NERC Petition

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
North American Electric Reliability
Corporation
Texas Reliability Entity, Inc.

)
)
)

Docket No. _______

JOINT PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
AND TEXAS RELIABILITY ENTITY, INC.
FOR APPROVAL OF PROPOSED REGIONAL RELIABILITY STANDARD
BAL-001-TRE-01 – PRIMARY FREQUENCY RESPONSE IN THE ERCOT REGION
Gerald W. Cauley
President and Chief Executive Officer
North American Electric Reliability
Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
(404) 446-2560

Charles A. Berardesco
Senior Vice President and General Counsel
Holly A. Hawkins
Assistant General Counsel
S. Shamai Elstein
Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
charlie.berardesco@nerc.net
holly.hawkins@nerc.net
shamai.elstein@nerc.net

Donald G. Jones
Director, Special Projects
Texas Reliability Entity, Inc.
805 Las Cimas Parkway, Suite 200
Austin, Texas 78746
(512) 583-4929
don.jones@texasre.org

Tammy Cooper
General Counsel
Texas Reliability Entity, Inc.
805 Las Cimas Parkway, Suite 200
Austin, Texas 78746
(512) 583-4929
tammy.cooper@texasre.org
September 18, 2013

TABLE OF CONTENTS
I.

EXECUTIVE SUMMARY .................................................................................................... 2

II.

NOTICES AND COMMUNICATIONS ................................................................................ 5

III. BACKGROUND .................................................................................................................... 5
A.

Regulatory Framework ..................................................................................................... 5

B.

History and Basis of the Proposed Regional Reliability Standard ................................... 8

IV. JUSTIFICATION FOR APPROVAL................................................................................... 10

V.

A.

Purpose of Proposed BAL-001-TRE-01 ........................................................................ 10

B.

Requirements in Proposed BAL-001-TRE-01 ............................................................... 11

C.

Enforceability of Proposed BAL-001-TRE-01 .............................................................. 17
CONCLUSION ..................................................................................................................... 18

Exhibit A

Proposed Reliability Standard

Exhibit B

Implementation Plan for BAL-001-TRE-01

Exhibit C

Order No. 672 Criteria for BAL-001-TRE-01

Exhibit D

Analysis of Violation Risk Factors and Violation Security Levels

Exhibit E

Record of Development of BAL-001-TRE-01

i

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

North American Electric Reliability
Corporation
Texas Reliability Entity, Inc.

)
)
)

Docket No. _______

JOINT PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
AND TEXAS RELIABILITY ENTITY, INC.
FOR APPROVAL OF PROPOSED REGIONAL RELIABILITY STANDARD
BAL-001-TRE-01 – PRIMARY FREQUENCY RESPONSE IN THE ERCOT REGION
Pursuant to Section 215(d)(1) of the Federal Power Act (“FPA”)1 and Section 39.52 of the
regulations of the Federal Energy Regulatory Commission (“FERC” or “Commission”), the
North American Electric Reliability Corporation (“NERC”) 3 and the Texas Reliability Entity,
Inc. (“Texas RE”) hereby submit proposed regional Reliability Standard BAL-001-TRE-01 for
Commission approval. NERC and Texas RE request that the Commission approve proposed
regional Reliability Standard BAL-001-TRE-01 (Exhibit A) as just, reasonable, not unduly
discriminatory or preferential, and in the public interest. 4 NERC and Texas RE also request
approval of the associated implementation plan (Exhibit B), and the associated Violation Risk
Factors (“VRFs”) and Violation Severity Levels (“VSLs”) (Exhibits A and D), as detailed in
this petition.

