# Attachment 9

ISO New England, Inc., Transmission, Markets and Services TariffFERC Electric Tariff No. 3, Appendix E 

# Attachment 9



# iso New England, Inc., Transmission, Markets

and Services TariffFERC Electric Tariff 

# No. 3, 

# Appendix EISO New England Inc. FERC Electric Tariff No.3 Section lll- Market Rule I- Standard Market Design Appendix E-Load Response Program Original Sheet No. 7900



# SECTION III

MARKET RULE 1

APPENDIXE LOAD RESPONSE PROGRAM

Issued by: Kathleen A. Carrigan, Senior Vice President and General Counsel Issued on: December 22. 2004 Effective: With notice, on or after February 1, 2005 iso New England Inc. FERC Electrc Tarff NO.3 

### Section ll- Market Rule i - Stadad Maet Design Appendx E-Load Response Progr Orginal Sheet No. 7900

SECTION 

### ILL



# MARKT RULE 1

APPENDIXE LOAD RESPONSE PROGRAM

Issued by: Kaeen A. Cagan Senior Vice Prident and General Counsel 

### Issued on: Deember 22. 200 Effective: With notice, on or afr Feru 1, 2005ISO New England Inc.

FERC Electric Tariff No. 3 Section III - Market Rule 1 - Standard Market Design Appendix E-l.oad Response Program Table of Contents 3rd Rev Sheet No. 790 I Superseding 2nd Rev 7901



### APPENDIXE LOAD RESPONSE PROGRAM

Table of Contents

TIlE.I. Introduction 7902 III.E.2. Day-Ahead Load Response Program 7906 m.E.3. Real-Time Demand Response Programs 7908 m.E.4. Real-Time Price Response Program 7911 m.E.5. Real-Time Profiled Response Program 7913 m.E.6. Metering and Settlement 7915 m.E.7. Installation Cost of Internet-based Communication Systems 7916 m.E.8. Demand Response Pilot Program 7919

Issued by: Kathleen A. Carrigan. Senior Vice President and General Counsel Issued on: January 31.2006 Effective: April I. 2006 iso New England Inc. 

### FEC Electrc Tarf No. 3 Section II - Market Rule 1 - Stadad Market Design Appendix E-Load Response Program Table of Contents 3rd Rev Sheet No. 790 i Superseding 2nd Rev 7901



### APPENDIXE LOAD RESPONSE PROGRAM

Table of Contents



### TIE.l. Introduction........................................................................................ 7902 

### III.E.2. Day-Ahead Load Response Progr...... ........................................... 7906 m.E.3. Real. Time Demand Response Progr ........................................... 7908 

### m.E.4. Real-Time Prce Response Progr.................................................. 7911 m.E.5. Real-Time Profied Response Prgram ............................................. 7913 m.E.6. Metenng and Settement.................................................................... 7915 

### m.E.7. Intalation Cost of Internet-based Communication Systems ............ 7916 m.E.8. Demad Response Pilot Progr ...................................................... 7919

Issued by: Katheen A. Cagan, Senior Vice Prsident and General Counsel Issued on: Janua 31,200 Effective: April 1,200ISO New England Inc. FERC Electric Tariff No.3 Section III - Market Rule 1 - Standard Market Design Appendix E-Load Response Program Introduction 2nd Rev Sheet No. 7902 Superseding 1st Rev 7902



### APPENDIXE LOAD RESPONSE PROGRAM m.E.l. Introduction DI.E.l.l Goal. The purpose of the Load Response Program ("LRP") is to facilitate load response during periods of peak electricity demand by providing appropriate incentives. Load Response Program incentives are available to any Market Participant which, consistent with the requirements set forth herein, enrolls itself and/or one or more retail customers ("Demand Resources") to provide a reduction in their electricity consumption in the New England Control Area during peak demand periods. DRP-Only Customers must satisfy any applicable fmancial assurance criteria and pay an annual service fee of $500. End User Participants that participate as Governance-Only Members and wish to be paid as a supplier of Demand Resources must satisfy any applicable financial assurance criteria. The service fee will be applied to the ISO's expenses. ill.E.l.2 EUgibility. The overall Load Response Program comprises the following individual components:

Issued by: Kathleen A. Carrigan, Senior Vice President and General Counsel Issued on: November 7,2006 Effective: December 1, 2006 iso New England Inc. 

### FERC Electrc Tarf NO.3 Section II - Market Rule 1 - Stadard Market Design Appendix E-Load Response Program Introduction 2nd Rev Sheet No. 7902 Superseding 1st Rev 7902



### APPENDIXE LOAD REPONSE PROGRAM 

## m.E.1. Introduction ßI.E.1.1 Goal. The purse of the Load Response Progra ("LRP") is to faclitate load response durng periods of peak electrcity demad by providing appropriate incentives. 

### Load Response Progr incentives ar avaiable to any Market Parcipant which, consistent

with the reuirments set fort herein, enrolls itself and/or one or more retal customers 

### ("Demand Resources") to provide a reduction in their electrcity consumption in the New England Control Area durng peak demand periods. DRP-Only Customers must satisfy any 

## applicable financial assurace criteria and pay an annual service fee of $500. End User Parcipants that parcipate as Governance-Only Members and wish to be paid as a supplier of 

### Demand Resources must satisfy any applicable financial assurance critera. The service fee wi be applied to the ISO's expenses.

il.E.1.2 EUgibilty. The overall Load Response Prgr comprises the followig

individua components:

Issued by: Katheen A. Cargan, Senior Vice Prsident and Genera Counsel 

### Issued on: Novembr 7,2006 Effective: Dember 1, 200ISO New England Inc.

FERC Electric Tariff No.3 Section Ill - Market Rule I - Standard Market Design Appendix E-Load Response Program Introduction 2nd Rev Sheet No. 7903 Superseding 1st Rev 7903



### • Day-Ahead Load Response Program • Real-Time 30 Minute Demand Response Program • Real-Time 2 Hour Demand Response Program • Real-Time Price Response Program • Real-Time Profiled Response Program These programs are further defined in this Appendix E and the ISO New England Manuals. Demand Resources are only eligible to participate in one Real-Time program at a time. A program participant in any of the Real-Time programs also has the option of participating in the Day-Ahead Load Response Program. Generating Resources that are already qualified as generating assets are not eligible to participate in the Load Response Program. Any Demand Resource that is eligible to qualify as an ICAP Resource must be available, at a minimum, for the summer period (May 1 through September 30).

III.E.l.3 Effectiveness. The current Load Response Program will be effective from the Operations Date through May 31,2010; except as provided in Section ill.E.2.l. Consideration of the Load Response Program for energy-based resources beyond May 31, 2010 is subject to further study and consultation with NEPOOL stakeholders and state utility regulatory agencies. The resulting determination will be filed by the ISO in an amended Market Rule filing in adequate time to allow for such program to continue uninterrupted beyond May 31, 2010.

Issued by: Kathleen A Carrigan, Senior Vice President and General Counsel Issued on: February 15, 2007 Effective: June 15, 2007 iso New England Inc. 

### FEC Electrc Tarff No.3 Section II - Market Rule i - Stadard Market Design Appendix E-Load Response Program Introduction 2nd Rev Sheet No. 7903 Supersding 1st Rev 7903



### · Day-Ahead Load Response Progr · Rea-Time 30 Minute Demand Response Prgr
· Real-Time 2 Hour Demand Response Program 

### · Rea-Time Prce Response Prgr · Real-Time Profied Response Progr
These programs are fuer defined in this Appendix E and the ISO New England 

### Manuals. 

### Demand Resources are only eligible to paricipate in one Real-Time program at a time. 

### A program parcipant in any of the Real-Time programs also has the option of parcipating in the Day-Ahead Load Response Program. Generatig Resources that are aleady quafied as 

### generating assets ar not eligible to parcipate in the Load Response Progr. Any Demand Resoure that is eligible to qualify as an ICAP Resoure must be avaiable, at a minimum, for the summer period (May 1 thugh September 30). 

## III.E.l.3 Effecvenes. The curnt Load Respons Prgram wil be effective from the Operations Date thugh May 31,2010; except as provided in Section il.E.2.1. Consideraon of the Load Response Progr for energy-bas resources beyond May 31, 2010 is subject to 

### fuer study and consultation with NEPOOL staeholders and state utility regulatory agencies. The resulting determination wil be fied by the iso in an amended Market Rule filing' in 

### adequate time to allow for such progr to continue uninterrpted beyond May 31, 2010.

Isue by: Katheen A Cagan, Senior Vice Prsident and General Counsel Issue on: Febru 15, 2007 Effective: June 15, 2007ISO New England Inc. FERC Electric Tariff No.3 Section III - Market Rule 1 - Standard Market Design Appendix E-Load Response Program Introduction Ist Rev Sheet No. 7904 Superseding Original 7904



### III.E.l.4 Allocation of 

### Costs. The costs of Real-Time Load Response Programs will be allocated to the applicable Real-Time Load Obligation on a system wide basis, except for the costs associated with the Internet-based Communication System ("mCS") as provided in Section m.E.7. Until the Day-Ahead program is implemented, Real-Time program costs will be allocated to Real-Time Load Obligation on a system wide basis (calculated by summing the Real-Time Load Obligation in each Load Zone). Commencing on the date that the Day-Ahead program is implemented, the allocation of the Load Response Program costs (except for mcs costs provided in Section m.E.7.) will change from Load Obligation to Network Load on a system wide basis. To the extent that a program participant's offer clears (is accepted), any charges or credits associated with such deviations will be allocated to the program participant
I 

### The balancing credit or charge will be allocated to Network Load on a system wide basis. As stated in Section m.E.2.1, the effective date for the Day-Ahead Load Response Program will be the date specified by the ISO and posted on its website. Such date will be at least two weeks after the ISO has given the Commission written notice and has posted on its website that the ISO New England System Rules and computer programs necessary to implement the Day-Ahead Load Response Program are fully in place and functional.

Issued by: Kathleen A. Carrigan. Senior Vice President and General Counsel Issued on: February 18, 2005 Filed to comply with order of the Federal Energy Regulatory Commission. Docket No. ER04-1255-OOO. issued December 21,2004, 109 FERC 

### t 61,314 (2004). Effective: June 1, 2005 iso New England Inc. FERC Electrc Tanff No.3 Secion II - Market Rule 1 - Stadad Market Design Appendix E-Load Response Program Introduction 1st Rev Sheet No. 7904 Supersing Original 7904



## III.E.l.4 Allocation of Costs. The costs of Real. Time Load Response Prgrs wil be allocated to the applicable Real. Time Load Obligation on a system wide basis, except for the costs associated with the Internet-based Communication System ("mCS") as provided in Section 

## m.E.? Until the Day-Ahead progra is implemented, Rea-Time progr costs wil be allocated to Real-Time Load Obligation on a system wide basis (calculated by summng the Real-Time Load Obligation in each Load Zone). Commencing on the date that the Day-Ahead

progr is implemented, the allocation of the Load Response Prgram costs (except for mcs 

### costs provided in Section m.E.7.) wil change from Load Obligation to Network Load on a 

### system wide basis. To the extent that a progrm paricipant's offer clears (is accepted), any charges or credits associated with such deviations wil be allocated to the program parcipant

i 

### The balancing credit or charge wil be alocated to Network Load on a system wide basis. As 

### stated in Section il.E.2.1, the effective dae for the Day-Ahea Load Response Progr wil be

the date speifed by the iso and posted on its website. Such date wil be at leat two weeks 

### afer the isO has given the Comnssion wrtten notice and has posted on its website that the iso 

### New England System Rules and computer progr necessary to implement the Day-Ahead Load Response Prgram are fully in place and functional.

Issued by: Kaeen A. Cagan Senior Vice Pridet and Geneal Counsel Isued on: Febru 18, 2005 

### Filed to comply with orr of th Fedra Energy Regulatory Commssion, Doket No. ER041255-O, isued Deember 21,200, 109 FERC t 61,314 (200). Effective: June 1, 2005ISO New England Inc.

FERC Electric Tariff No.3 Section ill - Market Rule 1 - Standard Market Design Appendix E-Load Response Program Introduction 1st Rev Sheet No. 7905 Superseding Original 7905



### m.E.I.5 General Requirements. A Demand Resource cannot span multiple Load Zones. A Price Response customer cannot span multiple, Load Zones. All programs, require interval metering or an approved Measurement and Verification Plan ("M&V Plan"). With the exception of the Profiled Response Program and "Super" Low-Tech option of the Real-Time Price Response Program, meters are read at least daily and some will require an 

## mes.

Issued by: Kathleen A Carrigan, Senior Vice I'resident and General Counsel Issued on: February 18,2005 Filed to comply with order of the Federal Energy Regulatory Commission, Docket No. ER04-1255-000, issued December 21, 2004, 109 FERC 

### i 61,314 (2004). Effective: June 1,2005 iso New England Inc. FEC Elecmc Tarff No.3 

### Section il - Market Rule i - Stadad Maret Design Appendi E-Load Response Progrm 

### Intruction 1st Rev Sheet No. 7905 Supersding Onginal 7905



## m.E.I.5 General Requirements. A Demand Resource cannot span multiple Load Zones. A Prce Response customer cannot span multiple, Load Zones. All programs, require 

### interval metenng or an approved Measurment and Venfication Plan ("M&V Plan"). With the exception of the Profied Response Prgram and "Supet' Low-Tech option of the Real-Time

Prce Response Program, meters are read at leat daily and 

### some will require an mes.

Issued by: Kaleen A Cargan, Senior Vice I'ident and General Counsel 

### Issue on: Febru 18,2005 Filed to comply with order of the Federal Energy Reguatory Commission, Doket No. ER04- i 255-00, issued Deember 2 i, 200, 109 FEC i 61,314 (20). Effective: June 1,2005ISO New England Inc.

PERC Electric Tariff No.3 Section ill- Market Rule 1 - Standard Market Design Appendix E-Load Response Program Day-Ahead Load Response Program 2nd Rev Sheet No. 7906 Superseding lst Rev 7906



### ID.E.2. Day-Ahead Load Response Program The Day-Ahead Load Response Program provides a Day-Ahead aspect to the Real-Time programs. The Day-Ahead Load Response Program allows Real-Time program participants to make energy reduction offers concurrent with the Day-Ahead Energy Market. The Day-Ahead Load Response Program is not intended to pay for load reductions that would have been scheduled in any event, such as facility shut-downs. m.E.2.1 Effective Date. The Day-Ahead Load Response Program will be effective as soon as practicable. The effective date for this program will be the date specified by the ISO and posted on its website. Such date will be at least two weeks after the ISO has given the Commission written notice that the ISO New England System Rules and computer programs necessary to implement the Day-Ahead Load Response Program are fully in place and functional and the ISO will post the date on its website at the time that the ISO makes such notice to the
Commission.

m.E.2.2 Offer Parameters.

(a) A program participant may submit an offer concurrent with the DayAhead Energy Market on behalf of a Demand Resource in increments of 100 kW or more. Resources may be aggregated to reach the 100 kWminimum.

Issued by: Raymond W. Hepper, Vice President and General Counsel Issued on: February 5, 2008 Effective: February 7, 2008 iso New Englad Inc. 

