Status:
The interpretation was adopted by the NERC Board of Trustees on November 7, 2012, and is pending regulatory approval. Summary:
The Northwest Power Pool Reserve Sharing Group respectfully requests clarification as to whether:
- although a Disturbance [1] that exceeds the most severe single Contingency must be reported by the Balancing Authority or Reserve Sharing Group (as applicable), the Disturbance is excluded from compliance evaluation for the applicable Balancing Authority or Reserve Sharing Group;
- with respect to either simultaneous Contingencies or non-simultaneous multiple Contingencies affecting a Reserve Sharing Group, the exclusion from compliance evaluation for Disturbances exceeding the most severe single Contingency applies both when (a) all Contingencies occur within a single Balancing Authority member of the Reserve Sharing Group and (b) different Balancing Authorities within the Reserve Sharing Group experience separate Contingencies that occur simultaneously, or non-simultaneously but before the end of the Disturbance Recovery Period following the first Reportable Disturbance; and
- the meaning of the phrase "excluded from compliance evaluation" as used in Section 1.4 ("Additional Compliance Information") of Part D of BAL-002-0 and for purposes of the preceding statements is that, with respect to Disturbances that exceed the most severe single Contingency for a Balancing Authority or Reserve Sharing Group (as applicable), a violation of BAL-002-0 does not occur even if ACE is not recovered within the Disturbance Recovery Period (15 minutes unless adjusted pursuant to BAL-002-0, R4.2).
[1] Irrespective of cause, including a single event, simultaneous Contingencies, or non-simultaneous multiple Contingencies.
Purpose/Industry Need:
In accordance with the Reliability Standards Development Procedure, the interpretation must be posted for a 30-day pre-ballot review, and then balloted. There is no public comment period for an interpretation. Balloting will be conducted following the same method used for balloting standards. If the interpretation is approved by its ballot pool, then the interpretation will be appended to the standard and will become effective when adopted by the NERC Board of Trustees and approved by the applicable regulatory authorities. The interpretation will remain appended to the standard until the standard is revised through the normal standards development process. When the standard is revised, the clarifications provided by the interpretation will be incorporated into the revised standard.
Appeal:
On January 17, 2012 NERC received a Level 1 Appeal for inaction from the ISO/RTO Council's Standards Review Committee on Project 2009-19 - Northwest Power Pool's Reserve Sharing Group's request for an interpretation of BAL-002-0, Requirement R4. The appellants asked for clarity on the following issues:
Did NERC, or the Standards Committee, convene the IDT, after comments were received. What industry and/or NERC personnel made up the IDT?
What accounted for the Standards Committee placing the RFI on hold (in October 2010) and the delay in processing the RFI prior to the Standards Committee 2011 action to place on hold pending Interpretations?'
Do the Standards Committee Agendas correctly indicate that NERC considered the RFI an invalid request, and if so, why?
IRC Appeal
Data Information Request and Exhibits
NERC Response
All comments should be forwarded to sarcomm@nerc.net.
