UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
Mandatory Reliability Standards for the)
Bulk Power System)Docket Nos. RM06-16-010
)RM06-16-011
COMMENTS OF
THE NEW YORK INDEPENDENT SYSTEM OPERATOR, INC.
The New York Independent System Operator, Inc. (“NYISO”) respectfully submits these comments to the Commission’s Notice Allowing Post Technical Conference Comments, issued on September 24, 2010 following the Technical Conference held on September 23, 2010
concerning Frequency Response in the Wholesale Electric Grid.
The NYISO appreciates the opportunity to submit comments on this issue and agrees
with the Commission and industry participants at the technical conference that proper
interconnection frequency response is critical for the recovery of interconnected frequency to
acceptable levels. The NYISO supports the NERC Resources Subcommittee’s (“RS”) current
efforts on this matter. The RS is the correct forum to analyze this issue and continue its ongoing
evaluation. Given the importance of this issue to bulk power system reliability, FERC, as well as
industry, needs the intelligence from this evaluation, already underway, to provide valuable input
into the standards development process. The results of this evaluation will inform the NERC
standards drafting team as to appropriate frequency response levels to maintain systematic
reliability. While the NYISO appreciates the Commission’s concern that over three years have
passed since the issuance of Order 6931, FERC should allow the NERC RS to complete its
evaluation before NERC drafts a revised standard. Participants in the Commission’s technical
1 Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, FERC Stats. & Regs., ¶ 31,242 (2007)(“Order 693”).
conference correctly identified the NERC RS as the best resource for developing a standard on frequency response. NERC needs the opportunity to thoroughly examine and set appropriate target frequency response levels, and the schedule established by FERC should allow this to be completed. NERC will then be able to develop the most accurate and workable standards
focused on system reliability.
As to a final standard, NYISO offers comments on what it believes to be the proper
structure of the new standard and how the compliance obligations should be defined.
Opportunities also exist to leverage new technologies to solve the challenges associated with
frequency response, and any new or revised standard should be designed to accommodate such
technology.
In addition to these comments, the NYISO is a signatory to, and supports, the Comments of the ISO/RTO Council, which were also submitted today.
I.BACKGROUND
In Order 693, issued in March 2007, FERC approved 83 of the 107 of the Reliability
Standards proposed by NERC, including the Resource and Demand Balancing Reliability
Standards2. Included in the approved standards was BAL-003-0, which is designed to ensure
that a Balancing Authority’s (“BA”) frequency bias setting is accurately calculated to match its
actual frequency response. However, with regard to BAL-003, FERC directed NERC “to
determine the optimal periodicity of frequency response surveys necessary,” and further to
define the “minimum frequency response needed for Reliable Operation” and identify “methods
of obtaining the frequency response.”3 On March 18, 2010, the Commission issued an order
setting a deadline for compliance directing NERC to submit a modification to Reliability
2 Id.
3 Id at ¶¶ 369-372.
Standard BAL-003 to comply with the Order 693 directives within six months.4 Following
extensive industry comment, an order granting rehearing for further consideration and scheduling
a technical conference was issued May 13, 2010.5 In that order, FERC recognized the complex
technical and procedural issues raised and deferred the six-month deadline, instead ordering
NERC to propose a schedule 30 days following the technical conference that included a firm
compliance deadline for submission of a modified BAL-003 standard that complies with the
Order 693 directives.6
As noted by the Commission7, the current approved BAL-003 standard provides an
enforceable and mandatory reliability standard setting forth a consistent method for calculating
the frequency bias component of Area Control Error (“ACE”). BAL-003 requires each BA to
review its frequency bias8 settings by January 1 of each year and recalculate its setting to reflect
any changes in the frequency response9 of the BA. BAL-003 specifically requires each BA to
establish and maintain a frequency bias setting that is equal to or greater than that BA’s actual
frequency response, but no less than 1% of its estimated peak load per .1 Hertz change. BAL-
003 requires each BA to operate its Automatic Generation Control (“AGC”) on tie line frequency
bias, unless such operation is adverse to system or interconnection reliability. The NYISO’s
current approach to frequency response parallels these requirements as outlined in the BAL-003
NERC standard.
4 Order Setting Deadline for Compliance, Docket No. RM06-16-010, 130 F.E.R.C ¶ 61,218 (March 18, 2010) (“March 18 Order”).
5 Order Granting Rehearing for Further Consideration and Scheduling a Technical Conference, Docket No. RM06-
16-011, (May 13, 2010).