### PEC Electrc Tan NO.3 Section il - Maret Rule i - Stadad Market Design Appendix E-Load Response Program Day-Ahead Load Response Program 2nd Rev Sheet No. 7906 Superseding 1st Rev 7906



### ID.E.2. Day-Ahead Load Response Prgra 

### The Day-Ahead Load Response Prgr provides a Day-Ahead aspect to the Real-Time
programs. The Day-Ahead Load Response Progr allows Real-Time progr parcipants to 

### mae energy reduction offers concurent with the Day-Ahead Energy Market. The Day-Ahead 

## Load Response Prgram is not intended to pay for load reductions that would have ben

scheduled in any 

### event, such as facilty shut-downs. 

## il.E.2.1 Effective Date. The Day-Ahead Load Response Prgr wil be effective as soon as practicable. The effective date for this progr wil be the date specifed by the iso and 

## posted on its website. Such date wil be at leat two weeks after the iso has given the

Comnssion wntten notice that the iso New England System Rules and computer programs 

### necessar to implement the Day-Ahead Load Respons Progr are fuly in plac and functional

and the iso wil post the date on its website at the time that the isO makes such notice to the 

## Comnssion. 

## IHE.2.2 Offer Paraeters.

(a) A progr paricipant may submit an offer concurnt with the Day

### Ahead Energy Market on beha of a Demad Resour in increments 

### of i 00 kW or more. Resources may be aggregated to reach the i 00 kWminimum.

Isued by: Raymnd W. Hepper, Vice Prident and General Counsel Isued on: Februar 5, 2008 Effective: Febru 7, 2008ISO New England Inc.

FERC Electric Tariff No. 3 Section ill - Market Rule 1 - Standard Market Design Appendix E-Load Response Program Day-Ahead Load Response Program 3rd Rev Sheet No. 7907 Superseding 2nd Rev 7907



### (b) The minimum offer level (expressed in $1MWh) is calculated on a monthly basis and is the Forward Reserve Fuel Index (expressed in $IMMBtu) multiplied by an effective heat rate of 11.37 MMBtulMWh with the product rounded to the nearest dollar, and shall be specified by the ISO prior to the start of each month. (c) The maximum offer level is $I,OOOIMWh. (d) Demand Resources participating in the Day-Ahead Load Response Program are eligible to qualify as an leAP Resource only if the Demand Resource is in either the Real-Time Demand Response Program or the Real-Time Profiled Response Program.
m.E.2.3 Payment. Demand Resource offers that clear concurrent with the Day-Ahead Energy Market will be paid the applicable Day-Ahead Zonal Price. To the extent a program participant's offer clears (is accepted), and the participant's Real-Time load response deviates from its nominated response, any charges or credits associated with such deviations will be allocated to the program participant. The balancing credit or charge will be allocated to Network Load on a system wide basis. Data for calculating actual performance, including the base line and actual reductions shall be provided on a daily basis with other meter reading data.

Issued by: Raymond W. Hepper, Vice President and General Counsel Issued on: April 15, 2008 Effective: July I, 2008 iso New England Inc.
FERC Electric Tarff No. 3 Section il - Market Rule i - Stadad Market Design Appendix E-Load Response Progrm Day-Ahead Load Response Program 3rd Rev Sheet No. 7907 Superseding 2nd Rev 7907



## (b) The minimum offer level (expressed in $1M) is calculated on a

monthly basis and is the Forward Reserve Fuel Index (expressed in 

## $/MBtu) multiplied by an effective heat rate of 11.37 MMBtul with the product rounded to the nearest dollar, and shall be specified
by the iso prior to the sta of each month. 

## (c) The maimum offer level is $ 1 ,OOIM. (d) Demand Resources paricipating in the Day-Ahead Load Response Progr are eligible to qualify as an ieAP Resource only if the Demand Resource is in either the Real-Time Demand Response Progr or the Rea-Time Profiled Response Progr. 

### m.E.2.3 Payment. Demad Resource offers that clear concurnt with the Day-Ahead 

### Energy Market will be pad the applicable Day-Ahead Zonal Prce. To the extent a progr

paricipant's offer clear (is accepte), and the parcipant's Real-Time load response deviates 

### frm its nominated reponse, any charges or credits associated with such deviations will be

allocated to the progr parcipant. The balancing credit or charge will be allocated to Network 

### Load on a system wide basis. Data for calculating actu pedormance, including the base line

and actual reductions shal be provided on a daiy basis with other meter readig data.

Issued by: Raymnd W. Hepper, Vice President and Genera Counsel Issued on: Apnl is, 2008 Effective: July i, 2008ISO New England Inc. FERC Electric Tariff No.3 Section III - Market Rule I - Standard Market Design Appendix E-Load Response Program Real-Time Demand Response Programs Original Sheet No. 7908



### m.E.3. Real-Time Demand Response Programs 

### m.E.3.1 General Terms. The Load Response Program includes two components thatprovide payments for Demand Resources that are willing and capable of responding to RealTime ISO instructions to interrupt load within a specific time period. The minimum, aggregated size to participate in these programs is 100 kW.



### m.E.3.1.1 Technical Requirements. Both the 30-Minute Demand Response and the 2-hour Demand Response Programs require the use of an Internet-based Communication System.



### m.E.3.1.2 Program Activation. The ISO may issue interruption instructions to Demand Resources on a zonal or system wide (implemented in blocks) basis. The ISO may issue interruption instructions in blocks and not just by zone, to allow for a controlled implementation. A block is a system wide slice of the Demand Resources (approximately 200 MW per block).

Issued 

### by: Kathleen A. Carrigan, Senior Vice President and General Counsel Issued on: December 22, 2004 Effective: With notice, on or after February I, 2005 iso New England Inc. FERC Electrc Tarf No.3 Section II - Market Rule i - Stada Maret Design Appendix E-Load Response Program 

### Real-Time Demad Response Prgram Orginal Sheet No. 7908



## m.E.3. Real. Time Demad Response Prgra
m.E.3.1 Genera Term. The Load Response Program includes two components that

### provide payments for Demand Resoures that are willng and capable of responding to RealTime iso instrctions to intemipt load withn a speific time period. The minimum, aggregated 

### size to parcipate in these progrs is 100 kW.

m.E.3.1.1 Technca Requirements. Both the 30-Minute Demand Response 

### and the 2-hour Demand Response Progrs require the use of an Internet-based Communication 

### System.


### m.E.3.1.2 Program Activation. The iso may issue intemiption instrctions to Demad Resoures on a zonal or system wide (implemented in blocks) basis. The iso may 

### issue intemiption instrctions in blocks and not just by zone, to allow for a controlled implementation. A block is a system wide slice of the Demad Resources (approximately 20 

### MW pe block).

Issued by: Kaeen A. Cargan, Senor Vice Prident and Genera Counsel 

### Issue on: Decembe 22 200 Effective: With notice on or afr 

### Febru i. 2005ISO New England Inc.

FERC Electric Tariff No. 3 Section III - Market Rule I - Standard Market Design Appendix E-Load Response Program Real-Time Demand Response Programs Original Sheet No. 7909



### Ill.E.3.2 30 Minute Demand Response Program. The 30 Minute Demand Response Program requires a Demand Resource to respond within 30 minutes of the ISO's instructions to interrupt.

ill.E.3.3 Payment • 30 Minute Demand Response Program. Program participants receive the higher of the applicable Real-Time Zonal Price for interrupted consumption (measured against the base line) or a guaranteed minimum payment of $5001MWh for a minimum of 2 hours. Demand Resources that participate in the 30 Minute Demand Response Program are eligible to qualify as an ICAP Resource, subject to the performance criteria identified in the ISO New England Manuals.

ill.E.3.4 2 Hour Demand Response Program. The 2 Hour Demand Response Program requires a Demand Resource to respond within 2 hours of the ISO's instructions to interrupt.

ill.E.3.S Payment. 2 Hour Demand Response Program. Program participants will receive the higher of the applicable Real-Time Zonal Price for interrupted consumption (measured against the base line) or a guaranteed minimum payment of $3501MWhfor a

Issued by: Kathleen A. Carrigan, Senior Vice President and General Counsel Effective: With notice, on or after Issued on: December 22, 2004 February I, 2005 iso New England Inc. PEC Electrc Tarff No. 3 Section II - Market Rule i - Stadard Market Design Appendix E-Load Response Program Real-Time Demand Response Progr Origina Sheet No. 7909



### Ill.E.3.2 30 Minute Demand Respons Prog. The 30 Minute Demad Response Progrm requires a Demand Resource to respond within 30 minutes of the ISO's

instrctions to intenupt.


## m.E.3.3 Payment . 30 Minute Demand Response Progrm. Progr

parcipants receive the higher of the applicable Real-Time Zonal Price for intenupted 

## consumption (meaured agaist the base lie) or a guartee minimum payment of $5001M 

## for a minimum of 2 hour. Demand Resources that parcipate in the 30 Minute Demand Response Progr are eligible to qualify as an ICAP Resource, subject to the perfonnance crteria identied in the iSO New England Manuals.


## m.E.3.4 2 Hour Demand Response Prgram. The 2 Hour Demand Response 

### Progr reuies a Demad Resoure to respond withn 2 hour of the ISO's intrctions to 

## interrpt.
m.E.3.5 

## Payment. 2 Hour Demad Response Program. Progr parcipants wi receive the higher of the applicable Real-Time Zonal Price for interpted consumption 

### (meaured aganst the base line) or a guarteed minium payment of $3501M for a

Issued by: Katheen A. Cangan Senior Vice President and Genera Counsel Effective: With notice, on or afr 

# Issued on: Decembe 22, 200 Februar i, 2005ISO New England Inc. FERC Electric Tariff No.3 Section III - Market Rule 1 - Standard Market Design Appendix E-Load Response Program Real-Time Demand Response Programs Original Sheet No. 7910



### minimum of 2 hours. Demand Resources that participate in the 2 Hour Demand Response Program are eligible to qualify as an lCAP Resource, subject to the performance criteria identified in the lSO·New England Manuals.

Effective: With notice, on or after February 1, 2005 Issued by: Kathleen A. Carrigan, Senior Vice President and General Counsel Issued on: December 22. 2004 iso New England Inc. 

### PERC Electrc Tarf NO.3 Section II - Market Rule i - Stadard Mart Design Appendix E-Load Response Program 

### Real-Tim Demad Respnse Program Original Sheet No. 7910

iinimum of 2 hour. Demand Resources that parcipate in the 2 Hour Demand Response 

## Program ar eligible to quaify as an lCAP Resoure, subject to the performance crtena identified in the lSO.New England Manuas.

Effective: With notice, on or aftr 

### Febru i, 2005 Isued by: Kathleen A. Cargan, Senior Vice President and Genera Counsl 

### Issued on: Decembe 22, 200ISO New England Inc.

PERC Electric Tariff No.3 Section III - Market Rule I - Standard Market Design Appendix E-Load Response Program Real-Time Price Response Program Original Sheet No. 7911



### m.E.4. Real-Time Price Response Program m.E.4.1 Conditions for Price Response. Voluntary reductions will be allowedwhen the forecasted hourly Zonal Price produced by the Day-Ahead Energy Market or any dayahead, or in day (based upon revised updates) Resource Adequacy analysis is greater than or equal to $100/MW and the ISO has transmitted instructions that the eligibility period is open. Real-Time telemetering is not required, but interval metering or an approved M&V Plan is required.

m.E.4.2 Payment. Program participants in the Real-Time Price Response Program will receive the higher of the applicable Real-Time Zonal Price for interrupted consumption (measured against the base line) or a minimum payment of $1001MWh when the eligibility period is opened. Since this program is voluntary, participants in the Price Response Program are not eligible to qualify as an ICAP Resource.

m.E.4.3 Communication That Eligibility Period Is Opened. Communication of opportunities to participate are made through the 

## mcs, e-mail notification and a posting on the
ISO's web site.

Issued by: Kathleen A Carrigan, Senior Vice President and General Counsel Effective: With notice, on or after Issued on: December 22, 2004 February I, 2005 iso New England Inc. PERC Electrc Tarff NO.3 Section II - Market Rule i - Stadar Market Design Appendix E-Load Response Program Real-Time Price Response Progrm Original Sheet No. 79 i i



## m.E.4. Real. Time Prce Respons Progrm 

## m.E.4.1 Conditions for Price Response. Volunta reductions will be alowedwhen the forecasted hourly Zonal Prce produced by the Day-Ahead Energy Market or any dayahead, or in day (based upon revised updates) Resoure Adequacy analysis is greater than or 

### equal to $ i OOIM and the ISO has trsmitte instrctions that the eligibilty period is open. Real-Time telemetering is not required but interval metering or an approved M&V Plan is 

## reuired.
m.E.4.2 Payment. Program parcipants in the Real-Time Prce Response Progr 

## wil reeive the higher of the applicable Real-Time Zonal Prce for interrpte consumption (measured against the base line) or a minimum payment of $1001M when the eligibilty

period is opened. Since this progr is voluntai, paricipants in the Prce Response Program 

### ar not eligible to qualify as an ICAP Resource.


## m.E.4.3 Communication That Eligibilty Period Is Opened. Communication of

opportnities to parcipate are made thugh the mcs, e-mai notication and a posting on the
ISO's web site.



### Issued by: Katheen A Cagan, Senior Vice Prsident and Genera Counsel Effective: With notice, on or afr 

# Issued on: Deember 22, 200 Febru i, 2005ISO New England Inc.

PERC Electric Tariff No.3 Section III- Market Rule 1 - Standard Market Design Appendix E-Load Response Program Real-Time Price Response Program Original Sheet No. 7912



### ill.E.4.4 Data Reporting.

ill.E.4.4.1 Daily Reporting. The meter readings are submitted daily to the
ISO on the same schedule as other meter data.

III.E.4.4.2 ''Super'' Low Tech. Under this reporting option the interval meter is not read daily nor is the meter reading supplied to the ISO within the following 36 hours. The ISO will resettle the Real-Time Market after approximately 90 days and will pay program participants at that time. Program participants in this option waive their ability to request resettlement with respect to billing for these program participants.

Issued by: Kathleen A. Carrigan, Senior Vice President and General Counsel Issued on: December 22, 2004 . Effective: With notice, on or after February 1, 2005 iso New England Inc. PEC Electrc Tanff NO.3 

### Setion II - Market Rule 1 - Sta Market Design Appendix E-Load Response Program Real-Time Prce Response Progrm Original Sheet No. 7912



## il.E.4.4 Data Reportng.


## il.E.4.4.1 Daily Reportng. The meter readings are submittd daily to the

iso on the same schedule as other meter data.



### III.E.4.4.2 

## ''Super'' Low Tec. Under this reporting option the interval meter is not read daily nor is the meter readng supplied to the iso within the following 36

hour. The iso wil resettle the Real-Time Market afer approximately 90 days and wil pay 

### progr paricipants at that time. Progr paricipants in ths option waive their abilty to 

## reuest resettement with respet to biling for these progr parcipants.

Isued by: Kathleen A. Cagan, Senior Vice Prsident and Genera Counl 

### Issued on: Decembe 22, 200 . Effective: With notice, on or afr 

### Febru 1, 2005ISO New England Inc.

FERC Electric Tariff No.3 Section III - Market Rule 1 - Standard Market Design Appendix E-Load Response Program Real-Time Profiled Response Program Original Sheet No. 7913



### Ill.E.S. Real- Time ProfIled Response Program 

### m.E.S.I Requirements. The Real-Time Profiled Response Program is for participants with loads that are capable of being interrupted on demand. Program participants are willing and capable of responding in Real-Time to ISO instructions to interrupt load within a specified time period. The implementation of the interruption is under the direct control of the program participant. The type of Demand Resources that might participate in this program could include aggregated residential super-thermostat programs, pool pumps and distributed generation. A program participant aggregating Demand Resources for this program is required to provide a statistical response factor for the group. For example, an aggregated 10 MW Demand Resource having a 50% response rate would be credited for 5 MW of response when called.