1

16 U.S.C. § 824o (2006).

2

18 C.F.R. § 39.5 (2013).

3

The Commission certified NERC as the electric reliability organization (“ERO”) in accordance with
Section 215 of the FPA on July 20, 2006. N. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062 (2006).
4

Unless otherwise designated, all capitalized terms shall have the meaning set forth in the Glossary of Terms
Used in NERC Reliability Standards, available at http://www.nerc.com/files/Glossary_of_Terms.pdf

1

As required by Section 39.5(a)5 of the Commission’s regulations, this petition presents
the technical basis and purpose of the proposed regional Reliability Standard, a summary of the
development proceedings (Exhibit E), and a demonstration that the proposed Reliability
Standard meets the criteria identified by the Commission in Order No. 672 6 (Exhibit C).
Proposed Reliability Standard BAL-001-TRE-01 was approved by the Texas RE Board of
Directors on April 23, 2013 and by the NERC Board of Trustees on August 15, 2013.
NERC proposes an effective date of the first day of the first calendar quarter following
applicable regulatory approval.

This standard will only be effective within the Texas RE

footprint (the Electric Reliability Council of Texas (“ERCOT”) Interconnection). Registered
entities within the Texas RE footprint must comply with the requirements of the proposed
regional Reliability Standard in accordance with the schedule set forth in the associated
implementation plan provided in Exhibit B.
I.

EXECUTIVE SUMMARY
The purpose of proposed BAL-001-TRE-01 is to provide a regional Reliability Standard

for the ERCOT Interconnection related to the maintenance of steady-state frequency within
defined limits by balancing real power demand and supply in real-time. Proposed BAL-001TRE-1 seeks to establish and maintain adequate Frequency Response in the ERCOT region by
ensuring prompt and sufficient Frequency Response from resources to stabilize frequency during

5

18 C.F.R. § 39.5(a) (2013).

6

The Commission specified in Order No. 672 certain general factors it would consider when assessing
whether a particular Reliability Standard is just and reasonable. See Rules Concerning Certification of the Electric
Reliability Organization; and Procedures for the Establishment, Approval, and Enforcement of Electric Reliability
Standards, Order No. 672, FERC Stats. & Regs. ¶ 31,204, at P 262, 321-37, order on reh’g, Order No. 672-A,
FERC Stats. & Regs. ¶ 31,212 (2006).

2

changes in the system generation-demand balance.7 As explained below, the proposed regional
Reliability Standard improves upon ERCOT’s existing practices for Frequency Response, is
necessitated by physical differences in the ERCOT system and represents an alternative, more
stringent means of assuring Frequency Response performance than the continent-wide NERC
Reliability Standard.
The proposed regional Reliability Standard responds to a Commission directive in Order
No. 693 to develop a regional Reliability Standard for assuring frequency performance in the
ERCOT Interconnection.8 In Order No. 693, the Commission approved a regional difference for
the ERCOT Interconnection from BAL-001-0, allowing ERCOT to be exempt from Requirement
R2 of BAL-001-0. 9

ERCOT requested waiver of Requirement R2 because of physical

differences in the ERCOT system and because compliance with Requirement R2 may not be
feasible under ERCOT’s competitive balancing energy market.

In approving the regional

difference, the Commission found that “ERCOT’s approach to Frequency Response under
section 5 of the ERCOT Protocols appears to be a more stringent practice than Requirement R2
in BAL-001-0.” 10 The Commission directed the ERO to file a modification of the ERCOT
regional difference to include the requirements concerning Frequency Response contained in
section 5 of the ERCOT Protocols. As discussed below, proposed BAL-001-TRE-01 improves

7

In the proposed regional Reliability Standard, the term “resource” is synonymous with “generating unit” or
“generating facility.”
8

Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, 72 FR 16416 (Apr. 4, 2007),
FERC Stats. & Regs. ¶ 31,242, at PP 313-15 (2007), order on reh’g, Order No. 693-A, 120 FERC ¶ 61,053 (2007).
9

Order No. 693 at PP 313-15.

10

Order No. 693 at P 314. The ERCOT Protocols contain the scheduling, operating, planning, reliability, and
settlement (including Customer registration) policies, rules, guidelines, procedures, standards, and criteria of
ERCOT. Section 5 of the ERCOT Protocols addresses Frequency Response. The ERCOT Protocols are available
at http://www.ercot.com/mktrules/protocols/current.

3

upon the ERCOT Protocols by requiring individual generators to provide appropriate Frequency
Response.11
The proposed regional Reliability Standard represents a comprehensive approach to
assuring frequency response performance in the ERCOT Interconnection.

