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.

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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 

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