### m.E.5.2 Payments. The amount of interruption is statistically determined, not measured against a base line. Participating Demand Resources are paid the higher of the applicable Real-Time Zonal Price for interrupted consumption or a minimum payment of $IOOIMWh for the statistically expected response quantity. Demand Resources that participate in the Real-Time Profiled Response Program are eligible to qualify as an leAP Resource, subject to the performance criteria identified in the ISO New England Manuals.

Issued by: Kathleen A. Carrigan, Senior Vice President and General Counsel Issued on: December 22, 2004 Effective: With notice, on or after February 1, 2005 iso New England Inc. FEC Electrc Tarff NO.3 Section II - Market Rule 1 - Stadad Market Design Appendix E-Load Response Program Real-Time ProfJed Response Program Orginal Sheet No. 7913



### Ill.E.S. 

## Real. Time Profied Respons Progr m.E.S.I Requirements. The Real-Time Prfiled Response Progr is for paricipants with loads that are capable of being interrpted on demand. Program paricipants are wiling and 

### capable of responding in Real-Time to ISO instrctions to interrpt load within a specified time 

## penod. The implementation of the interrption is under the diect control of the program paricipant. The typ of Demand Resources that might parcipate in this progr could include aggrgated residential super-thermostat programs, pool pumps and distrbuted generation. A 

### progr parcipant aggregating Demand Resources for this program is required to provide a statistical response factor for the group. For example, an aggrgated 10 MW Demand Resource having a 50% response rate would be credted for 5 MW of response when called.


## m.E.5.2 Payments. The amount of interrption is statistically determned, not measur against a base line. Parcipatig Demad Resources are paid the higher of the applicable Real-Time Zonal Prce for interrpte consumption or a minimum payment of 

### $1001M for the statistically expected response quatity. Demand Resources that paricipate in the Rea-Time Profied Response Program ar eligible to quaify as an ICAP Resoure, subject to the performance cnteria identied in the ISO New England Manuals.

Issued 

### by: Kaeen A. C8Igan Senior Vice Prsident and Gener Counsl Issued on: Deembe 22, 200 Effective: With notice, on or afr 

### Febru 1, 2005ISO New England Inc. PERC Electric Tariff No.3 Section III - Market Rule I - Standard Market Design Appendix E-Load Response Program Real-Time Profiled Response Program Original Sheet No. 7914



### In.E.S.3 Audits. Performance audits may be conducted on an annual basis at a time chosen by the ISO. The ISO may accept the statistical analysis instead of performing the audit. The program participant will be paid for an audit for the minimum guaranteed duration and at the minimum payment for the Load Response Program.

Issued by: Kathleen A. Carrigan, Senior Vice President and General Counsel Effective: With notice, on or after Issued on: December 22, 2004 February 1. 2005 iso New England Inc. PEC Electrc Tarff No.3 Section II - Market Rule i - Stada Market Design Appendix E-Load Response Progr 

### Real-Time Profied Respons Progr Origina Sheet No. 7914



### Iß.E.S.3 Audits. Performance audits may be conducted on an annual basis at a time chosen by the iso. The iso may accept the statistica analysis instead of performing the 

### audit. The program paricipant wil be paid for an audit for the minimum guteed durtion and at the minimum payment for the Load Response Program.

Issue by: Kathleen A. Caigan, Senior Vice Prident and Gener Counsel Effective: With notice, on or afr 

# Issued on: Dembe 22, 200 Feru i, 2005ISO New England Inc.

FERC Electric Tariff No.3 Section ill - Market Rule I - Standard Market Design Appendix E-Load Response Program Metering and Settlement Original Sheet No. 7915



### ill.E.6. Metering and Settlement Additional details concerning metering requirements and settlement procedures along with calculation of baseline quantities to be used to calculate the amount of interruption actually obtained are contained within the ISO New England Manuals.

Issued by: Kathleen A. Carrigan. Senior Vice President and General Counsel Issued on: December 22, 2004 Effective: With notice, on or after February 1, 2005 iso New England Inc. 

### FEC Electrc Tarf No.3 Section II - Market Rule I - Standad Market Design Appendix E-Load Response Program Metenng and Settement Orginal Sheet No. 7915



## m.E.6. Meterig and Settlement Additional details concernng metering requirements and settlement procedures along with 

### calculation of baseline quantities to be used to calculate the amount of interrption actually obtaned are contaned within the iso New England Manuals.

Isue by: Katheen A. Cagan Senior Vice President and Genera Counsel 

### Issued on: Deember 22, 200 Effective: With notice, on or afr 

### Febru I, 2005ISO New England Inc. FERC Electric Tariff No.3 Section III - Market Rule I - Standard Market Design Appendix E-Load Response Program Installation Cost of Internet-based Communication Systems 1st Rev Sheet No. 7916 Superseding Origina17916



### m.E.7. Installation Cost of Internet-based Communication Systems The cost of installation of the Internet-based software of an ISO-approved Internet-based Communications System vendor will be borne by the program participant that contracts for the Real-Time Demand Response Program or the Real-Time Price Response Program except:


### llI.E.7.1 For the first 2000 installations including both Real-Time Demand Response and Real-Time Price Response (reduced by the Type 6 Class I and Class 2 Interruptible Load installations already installed prior to the SMD Effective Date), up to 50% of the installation cost shall be borne by Market Participants. For these Customers, the Enrolling Participant will be paid by Market Participants for 50% of the installed hardware costs up to $1,100 per Customer installation, or $11 per enrolled kW per Customer installation, whichever is lower. For Customer installations without a Customer-supplied LAN, the reimbursement rate will be capped at $1,400 or $14 per enrolled kW per customer installation, whichever is lower. The minimum enrolled kW per Customer installation to be eligible for any reimbursement is 25kW. The share borne by Market Participants shall be allocated based on a percentage equal to each Market Participant'S Real-Time Load Obligation (excluding pumping load) in the appropriate Load Zone for the appropriate month divided by the sum of the Real-Time Load Obligations (excluding pumping load) for the appropriate Load Zone for the appropriate month.
The 50% share not

Issued by: Kathleen A. Carrigan, Senior Vice President and General Counsel Issued on: May 29, 2fXfl Effective: July 31,2007 iso New England Inc. FEC Electrc Tanff No.3 Section II - Market Rule I - Stada Market Design Appendix E-Load Response Program Instalaton Cost of Internet-based Communication Systems 1st Rev Sheet No. 7916
Superseding Original 7916



## m.E.7. Insation Cost of Internet-based Communication Systems
The cost of instalation of the Internet-based softare of an ISO-approved Internet-based 

### Communications System vendor wil be borne by the progr paricipant tht contracts for the Real-Time Demand Response Program or the Real-Time Prce Response Program except: 

### lll.E.7.1 For the first 2000 instalations including both Real-Time Demand Response and Real-Time Prce Response (reduced by the Type 6 Class i and Class 2 

### Interrptible Load instalations aleady installed prior to the SMD Effective Date), up to 50% of the installation cost shall be borne by Market Paricipants. For these Customers, the Enrollng

Parcipant wil be paid by Market Paricipants for 50% of the instaled hardwar costs up to 

### $1,100 per Customer instalation, or $11 per enrlled kW per Customer intalation, whichever is lower. For Customer installations without a Customer-supplied LA, the reimburement rate

wil be cappe at $1,40 or $14 per enrolled kW per customer instaation, whichever is lower. 

### The minimum enrolled kW pe Customer intallation to be eligible for any reimburment is 25kW. The share borne by Market Parcipants shall be alocated bas on a percentage equa to each Market Parcipant's Rea-Time Load Obligation (excluding pumping load) in the 

### appropriate Load Zone for the appropriate month divided by the sum of the Real-Time Load 

### Obligations (excludig pumping load) for the appropriate Load Zone for the appropriate month.
The 50% shar not

Issued by: Kaeen A. Cargan, Senior Vice Prident and Gera Counsel 

### Issued on: May 29, 2fX Effective: July 31,2007ISO New England Inc. FERC Electric Tariff No.3 Section ill - Market Rule I - Standard Market Design Appendix E-Load Response Program Installation Cost of Internet-based Communication Systems 1st Rev Sheet No. 7917 Superseding Original 7917



### borne by Market Participants will be charged to the program participant that registered the RealTime Demand Response or Real-Time Price Response Customer.

Issued by: Kathleen A. Carrigan, Senior Vice President and General Counsel Issued on: May 29, 2007 Effective: July 31, 2007 iso New England Inc. 

### FEC Electrc Tarff No.3 Section il - Maret Rule i - Stadad Market Design Appendix E-Load Response Program Intalation Cost of Internet-bas Communication Systems 1st Rev Sheet No. 7917 Superseding Orginal 79 i 7



### borne by Market Parcipants wil be charged to the progr paricipant that registered the RealTime Demand Response or Real-Time Prce Response Customer.

Issue by: Kaleen A. Cagan, Senior Vice Prsident and General Counsel Isued on: May 29, 200 Effective: July 31, 2007ISO New England Inc. FERC Electric Tariff No.3 Section III - Market Rule 1 - Standard Market Design Appendix E-Load Response Program Installation Cost of Internet-based Communication Systems 2nd Rev Sheet No. 7918 Superseding 1st Rev 7918



### m.E.7.2 For those Real-Time Demand Response installations within the first 

### 1000 installations (reduced by the Type 6 Class 1 Interruptible Load already installed prior to the SMD Effective Date), that have 300kW or more of load available for interruption, Market Participants will bear $100 of the monthly fee for the Internet-based Communication System. These costs will be allocated among Market Participants on a Load Zone basis and shall beallocated among Market Participants in a percentage equal to each Market Participant's RealTime Load Obligation (excluding pumping load) in the appropriate Load Zone for the appropriate month divided by the sum of the Real-Time Load Obligations (excluding pumping load) for the appropriate Load Zone for the appropriate month.

Effective: July 31, 2007 Issued by: Kathleen A. Carrigan, Senior Vice President and General Counsel Issued on: May 29, 2007 iso New Englan Inc. 

### FERC Electrc Tarff No.3 Section II - Maret Rule i - Stadard Market Design Appendix E-Load Response Program Instalation Cost of Internet-bas Communicatin Systems 2nd Rev Sheet No. 79 i 8 Superseding 1st Rev 7918



## m.E.7.2 For those Real-Time Demand Response instalations within the first 1000 instalations (reduced by the Typ 6 Class 1 Interrptible Load already instaled prior to the 

### SMD Effective Date), that have 300kW or more of load available for interrption, Market

Parcipants wil bea $100 of the monthy fee for the Internet-based Communication System. 

## These costs wil be allocated among Market Parcipants on a Lo Zone basis and shall beallocated among Market Parcipants in a percentage equal to each Market Paricipant's RealTime Load Obligation (excluding pumping load) in the appropriate Load Zone for the appropriate month divided by the sum of the Real-Time Load Obligations (excluding pumping 

### load) for the appropriate Load Zone for the appropriate month.

Effective: July 31, 2007 

### Issued by: Katheen A. Cargan, Senior Vice Prsident and Gener Counsel Issued on: May 29, 20ISO New England Inc. FERC Electric Tariff No. 3 Section III - Market Rule I - Standard Market Design Appendix E-Load Response Program Demand Response Reserve Pilot 1st Rev Sheet No. 7919 Superseding Original 7919



# m.E.s Demand Response Reserve Pilot Program ill.E.8.l Demand Response Pilot Program Objectives. The objectives of the Demand Response Reserve ("DRR") Pilot program are: (1) to demonstrate based on actual response data whether Demand Resources and Settlement Only Resources (collectively referred to in this Section m.E.8 as "DR Resources") can reliably provide reserve services. specifically IO-minuteand 30-minute Operating Reserve services; (2) to determine the requirements for the level and type of control room communications. dispatch. metering. and telemetry sufficient for DR Resources providing reserve services; and (3) to identify, evaluate. and deploy lower cost communications and telemetry solutions that meet the requirements to provide reserve services. m.E.8.2 DRR Pilot Program Description. ID.E.8.2.1 DRR Pilot Program Duration. The DRR Pilot program

Issued by: Raymond W. Hepper.

Vice President and General Counsel Issued on: July 28, 2008 Effective: October 1,2008 iso New England Inc.
FERC Electrc Tarff No. 3 Setion II - Market Rule i - Stadad Market Design Appendix E-Load Response Prgr Demand Response Reserve Pilot 1st Rev Sheet No. 7919 Supersding Orginal 79 19



### moE.S 

## Demad Response Resrve Piot Program m.E.8.l Demand Response Piot Prgram Objectives. The objectives of the

Demand Response Reserve ("DRR") Pilot progra are: (1) to demonstrate based on actu 

### response data whether Demad Resources and Settement Only Resources (collectively referred 

### to in this Section m.E.8 as "DR Resoures") can reliably provide reserve services, speifically 

### lD-miute and 3D-minute Operating Reserve servces; (2) to determne the reuirements for the level and tye of control room communications, dispatch, metering, and telemetr suffcient for DR Resources providing reserve services; and (3) to identify, evaluate, and deploy lower cost communications and telemetr solutions that meet the reuiements to provide reserve services. 

## ID.E.8.2 DRR Piot Program Deription.
ID.E.8.2.1 DRR Piot Program Duration. The DRR Pilot progr

Issued by: Raymond W. Hepper,

Vice Prident and General Counsel Issued on: July 28, 2008 Effective: October 1,2008ISO New England Inc. FERC Electric Tariff No.3 Section III - Market Rule 1 - Standard Market Design Appendix E-Load Response Program Demand Response Reserve Pilot lst Rev Sheet No. 7920 Superseding Original 7920



### will continue through May 31, 2010. Applications by Market Participants, with a valid DRR Pilot Training Certificate number, to participate in the Winter 200812009 Forward Reserve Procurement Period are due August 23, 2008, and for future Forward Reserve Procurement Periods will be submitted concurrent with the bidding window for the Forward Reserve
Procurement Period. During the course of the DRR Pilot program, the ISO may modify the program selection and availability criteria to take into account the actual performance of different DR Resource categories. The ISO will report at least annually to the Markets Committee on the status of the DRR Pilot program.