The requirements of

proposed BAL-001-TRE-01 relate to: (1) identifying Frequency Measureable Events; 12 (2)
calculating the Primary Frequency Response 13 of each resource in the Interconnection; (3)
calculating the Interconnection minimum Frequency Response and monitoring the actual
Frequency Response of the Interconnection; (4) setting Governor 14 deadband and droop
parameters under which resources must operate, and (5) providing Primary Frequency Response
performance requirements. These requirements work together to help ensure that generation and
load remain balanced (or are quickly restored to balance) in the ERCOT Interconnection so that
system frequency is restored to stability and near-normal frequency even after a significant
event, such as a large generator trip, occurs on the system.
For the reasons discussed in this petition, NERC and Texas RE respectfully request that
the Commission approve the standard as just, reasonable, not unduly discriminatory or
preferential, and in the public interest.

11

The Interconnection-wide Frequency Response required by the ERCOT Protocols is a function of the
cumulative response provided by individual generators.
12

The proposed regional standard defines Frequency Measureable Events as “an event that results in a
Frequency Deviation identified at the [Balancing Authority’s] sole discretion” and meeting one of two criteria set
forth in the proposed regional standard.
13

The proposed regional standard defines Primary Frequency Response as “[t]he immediate proportional
increase or decrease in real power output provided by generating units/generating facilities and the natural real
power dampening response provided by Load in response to system Frequency Deviations. This response is in the
direction that stabilizes frequency.”
14

The proposed regional standard defines Governor as “[t]he electronic, digital or mechanical device that
implements Primary Frequency Response of generating units/generating facilities or other system elements.”

4

II.

NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the

following:15
Charles A. Berardesco*
Senior Vice President and General Counsel
Holly A. Hawkins*
Assistant General Counsel
S. Shamai Elstein*
Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
charlie.berardesco@nerc.net
holly.hawkins@nerc.net
shamai.elstein@nerc.net
III.

Donald G. Jones
Director, Special Projects
Tammy Cooper*
General Counsel
Texas Reliability Entity, Inc.
805 Las Cimas Parkway, Suite 200
Austin, Texas 78746
(512) 583-4929
don.jones@texasre.org
tammy.cooper@texasre.org

BACKGROUND
A.

Regulatory Framework

By enacting the Energy Policy Act of 2005, 16 Congress entrusted the Commission with
the duties of approving and enforcing rules to ensure the reliability of the Nation’s Bulk-Power
System, and with the duties of certifying an ERO that would be charged with developing and
enforcing mandatory Reliability Standards, subject to Commission approval. Section 215(b)(1)17
of the FPA states that all users, owners, and operators of the Bulk-Power System in the United
States will be subject to Commission-approved Reliability Standards. Section 215(d)(5)18 of the
FPA authorizes the Commission to order the ERO to submit a new or modified Reliability

15

Persons to be included on the Commission’s service list are identified by an asterisk. NERC respectfully
requests a waiver of Rule 203 of the Commission’s regulations, 18 C.F.R. § 385.203 (2013), to allow the inclusion
of more than two persons on the service list in this proceeding.
16

16 U.S.C. § 824o (2006).

17

Id. § 824(b)(1).

18

Id. § 824o(d)(5).

5

Standard. Section 39.5(a)19 of the Commission’s regulations requires the ERO to file with the
Commission for its approval each Reliability Standard that the ERO proposes should become
mandatory and enforceable in the United States, and each modification to a Reliability Standard
that the ERO proposes should be made effective.
The Commission has the regulatory responsibility to approve Reliability Standards that
protect the reliability of the Bulk-Power System and to ensure that such Reliability Standards are
just, reasonable, not unduly discriminatory or preferential, and in the public interest. Pursuant to
Section 215(d)(2) of the FPA 20 and Section 39.5(c) 21 of the Commission’s regulations, the
Commission will give due weight to the technical expertise of the ERO with respect to the
content of a Reliability Standard and to the technical expertise of a Regional Entity, like Texas RE,
that is organized on an Interconnection-wide basis with respect to a regional Reliability Standard to
be applicable within that Interconnection.22

