In addition to the reliability-related decisions and Notices of Proposed Rulemaking (NOPR) issued during the Federal Energy Regulatory Commission’s (FERC) July 18, 2013 Open Meeting, there are two reliability-related dockets that are worthy of mention and provide an opportunity for interested parties to submit comments.

Frequency Response

On July 18, FERC issued a Notice of Request for Comments concerning the Market Implications of Frequency Response and Frequency Bias Setting Requirements in Docket No. AD13-8-000. FERC issued the Notice concurrently with an NOPR proposing to approve the North American Electric Reliability Corporation’s (NERC) proposed Reliability Standard BAL-003-1 (Frequency Response and Frequency Bias Setting). See FERC Makes Several Reliability-Related Issuances at Its July Open Meeting for more details on proposed Reliability Standard BAL-003-1.

In its Notice, FERC seeks comment on the potential market and commercial impacts of certain requirements of the proposed Reliability Standard. In particular, FERC is interested in comments on the potential market and commercial impacts of:

  1. Allowing the minimum Frequency Bias Setting to be different than actual frequency response for prolonged periods, and how such impacts may be addressed in future versions of the proposed Reliability Standard, in market rules and tariffs, or by other means.

FERC explains under proposed Reliability Standard BAL-003-1, each Balancing Authority would be required to achieve an annual Frequency Response Measure that is equal to or more negative than its Frequency Response Obligation. However, as FERC notes, frequency response which does not match the Frequency Bias Setting results in a systematic error in the determination of power balance that causes Balancing Authorities (that are following their area control error or ACE) to overproduce secondary frequency response through automatic generation control (AGC). This affects both normal and contingency operations. During normal operation, a Balancing Authority achieving a zero ACE would actually be over-generating whenever the frequency is below 60 Hz. During a contingency, every Balancing Authority would record a change in their ACE and respond as if they each had a contingency even though only one of the Balancing Authorities actually had the contingency. Such results can create loop flows and inadvertent interchange, which in turn can create imbalances on neighboring systems and lower the amount of transmission capacity that is available to the market.

  1. Not accounting for transmission limitations and historical flows when calculating each Balancing Authority’s Frequency Response Obligation, and how such impacts may be addressed in future versions of the proposed Reliability Standard, in market rules and tariffs, or by other means.

Proposed Reliability Standard BAL-003-1 includes a formula to determine a Balancing Authority’s Frequency Response Obligation based on generation and load within the Balancing Authority in proportion to the Interconnection Frequency Response Obligation. However, that formula does not take into account transmission limitations or historical transmission use, two factors Balancing Authorities take into account and use together with the results of system studies to estimate the appropriate Transmission Reliability Margins (TRM). FERC states that “Excluding historical flows and transmission limitations from consideration during the calculation of each Balancing Authority’s Frequency Response Obligation would appear to allow some Balancing Authorities to continue “leaning” on other Balancing Authorities and could also result in lower TRM set-asides, making increased transmission capacity available for market transactions.” Notice at P 8.

  1. Crediting the entire Western Interconnection for load resources and how such impacts may be addressed in future versions of the proposed Reliability Standard, in market rules and tariffs, or by other means.

Under the proposed Reliability Standard, NERC proposes to reduce the Interconnection Frequency Response Obligation for the Western Interconnection by applying “a credit for load resources” that subtracts the performance of load-side resources (such as frequency responsive demand response) from the resource contingency criteria before calculating the Interconnection Frequency Response Obligation. This effectively credits the Western Interconnection with the frequency responsive load resources located in particular Balancing Authorities rather than allowing a Balancing Authority to benefit from locally-located load resources in achieving its own Frequency Response Obligation.

FERC makes it clear that it will not propose changes to proposed Reliability Standard BAL-003-1 as a result of comments received; instead, any comments submitted in this docket will inform FERC’s consideration of whether potential future actions are necessary to coordinate the requirements of the proposed Reliability Standard with FERC-jurisdictional tariffs and markets rules.

FERC has requested that interested parties submit comments on or before the date on which comments are due on the NOPR, which will be 60 days after publication in the Federal Register.

Vegetation Management

On July 12, 2013, in accordance with certain of FERC’s directives in Order No. 777, NERC submitted a compliance filing: (1) providing a description of its plan to conduct testing to develop empirical data regarding the flashover distances between conductors and vegetation; (2) modifying the Violation Risk Factor (VRF) for Requirement R2; and (3) confirming that it has posted guidance materials for NERC Reliability Standard FAC-003-2 to its website. FERC has requested that interested parties submit comments by August 7, 2013.

Minimum Clearance Values Study

NERC is in the process of complying with FERC’s Order No. 777 directive to undertake testing to develop empirical data regarding the flashover distances between conductors and vegetation (Project). The primary objective of the Project is to determine the appropriate gap factor (specified in NERC Reliability Standard FAC-003-2) for calculating minimum vegetation clearance distances (MVCD) utilizing the Gallet Equation. NERC has held discussions with the Electric Power Research Institute, industry members, and FERC staff regarding the Project’s scope of work and the tasks necessary to complete the work. NERC plans to commence the Project in September 2013, subject to availability of approximately $350,000 in funding, and hopes to complete it with a final FERC-filed report in June 2015.

Assignment of a “High” VRF to FAC-003-2 R2

In Order No. 777, FERC directed NERC to submit a modification assigning a “high” VRF for Requirement R2 of NERC Reliability Standard FAC-003-2. In its compliance filing, NERC submitted that modification for FERC’s approval.

FAC-003-2 Guidance

In accordance with FERC’s Order No. 777 directive, NERC posted reference materials relating to vegetation management on its website in the “Related Links” portion of the standard page for NERC Reliability Standard FAC-003-2. The materials include NERC’s Petition for Approval of Proposed Reliability Standard FAC-003-2 and NERC’s May 25, 2012 response to Commission staff data requests. The Guideline and Technical Basis document is incorporated into the same file as NERC Reliability Standard FAC-003-2 and can be found here. In the Guidelines and Technical Basis document, NERC explains that Requirements R1 and R2 are, content-wise, the same requirements; however, they apply to different Facilities. It also explains the rationale behind their application. Finally, NERC states that for R3, there are many acceptable approaches to manage vegetation and avoid Sustained Outages; however, the Transmission Owner must be able to show the documentation of its approach and how it conducts work to maintain clearances.