Template fr Quality Review f NERC Reliability Standard BAL-003-1 Frequency Respnse and Frequency Bias Setting Basic Infrmatin: Prject number: 2007-12 Standard number: BAL-003-1 Prject title: Frequency Respnse Standard Title: Frequency Respnse and Frequency Bias Setting Crdinatr s name: Darrel Richardsn Draft date: July 12, 2011 Draft Number: 2 Date f review: July 26, 2011 Reviewer Names: Andrew Dressel Hlly Hawkins Maureen Lng Sctt Miller Requirements Requirement R1: The reliability utcme fr the requirements may be bvius t a subject matter expert, but the requirement, as written, des nt cntain a statement t indicate the desired reliability utcme. It isn t clear where r when the BA r RSG gets its FRO... Detailed in Attachment A Nt sure if R1 is a real-time requirement r nt... DWR prvide respnse The phrase, as detailed in Attachment A sunds as thugh Attachment A includes smething fr the respnsible entity t d but this seems t be an attachment telling what the ERO will d. The sentence shuld be rephrased. If the respnsible entity desn t perfrm any f the actins n Attachment A, the reference t this attachment shuld be deleted. Attachment A part f standard? Attachment A shuld be revised t remve passive language and insert additinal language t identify the respnsible entity fr the varius steps in the prcess. Mdified Attachment A Remve language referencing particular cmmittees and subcmmittees. Mdified Attachment A The requirement is very pen-ended... What is yur meaning? July 26, 2011 1
Requirement R2 If the BA des nt perfrm the calculatin in Attachment A then suggest remving this reference frm the requirement... mdified The term, crdinated secndary cntrl is nt defined and may nt be understd by all suggest adding mre wrds s the meaning is clear mdified The phrase, shall implement... int is awkward cnsider revising mdified Is the RSG applicable t R2? N Requirement R3 This requirement lks like a real time requirement that may be better lcated in anther standard... Part f riginal If the BA can t perate in tie line bias mde, there is n bligatin t ntify anyne it isn t clear wh shuld be ntified and isn t clear if there are any adjustments t any f the calculatins t adjust fr this making this requirement very pen ended... Lk in ther stds There is n timing cmpnent t this is it the expectatin that this is cntinuus? Yes What is the reliability utcme? mdified Is the RSG applicable t R3? N Requirement R4 The reliability utcme fr sme f the requirements may be bvius t a subject matter expert, but the requirement, as written, des nt cntain a statement t indicate the desired reliability utcme. mdified The phrase, t apprximate the respnse is ambiguus respnse t what? Hw clse is clse enugh? This needs sme bundaries. mdified There is n deadline fr perfrming this actin. When perfrming Is the RSG applicable t R4? July 26, 2011 2
N Requirement R5 There is n reliability utcme fr this requirement. This requirement shuld be subdivided as it is t cmplex in its current frmat. The requirement needs t be re-phrased t start with, Each BA shall... Mdified Nt sure what have means is this a value that is calculated r ne that is a measure f perfrmance after the fact... suggest with an abslute value, what is the actin required? Shuld the BAs implement the mnthly average FBS? It isn t clear what the BA has t d with this Frequency Bias Setting... If the intentin f this standard is t set sme parameters fr ACE calculatins then the requirements shuld be rephrased with that intent mre clear. Is the intentin t prvide a number t the ERO? Is the RSG applicable t R5? N Measures Measure M1 Shuld clearly state that the entity must have its Frm 1... using the phrase, such as is misleading. If a timing cmpnent is added t R1 it shuld als be added t M1. Measure M3 An peratr interview, by itself, wuld nt be sufficient t use as an attestatin. Measure M4 Nt familiar with verlap regulatin service but it seems like this is a cntractual bligatin and wuldn t be reflected. If there is a frmal agreement fr this service, then the measure shuld include this agreement. Evidence shuld nt fcus n shwing that the entity s ACE calculatin was adjusted as specified in the requirement... If a timing cmpnent is added t the requirement, it shuld als be added t the measure. Measure M5 Revise after revising the requirement. Cmpliance Mnitring and Assessment Prcesses There is a situatin where the BA wrks fr the RE t cver this situatin, revise t include the fllwing: July 26, 2011 3