A Regional Reliability Standard proposed by a Regional Entity must meet the same
standards that NERC’s Reliability Standards must meet, i.e., the Regional Reliability Standard
must be shown to be just, reasonable, not unduly discriminatory or preferential, and in the public
interest.23 Order No. 672 also requires additional criteria that a regional Reliability Standard
must satisfy. A regional difference from a continent-wide Reliability Standard must either be (1)
more stringent than the continent-wide Reliability Standard (which includes a regional standard

19

18 C.F.R. § 39.5(a) (2012).

20

16 U.S.C. § 824o(d)(2).

21

18 C.F.R. § 39.5(c)(1).

22

Order No. 672 at P 344.

23

Section 215(d)(2) of the FPA and 18 C.F.R. §39.5(a).

6

that addresses matters that the continent-wide Reliability Standard does not), or (2) necessitated
by a physical difference in the Bulk Power System.24
Texas RE is an “interconnection-wide” Regional Entity, and its standards are intended to
apply to the ERCOT Interconnection. As discussed in the Texas Reliability Entity Standard
Development Process, 25 Texas RE’s standards are developed according to the following
characteristic attributes:
Developed in a fair and open process that provides an opportunity for all interested
parties to participate;
Drafted to help ensure that the standard does not have an adverse impact on commerce
that is not necessary for reliability;
Provides a level of Bulk Power System reliability that is adequate to protect public
health, safety, welfare, and national security and does not have a significant adverse
impact on reliability; and
Based on a justifiable difference between regions or between sub-regions within the
Regional geographic area.
Proposed Texas RE regional standards are subject to approval by the Texas RE Board of
Directors, NERC, as the ERO, and the Commission before becoming mandatory and enforceable
under Section 215 of the FPA.26 Applicable users, owners, and operators of the Bulk-Power
System in the ERCOT Interconnection must adhere to the NERC Reliability Standards as well as
the Texas RE regional Reliability Standards. NERC Reliability Standards and the Texas RE
regional Reliability Standards are both enforced through the Texas RE Compliance Program.

24

Order No. 672 at P 291.

25

The Texas Reliability Entity Standard Development Process is available at:
http://www.nerc.com/pa/Stand/Procedures%20and%20Comments/Texas_Reliability_Entity_Standards_Development_
Process.pdf.
26

16 U.S.C. 824o.

7

B.

History and Basis of the Proposed Regional Reliability Standard

As noted above, the proposed regional Reliability Standard responds to a Commission
directive in Order No. 693 to develop a regional Reliability Standard as an alternate means of
assuring frequency performance in the ERCOT Interconnection.

In Order No. 693, the

Commission approved a regional difference to the continent-wide NERC Reliability Standard
BAL-001-0 for the ERCOT Interconnection, exempting ERCOT from Requirement R2 of BAL001.27 Requirement R2, referred to as the Control Performance Standard 2, requires that each
Balancing Authority operate such that its average Area Control Error for each of the six tenminute periods during the hour be within specific limits, and that it achieve 90 percent
compliance.
The basis for the exemption relates to the physical differences in the ERCOT system and
its competitive market structure. The ERCOT Interconnection is separated electrically from the
rest of North America. Two DC (direct current) ties link the ERCOT system with Southwest
Power Pool to the north and east. ERCOT schedules and centrally dispatches its grid within a
single control area, ensures transmission reliability and wholesale open access, and manages
financial settlement in the wholesale power market. It also administers the Texas competitive
retail market, including customer switching. ERCOT requested a waiver of BAL-001-0,
Requirement R2 because (1) ERCOT, as a single Balancing Authority asynchronously connected
to the Eastern Interconnection, cannot create inadvertent flows or time errors in other control
areas, and (2) Control Performance Standard 2 may not be feasible under ERCOT’s competitive
balancing energy market. In support of this argument, ERCOT cited to a study showing that
under its market structure, the ten control areas in its region (at that time) individually were able

27

Order No. 693 at PP 313-15.