Effective: October 1, 2008 Issued by: Raymond W. Hepper,

Vice President and General Counsel Issued on: July 28, 2008 iso New England Inc. PEC Electrc Tarff No.3 Setion II - Market Rule 1 - Stadad Market Design Appendix E-Load Response Progrm Demad Response Reserve Pilot 1st Rev Sheet No. 7920 Superseding Orginal 7920



### wil continue though May 31, 2010. Applications by Market Paricipants, with a valid DRR 

### Pilot Traning Certficate number, to paricipate in the Winter 20081200 Forward Reserve

Procurment Penod are due August 23, 2008, and for futue Forward Reserve Procurement
Penods wil be submittd concurent with the bidding window for the Forward Reserve 

### Procurement Penod. 

### Dunng the coure of the DRR Pilot program, the iso may modify the program selection 

### and availabilty cntena to tae into account the actual performance of different DR Resoure categones. The iso wil report at least annually to the Markets Committee on the status of the DRR Pilot program.

Effective: October 1, 2008 Issued by: Raymond W. Hepper,

Vice Prident and Genera Counsel Issued on: July 28. 200ISO New England Inc.

FERC Electric Tariff No. 3 Section ill - Market Rule 1 - Standard Market Design Appendix E-Load Response Program Demand Response Reserve Pilot 1st Rev Sheet No. 7921 Superseding Original 7921



### m.E.8.2.2 DRR Pilot Program Size and DR Resource Enrollment. A total of up to 50 MW from the Connecticut Load Zone will be enrolled in the DRR Pilot program from the following categories of DR Resources:

(i) 

### customers with Distributed Generation or Settlement Only Resources; (ii) 

### customers with Distributed Generation and weather-dependentload; (iii) weather-independent load reduction Resources; and (iv) weather-dependent load reduction Resources. DR Resources will be selected in accordance with Section ill.E.8.2.3 so as to represent the population of DR Resources that would likely participate in a competitive reserve services market. Resources that are 5 MW or larger may be eligible to participate in the DRR Pilot program, subject to approval by the ISO. DR Resources may be aggregated provided the aggregated DR Resources must be located at a single Node within the New England Control Area and must comply with the measurement and verification requirements applicable to DR Resources as specified in the ISO New England Manuals. Once DR Resources have been integrated into reserve markets, however, aggregation of DR Resources participating in the reserve markets will be governed by the applicable reserve market requirements. The DRR Pilot program will not affect the quantity or the applicable lO-Minute or 30- Minute Forward Reserve Clearing Prices for Resources acquired through the Forward Reserve Auction. A DR Resource may not simultaneously participate in the DRR Pilot program and the
Forward Reserve Auction. Issued by: Raymond W. Hepper,

Vice President and General Counsel Issued on: July 28, 2008 Effective: October 1, 2008 iso New England Inc.
FEC Electrc Tarff No. 3 Section il - Market Rule 1 - Stadad Market Design Appendi E-Load Respons Progra Demand Response Reerve Pilot 1st Rev Sheet No. 7921 Supeding Oñginal7921



## m.E.8.2.2 DRR Piot Progrm Size and DR Resurce Enrollment. A total of up to 50 MW from the Connecticut Load Zone wil be enrolled in the DRR Pilot progr from the following categories of DR Resources:

(i) customers with Distrbuted Generation or Settement Only Resources;

(ii) customers with Distrbuted Generation and weather-dependent load;
(ii) weather-independent load reuction Resources; and
(iv) weather-dependent load reduction Resources. 

### DR Resources wil be selected in accordance with Section m.E.8.2.3 so as to represent the population of DR Resoures that would likely paricipate in a competitive reserve serces
market. 

## Resources that ar 5 MW or larger may be eligible to parcipate in the DRR Pilot program, subject to approval by the iSO. DR Resoures may be aggrgated provided the 

### aggrgated DR Resources must be located at a single Node within the New England Contrl Area and must comply with th meaurment and verication requirments applicable to DR 

### Resoures as spefied in the iSO New England Manuas. Once DR Resoures have ben 

## integrted into reserve marets, however, aggrgation of DR Resources parcipatig in. the reserve marets wil be governed by the applicable reserve market reuiments. 

### The DRR Pilot progr wil not affect the quantity or the applicable lO-Minute or 30- Minute Forward Reserve Clearng Prices for Resource acqui thugh the Forwar Reserve

Auction. A DR Resource may Dot simultaneously paricipate in the DRR Pilot progr and the 

### Forward Reserve Auction.

Isued by: Raymond W. Hepper,

Vice Prsident and Genera Counsel Issued on: July 28, 2008 Effective: October 1, 2008ISO New England Inc. FERC Electric Tariff No.3 Section III - Market Rule I - Standard Market Design Appendix E-Load Response Program Demand Response Reserve Pilot 1st Rev Sheet No. 7922 Superseding Original 7922



### nI.E.S.2.3 Selection Process. Separate OR Resource selections will be
conducted for the winter and summer seasons consistent with the Forward Reserve Service
Periods. The selection process for the ORR Pilot program will consist of the following steps: (1) the ORR Pilot program will be noticed through an email transmitted to Market Participants with a valid ORR Pilot Training Certificate number when the ORR Pilot program request to participate forms are available and the period for the submission of completed forms has begun; (2) Enrolling Participants will be permitted to offer OR Resources to the ISO for consideration to be permitted to participate in the ORR Pilot program concurrent with the Forward Reserve Auction Offers; and (3) the ISO will select DR Resources so that the amount of load reduction capacity reflects the load reduction goals for each category of DR Resource listed in Section m.E.8.2.2. In the event that participation in the ORR Pilot program exceeds the limits defined for a category of OR Resources, the ISO will conduct a random drawing by OR Resource category to determine the final participants for the period. If a OR Resource category is not fully subscribed for the period,

Issued by: Raymond W. Hepper,

Vice President and General Counsel Issued on: July 28, 2008 Effective: October 1,2008 iso New England Inc. PERC Electrc Tarff No.3 Section II - Maret Rule 1 - Stada Market Design Appendix E-Load Response Program Demand Response Reserve Pilot 1 st Rev Sheet No. 7922 Supersing Original 7922



### nl.E.8.2.3 Selection Proces. Separate OR Resoure selections wil be 

### conducted for the winter and summer seaons consistent with the Forwar Reserve Servce
Periods. 

### The selection process for the ORR Pilot progr wil consist of the following steps: (1) the ORR Pilot progr wil be noticed thugh an emai trmitted to Market Paricipants with 

### a valid ORR Pilot Traning Certificate number when the ORR Pilot progr request to paricipate forms ar available and the period for the submission of completed forms ha begun; 

### (2) Enrollng Paricipants wil be pemutted to offer OR Resoures to the iso for consideration to
be pemutted to parcipate in the ORR Pilot progra concurent with the Forward Reserve 

### Auction Offers; and (3) the isO wil select DR Reoures so that the amount of load reuction 

### capacity reflects the load reduction goals for each category of DR Resource listed in Section

m.E.8.2.2. In the event that paricipation in the ORR Pilot program exceeds the limits defined 

## for a category of OR Resources, the isO wil conduct a radom drawing by OR Resoure category to determine the final paricipants for the period. If a OR Resoure category is not fully subscrbe for the period,

Issued by: Raymnd W. Hepper,

Vice Prident and Genera Counsel Issued on: July 28, 2008 Effective: October 1,2008ISO New England Inc. FERC Electric Tariff No.3 Section ill - Market Rule I - Standard Market Design Appendix E-Load Response Program Demand Response Reserve Pilot 1st Rev Sheet No. 7923 Superseding Original 7923



### then the ISO will have the option of selecting other DR Resources that were not initially selected to participate in the DRR Pilot program. Once a DR Resource is selected and the Enrolling Participant agrees to participate, there will be no substitution of OR Resources during that Forward Reserve Service Period. The ISO can vary the asset selection process as necessary in order to produce unbiased, statistically meaningful results, and will maintain sole discretion over the selection of assets to participate in the DRR Pilot program. An Enrolling Participant will be given an opportunity to opt selected DR Resources out of the DRR Pilot program should it deem the payments to participating DR Resources (described in Section m.E.8.3) to be insufficient Any OR Resource that is selected to participate in the DRR Pilot program and that does not opt out after being given an opportunity to do so will be eligible for DRR Availability Payments and ORR Performance Payments and will be subject to ORR Replacement Energy Cost Penalties (described in Section m.E.8.4).

llLE.8.2.4 AvaDability. DR Resources participating in the ORR Pilot program must be available for dispatch between 7 a.m. and 11 p.m. during non-holiday weekdays, must meet the availability requirements of the Real-Time 30-Minute Demand Response Program, and must make the ORR Contract Amount (defined in Section m.E.8.3.1) available for dispatch as described in Section m.E.8.2.5. In addition, for research purposes, the ISO may investigate certain subsets of hours surrounding

Issued by: Raymond W. Hepper,

Vice President and General Counsel Issued on: July 28, 2008 Effective: October 1, 2008 iso New England Inc. FERC Elecmc Tarff No.3 Section il - Market Rule 1 - Standa Market Design Appendix E-Load Response Program Demand Response Reserve Pilot 1st Rev Sheet No. 7923 Superseing Onginal 7923



### then the iso will have the option of selecting other DR Resources that were not initially selected

to parcipate in the DRR Pilot progr. Once a DR Resource is selected and the Enrollng 

### Paricipant agres to parcipate, there wil be no substitution of OR Resources durg that Forward Reserve Service Period. The iso can var the asset selection proess as necessar in 

### order to produce unbiased, statistically meaningful results, and will maintain sole discretion over 

### the selection of assets to parcipate in the DRR Pilot progr.

An Enrollng Parcipant wil be given an opportnity to opt selected DR Resources out
of the DRR Pilot progr should it deem the payments to paricipating DR Resources (describe 

## in Section m.E.8.3) to be insufcient Any OR Resource that is selecte to parcipate in the DRR Pilot program and that does not opt out afer being given an opportunity to do so wil be

eligible for DRR Availabilty Payments and ORR Pedormce Payments 

### and wil be subject to ORR Replacement Energy Cost Penalties (described in Section m.E.8A).



## llE.8.2.4 AvaDabilty. DR Resoures parcipating in the ORR Pilot program must be available for dispatch between 7 a.m. and i 1 p.m. durng non-holiday 

### weekdays, must meet the avaiabilty requiements of th Rea-Time 30-Minute Demand 

### Response Program and must make the ORR Contrct Amount (defined in Section m.E.8.3.l) available for dispatch as desribed in Section m.E.8.Z.5. In addition, for research puroses, the 

### ISO may investigate certn subsets of hour surounding

Isued by: Raymond W. Hepper,

Vice President and Genera Counsel Issued on: July 28, 2008 

### Effective: Octor 1, 200ISO New England Inc. FERC Electric Tariff No.3 Section 

### m - Market Rule 1 - Standard Market Design Appendix E-Load Response Program Demand Response Reserve Pilot 1st Rev Sheet No. 7924 Superseding Original 7924



### seasonal daily peak hours. In connection with any such investigation, the ISO may request that a certain category of DR Resource make itself available to respond to ISO dispatch instructions during such conditions. Any change to availability requirements will be made in consultation with the Enrolling Participants, and sufficient notice will be provided to participating DR Resources before any such change, and can include a request to test new communication protocols during the ORR Pilot program.



### m.E.8.2.5 Dispatch. DR Resources participating in the ORR Pilot program will be dispatched in order to restore or maintain first contingency protection ("ORR Reportable Events"). In addition, the ISO may dispatch DR Resources at additional times if ORR Reportable Events do not provide sufficient data for the ISO to evaluate DR Resources across all pre-defined test conditions, including dispatch frequency, duration of load reduction, and season. Except as provided below, the random activations by the ISO to gather performance data and any ORR reportable event activations of the ORR Pilot program shall not exceed 25 times and shall not exceed 50 hours in a Forward Reserve Delivery Period. If total activations approach the cap of 25 times or 50 hours, the ISO will notify participating DR

Issued by: Raymond W. Hepper,

Vice President and General Counsel Issued on: July 28, 2008 Effective: October 1,2008 iso New England Inc. FEC Electnc Tanff NO.3 Section m - Maret Rule 1 - Stadad Market Design Appendix E-Load Response Prgram Demad Response Reserve Pilot 1st Rev Sheet No. 7924 Superseding Original 7924



### seaona daly peak hours. In connection with any such investigation, the iso may request tht a 

### certn category of DR Resource make itself available to respond to iso dispatch instrctions 

### durng such conditions. Any chage to availabilty requirements wil be made in consutation with the Enrollng Paricipants, and suffcient notice wil be provided to paricipating DR Resources before any such change, and can include a request to test new communication

protocols during the ORR Pilot progr.

m.E.8.2.5 Dipatc DR Resources parcipating in the ORR Pilot progr 

### wil be dispatched in order to restore or maintan first contingency protection ("ORR Reportble 

### Events"). In addtion, the iso may dispatch DR Resoures at additional times if ORR Reportble Events do not provide suffcient data for the iso to evaluate DR Resources across all pre-defined test conditions, including dispatch frquency, duration of load reuction, and sen. 

### Except as provided below, the radom activations by the iso to gather performance data

and any ORR reportble event activations of the ORR Pilot progr shall not exce 25 ties 

### and shal not exceed 50 hour in a Forward Reserve Deliver Period. If tota activations

approach the cap of 25 times or 50 hour, the iso wi notify paricipating DR

Isued by: Raymnd W. Heppr,

Vice Prident an Genera Counsel Issued on: July 28, 2008 Effective: October 1,208ISO New England Inc. FERC Electric Tariff No.3 Section III - Market Rule I - Standard Market Design Appendix E-Load Response Program Demand Response Reserve Pilot Original Sheet No. 7925



### Resources that if the cap is reached, the ISO will permit participating OR Resources to opt out of the ORR Pilot program. DR Resources that exercise this opt-out right will no longer be eligible to receive ORR Availability Payments and ORR Performance Payments or subject to ORR Replacement Energy Cost Penalties and will no longer be required to respond to ISO dispatch instructions in response to DRR Reportable Events pursuant to the DRR Pilot program. Those not exercising this opt-out provision will continue to be obligated to respond to ISO dispatch instructions in response to DRR Reportable Events through the end of the then current Forward Reserve Service Period; such resources will continue to receive ORR Availability Payments and DRR Performance Payments, and will be subject to DRR Replacement Energy Cost Penalties.
The ISO will continue to study the performance of DR Resources that choose to not exercise the opt-out provision.

Issued by: Kathleen A. Carrigan,

Senior Vice President and General Counsel Issued on: September 7, 2005 Effective; January 1,2006 iso New England In. FERC Electrc Tarff No.3 Section II - Market Rule I - Stadard Market Design Appendix E-Load Response Progr Demand Response Reserve Pilot Original Sheet No. 7925



### Resources that if the cap is reached, the iso wil permt parcipatig OR Resources to opt out of the ORR Pilot progr. DR Resources that exercise ths opt-out right wil no longer be eligible to receive ORR Avaiabilty Payments and ORR Performance Payments or subject to ORR 

### Replacement Energy Cost Penalties and wil no longer be requird to respond to iso dispatch instrctions in reponse to DRR Reportable Events puruant to the DRR Pilot progr. Those 

### not exercising this opt-out provision wil continue to be obligated to respond to iso dispatch instrctions in response to DRR Reportable Events though the end of the then CUlent Forward Reserve Service Period; such resources will continue to receive ORR Availabilty Payments and DRR Performance Payments, and wil be subject to DRR Replacement Energy Cost Penalties. 

### The iso will continue to study the performance of DR Resoures that choose to not exercise the

opt-out provision.

