file:///C|/Documents%20and%20Settings/aassem01/Desktop/For%20Rendering/EPA-HQ-OAR-2008-0708-DRAFT-0346.txt

-----Forwarded by Melanie King/RTP/USEPA/US on 02/15/2010 09:47PM ----- To: Melanie King/RTP/USEPA/US@EPA, Don DiCristofaro <DDiCristofaro@enernoc.com>, Rick Counihan <RCounihan@enernoc.com> From: Ken Schisler <kschisler@enernoc.com> Date: 01/08/2010 11:34AM Subject: NERC standards and the definition for emergency demand response

The relevant standards for how NERC mandates electric system operators would be the Emergency Preparedness and Operations title (Standard EOP-001-000 et seq.) of the NERC Reliability Standards of the Bulk Electric System of North America. The EOP title also refers to a Reliability Coordinator in its procedures. In most cases, I suspect that the Balancing Authority, Transmission Operator, and Reliability Coordinator would be the same entity, but perhaps not. I would suggest that you add this term to you regulation to ensure that it is all-inclusive. The NERC definitions for these terms appears at the bottom of this email.

The Ohio language we discussed would work for your purposes if you used the following language:

Conditions where a Balancing Authority, Transmission Operator or Reliability Coordinator regional transmission organization notifies electric distributors than an emergency exists or may occur and it is necessary to implement emergency procedures for voluntary load curtailments by customers within Ohio, in response to unusually low frequency, equipment overload, capacity or energy deficiency, unacceptable voltage levels, or other emergency conditions leading to a potential electrical blackout.

If I can be of further assistance, please feel free to contact me.

Balancing Authority - The responsible entity that integrates resource plans ahead of time, maintains load-interchange-generation balance within a Balancing Authority Area, and supports Interconnection frequency in real time.

Reliability Coordinator - The entity that is the highest level of authority who is responsible for the reliable operation of the Bulk Electric System, has the Wide Area view of the Bulk Electric System, and has the operating tools, processes and procedures, including the authority to prevent or mitigate emergency operating situations in both next-day analysis and real-time operations. The Reliability Coordinator has the purview that is broad enough to enable the calculation of Interconnection Reliability Operating Limits, which may be based on the operating parameters of transmission systems beyond any Transmission Operator’s vision.

file:///C|/Documents%20and%20Settings/aassem01/Desk...For%20Rendering/EPA-HQ-OAR-2008-0708-DRAFT-0346.txt (1 of 2)2/19/2010 12:5 0:39 PMfile:///C|/Documents%20and%20Settings/aassem01/Desktop/For%20Rendering/EPA-HQ-OAR-2008-0708-DRAFT-0346.txt

Transmission Operator – The entity responsible for the reliability of its “local” transmission system, and that operates or directs the operations of the transmission facilities.

Kenneth D. Schisler - Senior Director, Regulatory Affairs EnerNOC, Inc. | 101 Federal Street, Suite 1100 | Boston, MA 02110 o: 410.745.8104 | m: 410.725.1462 kschisler@enernoc.com | www.enernoc.com EnerNOC - get more from energy This email and any information disclosed in connection herewith, whether written or oral, is the property of EnerNOC, Inc. and is intended only for the person or entity to which it is addressed. This email may contain information that is privileged, confidential or otherwise protected from disclosure. Distributing or copying any information contained in this email to anyone other than the intended recipient is strictly prohibited.

file:///C|/Documents%20and%20Settings/aassem01/Desk...For%20Rendering/EPA-HQ-OAR-2008-0708-DRAFT-0346.txt (2 of 2)2/19/2010 12:5 0:39 PM