8

to meet Control Performance Standard 2 while the aggregate performance of the ten control areas
was not in compliance.
In approving the regional difference, the Commission directed the ERO to file a
modification of the ERCOT regional difference to include the requirements concerning
frequency response contained in section 5 of the ERCOT Protocols, which identifies the
necessary frequency controls needed for reliable operation in ERCOT. The Commission found
that “ERCOT’s approach to frequency response under section 5 of the ERCOT Protocols appears
to be a more stringent practice than Requirement R2 in BAL-001-0.”28
In response, Texas RE developed proposed BAL-001-TRE-01. Proposed BAL-001TRE-01was developed in an open, transparent, and inclusive fashion in accordance with the
Texas Reliability Entity Standard Development Process, as more fully described in Exhibit E
hereto.29 In short, the development of proposed BAL-001-TRE-01 was initiated with the posting
of a Standard Authorization Request for comment on April 24, 2008. Texas RE’s Reliability
Standards Committee approved the Standard Authorization Request for development on May 27,
2008 and an initial standard drafting team was formed on June 24, 2008.30 Between February
2009 and November 2010, the standard drafting team posted a draft of proposed BAL-001-TRE01 for formal comment on three separate occasions before posting for ballot. Several technical
workshops were conducted in conjunction with the comment periods, in order to inform
stakeholders about the proposed regional standard and to solicit and receive valuable feedback
from registered entities.
28

Order No. 693 at P 314.

29

The applicable standard development process for the Texas RE region changed from the Texas Regional
Entity Standards Development Process to the Texas Reliability Entity Standards Development Process on July 1,
2010. The proposed regional Reliability Standard was initiated under the Texas Regional Entity Standards
Development Process and completed under the Texas Reliability Entity Standards Development Process.
30

The standard drafting team roster is provided in Exhibit E hereto.

9

Following an unsuccessful first ballot, the standard drafting team conducted a Field Trial
to test the performance metrics in the draft standard, to demonstrate the application of the
proposed standard, and to educate entities regarding the purpose and benefits of the proposed
standard. Following the Field Trial and associated revisions to the proposed regional standard, a
second ballot was conducted, which passed with an 80% affirmative segment-weighted vote.
The proposed regional Reliability Standard was approved by the Texas RE Board of Directors on
April 23, 2013 and by the NERC Board of Trustees on August 15, 2013.
IV.

JUSTIFICATION FOR APPROVAL
As discussed in detail in Exhibit C, proposed regional Reliability Standard BAL-001-

TRE-01 satisfies the Commission’s criteria in Order No. 672 and is just, reasonable, not unduly
discriminatory or preferential, and in the public interest. The following section provides (1) a
discussion of the purpose of the proposed regional Reliability Standard, (2) a description of the
requirements of proposed BAL-001-TRE-01, and (3) a discussion of the enforceability of
proposed BAL-001-TRE-01.
A.

Purpose of Proposed BAL-001-TRE-01

As noted, the purpose of proposed BAL-001-TRE-01 is to maintain ERCOT
Interconnection steady-state frequency within defined limits by balancing real-power demand
and supply in real-time. This reliability goal is accomplished by requiring prompt and sufficient
Frequency Response from resources to stabilize frequency during changes in the system
generation-demand balance. To that end, the standard drafting team designed performance
metrics and requirements to: (a) require generators to operate within specified Governor settings;
(b) evaluate the actual Frequency Response performance of each generator; and (c) require the

10

Balancing Authority to monitor the Interconnection-wide Frequency Response and direct any
necessary actions to improve Frequency Response.
As noted above, the proposed regional Reliability Standard is responsive to a FERC
directive to incorporate section 5.9 of ERCOT’s Protocols concerning frequency control into an
enforceable Reliability Standard specific to the ERCOT region.

The proposed regional

Reliability Standard improves upon the ERCOT Protocols by requiring individual generators to
provide appropriate Frequency Response.