The Reginal Entity is the Cmpliance Enfrcement Authrity except where the respnsible entity wrks fr the Reginal Entity. Where the respnsible entity wrks fr the Reginal Entity, the Reginal Entity will establish an agreement with the ERO r anther entity apprved by the ERO and FERC (i.e. anther Reginal Entity), t be respnsible fr cmpliance enfrcement. Additinal Cmpliance Infrmatin Sectin: Sme infrmatin in this sectin f the standard belngs in the requirements... this is nt intended t be a supplement t the requirements. R1 Supplemental Infrmatin this shuld be rephrased this is supplemental infrmatin fr cmpletin f the peridic data submittal nt fr meeting R1. The explanatry infrmatin in the first sentence f the secnd paragraph is nt needed. The activity in the secnd paragraph is nt clear as t what functinal entity is assigned respnsibility fr this task. Third paragraph culd verlap service invlve mre than 2 BA Areas? If yes, this shuld be updated s it desn t limit the scpe t just tw BAs. R2 Supplemental Infrmatin remve this heading and the first paragraph. The first paragraph is either a repetitin f what was already written in this sectin - r is explanatry infrmatin abut what the ERO will d. The paragraph with details abut filling ut Frm 1 seem apprpriate. It is nt clear hw a BA r RSG is t use the fllwing infrmatin if it is t cmplete a specific sectin f Frm 1, then adding that infrmatin t this sentence wuld be a help: Fr Intercnnectins that are als Balancing Authrities, Tie Line Bias cntrl and Flat Frequency cntrl are equivalent and either is acceptable. Nte explanatry It is nt clear hw a BA r RSG is t use the fllwing infrmatin if the respnsible entity shuld use this infrmatin when cmpleting Frm 1, then mre details are needed. It isn t clear what shuld means here it sunds like this is a must... : By definitin, Balancing Authrities receiving Overlap Regulatin Service have an ACE and Frequency Bias Setting equal t zer (0). See the R1 Supplemental Infrmatin fr annual reprting n FRS Frm 1. Remved Evidence Retentin Missing any evidence retentin identificatin fr the RSG Dne Suggest current year plus previus three calendar years (Jan-Dec) fr additinal clarity Mdified plus questin Vilatin Risk Factrs R1 if this is a real-time requirement, this shuld be High Nt RT medium apprpriate R3 cnsider if this shuld be High July 26, 2011 4
N based n the descriptin.. Vilatin Severity Levels General Observatin: The increments between VSLs identifying different threshlds fr nncmpliant perfrmance appear t large. VSLs fr R1 VSLs vilate FERC s guideline 3 as they add language nt used in the requirement. VSLs fr R2 Shuld include language specifying that they are fr BAs nt receiving Overlap Regulatin Service Shuld accunt fr the situatin where the BA did nt d this at all VSLs vilate FERC s guideline 3 as they add language nt used in the requirement. VSLs fr R3 Shuld include language specifying that they are fr BAs nt receiving Overlap Regulatin Service... Shuld nt reference Measure M3 the VSLs identify nncmpliant perfrmance linked t the requirements, nt linked t the measures. Shuld nt include reference t nrmal mde as this language is nt in the requirement vilatin f FERC guideline 3 Shuld nt include language linked t prviding evidence as this language is nt in the requirement, it is in the measures - vilatin f FERC guideline 3 VSLs fr R3 These all need t be written withut regard fr the type f audit since the requirement des nt reference the type f audit. Shuld nt be tied t events, since this language is nt in the requirement VSLs fr R4 Dn t match the NERC guidelines f 5%, 10%, 15% threshlds. VSLs fr R5 Need t be written in the past tense as they describe perfrmance fund. Cmpleteness Because the requirements and attachments aren t clear abut wh des what when, it isn t clear if there is infrmatin in the attachments that is linked t perfrmance in R1 and R2. FERC and Stakehlder Issues Befre psting, prvide an explanatin t identify mre specifically hw the ther team is addressing the ther part f the directive and hw the tw teams are crdinating t ensure that the directive is fully met. July 26, 2011 5
If there were issues frm stakehlders (in additin t the issues frm FERC Orders) fr the team t address, these were nt prvided fr review. Implementatin Plan Need t identify when t retire the existing definitin f Frequency Bias Setting Missing prerequisites assciated with finalizing attachments and any change t the ROP Missing an explanatin fr phasing the implementatin Mapping Dcument - Hwever sme f the infrmatin will need t be updated after the standard is revised. Other Issues FRS Frm 1 FRS Frm 1 shuld have a clear set f instructins as a cver page... Attachment A See cmments embedded in the dcument Attachment B See cmments embedded in the dcument Backgrund Dcument Review and revise t have the language in the supprting dcument match the language in the standard. The bservers culd nt tell if the purpse f the standard is supprted by the requirements as written. July 26, 2011 6