UNITED STATES OF AMERICA
BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

Real Power Balancing Control)Docket No. RM14-10-000

Performance Reliability Standard)

The New York Independent System Operator (“NYISO”) submits these comments in
response to the Notice of Proposed Rulemaking (“NOPR”) issued on November 20, 2014, by
the Federal Energy Regulatory Commission (“FERC” or “Commission”) in this proceeding.

I.INTRODUCTION

During the NERC stakeholder process developing the proposed BAL-001-2 reliability
standard the Commission proposes to approve in this NOPR, the NYISO opposed approval of
BAL-001-2 in its present form based on the same concerns the Commission expresses here
regarding the results of NERC’s field trial of the Balancing Authority ACE Limit (“BAAL”)
requirement. As a Reliability Coordinator, Balancing Authority, and Transmission Operator, the NYISO is concerned that BAL-001-2 will allow balancing authorities to have a very large
deviation from an Area Control Error (“ACE”) of zero—and potentially negatively affect
reliability—yet still be compliant with the dynamic values of the BAALs calculated pursuant to the proposed Reliability Standard. Significant unscheduled power flows will be allowed to
occur, which could result in power flows approaching or exceeding system operating limits
(“SOLs”) or interconnection reliability operating limits (“IROLs”). These circumstances would require system operators to take action, up to and including load shedding, potentially unaware
of the source of the unscheduled flow causing the overloads.

Given these concerns, the NYISO submits these comments to support the Commission’s
proposal that NERC collect data regarding unscheduled power flows for the first two years the
standard is in effect, prepare an informational filing based on that data collection and, if the data

indicates reliability issues due to increases in unscheduled power flows and inadvertent

interchange under the new BAAL requirement at any time during the two-year study, require that NERC immediately propose and implement adequate remedies.

II. COMMUNICATIONS AND CORRESPONDENCE

All communications regarding this filing should be directed to:

Robert E. Fernandez, General Counsel

Raymond Stalter, Director, Regulatory Affairs
*Christopher Sharp, Compliance Attorney

10 Krey Boulevard

Rensselaer, NY 12144
Tel: (518) 356-8540
Fax: (518) 356-7678
rfernandez@nyiso.com
rstalter@nyiso.com
csharp@nyiso.com

* Person designated for receipt of service.

III. COMMENTS

On April 2, 2014, NERC filed a petition (“Petition”) seeking approval of proposed
Reliability Standard BAL-001-2. The proposed reliability standard focuses on ensuring that
entities subject to the standard maintain system frequency within narrow bounds around a
scheduled value. Among other things, BAL-001-2 would replace the Control Performance
Standard 2 with the BAAL: a calculation unique for each balancing authority that contains
dynamic limits based on interconnection frequency and provides the basis for a balancing

authority’s obligation to balance its resources and demand in real-time so that its clock-minute
average ACE does not exceed its BAAL for more than 30 consecutive minutes. BAL-001-2
permits a balancing authority to allow its ACE to deviate from zero—even substantially—as
long as the balancing authority does not exceed its BAAL for more than 30 consecutive minutes.

As the Commission observed in the NOPR, during the development of the proposed
Reliability Standard some stakeholders that participated in a field trial of the revised standard
commented to the NERC standard drafting team that the proposed BAAL calculated pursuant to
Requirement R2 of BAL-001-2 caused increased system operating limit violations. Specifically
of concern, the field trials indicated the potential for an increased number of SOL violations as
well as potential for increased unscheduled flows with the proposed BAAL limits based on
frequency triggers. Further, as the NYISO noted in comments submitted to NERC on BAL-001-

2 during the balloting process, the reliability standards governing SOLs and IROLs may be

inadequate to address these additional overloads, as the flows that are causing the overloads due
to the allowable increase in ACE, under the proposed standard, are not identifiable in energy
management systems if they originate in distant balancing authority areas. For these reasons, the
NYISO strongly supports the Commission’s proposal to order that NERC collect data regarding
unscheduled power flows in the Western and Eastern Interconnections, prepare an informational
filing based on that data collection, and if the data indicates reliability issues due to increases in
unscheduled power flows and inadvertent interchange under the new BAAL requirement at any
time during the two-year study, require that NERC will immediately propose and implement
adequate remedies.

With respect to the nature of the data collection, the NYISO agrees with the data points
the Commission suggests, namely: the number, date and time, location, duration, and magnitude
of SOL/IROL violations due to unscheduled power flows within Western and the Eastern
Interconnections. In order to ensure that NERC is correctly identifying instances of SOL/IROL
violations associated with the BAAL calculation—and, more specifically, large ACE values—
the NYISO suggests that, in addition to these data points, NERC also be required to track ACE

and BAAL values for the SOL/IROL violations that may be caused by unscheduled power flows or inadvertent exchange.

III.CONCLUSION

For the foregoing reasons, the NYISO respectfully requests that Commission consider the NYISO’s comments as articulated above.

Respectfully submitted,

/s/ Christopher R. Sharp

Robert E. Fernandez
General Counsel
Christopher R. Sharp
Compliance Attorney

New York Independent System Operator, Inc

January 26, 2015

cc:Michael Bardee

Gregory Berson
Anna Cochrane
Morris Margolis
David Morenoff
Daniel Nowak
Kathleen Schnorf
Jamie Simler

Kevin Siqveland

CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing document upon each person

designated on the official service list compiled by the Secretary in this proceeding in accordance with the requirements of Rule 2010 of the Rules of Practice and Procedure, 18 C.F.R. §385.2010.
Dated at Rensselaer, NY this 26th day of January, 2015.

/s/ Joy A. Zimberlin

Joy A. Zimberlin

New York Independent System Operator, Inc.

10 Krey Blvd.

Rensselaer, NY 12144 (518) 356-6207