The Interconnection-wide Frequency Response

currently required by the ERCOT Protocols is a function of the cumulative response provided by
individual generators.
Although the proposed regional Reliability Standard is focused on requiring Frequency
Response from each individual generator, it does not restrict the Balancing Authority’s ability to
employ other sources of Frequency Response to meet the Interconnection’s required level of
performance. For instance, the proposed regional standard does not prohibit the development of
a market for Frequency Response that allows other sources to assist in meeting the region’s
needs. This market could allow generators to be re-dispatched to more economic operating
levels, which would reduce their operating margins (and available Frequency Response) but
improve the overall operating efficiency of the region. However, any generator with adequate
operating margin would still be expected to meet the performance measures of the proposed
regional standard, subject to applicable exclusions and limitations.
B.

Requirements in Proposed BAL-001-TRE-01

As noted above, the requirements of proposed BAL-001-TRE-01 relate to: (1) identifying
and posting Frequency Measureable Events (Requirement R1); (2) calculating the Primary
Frequency Response of each resource in the Interconnection (Requirement R2); (3) calculating

11

the Interconnection minimum Frequency Response and monitoring the actual Frequency
Response of the Interconnection (Requirements R3-R5); (4) requiring resources to operate in
accordance with specified Governor deadband and droop parameters and to promptly notify the
Balancing Authority of any change in Governor status (Requirements R6-R8); and (5) providing
Primary Frequency Response performance requirements for each generator (Requirements R9R10).

The requirements in proposed BAL-001-TRE-01 work together to help ensure that

generation and load remain balanced (or are quickly restored to balance) in the ERCOT
Interconnection so that system frequency is restored to stability and near normal frequency even
after a significant event occurs on the system. A discussion of each of the requirements in
proposed BAL-001-TRE-01 follows.
Requirement R1 requires the Balancing Authority to identify system events qualifying as
Frequency Measurable Events and to post basic information about such events, including event
time and pre- and post-event frequency. Frequency Measureable Events are defined as “an event
that results in a Frequency Deviation, identified at the [Balancing Authority’s] sole discretion,
and meeting one of two conditions” specified in the standards. 31 Requirement R1 states as
follows:
The [Balancing Authority] shall identify Frequency Measurable Events (FMEs),
and within 14 calendar days after each FME the [Balancing Authority] shall
notify the Compliance Enforcement Authority and make FME information (time
of FME (t(0)), pre-perturbation average frequency, post-perturbation average
frequency) publicly available.

31

Those condition are: (i) a Frequency Deviation that has a pre-perturbation [the 16-second period of time
before t(0)] average frequency to post-perturbation [the 32-second period of time starting 20 seconds after t(0)]
average frequency absolute deviation greater than 100 mHz (the 100 mHz value may be adjusted by the BA to
capture 30 to 40 events per year); or (ii) a cumulative change in generating unit/generating facility, DC tie and/or
firm load pre-perturbation megawatt value to post-perturbation megawatt value absolute deviation greater than 550
MW (the 550 MW value may be adjusted by the BA to capture 30 to 40 events per year).

12

The identification and posting information on Frequency Measurable Events allows all
applicable entities to know which events are subject to performance measurement under the
proposed regional standard (Requirements R9 and R10), and to allow entities to perform their
own Primary Frequency Response performance measurement calculations.
Requirement R2 requires the Balancing Authority to calculate the Primary Frequency
Response of each applicable generating unit or facility. The Primary Frequency Response of a
resource is defined as “[t]he immediate proportional increase or decrease in real power output
provided by generating units/generating facilities and the natural real power dampening response
provided by Load in response to system Frequency Deviations. This response is in the direction
that stabilizes frequency.” The calculations of each resource’s Primary Frequency Response are
used to determine whether Generation Owners comply with the Primary Frequency Response
performance metrics set forth in Requirements R9 and R10.
Under Requirement R2, the Balancing Authority’s calculation must provide a 12-month
rolling average of initial and sustained Primary Frequency Response performance and must be
completed each month for the preceding 12 calendar months. Requirement R2 also provides the
following:
The performance of a combined cycle facility will be determined using an expected
performance droop of 5.78%.32
The calculation results shall be submitted to the Compliance Enforcement Authority and
made available to the Generator Operator by the end of the month in which they were
completed.
If a generating unit/generating facility has not participated in a minimum of eight
Frequency Measureable Events in a 12-month period, its performance shall be based on a
rolling eight Frequency Measureable Events average response.
32

A combined cycle generating facility contains a combustion turbine that can provide Primary Frequency
Response and a steam turbine that cannot. The 5.78% evaluation droop is used in the performance measurement
process to correctly adjust the expected frequency response of the facility for the non- responsiveness of the steam
turbine.

