June 25,2004 

Robert Donaldson, Associate Director 

Bureau of Waste Prevention, Division of Business Compliance 

Department of Environmental Protection 

One Winter Street 

Boston, MA 02108 

Dear Mr. Donaldson: 

I am writing on behalf of ISO New England Inc., the Independent System Operator for 

the bulk power grid in New England, to offer comments on the proposed amendments to 310 

CMR 7.00 relating to engines and combustion turbines. 

ISO New England offered comments on the draft regulations in November 2003. At that 

time, ISO New England recommended modifying the proposed definition of an "Emergency" to 

more fully encompass the spectrum of operating procedures undertaken by ISO New England 

under certain system conditions. ISO New England would like to take this opportunity to 

express its continued support for an expanded definition of "Emergency" in the regulations. 

ISO New England's Operating Procedures are part of its stakeholder-approved process 

for responding to critical system conditions. These procedures may be undertaken for the entire 

New England bulk power grid or they may be targeted to specific region of the grid depending 

on system conditions. Because of this range of scope, the current language in the regulations 

encompassing a "failure of the grid" as an emergency makes it unclear what actions would 

constitute such a condition. It would be helpful if this term were clarified to encompass both 

system-wide and localized conditions on the grid. We have suggested language below to 

accomplish this. 

Additionally, the current language in 103 CMR 7.26 § 41 does not specifically cover all 

of the pertinent actions that ISO New England relies on under certain emergency conditions that 

call on the use of on-site, emergency generators. ISO New England's Operating Procedures 

include Actions during a Capacity Deficiency (OP4) and Actions during an Emergency (OP7). 

Operations during a Capacity Deficiency contain 16 specific actions to be taken by the grid 

operator. 
One of the actions during OP4 is action 12, which implements a 5% voltage reduction. 

The current language in the definition of "Emergency" would cover this action. However, 

conditions can sometimes occur, as they did during the August 2003 blackout, in a rapid and 

cascading fashion that may require actions beyond, or instead of, voltage reductions and should 

also be considered emergencies for purposes of the Department's regulations. ISO New England 

suggests also incorporating language from these actions (OP 4 actions 9,14, 15, 16 and OP7) 

into the regulations. Our suggested language below would make this possible. 

During these other electricity system conditions, participants in several of ISO New 

England's Demand Response Programs may need to respond to system operator instructions to 

emergency generators and thus need to comply with emissions regulations. The nature of bulk 

power system operations, and the need for emergency on-site generators to occasionally be 

called on, to establish the electric system reliability in New England, is best served by clear, 

unambiguous language governing engines and combustion turbines. Language that is consistent 

with ISO New England's applicable Operating Procedures, which may impact on-site emergency 

generators, may provide further clarity. 

ISO New England respectfully requests that the Department consider the following 

modification to the definition of "Emergency" in the Department's proposed regulation: 

(CAPITAL letters indicate suggested language.) 

"Emergency means an electric power outage due to failure of the grid, IN WHOLE OR 

IN PART, on-site disaster, local equipment failure, flood, fire, or natural disaster. Emergency 

shall also mean when the imminent threat of a power outage is likely due to failure of the 

electrical supply or when capacity deficiencies result in a deviation of voltage from the electrical 

supplier to the premises of three percent (3%) above or five percent (5%) below standard 

voltage, OR PERIODS DURING WHICH ISO NEW ENGLAND, OR ANY SUCCESSOR 

REGIONAL TRANSMISSION ORGANIZATION, DIRECTS THE IMPLEMENTATION OF 

VOLTAGE REDUCTIONS, VOLUNTARY LOAD CURTAILMENTS BY CUSTOMERS, OR 

AUTOMATIC OR MANUAL LOAD SHEDDING WITHIN MASSACHUSETTS IN 

RESPONSE TO UNUSUALLY LOW FREQUENCY, EQUIPMENT OVERLOAD, 

CAPACITY OR ENERGY DEFICIENCY, UNACCEPTABLE VOLTAGE LEVELS, OR 

OTHER SUCH EMERGENCY CONDITIONS." 

If additional information about Demand Response programs, emergency generation, or 

Operating Procedures would assist in the Department's determination, please do not hesitate to 

contact me to further discuss this matter. 

Sincerely, 

Henry Yoshimura 

Manager, Demand Response