Issued by: Kathleen A. Cagan,

Senior Vice Prsident and Gener Counsel Issued on: September 7, 2005 

### Effective; Janua 1,200ISO New England Inc.

PERC Electric Tariff No.3 Section ill - Market Rule 1 - Standard Market Design Appendix E-Load Response Program Demand Response Reserve Pilot 1st Rev Sheet No. 7926 Superseding Original 7926



### m.E.S.2.6 Metering & 

### Communication. The DRR Pilot program will use the existing Internet Based Communication System for activation of the participating DR Resources. Telemetry data, which is automatically transmitted from each DR Resource through
their 

## mcs provider to the 

## mcs open solution every five minutes, will be transmitted by the


## mcs open solution to the ISO. A separate sub-project will identify and evaluate the lower-cost, two-way communication alternatives to the current combination of Supervisory Control and Data Acquisition ("SCADA") and Remote Intelligent Gateway ("RIG") technology that is presently required to connect dispatchable Resources to the ISO. This sub-project will evaluate the use of the lower-cost dispatch and telemetering for use by DR Resources that are less than 5 MW in size. To support this evaluation, the ISO may use, in consultation with participating Enrolling Participants, alternative dispatch and telemetering solutions during the course of the DRR Pilot program. Alternative dispatch and telemetry solutions may require the transmission of telemetry data to the ISO more frequently than every five minutes. The ISO will report to the Markets Committee regarding any implementation of alternative dispatch and telemetry solutions on a
semi-annual basis. 

### m.E.8.3 Payments To Participating DR Resources. Enrolling Participants whose DR Resources participate in the DRR Pilot program will be eligible to receive a DRR Availability Payment, based on the applicable 30-Minute hourly Forward Reserve Payment Rate for the Connecticut Load Zone, and a DRR Performance Payment. Such payments are intended to compensate DR Resources for the additional obligations and risks associated with participation in the DRR Pilot program.

Effective: October I, 2008 Issued by: Raymond W. Hepper,

Vice President and General Counsel Issued on: July 28, 2008 iso New England Inc. PEC Electrc Tarff No.3 

### Section il - Maret Rule i - Stadard Maet Design Appendix E-Load Response Prgrm Demand Response Reserve Pilot i st Rev Sheet No. 7926 Superseing Onginal 7926

m.E.8.2.6 Meterig & Communication. The DRR Pilot progrm wil use 

### the existing Internet Based Communication System for activation of the parcipating DR Resources. Telemetr data which is automatically trsmitted from each DR Resource though their mcs provider to the mcs open solution every five minutes, will be transmitted by the mcs open solution to the iso. A separte sub-project wil identify and evaluate the lower-cost, two-way communication alternatives to the curent combination of Supervisor Control and Data 

### Acquisition ("SCADA") and Remote Intellgent Gateway ("RIG") technology that is presently

required to connect dispatchable Resources to the isO. This sub-project wil evaluate the use of 

## the lower-cost dispatch and telemetering for use by DR Resur tht are less th 5 MW in size. To support ths evaluation, the iso may use, in consultation with parcipating Enrllng Parcipants, alternative dispatch and telemetering solutions durng the coure of the DRR Pilot

progr. Alternatve dispatch and telemetr solutions may require the trsmission of telemetr 

### data to the iSO more frequently than every five minutes. The iso wil report to the Markets 

### Commtt regarding any implementation of alternative dispatch and telemetr solutions on a 

## semi-anua basis. 

## m.E.8.3 Payments To Parcipating DR Resources. Enrllng Parcipants whose
DR Resoures parcipate in the DRR Pilot progr wi be eligible to reive a DRR

Availabilty Payment, bas on the applicable 30-Minute hourly Forward Reserve Payment Rae 

### for the Connecticut Load Zone, and a DRR Performance Payment. Such payments ar intende 

### to compensate DR Resoures for the additional obligations and risks assoiated with parcipation in the DRR Pilot progr.
Effective: Ocber I, 200 Issued by: Raymond W. Heppr,

Vice President an Genera Counsel Issued on: July 28, 2008ISO New England Inc. PERC Electric Tariff No. 3 Section III - Market Rule I - Standard Market Design Appendix E-Load Response Program Demand Response Reserve Pilot 1st Rev Sheet No. 7927 Superseding Original 7927



### m.E.8.3.l DRR Avallability Payment. Participating OR Resources will receive a ORR Availability Payment based upon the applicable 30-Minute Hourly Forward Reserve Clearing Price for the Connecticut Load Zone. At the beginning of each Forward Reserve Service Period, ORR Availability Payments for participating OR Resources will be based on the amount that the Enrolling Participant agrees to provide within 30 minutes when called upon by the ISO ("ORR Contract Amount"). Each time a dispatch event occurs, the ORR Availability Payment from the event start time going forward will be based on the lower of the ORR Contract Amount or the actual performance of the OR Resource. The ORR Availability Payment between the last dispatch event and the end of the Forward Reserve Service Period will be based on the actual performance of the DR Resource in the last dispatch event, not to exceed
the DRR Contract Amount. Specifically, ORR Availability Payments to a OR Resource for each hour that the DR Resource is required to be available for dispatch will equal:

(the 30-Minute hourly Forward Reserve Payment Rate for the Connecticut Load Zone) multiplied by (the lower of the ORR Contract Amount or the actual performance of the OR Resource).

Issued by: Raymond W. Hepper,

Vice President and General Counsel ISsued on: July 28, 2008 Effective: October 1.2008 iso New England Inc.
PERC Electrc Tarff No. 3 Section II - Market Rule i - Stadad Market Design Appendix E-Load Response Progrm Demand Response Reserve Pilot 1st Rev Sheet No. 7927 Superseding Original 7927

il.E.8.3.1 DRR Avallability Payment. Paricipating OR Resources wil
receive a ORR Availabilty Payment based upon the applicable 30-Minute Hourly Forward 

### Reserve Clearng Price for the Connecticut Load Zone. At the beginning of each Forward Reserve Service Period, ORR Availabilty Payments for parcipating OR Resources wil be 

### based on the amount tht the Enrollng Paricipant agres to provide within 300unutes when called upon by the iso ("ORR Contract Amount"). Each time a dispatch event occur, the ORR 

### Availabilty Payment from the event sta time going forward wil be based on the lower of the 

### ORR Contrct Amount or the actual pedormance of the OR Resoure. The ORR Availabilty Payment between the last dispatch event and the end of the Forward Reserve Serce Period wil be baed on the actual performance of the DR Resource in the last dispatch event, not to excee


### the DRR Contrct Amount. 

### Specifically, ORR Availabilty Payments to a OR Resource for each hour that the DR Resoure is reuid to be avaiable for dispatch will equal:



### (the 30-Minute hourly Forwar Reserve Payment Rate for the Connecticut Load Zone) multiplied by 

### (the lower of the ORR Contrct Amount or the actu performance of the OR Resource).

Issued by: Raymond W. Hepper,

Vice President and Genera Counsel iSsued on: July 28, 2008 Effective: October t, 2008ISO New England Inc. FERC Electric Tariff No.3 Section III - Market Rule I - Standard Market Design Appendix E-Load Response Program Demand Response Reserve Pilot 1st Rev Sheet No. 7928 Superseding Original 7928



### m.E.8.3.2 DRR 

### Performance Payment. The DRR Performance Payment will be calculated as the product of the Amount Interrupted and the higher of the applicable
Forward Reserve Threshold Price or the Real-Time Connecticut Zonal Price. For hours in which both a ORR Pilot program dispatch event and a Real-Time 30-Minute Demand Response Program event occur, DRR Pilot program participants will receive no ORR Performance Payment. At such times, DRR Pilot program participants will receive Real-Time hourly payments associated with the Real-Time 30-Minute Demand Response Program; provided, however that ORR Pilot program participants will still be subject to ORR Replacement Energy Cost Penalties as described in Section m.E.S.4.

m.E.8.3.3 Performance Measurement. DR Resource performance will be determined in the same manner as in the existing Real-Time 3D-Minute Demand Response Program as described in the ISO New England Load Response Program Manual, provided, however, that the customer baseline adjustment for the DRR Pilot program will be increased or decreased to reflect actual metered consumption during the two hours prior to the dispatch of the Demand Resources (i.e., adjusted symmetrically).

Issued by: Raymond W. Hepper,

Vice President and General Counsel Issued on: July 28, 2008 Effective: October 1,2008 iso New England Inc. FERC Electrc Tarff No.3 Section Il- Market Rule i - Stada Market Design Appendix E-Load Response Progrm Demand Response Reserve Pilot 1st Rev Sheet No. 7928 Supersding Original 7928

m.E.8.3.2 DRR Performance Payment. The DRR Performance Payment 

### wil be calculated as the product of the Amount Interrpte and the higher of the applicable
Forwar Reserve Theshold Price or the Real-Time Connecticut Zonal Price. 

### For hour in which both a ORR Pilot program dispatch event and a Rea-Time 30-Minute 

### Demand Response Program event occu, DRR Pilot program paricipants wil receive no ORR 

### Performance Payment. At such times, DRR Pilot program parcipants wil receive Real-Time 

## hourly payments associate with the Real-Time 30-Minute Demand Response Progr; provided, however that ORR Pilot program parcipants wil still be subject to ORR Replacement Energy Cost Penalties as described in Section m.E.SA.

IIE.8.3.3 Performance Meaurement. DR Resource performance wil be
determned in the same manner as in the existing Real-Time 3D-Minute Demand Response 

## Program as described in the iso New England Load Response Progr Manual, provided however, that the customer basline adjustment for the DRR Piot progr wil be increased or decreased to reflect actual metere consumption durng the two hour prior to the dispatch of the 

### Demand Resources (i.e., adjusted symetrcaly).

Issue by: Raymnd W. Heppe, 

### Vice Prsident an Gener Counsel Isue on: July 28, 2008 Effective: October 1,2008ISO New England Inc.

FERC Electric Tariff No.3 Section ill - Market Rule 1 - Standard Market Design Appendix E-Load Response Program Demand Response Reserve Pilot lst Rev Sheet No. 7929 Superseding Original 7929



### III.E.8.4 Performance Penalties III.E.8.4.1 ORR Replacement Energy Cost Penalty. The DR Resources participating in the DRR Pilot program will not be subject to a failure to reserve penalty, since such DR Resources will not be bidding into the Day-Ahead or Real-Time Energy Markets, nor will they be dispatched based upon a price. However, the formula in Section rn.E.8.3.1 will decrease the DRR Availability Payment by the portion of the DRR Contract Amount not provided. DR Resources participating in the DRR Pilot program will be required to pay a failure to activate reserve penalty based on replacement energy costs ("DRR Replacement Energy Cost Penalty"), as defined below, when they provide less than the DRR Contract Amount in response to ISO dispatch instructions. Standard Load Response Program curtailment measurement (including a symmetrically adjusted customer baseline for the two hours prior to the event as described in Section m.E.8.3.3 above) is utilized to determine performance of DR Resources including any undelivered response. The Real-Time Zonal Price used in the formula shall be the hourly Connecticut Real-Time Zonal Price.

DRR Replacement Energy Cost Penalty 

# = (DRR Contract Amount - Amount Interrupted) multiplied by (Real-Time Connecticut Zonal Price).

Issued by: Raymond W. Hepper,

Vice President and General Counsel Issued on: July 28, 2008 Effective: October 1,2008 iso New England Inc. FERC Electrc Tarff NO.3 Section il - Market Rule 1 - Stadard Market Design Appendix E-Load Response Program Demand Response Reserve Pilot 1st Rev Sheet No. 7929 Supersing Onginal 7929

II.E.8.4 Performance Penalties 

### III.E.8.4.1 ORR Replacement Energ Cost Penaty. The DR Resources 

### parcipating in the DRR Pilot program wil not be subject to a failur to reserve penalty, since such DR Resources wil not be bidding into the Day-Ahead or Rea-Time Energy Markets, nor 

### wil they be dispatched based upon a price. However, the formula in Section rn.E.8.3. I wil 

### decrease the DRR Availabilty Payment by the portion of the DRR Contract Amount not provided. 

### DR Resources parcipating in the DRR Pilot program will be required to pay a failure to activate reserve penalty based on replacement energy costs ("DRR Replacement Energy Cost 

### Penaty"), as defined below, when they provide less than the DRR Contrct Amount in response 

## to ISO dispatch instrctions. Standard Load Response Program curlment measurement (including a symetrically adjusted customer baseline for the two hour prior to the event as desbe in Section m.E.8.3.3 above) is utilized to determine performce of DR Resources 

### including any undelivere response. The Real-Time Zonal Prce used in the formula shal be the hourly Connecticut Real. Time Zonal Prce.



### DRR Replacement Energy Cost Penalty = 

### (DRR Contract Amount - Amount Interrpted) multiplied by (Real-Time Connecticut Zonal Prce).

Isued by: Raymond W. Hepper,

Vice Prident and Genera Counsel Isued on: July 28, 2008 

### Efective: Ocob t, 2008ISO New England Inc.

PERC Electric Tariff No.3 Section ill - Market Rule 1 - Standard Market Design Appendix E-Load Response Program Demand Response Reserve Pilot 1st Rev Sheet No. 7930 Superseding Original 7930



### m.E.8.5 EnroUment and ICAP Credit III.E.8.5.1 EnroUment. DR Resources participating in the DRR Pilot program must be registered in the Real-Time 30-Minute Demand Response Program. DR Resources participating in the DRR Pilot program shall only respond to DRR Pilot program dispatch instructions. Settlement Only Resources participating in the DRR Pilot program must change their registration with the ISO to participate in the Real-Time 30-Minute Demand Response Program. Any Settlement Only Resource that elects to participate in the ORR Pilot program will be afforded the option at the end of the DRR Pilot program to return to "settlement only" status or to continue to participate in the Real-Time 30 Minute Demand Response Program.

m.E.8.5.2 ICAP Credit. DRR Pilot program participants will receive ICAP credit pursuant to the provisions of the Real-Time 30-Minute Demand Response Program. leAP credit will be based on DR Resource performance in response to Real-Time 30-Minute Demand Response Program events only. No additional leAP credit will be afforded a OR Resource for participation in the DRR Pilot program. To the extent that payments associated with the Forward Reserve Auction are modified in the future, ORR Availability Payments and leAP credits for OR Resources participating in the ORR Pilot program will also be modified in a consistent

manner.

Issued by: Raymond W. Hepper.

Vice President and General Counsel Issued on: July 28. 2008 Effective: October 1.2008 iso New England Inc. PERC Electrc Tarf No.3 Section il - Market Rule I - Stadar Market Design Appendix E-Load Response Program Demand Response Reserve Pilot 1st Rev Sheet No. 7930 Supersding Original 7930

m.E.8.5 Enrollment and ICAP Credt III.E.8.5.1 Enrollment. DR Resource parcipating in the DRR Pilot 

## program must be registere in the Real-Time 30-Minute Demad Response Progr. DR Resources parcipating in the DRR Pilot program shall only respond to DRR Pilot progr

dispatch instrctions.
Settement Only Resources parcipating in the DRR Pilot progr must change their 

### registrtion with the ISO to paricipate in the Rea-Time 30-Minute Demad Response Progr. 

### Any Settlement Only Resource that elects to parcipate in the ORR Pilot program will be aforded the option at the end of the DRR Pilot progrm to retu to "settlement only" status or 

### to continue to parcipate in the Real. Time 30 Minute Demand Response Program.



### m.E.8.5.2 ICAP Credit. DRR Pilot program paricipants wil reive ICAP 

### credit puruat to the provisions of the Real-Time 30-Minute Deand Response Prgr. ICAP creit will be based on DR Resource performance in response to Real. Time 3Q-Minute Demand Response Prgr events only. No additional ICAP credit wil be aforded a OR Resource for 

### paricipaton in the DRR Pilot progr. To the extent that payments assoated with the Forwar 

### Reserve Auction are moded in the future, ORR Availabilty Payments and ICAP crets for 

## OR Resoures parcipating in the ORR Pilot progr wil also be modifed in a consistent

manner.