13

Requirement R2 specifies that the Primary Frequency Response must be calculated in
accordance with Texas RE’s Primary Frequency Response Reference Document.33 The Primary
Frequency Response Reference Document is maintained by Texas RE and provides the specific
methodology for determining the Primary Frequency Response performance for individual
resources.

The technical details set forth in the Primary Frequency Response Reference

Document were initially included in early drafts of the proposed standard. The standard drafting
team, however, determined that it was preferable to create a separate document setting forth
those details so as to provide for an efficient mechanism for revising the methodology used to
calculate Primary Frequency Response.
The following process will be used to revise the Primary Frequency Response Reference
Document. Any interested entity may submit a request for revision to the Primary Frequency
Response Reference Document to the Texas RE Reliability Standards Manager. The Texas RE
Reliability Standards Manager will, in turn, present the requested revision to the Texas RE
Reliability Standards Committee for consideration. The requested revision will also be publicly
posted in accordance with Reliability Standards Committee procedures. The Reliability
Standards Committee must hold a public meeting to discuss the proposed revision, and will
accept and consider verbal and written comments. Following the public meeting, the Reliability
Standards Committee will make a recommendation to the Texas RE Board of Directors, which
may adopt the proposed revision, reject it, or adopt it with modifications. Any approved revision
to the Primary Frequency Response Reference Document shall be filed with NERC and FERC
for informational purposes.

33

The Primary Frequency Response Reference Document is provided as Attachment 2 to proposed BAL-001TRE-01, Exhibit A hereto.

14

Requirement R3 requires the Balancing Authority to “determine the Interconnection
minimum Frequency Response (IMFR) in December of each year for the following year, and
make the IMFR, the methodology for calculation and the criteria for determination of the IMFR
publicly available.”

The IMFR represents the desired response that the actual system

performance will be measured against.
The standard drafting team decided not to specify a permanent IMFR in the proposed
regional standard, as is provided for in the ERCOT Protocols,34 because the desired IMFR is
actually a dynamic amount that should reflect changes in system conditions from year-to-year
and even season-to-season. Requirement R3 obligates the Balancing Authority to determine the
IMFR each year so that changing system conditions can be taken into account.
Requirement R4 provides that “[a]fter each calendar month in which one or more
Frequency Measureable Events occur, the [Balancing Authority] shall determine and make
publicly available the Interconnection’s combined Frequency Response performance for a rolling
average of the last six Frequency Measureable Events by the end of the following calendar
month.” This six-event rolling average is then compared against the IMFR established pursuant
to Requirement R3.
Requirement R5 provides that if any Frequency Measureable Event causes the
Interconnection’s six-event rolling average Frequency Response performance to be less than the
IMFR, the Balancing Authority shall direct any necessary actions to improve Frequency
Response. The Balancing Authority’s actions may include, for example, directing generators to
change their Governor settings, re-dispatching generators to adjust frequency responsive reserve
margins, and seeking other sources to provide Primary Frequency Response.
34

Section 5.9.2.1 of the ERCOT Protocols called for the Interconnection-wide Frequency Response to be at
least 420 MW/0.1 Hz. ERCOT region market participants may consider whether to revise this protocol requirement
when the proposed regional standard becomes effective.