6 Id. at ¶ 15.
7 See March 18 Order
8 See, Frequency Response and Bias, NERC standard BAL 003-0.1b (May 13, 2009), available at
http://www.nerc.com/files/BAL-003-0_1b.pdf.
9 Id.
II.COMMENTS
A.The NERC Resources Subcommittee is the Correct Industry Group to Address
Frequency Response.
The NYISO supports the NERC RS group as the appropriate forum to complete
Frequency Response Initiative (“FRI”) analysis and issue a white paper making
recommendations on how to revise BAL-003. This group has been closely associated with the
issue from the beginning and has initiated the Standard Authorization Request (“SAR”) to
evaluate the adequacy of frequency response and identify any underlying issues. As correctly
stated by NERC in its comments to the March 18 order, this is a complex issue that cannot be
addressed in a hurried manner. There needs to be ample time for NERC, with input from
industry to evaluate the historical frequency response targets for reliability purposes. The NERC
RS process should be completed prior to NERC drafting a standard. Questions inherent in that
analysis include: (i) an examination of how fast the interconnection needs to return to 60 hertz to
minimize the risk of activation of under-frequency load shedding or accidental generation
tripping, (ii) what combination and interaction of frequency response and AGC response are
needed, and (iii) what are appropriate levels of both frequency response and AGC service to
safely enable restoration of 60 hertz. These points are more thoroughly discussed in the
Comments of the ISO/RTO Council, submitted today. Answers to these technical questions from
the NERC RS group are vital prior to determining what should be included in the final standard.
B.Comments Regarding Drafting the Final Standard.
With regard to the structure of the final standard, Balancing Authorities (“BAs”),
Generator Owners/Operators, and other potential frequency response service providers (such as
Limited Energy Storage Resources [“LESRs”] and new smart grid technologies) should all have
a role to play in the revised standard. While generators provide the vast majority of existing
governor response and AGC services, reliability concerns require coordination with BAs and the
total system interconnection. The new or revised standard will require coordination between the
BA, Generator Owners/Operators, and new technologies capable of providing this service.
Any final standard should consider to which entities the frequency response standard will be directed and further which components of the standard should apply to which entities. The most efficient solution may not be a standard mandating frequency response from all generating units. Specifically, consideration should be given as to which entities the governor response component and AGC component of the frequency standard should apply. While both could be made applicable to generators exclusively, the NYISO does not believe this is the best solution. For example, governor response could be a service provided by LESRs, such as fly-wheels or batteries, or even new smart grid technologies in the form of local monitoring and frequency response to bus-bar frequency measurements. The AGC component can currently be offered by LESRs under existing NYISO market designs and tariffs. A better approach could be to develop a frequency response standard administered by the BA on an interconnection-wide basis, as
opposed to a standard focused on generators and other service providers. This could not be
accomplished in a short amount of time as BAs do not currently have jurisdiction over generator
governor controls. A change of that magnitude would require substantial tariff changes, must be
coordinated across BAs, and would need a prudent schedule for development to avoid unexpected consequences.
III.COMMUNICATIONS
Correspondence and communications with respect to this filing should be sent to:
Robert E. Fernandez, General Counsel
Elaine D. Robinson, Director of Regulatory Affairs *Carl F. Patka, Assistant General Counsel
*Kristin A. Bluvas, Attorney
New York Independent System Operator, Inc.
10 Krey Boulevard
Rensselaer, NY 12144
Tel: (518) 356-8875
Fax: (518) 356-7678
rfernandez@nyiso.com
erobinson@nyiso.com
cpatka@nyiso.com
kbluvas@nyiso.com
*Persons designated for receipt of service.
IV.CONCLUSION
For the reasons set forth above, the NYISO respectfully requests that any final rule issued in these proceedings adopt the recommendations made in these comments as well as those
submitted by the ISO/RTO Council.
Respectfully Submitted,
/s/ Kristin A. Bluvas
Kristin A. Bluvas
Counsel for the
New York Independent System Operator, Inc.
10 Krey Blvd.
Rensselaer, NY 12144
Tel: (518) 356-8540
Fax: (518) 356-7678
October 14, 2010
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 14th day of October, 2010
/s/ Joy A. Zimberlin
Joy A. Zimberlin
New York Independent System Operator, Inc
10 Krey Blvd
Rensselaer, NY 12114 (518) 356-6207
