### 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

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(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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