15

Requirement R6 requires Generation Owners to set their Governor deadband and droop
parameters to the limits set forth in the proposed Reliability Standard, which are based on the
type of generating facility. This requirement helps ensure that every generator provides an
appropriate contribution to system Frequency Response. Importantly, the proposed standard
requires generators to remove step-functions from their Governor settings, which, along with
reducing the deadband, significantly improves system stability and maintains system frequency
closer to the desired level.
Requirement

R7

requires

Generator

Operators

to

“operate

each

generating

unit/generating facility that is connected to the interconnected transmission system with the
Governor in service and responsive to frequency when the generating unit/generating facility is
online and released for dispatch, unless the [Generator Owner] has a valid reason for operating
with the Governor not in service and the [Generator Operator] has been notified that the
Governor is not in service.” In the ERCOT region, the normal communication path between a
Generator Owner and the Balancing Authority is often through the Generator Operator. As such,
Requirement R7 requires the Generator Owner to notify the Generator Operator of any deviation.
Requirement R8 requires “each [Generator Operator] to notify the [Balancing Authority]
as soon as practical but within 30 minutes of the discovery of a status change (in service, out of
service) of a Governor.” This ensures that the Balancing Authority maintains awareness of
Primary Frequency Response capabilities in its area.
Requirement R9 provides a specific Primary Frequency Response performance metric
relating to a generator’s initial response to a Frequency Measurable Event. Requirement R9
requires each generator to meet a minimum 12-month rolling average initial Primary Frequency
Response performance metric of 0.75, based on a participation in at least eight Frequency

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Measurable Events. Requirement R9 compares the actual megawatt response of each generator
to the expected megawatt response of the generator in the first minute after a Frequency
Measurable Event (average between 20 and 52 seconds). The results are averaged over one year
(or at least 8 events), and the requirement threshold is set at 75% of the expected response.
Failure to meet this threshold indicates incorrect Governor or control system settings, failure to
operate with Governor-in-service, or a malfunction of the generator’s Frequency Response
function.
Requirement R10 provides a specific Primary Frequency Response performance metric
relating to a generator’s sustained response to a frequency event. Requirement R10 requires
each generator to meet a minimum 12-month rolling average sustained Primary Frequency
Response performance metric of 0.75, based on a participation in at least eight Frequency
Measurable Events. Requirement R10 compares the actual megawatt response of a generator to
the expected megawatt response of the generator after the first half minute of a Frequency
Measurable Event (average between 46 and 60 seconds).

Sustained Primary Frequency

Response is important to facilitate system recovery after an event. There are a number of factors
that can cause a generator’s Frequency Response to be withdrawn prematurely, such as allowing
the Governor response to be over-ridden by other control system operations, and this requirement
helps to ensure that these factors do not interfere with correct Primary Frequency Response.
C.

Enforceability of Proposed BAL-001-TRE-01

The proposed regional Reliability Standard includes VRFs and VSLs. The VRFs and
VSLs provide guidance on the way that NERC will enforce the requirements of the proposed
regional Reliability Standard.

The proposed VRFs and VSLs comport with NERC and

Commission guidelines related to their assignment. For a detailed review of the VRFs, the

17

VSLs, and the analysis of how the VRFs and VSLs were determined using these guidelines,
please see Exhibit D.
The proposed regional Reliability Standard also includes measures that support each
requirement by clearly identifying what is required and how the requirement will be enforced.
These measures help ensure that the requirements will be enforced in a clear, consistent, and
non-preferential manner and without prejudice to any party.35
V.

CONCLUSION
For the reasons set forth above, NERC respectfully requests that the Commission:
approve the proposed regional Reliability Standard and associated elements included in
Exhibit A, effective as proposed herein; and
approve the implementation plan included in Exhibit B.
Respectfully submitted,
/s/ S. Shamai Elstein

Donald G. Jones
Director, Special Projects
Tammy Cooper
General Counsel
Texas Reliability Entity, Inc.
805 Las Cimas Parkway, Suite 200
Austin, Texas 78746
(512) 583-4929
don.jones@texasre.org
tammy.cooper@texasre.org

Charles A. Berardesco
Senior Vice President and General Counsel
Holly A. Hawkins
Assistant General Counsel
S. Shamai Elstein
Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
charlie.berardesco@nerc.net
holly.hawkins@nerc.net
shamai.elstein@nerc.net
Counsel for the North American Electric
Reliability Corporation

Date: September 18, 2013
35

See Order No. 672 at P 327.

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