE:

                1.   In the interest of expediting the drafting process, the drafting team will leave the
                                standard in its existing format. If approved by the OC, WECC staff will
                                conform the standard into the latest NERC template format.
                2.   The drafting team believes that this issue is beyond the charge given it. FERC did
                                not raise this as a concern in its order on remand.
                3.   The drafting team made this modification.
                4.   The drafting team modified this language significantly. Please review the revised
                                posting for the modified language.
                5.   The drafting team has considered the issues as directed in the referenced
                                paragraphs. Based on the comments received, the drafting team has
                                revised the proposal. Please review the revised standard.


     Iberdrola Renewables supports the comments of John Stout of Mariner Consulting Services.


                RESPONSE: Please refer to the response to Mr. Stout.

     To improve the accuracy of R3, SCL suggests replacing notification with request; a revised R3
     would read as follows: “Each Reserve Sharing Group or Balancing Authority shall use the
     following acceptable types of reserve which must be fully deployable within 10 minutes of a request
     to meet R1:”


                RESPONSE: After discussion, the drafting team believes that the correct term is
                notification rather than request.

     Will the term Self-Provided Load be added to the WECC Glossary?




                                                   44
            RESPONSE: Based on the revision made to the proposed standard, there is no need
            to define the term Self-Provided Load.


Total: 17




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