Issued by: Raymond W. Hepper.



### Vice Prident and Gener Counl Issued on: July 28. 2008 Effective: October 1.2008ISO New England Inc. FERC Electric Tariff No.3 Section III - Market Rule 1 - Standard Market Design Appendix E-Load Response Program Demand Response Reserve Pilot 2nd Rev Sheet No. 7931 Superseding 1st Rev 7931



### III.E.S.6 Program Cost Allocation. There are two separately calculated charges for the DRR Pilot program: (1) 

### payments associated with the DRR Availability Payment, and (2) payments associated with the DRR Performance Payment (net of DRR ReplacementEnergy Cost Penalties) when loads are called upon to interrupt.

m.E.S.6.1 DRR Availability Payment Allocation. The charge for the DRR Availability Payments will be allocated on a pro-rata basis based on each Market Participant's share of the aggregate charges under Schedules 1, 

### 2, and 3 of Section IV.A (Recovery of ISO Administrative Expenses) of the ISO New England Transmission, Markets and Services Tariff.

III.E.S.6.2 DRR Performance Payment Allocation. The charge for the DRR Performance Payment associated with the actual interruption (net of DRR Replacement Energy Cost Penalties) will be allocated to Real-Time Load Obligation Deviation in the Connecticut Load Zone.

Issued by: Raymond W. Hepper,

Vice President and General Counsel Issued on: July 28, 2008 Effective: October 1,2008 iso New England Inc. FEC Electrc Tarff No.3 Secion II - Market Rule 1 - Stadard Market Design Appendix E-Load Response Program Demand Response Reserve Pilot 2nd Rev Sheet No. 7931 Superseding 1 st Rev 7931



## III.E.8.6 Program Cost Alloction. There ar two separately calculated charges for

the DRR Pilot progr: (1) payments associated with the DRR Availabilty Payment, and (2) 

### payments associated with the DRR Performance Payment (net of DRR Replacement Energy Cost

Penalties) when loads ar caled upon to interrpt.



## m.E.8.6.1 DRR Availabilty Payment Allocation. The charge for the DRR Availabilty Payments wil be allocated on a pro-rata basis based on each Market Paricipant's shar of the aggrgate charges under Schedules i, 2, and 3 of Section IV.A (Recovery of iso

Admnistrtive Expenses) of the iso New England Transmission, Markets and Services Tar.

llE.8.6.2 DRR Performance Payment Allocation. The chage for the 

### DRR Performance Payment associated with the actu interrption (net of DRR Replacement Energy Cost Penalties) wil be allocated to Real. Time Load Obligation Deviation in the
Connecticut Load Zone.

Issued by: Raymnd W. Heppr,

Vice Prsident and General Counsel Issued on: July 28, 2008 Effective: October 1,2008ISO New England Inc. PERC Electric Tariff No.3 Section III - Market Rule 1 - Standard Market Design Appendix E-Load Response Program 1st Rev Sheet No. 7932 Superseding Original 7932



### Reserved for future use.

Effective: April 1. 2006 Issued by: Kathleen A. Carrigan, Senior Vice President and General Counsel Issued on: January 31,2006 iso New England Inc. PEC Electrc Tarff NO.3 Section II - Market Rule 1 - Stada Market Design Appendix E-Load Response Progrm 1st Rev Sheet No. 7932 Superseding Original 7932



### Reserved for futue use.

Effective: April I, 200 

### Issued by: Kaleen A. Cagan, Senior Vice Prsidet and Gener Counsel Isued on: Janua 31,200ISO New England Inc. FERC Electric Tariff No.3 Section ill - Market Rule 1 - Standard Market Design Appendix E - Load Response Program 1st Rev Sheet No. 7933 Superseding Original 7933



### Reserved for future use.

Issued by: Kathleen A Carrigan, Senior Vice President and General Counsel Issued on: January 31, 2006 Effective: April 1, 2006 iso New England Inc. FEC Electrc Tarff NO.3 

### Section il - Maret Rule i - Stada Maret Design Appendix E - Load Response Progr 1st Rev Sheet No. 7933 Superseding Onginal 7933



### Reserved for futue use.

Issued by: Kateen A Cargan Senior Vice Prsident and Genera Counsel Issued on: Januar 31, 2006 

### Effective: Apn1, 200ISO New England Inc. FERC Electric Tariff No.3 Section ill - Market Rule 1 - Standard Market Design Appendix E - Load Response Program lst Rev Sheet No. 7934 Superseding Original 7934



### Reserved for future use.

Issued by: Kathleen A Canigan, Senior Vice President and General Counsel Issued on: January 31,2006 Effective: April 1, 2006 iso New England Inc. FEC Electrc Tanff No.3 Section II - Market Rule 1 - Stadad Maret Design Appendix E - Load Response Progr 1st Rev Shet No. 7934 Superseding Origial 7934



### Reserved for future use.

Isue by: Kathleen A Cagan, Senior Vice President and Genera Counsel 

### Isued on: Janua 31,206 Effective: April 1, 200ISO New England Inc.

FERC Electric Tariff No.3 Section ill - Market Rule 1 - Standard Market Design Appendix E - Load Response Program 1st Rev Sheet No. 7935 Superseding Original 7935



### Reserved for future use.

Issued by: Kathleen 

### A Carrigan, Senior Vice President and General Counsel Issued on: January 31,2006 Effective: Aprill, 2006 iso New England Inc. FERC Electrc Tarff No.. 3 Section II - Market Rule i - Stada Market Design Appendix E - Load Response Progr 1st Rev Sheet No. 7935 Superseding Original 7935



### Reserved for futue use.

Isued by: Kaeen A Camgan Senior Vice Prsident and ~neral Counsl Issued on: Janua 31,2006 Effective: Apnl1, 200ISO New England Inc.

FERC Electric Tariff No.3 Section III - Market Rule I - Standard Market Design Appendix E-Load Response Program Sheet Nos. 7936 through 7999



### Sheet Nos. 7936 through 7999 are reserved for future use.

Issued by: Kathleen A Carrigan. Senior Vice President and General Counsel Issued on: October 28, 2005 Effective: December 1, 2005 iso New England Inc. FEC Electric Tarff No.3 Section II - Market Rule i - Stadad Maret Deign Append E-Load Response Program Sheet Nos. 7936 though 7999



### Sheet Nos. 7936 through 7999 ar reserved for future use.



### Issued by: Kaeen A Cagan Senior Vice President and Genera Counsel Issued on: October 28, 2005 

### Effective: Dember 1, 2005

# Attachment 10

ISO New England Operating Procedure No.4, Action During a Capacity Deficiency 

# Attachment 10

iso New England Operating Procedure 

# No.4, Action During a Capacity Deficiency

### ISO New England Operating Procedures OP 4 - Action During A Capacity Deficiency 

### ISO New England Operating Procedure No.4 Action During A Capacity Deficiency

Effective Date: March 5, 2008

REFERENCES: NERC Standard EOP-002 - Capacity and Energy Emergencies

NERC Standard COM-002 - Communications and Coordination NPCC Emergency Operation Criteria A-03 NPCC Operating Reserve Criteria A-06 NPCC Procedures During Abnormal Operating Conditions C-20 ISO New England Operating Procedure No. 'l - Action in an Emergency (OP?) ISO New England Operating Procedure No. 8- Operating Reserve and Regulation (OP 8) ISO New England Operating Procedure No.9 - Scheduling and Dispatch of External Transactions (OP 9) ISO New England Operating Procedure No. 10 - Analysis and Reporting of Power System Emergencies (OP 10) ISO New England Operating Procedure No. 14 - Technical Requirements for Generators, Demand Resources and Asset Related Demands (OP 14) MasterlLocal Control Center Procedure No.2 - Abnormal Conditions Alert (MILCC 2) ISO New England Manuals
Local Control Center Instructions:

CONVEX: Operating Instruction 0004 - Action During A Capacity Deficiency MAINE: Operating Procedure No.4 - Action During A Capacity Deficiency NEW HAMPSHIRE: Operating Procedure No.4 - NHSOP #4 - Capacity Deficiency Actions NSTAR OP-4 Action During a Capacity Deficiency REMVEC II Operating Procedure 4, Action During A Capacity Deficiency VELCO: VELCO Operating Procedure OP-4

Revision 8, Effective Date: March 5, 2008 

### iso New England Opraing ProcW's OP 4 - Action Durng A Capacity Deficiency



### iso New England Operating Procedure No.4 Action During A Capacity Deficiency



### Effective Date: March 5, 2008



## REFERECES: NERC Stadad EOP-002 - Capacity and Energy Emergencies



### NERC Stadar COM-002 - Communications and Coordination 

### NPCC Emergency Operation Criteria A-03 

### NPCC Operating Reserve Criteria A-06 

### NPCC Procedures Durng Abnonnal Operating Conditions C-20 iSO New England Operaing Procedure No. ? - Action in an Emergency 

## (OP?) iSO New England Operating Proceure No.8- Operating Reserve and Regulation (OP 8) 

### iSO New England Operating Proceure No.9 - Scheduling and Dispatch 

### of External Trasactions (OP 9) 

### iso New England Operating Procedure No. 10 - Analysis and Reporting

of Power System Emergencies (OP 10) 

### iso New England Operatig Procur No. 14 - Technical Requireents for Generators. Demand Resources and Asset Related Demands (OP 14) 

### Master/Local Control Center Proceure NO.2- Abnonnal Conditions 

### Alert (MCC 2) iSO New England Manuas 

### Loal Control Center Instrctions: 

## CONVEX: Operating Instrction 0004 - Action Dung A Capaity Deficiency 

## MAIN: Operating Procedur No.4- Action Durng A Capacity Deficiency NEW HASHI: Operating Procedure No.4- NHSOP #4 - Capacity Deficiency Actions 

## NSTAR OP-4 Action Durng a Capacity Deficiency REMVC II Operating Proceur 4. Action During A Capacity Deficiency 

# VELCO: VELCO Operating Proceur OP-4

Revision 8, Effective Date: March 5, 2008

### ISO New England Operating Procedures OP 4 - Action During A Capacity Deficiency



### Table of Contents

I. IMPLEMENTATION BY ISO NEW ENGLAND 4 II. CANCELLATION OF ACTIONS _ 8 ill. IMPLEMENT A nON BYLees 8 IV. 

### COMMUNICATIONS 8 

### V. 'IMPLEMENTATION OF AN ALERT 9 VI. PUBLIC NOTIFICATIONS " _ 10 OP 4 REVISION mSTORY .........................................................•.................... _ 10 Appendix A - Estimates Of Additional Generation And Load Relief From System Wide Implementation Of Actions In ISO New England Operating Procedure No.4

Revision 8, Effective Date: March 5, 2008 2 iso New England Oprating Procedures 

### OP 4 - Action Durg A Caacity Deficiency


## Table of Contents

I. IMLEMENTATION BY iso NEW ENGLAN..........................................................4 ß. CANCELLATION OF ACTIONS.............................................................................._....8

il. IMLEMENT 

### A nON BY Lees......................................................................................8 

### iv. COMMCATIONS.......................................................................................................8 V. 'IPLEMENTATION OF AN ALERT............................................................................9 VI. PUBLIC NOTIFCATIONS ................................................."............................_........... 10 OP 4 REVISION mSTORY .............................................................................._...................... 10

Appendix A - Estimates Of Additional Generation And Load Relief 

### From System Wide 

### Implementation Of Actions In iSO New England Operating Procedure NO.4

Revision 8, Effective Date: March 5, 2008 2

### ISO New England Operating Procedures OP 4 - Action During A Capacity Deficiency

PART I - INTRODUCTION This Procedure establishes criteria and guides for actions during capacity deficiencies, as directed by the ISO and as implemented by the ISO and the Local Control Centers (LCCs). This Procedure may be implemented any time one or more of the following events, or other similar events, occur or are expected to occur: • The New England Control Areas / Balancing Authorities (CAlBA's) available Resources are insufficient to meet the anticipated load plus Operating Reserve Requirements. It will not be utilized to maintain Replacement Reserve Requirements. • One or more contingencies have occurred resulting in an immediate deficiency in the New England CAlBA's available capacity resources required to meet the load plus Operating Reserve Requirements. • Transmission facilities into a sub area of the New England CAIBA 

### are loaded beyond established transfer capabilities. • A sub area ofthe New England CAIBA 

### is experiencing abnormal voltage and/or reactive conditions. • The need to implement manual load shedding as required by ISO New England Operating Procedure No.7 - 'Action In An Emergency' (OP 7) is imminent but load shedding may be avoided, or reduced in magnitude, by application of this Procedure. • Another NPCC Area, or a remote system or pool, is experiencing a capacity deficiency and has requested assistance from the ISO, which, if provided, will reduce the New England CAlBA's actual Operating Reserve below the required levels. • Any other serious threat to the integrity of the bulk power system for which the ISO determines that this Procedure will mitigate the impact Appendix A contains an estimate of the additional generation and load relief, which will be achieved through implementation of the Actions specified in this Procedure.

Revision 8, Effective Date: March 5, 2008 3 

### iso New England Oprang Procedures OP 4 - Action Dunng A Capacity Deficiency



### PART I - INTRODUCTION This Procedure establishes criteria and g~ides for actions during capacity deficiencies, as directed by the iso and as implemented by the iso and the Local Control Centers (LCCs). This 

### Procedure may be implemented any time one or more of the following events, or other similar 

### events, occur or are expected to occur: 

### · The New England Control Area / Balancing Authorities (CA/A's) available Resources are insuffcient to meet the anticipated load plus Operating Reserve 

### Requirments. It wil not be utilized to maintan Replacement Reserve Requirements. 

### · One or more contingencies have occurrd resulting in an immediate deficiency in the New England CAlA's available capacity resources required to mee the load plus Operating Reserve Requirements. 

## · Trasmission facilties into a sub area of the New England CAIA ar loaded beyond established transfer capabilties. 

### · A sub ara ofthe New England CA/A is experiencing abnormal voltage and/or reactive conditions.

· The need to implement manual load shedding as reuired by iso New England 

### Operang Procedure No.7 - 'Action In An Emergency' (OP 7) is imminent but
load shedding may be avoided, or reduced in magnitude, by application of 

### this Procedure. 

### · Another NPCC Area, or a remote system or pool, is experiencing a capacity

deficiency and has requested assistce from the iso, which, if provided, wil 

### reduce the New England CA/A's actual Operating Reserve below the reuired 

### levels. 

### · Any other serious theat to the integrty of the bulk power sysm for which the iso determines tht this Procedur will mitigate the impact

Appendix A contains an estimate of 

### the additional generation and load relief, which will be achieved through implementation of the Actions specified in this Procure.

