rom: Don DiCristofaro <DDiCristofaro@enernoc.com> 

To: Melanie King/RTP/USEPA/US@EPA 

Cc: Rick Counihan <RCounihan@enernoc.com> 

Date: 11/28/2012 04:57 PM 

Subject: EPA Trigger with Suggested Emergency DR Change

 

Melanie, 

We have reviewed EPA’s proposed changes to the emergency DR trigger (attached) and offer 

the following. From the NERC reliability standards: 

http://www.nerc.com/docs/standards/rs/Reliability_Standards_Complete_Set.pdf 

In particular, page 301 (page 2 of EOP-002-3.1), R7., it is clear that the Reliability Coordinator, 

not the Balancing Authority, has the control in calling Energy Emergency Alerts: 

R7. Once the Balancing Authority has exhausted the steps listed in Requirement 6, or if these 

steps cannot be completed in sufficient time to resolve the emergency condition, the Balancing 

Authority shall: 

R7.1. Manually shed firm load without delay to return its ACE to zero; and 

R7.2. Request the Reliability Coordinator to declare an Energy Emergency Alert in accordance 

with Attachment 1-EOP-002 “Energy Emergency Alerts.” 

Also check page 305, A. 1: 

Initiation by Reliability Coordinator. An Energy Emergency Alert may be initiated only by a 

Reliability Coordinator at 1) the Reliability Coordinator’s own request, or 2) upon the request of 

a Balancing Authority, or 3) upon the request of a Load Serving Entity. 

Therefore, we agree that the revised language is more accurate. We spoke to a NERC 

expert and he confirmed that all ISOs (e.g., ISO-New England, NYISO, PJM, ERCOT, etc.) 

are Reliability Coordinators. We also learned that Reliability Coordinators can delegate to 

balancing authorities the ability to call Energy Emergency Alerts under certain 

circumstances. Therefore, to make this clear, we recommend adding the yellow highlighted 

language in the attached (“as determined by the Reliability Coordinator”). Finally, we 

believe it is important to either define Reliability Coordinator or reference it. The reference 

I found is the 2008 NERC Glossary of Terms Used in Reliability Standards for Reliability 

Coordinator. Here is the definition from the Glossary (page 16) with a link to the document: 

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. 

http://www.nerc.com/files/Glossary_12Feb08.pdf 

Let me know if you need any additional information. 
Don 

Don DiCristofaro, CCM – Air Quality Meteorologist Consultant 

EnerNOC, Inc. | 101 Federal Street, Suite 1100 | Boston, MA 02110 

m: 617.834.8408 | f: 857.221.9464 

DDiCristofaro@EnerNOC.com| www.EnerNOC.com 

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attached file: NESHAP 40 CFR 63 - EPA Trigger with suggested change 112712.docx)
NESHAP  40 CFR 63.6640(f)(2)

(ii)  Emergency stationary RICE may be operated for emergency demand response

for periods in which the Reliability Coordinator or other authorized entity as

determined by the Reliability Coordinator under NERC Reliability Standard EOP‐

002‐3 has declared an Energy Emergency Alert Level 2 (EEA Level 2).

Deleted: regional transmission authority or

equivalent balancing authority and transmission

operator has declared an Energy Emergency Alert

Level 2 (EEA Level 2) as defined in the North

American Electric Reliability Corporation Reliability

Standard EOP‐002‐3, Capacity and Energy

Emergencies.

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