Revision 8, Effectve Date: March 5, 2008 3

### ISO New England Operating Procedures OP 4 - Action During A Capacity Deficiency



### PART II - PROCEDURE
I. IMPLEMENTATION BY ISO NEW ENGLAND The ISO will alert the LCCs and Market Participants promptly any time one or more of the above conditions are anticipated, or have actually been experienced, and application of this Procedure may be required. The ISO will also alert the surrounding CAlBAs and coordinate with these Areas in accordance with NPCC Document A-06 - Operating Reserve Criteria, and C-20 - Procedures During Abnormal Operating Conditions. The alert will be issued in accordance with MasterlLocal Control Center Procedure No. 2 - 'Abnormal Conditions Alert' (MlLCC 2). Upon implementation, the ISO will notify the LCCs of the Actions required by number. The ISO and the LCCs will initiate Actions according to the authority and responsibility assigned by this Procedure. To the extent possible, the ISO will continue to dispatch resources in accordance with Market Rule 1, while ensuring reliability in the New England CAIBA during implementation of OP 4. Action 1 through 5 and Action 7 through 10 will be implemented to the extent required to maintain Operating Reserve Requirements, in accordance with ISO New England Operating Procedure No.8 - 'Operating Reserve and Regulation' (OP 8) and/or to provide necessary dispatch options during abnormal conditions. 

### ACTION 1 (An ISO responsibUity) The ISO will inform all Resources that a capacity shortage exists. Each Resource will notify the ISO and prepare to provide any additional Operable Capability identified as being available under emergency conditions. Implement a Power Caution.



### ACTION 2 (An ISO responsibility) Order on all Generators less than 5 MW requiring special treatment by the ISO under ISO New England Operating Procedure No. 14 - 'Technical Requirements for Generators, Demand Resources and Asset Related Demands,' (OP 14) Section II.D.2. Request all "Settlement Only" Generators under (5) MW to come on line via "Special Notices" on the ISO New England website.



### ACTION 3 (An ISO responsibility) Interrupt Real-Time Demand Response - 2 hour or less notification Block A. Interrupt Real-Time Profiled Response Resources.

Revision 8, Effective Date: March 5, 2008 4 

### iso New England Oprag Procures OP 4 - Action Durng A Capacity Deficiency


### PART II. PROCEDUR


## I. IMLEMENTATION BY ISO NEW ENGLAN

The iso wil alert the LCCs and Market Paricipants promptly any time one or more of 

### the above conditions are anticipated, or have actually been experienced, and application 

## of this Procdur may be required. The iso wil also alert the surunding CAlAs and coordinate with these Areas in accordance with NPCC Document A-06 - Operaing Reserve Criteria, and C-20 - Procedures Durg Abnormal Operating Conditions. The 

## alert will be issued in accordance with MasrlLl Contrl Center Procedure No. 2 - 'Abnonnal Conditions Alert' (M/CC 2). Upon implementation, the iso wil notify the 

### LCCs of the Actions required by number. The iso and the LCCs wil initiate Actions according to the authority and responsibilty assigned by this Procedure. To the extent 

## possible, the iso wil continue to dispatch resourc in accrdace with Maret Rule i, while ensuring reliabilty in the New England CAIA durng implementation of OP 4. Action 1 though 5 and Action 7 though 10 wil be implemented to the extent required to 

## maintain Operating Reserve Requirements, in accordace with iso New England Operating Procedure No.8 - 'Operating Resere and Regulation' (OP 8) and/or to provide necessar dispatch options during abnormal conditions. 

### ACTON i (An iSO responsibUity) The iso will inform all Resources that a capacity shortge exist. Each Resource wil notify the iso and prepare to provide any additional Operable Capabilty identified as being available under emergency conditions. Implement a Power Caution.


### ACTON 2 (An ISO reponsibUity) Order on all Generators less than 5 MW requiring special tratment by the iso under iSO New England Opeting Prour No. 14. 'Technical Requirents 

### for Generators, Demand Resoures and Asset Relate Demands,' (OP 14) Section 

### II.D.2. 

### Reques all "Settlement Only" Generators under (5) MW to come on line via 

### "Speial Notices" on the iSO New England website.


## ACTON 3 (An iSO reponsibility) Interrpt Real. Time Demand Response - 2 hour or less notification Block A. 

### Interrpt Real-Time Profied Response Resource.

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### ISO New England Operating Procedures OP 4 - Action During A Capacity Deficiency


### ACTION 4 (An ISO responsibility) Interrupt Real-Time Demand Response - 2 hour or less notification Block B.

ACTION 5 (An ISO responsibility) Interrupt Real-Time Demand Response - 2 hour or less notification Block C.

ACTION 6 (An ISO responsibility) Begin to allow the depletion of 30-minute reserve.

ACTION 7 (An ISO responsibility) Interrupt Real-Time Demand Response - 2 hour or less notification Block D.

ACTION 8 (An ISO responsibility) Interrupt Real-Time Demand Response - 2 hour or less notification Block E.

ACTION 9 (ISO responsible for plants, LCCs for office complexes.) Request voluntary load curtailment of Market Participants' facilities in the New England CAIBA. Interrupt Real-Time Demand Response - 30 Minutes or Less Notification (that does not require a voltage reduction to be implemented). Implement a Power Watch.

ACTION 10 (A Local Control Center responsibility) Request all of the customer generation contractually available to Market Participants.

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### OP 4 - Action During A Capacity Deficiency



### ACTION 4 (An iso responsibility) Interrpt Real. Time Demand Response - 2 hour or less notification Block B.


### ACTION 5 (An iso reponsibilty) Interrpt Real. Time Demand Response - 2 hour or less notification Block C.


### ACTION 6 (An iso reponsibilty)

Begin to allow the 

### depletion of 30-mInute reserve.


### ACTION 7 (An iso responsibilty) Interrpt Real-Time Demand Response - 2 hour or less notification Block D.


### ACTION 8 (An iso responsibilty) Interrpt Real. Time Demand Response - 2 hour or less notification Block E.


### ACTION 9 (IO responsible for plants, LCCs for offce complexes.)

Request voluntar load curilment of 

### Market Paricipants' facilties in the New 

### England CAIA. Interrpt Real. Time Demand Response - 30 Minutes or Less Notification (that does not reuire a voltage reuction to be implemented). 

### Implement a Power Wath.


### ACTION 10 (A Locl Control Center responsibilty)

Request all of the customer generation contrally available to Market 

### Paricipants.

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### ISO New England Operating Procedures OP 4 - Action During A Capacity Deficiency



### Actions 14~15 and 16 will normally be implemented by the ISO through the LCCs based upon advance projections made by the ISO that it will be necessary to implement Actions 1 through 13~ and that it will not be possible to maintain adequate IO-minute synchronized reserve. When Actions 14 and 15 are requested, the particular hours that they are to be implemented will be specified by the ISO. Actions 14~15, and 16 should be implemented as early as possible to achieve maximum benefit. ACTION 14 (LCC responsibility) Request all of the customer generation not contractually available to Market Participants. Request voluntary load curtailment by large industrial and commercial customers.

ACTION 15 (An ISO and LCC responsibility) Initiate radio and television appeals for voluntary load curtailment. Implement a Power Warning. Depending on the circumstances and the time required to institute certain of the above Actions, it may be necessary to call for some Actions simultaneously, or to alter the order of initiations. When all of the above Actions have been taken, further action, if required, is covered under OP 7. It may be necessary to implement OP 7, prior to the implementation of all of the above Actions. If, at any time during implementation of the above Actions, it appears that implementation of OP 7 will be required; the ISO shall so notify all LCCs.

Action 16 will be implemented by the ISO. When Action 16 is requested, the particular hours that this Action is to be implemented will be specified by the ISO. ACTION 16 (An ISO responsibility) Request New England state Governors to reinforce appeals for voluntary load curtailment and the declaration ofa Power Werning, as initiated in Action 15.

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### OP 4 - Action During A Capacity Deficiency



### Actions l4~ is and 16 wil normally be implemented by the iso thrugh the LCCs basd upon advance projections made by the iso that it wil be necessary to implement Actions 1 through 13, and tht it wil not be possible to maintain adequate i O-minute 

### synchronized reserve. When Actions 14 and is are requested the paricular hours that they are to be implemented wil be specifed by the iso. Actions 14, IS~ and 16 should be 

### implemented as early as possible to achieve maximum benefit. 

### ACTION 14 (LCC responsibilty)

Request all of 

### the customer generation not contrctually available to Market 

### Paricipants. Request volunta load curilment by large industal and commercial customers.


## AClON 15 (An iso and LCC responsibilty) Initiate raio and television appeals for volunta load curilment. Implement a Power Waring.

Depending on the circumstces and the time required to institute certain of 

### the above Actions, it may be necessa to call for some Actions simultaeously~ or to 

### alter the order of initiations. When all of the above Actions have been taken,

fuer action, if 

### required, is covered under OP 7. It may be necessai to implement OP 7, prior to the implementation of all of the 

### above Actions. If~ at any time durng implementation of the above Actions, it 

### appears that implementation of OP 7 will be required; the iso shall so notify all LCCs.
Action 16 wil be implemented by the isO. When Action 16 is reuested, the paicular hour that this Action is to be implemente will be specifed by the iso. 

### ACTON 16 (An ISO responsibilty) Request New England state Governors to reinforce appeals for voluntary load curilment and the declartion ofa Power Waring~ as initiated in Action 15.

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### ISO New England Operating Procedures OP 4 - Action During A Capacity Deficiency



## n, CANCELLATION OF ACTIONS When the system conditions have improved sufficiently, the ISO will cancel the Actions instituted in Section I. above. Depending on system conditions, the order of cancellation may be different from the order of initiation.


# m. IMPLEMENTATION BY LCCS Any of the Actions provided in this Procedure may be implemented by an LCC to deal with local conditions within that LCe. The severity of the condition will determine the Actions taken. The ISO will review LCC implementation of this Procedure to ensure the implementation is consistent with Market Rule 1 and the ISO Manuals.
IV. COMMUNICATIONS The ISO Control Room Staff will use the "party line" telephone circuit to implement this Procedure. The ISO will briefly inform all LCCs simultaneously of system conditions and issue an implementation message as illustrated below. Each LeC, in alphabetical order, will repeat back the directed action to provide acknowledgment When each LCC completes a directed action, they will report back to the ISO they have completed the directed action and the implementation time of the action. These communications will be performed per the communications protocol required by NERC Standard COM-002 and as stated in SOP·RTMKTS.0125.0020 - Communicate With Internal and External Parties. Typical Messages: Implementation • ISO to all LCCs: "Implement ISO New England OP 4, Actions 1 and 2 at 0930." Each LeC to ISO: "Implement ISO New England OP-4 Actions 1 and 2 at 0930." ISO to each Lce: "That is correct." ISO to REMVEC II: "Implement ISO New England OP 4, Action 3 and Action 4 at 1030." REMVEC II to ISO: "Implement ISO New England OP-4 Actions 3 and 4 at 1030." ISO to REMVEC II: "That is correct"
• ISO to all LCCs: "Implement ISO New England OP' 4, Action 6 at 1100."

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### iso New England Operating Procedures OP 4 - Action During A Capacity Deficiency



## n. CANCELLATION OF ACTIONS

When the system conditions have improved suffciently, the iso wil cacel the Actions 

### instituted in Secion i. above. Depending on system conditions, the order of cacellation may be different from the order of initiation.

m. IMPLEMENTATION BY 

### LCCS Any of the Actions provided in this Procedure may be implemented by an LCC to deal 

### with local conditions within that LCC. The seventy of the condition will detennine the 

### Actions taken. The iso wil review LeC implementation of this Procedur to ensure the implementation is consistent with Maret Rule 1 and the iso Manuals. 

# IV. COMMCATIONS The iso Contrl Room Staff wil use the "par line" telephone ciruit to implement this Procedur. The iso wil bnetly infonn all LCCs simultaeously of system conditions and 

### issue an implementaion messae as ilusated below. Each LCC, in alphabetical order, 

### wil repeat back the directed action to provide acknowledgment When each LCC 

### completes a directed action, they wil report back to the iso they have completed the directed action and the implementation time of the action. These communications wil be 

### perfonned per the communications protocol reuir by NERC Stadad COM-002 and as stated in SOP-RTMTS.0125.0020 - Communicate With Internal and External 

### Paries. Typical Messages: 

### Implementation

. iso to all LCCs: "Implement iso New England OP 4, Actions 1 and 2 at 

### 0930." 

### Each LCC to iso: "Implement iSO New England OP-4 Actions 1 and 2 at 0930."
iso to each LCC: "That is corrt." 

### iso to REMVC II: "Implement iso New England OP 4, Action 3 and Action 4 at 1030." 

### REMVEC II to iso: "Implement iso New England OP-4 Actions 3 and 4 at 1030." 

### iso to REMVC ß: "That is correct"

. iso to all LCCs: "Implement iso New Englad OP' 4, Action 6 at 1100."

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### ISO New England Operating Procedures OP 4 - Action During A Capacity Deficiency


### Each LCC: "Implement ISO New England OP-4 Actions 6 at llO0." ISO to each LCC: "That is correct" Confinnation
• LCC (VELCO) to ISO: "ISO this is VELCO. OP 4 Actions 

### I and 

### 2 have been implemented at 1045." ISO to VELCO: "VELCO has implemented OP 4 Actions 1 

### and 2 at 1045." VELCO to ISO: "That is correct."
Cancellation
• ISO to all LCCs: "Cancel ISO New England OP 4, Actions 2 and 1 at 1200." Each LCC to ISO: "Cancel ISO New England OP-4 Actions 1 and 2 at 1200." ISO to each LCC: "That is correct" • ISO to REMVEC II: 

### "Cancel ISO New England OP 4, Actions 3 and 4 at 1300." REMVEC II 

### to ISO: "Cancel ISO New England OP-4 Actions 3 and 4 at 1300." ISO to REMVEC II: "That is correct" • ISO to all LCCs: "Cancel ISO New England OP 4, Action 6 at 1400." Each LCC to ISO: "Cancel ISO New England OP-4 Actions 6 at 1400." ISO to each LCC: "That is correct." Each LCC shall be responsible for keeping its member companies and the ISO informed of all situations pertaining to implementation and cancellation of this Procedure. The ISO will make notifications to the Department of Energy as required by ISO New England Operating Procedure No.1 0 - Analysis and Reporting of Power System Emergencies (OP 10). The LCCs will make notifications to state regulatory agencies as required. The ISO will issue a report to the appropriate Technical Committee(s) following implementation of this Procedure within 3 business days of the implementation.
V. IMPLEMENTATION OF AN ALERT The ISO Control Room staff will notify, as appropriate, the LeCs and the generation stations or designees and Dispatchable Asset Related Demands as soon as OP 4 conditions are anticipated or underway by executing its responsibilities as declared by MlLCC 2.

Revision 8, Effective Date; March 5, 2008 9 iso New England Oprating, Procdures 

### OP 4 - Action Dunng A Capacity Deficiency



### Each LCC: "Implement iso New England OP-4 Actions 6 at 1100."

iso to each LCC: "That is correct" 

### Confinnation 

### · LCC (VELCO) to iso: "iso this is VELCO. OP 4 Actions I and 2 have been implemented at 1045." 

### iso to VELCO: "VELCO has implemented OP 4 Actions i and 2 at 1045." 

### VELCO to iso: "That is correct."
Cancellation

· iso to all LCCs: "Cancel iso New England OP 4, Actions 2 and 1 at 

### 1200." 

### Each LCC to iso: "Cancel iso New England OP-4 Actions 1 and 2 at 1200." iso to each LCC: "That is correct." 

### · iso to REMVEC II: "Cancel iso New England OP 4, Actions 3 and 4 at 1300." 

### REMVC II to iso: "Cancel iso New England OP-4 Actions 3 and 4 at 1300." 

## iso to REMVC II: "That is corrt" · iso to all LCCs: "Cancel iso New England OP 4, Action 6 at 1400." 

### Each LCC to iso: "Cancel iso New England OP-4 Actions 6 at 1400." iso to each LCC: "That is correct." 

### Each LCC shall be responsible for keeping its member companies and the iso infonned

of all situations pertining to implementaion and cancellation of 

### this Procedure. The iso

wil make 

### notifications to the Deparent of Energy as reuire by iso New England Operating Procedur No.1 0 - Analysis and Reporting of Power System Emergencies (OP 10). The LCCs wil make notifications to ste regulaory agencies as required. The iso 

### wil issue a report to the appropriate Technical Committees) following implementation

of this Procedur within 3 business days of 

### the implementation.


## V. IMLEMENTATION OF AN ALERT The iso Contrl Room stff will notify, as approprate, the LeCs and the generation stations or designees and Dispatchable Asset Related Demands as soon as OP 4 

### conditions ar anticipated or underway by executing its responsibilties as declar by 

## MlCC 2.

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### ISO New England Operating Procedures OP 4 - Action During A Capacity Deficiency



### VI. PUBLIC NOTIFICATIONS Notifications associated with the forecasted or actual implementation of OP 4 will be conducted in accordance with OP 10 for Abnormal or Emergency Conditions. Power Advisories will be issued by the ISO via its external website. These Power Advisories will be triggered by the implementation of certain Actions of OP 4 as described below. These notifications are considered public information.
Power Caution A Power Caution is triggered by the initial implementation of OP 4 Action 1. A Power Caution is defined as a notification that electric reserves can no longer be maintained using normal measures. Although full reserves are being maintained, utility personnel will begin to take further steps to continue to maintain these reserves. Power Watch A Power Watch is triggered by the implementation ofOP 4 Action 9. A Power Watch is defined as a notification that further steps to manage capacity could affect the public. Power Warning A Power Warning is triggered by the implementation ofOP 4 Action 15. A Power Warning is defined as a notification for public appeals when an immediate reduction in power usage is necessary to avert overload of the electrical system. Public appeals are made when other efforts (e.g. emergency purchases, voluntary curtailment, contracted curtailment and voltage reduction) have been unsuccessful in bringing supply and demand back into balance.

OP 4 REVISION mSTORY Document History (This Document History documents action taken on the equivalent NEPOOL Procedure prior to the RTO Operations Date as well revisions made to the ISO New England Procedure subsequent to the RTO Operations Date.)

Rev. No. Date Reason Rev 0 8/21/98 Rev 1 8/26/99 Rev 2 1111102 Rev 3 06126/03 Rev 4 02101/05 Updated to conform to RTO terminolozv

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### OP 4 - Action During A Capacity Deficiency



### VI. PUBLIC NOTIFCATIONS Notifications asociated with the forecasted or actual implementation of OP 4 wil be conducted in accordace with OP 10 for Abnonnal or Emergency Conditions. Power Advisones will be issued by the iso via its external website. These Power Advisories wil be trggered by the implementation of certin Actions of OP 4 as descnbed below. 

### These notifications ar considered public informtion.
Power Caution 

### A Power Caution is triggered by the initial implementation of OP 4 Action 1. A Power Caution is defined as a notification that electric reserves can no longer be 

### maintained using nonnal measurs. Although full reserves are being maintained, utilty personnel wil begin to tae fuher steps to continue to maintain these 

### reserves.

Power 

### Watch

A Power Watch is tnggered by 

### the implementation ofOP 4 Action 9. A Power 

### Watch is defined as a notification that fuer steps to manage capacity could affect the public. 

### Power Waring A Power Waring is trggered by the implementation ofOP 4 Action 15. A Power Waring is defined as a notification for public appeals when an immedate reduction

in power usge is necessaito aver overload of 

### the electrical system. Public appeals 

### ar made when other effort (e.g. emergency purchaes, volunta curilment, contrate curlment and voltage reuction) have been unsuccessful in bnnging 

### supply and demand back into balance.



### OP 4 REVISION mSTORY Document Hitory (This Doument History documents acon taen on the equivalent NEPOOL Procur prior to 

### the RTO Opons Da as well reviions mae to the iso New England Procure subsequent to the RTO Operons Dae.)

Rev. No. Date 

### Reasn

Rev 0 8/21/98 Rev i 8/26/99

Rev 2 i 1/1/02

Rev 3 06126/03

Rev 4 02101/05 Updaed to conform to RTO tenninolo2V

Revision 8, Effecve Date: March 5, 2008 10

### ISO New England Operating Procedures OP 4 - Action During A Capacity Deficiency

RevS 05/06/05 Update for initiation of VEL CO Local Control Center and NERC Version 0 Standards Rev 6 08/05/05 Clarified that EEA notifications are done by the ISO not the LCC Rev 7 10/01106 Updated for ASM 2 Update for NST AR becoming an LCC; global change of Control Area to Control Area !Balancing Authority and defined acronym of CAlBA; global change for Local Control Center to defined acronym ofLCC; Rev 8 03/05108 revised reference documents; corrected document titles; re-worded comment prior to ACTION 11; added language addressing communication standards and procedures; added requirement for LCCs to confirm completion of Actions. Annual procedure review by Procedure Owner

Revision 8, Effective Date: March 5, 2008 11 iso New England Oprating Procedurs 

### OP 4 - Action Dunng A Capacity Deficiency

RevS 05/06/05 Update for initiation of VEL CO Local Control Center and NERC Version 0 Stadads

Rev 6 08/05/05 Clarfied that EEA notifcaions are done by the iso

not the LCC Rev 7 10/01106 Updated for ASM 2 Update for NST AR beomig an LCC; global change of Control Area to Control Area /Balancing Authority and defined acronym of CA/A; global change for Loca Control Center to defined acronym ofLCC;

Rev 8 03/05/08 revised reference documents; corrected document titles; re-worded comment pnor to ACTION Ii; added langue addressing communicaion stadards and procdures; added requirement for LCCs to confinn completion of Actons. Annual nrocedure review bv Procedure Owner

Revision 8, Effective Date: March 5, 2008 11

# Attachment 11

NY ISO Emergency Operations Manual 15 Attachment 11



# NY iso Emergency Operations

Manual 

# 15

# ~ ISD NEWYORK INDEPENDENT SYSTEM OPERATOR 

# MANUAL 15



# Emergency Operations

Manual

May 2010 

# ~ISØNEWYORK INDEPENDENT SYSTEM OPERATOR 

# MANUAL 15


# Emergency Operations

Manual

May 2010NYISO EMERGENCY OPERATIONS MANUAL



### In all ofthe following steps where additional capacity resources are being evaluated, the SS shall determine if each step is sufficient to eliminate the deficiency. In addition, all notifications made to TOs shall include approximate next-day starting time and duration associated with each curtailment step. 1. Perform an SRE Request from the Market Information System (MIS) database of unaccepted/uncommitted bids for additional Reserve for the hours specified and commit/schedule the generation. 2. Initiate an e-mail to all Market Participants requesting additional (bids) generation for the specific category required. 3. Determine the amount of energy available from external NYCA Installed Capacity (lCAP) providers that were not selected in the DAM. Count energy associated with these ICAP providers from other control areas to NYCA and NYISO Operating Reserve. Advise the affected external CA accordingly. 4. Count energy associated with external energy sales by NYCA ICAP providers as NYISO Operating Reserve, and determines if it is of sufficient quantity to eliminate the deficiency. Advise the affected external Independent System Operators (lSOs) accordingly. 5. Count NYISO Special Case Resources (ICAP) as NYISO Operating Reserve and determine if it is of sufficient quantity to eliminate the deficiency. 6. Count expected Emergency Demand Response Program (EDRP) as NYISO Operating Reserve and determines if it is of sufficient quantity to eliminate the deficiency. 7. Notify NYISO Customer Relations of Predicted day-ahead System Conditions. 8. Direct the TOs, via hot line to notify the appropriate Market Participants to be prepared for a maximum generator capability alert for the next day. 9. Notify the appropriate Market Participants to prepare to make Special Case Resources (ICAP) and EDRP resources available for the next day. 10. Notify the appropriate Market Participants to prepare to make the EDRP resources available for the next day. 11. Initiate an "Emergency Energy Alert" in accordance with Appendix 5C, "Energy Emergency Alerts" for the next day via the SCIS; follow NPCC notification requirement (C-19); and notify Communications Division, PSC, and Department of Environmental Conservation (DEC). 12. Direct the TO's, via hot line, to prepare to curtail non-essential company loads forthe next day and to notify appropriate Market Participants to prepare to curtail nonessential company load for the next day. • Direct the TOs, via hot line, to notify interruptible customers in accordance with contractual agreements to prepare to make interruptible load available for curtailment for the next day. • Direct the TOs, with Manual Voltage reduction equipment, via hot line, to prepare to initiate procedures to reduce voltage by 5% for the next day. • Direct the TOs, via hot line, to contact large industrial and commercial customers to request voluntary curtailment of load the next day.

NYISO Dispatch Operations Version 6.7 051/412010 4-5 

### NYISO EMERGENCY OPERATIONS MANUAL


### In all ofthe following steps where additional capacity resources are being evaluated, the SS 

### shall determine if each step is suffcient to eliminate the deficiency. In addition, all notifications made to TOs shall include approximate next-day starting time and duration associated with each curtailment step. 1. Perform an SRE Request from the Market Information System (MIS) database of 

### unaccepted/uncommitted bids for additional Reserve for the hours specified and commit/schedule the generation. 2. Initiate an e-mail to all Market Participants requesting additional (bids) generation 

### for the specific category required. 3. Determine the amount of energy available from external NYCA Installed Capacity 

### (ICAP) providers that were not selected in the DAM. Count energy associated with these ICAP providers from other control areas to NYCA and NYISO Operating Reserve. Advise the affected external CA accordingly. 4. Count energy associated with external energy sales by NYCA ICAP providers as 

### NYISO Operating Reserve, and determines if it is of suffcient quantity to eliminate the deficiency. Advise the affected external Independent System Operators (ISOs) accordingly. 

### 5. Count NYISO Special Case Resources (ICAP) as NYISO Operating Reserve and determine if it is of suffcient quantity to eliminate the deficiency. 6. Count expected Emergency Demand Response Program (EDRP) as NYISO 

### Operating Reserve and determines if it is of sufficient quantity to eliminate the deficiency.

7. Notify NYISO Customer Relations of 

### Predicted day-ahead System Conditions. 8. Direct the TOs, via hot line to notify the appropriate Market Participants to be 

### prepared for a maximum generator capabilty alert for the next day. 9. Notify the appropriate Market Participants to prepare to make Special Case 

### Resources (ICAP) and EDRP resources available for the next day. 

### 10. Notify the appropriate Market Participants to prepare to make the EDRP resources available for the next day. 

### 1 1. Initiate an "Emergency Energy Alert" in accordance with Appendix 5C, "Energy Emergency Alerts" for the next day via the SCIS; follow NPCC notification requirement (C- 19); and notify Communications Division, PSC, and Department of Environmental Conservation (DEC). 

### 12. Direct the TO's, via hot line, to prepare to curtail non-essential company loads forthe next day and to notify appropriate Market Participants to prepare to curtil non

### essential company load for the next day. 

### · Direct the TOs, via hot line, to notify interrptible customers in accordance with contractual agreements to prepare to make interrptible load available for 

### curtilment for the next day. · Direct the TOs, with Manual Voltage reduction equipment, via hot line, to prepare to initiate procedures to reduce voltage by 5% for the next day. 

### · Direct the TOs, via hot line, to contact large industrial and commercial 

### customers to request volunta curtailment of load the next day.

NYISO Dispatch Operations Version 6.7 05/14/2010 4-5NYISO EMERGENCY OPERATIONS MANUAL


### • Direct the TOs, via hot line, to make general radio and TV appeals to the public to request voluntary curtailment of electric power. 13. Count load reliefthat can be implemented within 10 minutes using direct load control measures as NYISO lO-minute reserve. 

### 4.4.2 Shortage Operating Reserve - In Day The SS will monitor the total operating capacity ofthe NYISO in day. The SS or his designee shall prepare the NYISO daily status report twice daily, in anticipation ofthe morning peak and evening peak load. If deficiency in Operating Reserves is still forecasted, or if Real-Time Commitment (RTC) forecasts a shortage of reserve or energy for the next hour, the SS will take the steps not taken in the DAM that time permits, to meet reserve requirements. Additionally the SS will take any or all of the following actions as required based on the category of Operating Reverse Shortage: In all ofthe following steps where additional capacity resources are being evaluated, the SS shall determine if each step is sufficient to eliminate the deficiency. In additional all notifications made to TOs shall include approximate starting time and duration associated with each curtailment step. 1. Perform an SRE Request from the MIS database of unaccepted/uncommitted bids for additional Reserve for the hours specified and commit/schedule the generation. 2. Initiate an e-mail to all Market Participants requesting additional (bids) generation for the specific category required. Declare Warning State 

### 1. Determine the amount of energy recallable from external ICAP resources that was not selected in the DAM. Count energy available from external NYCA ICAP providers from other control areas to NYCA as NYISO Operating Reserve. Advise the affected external CA accordingly. 2. Count energy associated with exports from NYCA to other control areas by NYISO ICAP providers as NYISO Operating Reserve. Advise the affected external CA accordingly. 3. Count NYISO Special Case Resources (ICAP) as NYISO Operating Reserve. 4. Notify NYISO Special Case Resources (ICAP) that they are counted toward NYISO Operating Reserves, and may be required to be activated during a specified period oftime. (Estimated start and end time as announced.) 5. Count NYISO EDRP as NYISO Operating Reserves. 6. Notify EDRP that they are counted toward NYISO Operating Reserves, and may be requested to be activated during a specified period of time. (Estimated start and end time as announced.) 7. Notify NYISO Market Relations of predicted system conditions. 8. Notify the TOs, via hot line, to notify Market Participants to be prepared for a maximum generator capability alert for the day and direct all Market Participants to follow basepoints.

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### NYISO EMERGENCY OPERATIONS MANUAL



### . Direct the TOs, via hot line, to make general radio and TV appeals to the 

### public to request voluntary curtilment of electric power. 13. Count load reliefthat can be implemented within 10 minutes using direct load 

### control measures as NYISO lO-minute reserve.


### 4.4.2 Shortage Operating Reserve - In Day The SS wil monitor the total operating capacity ofthe NYISO in day. The SS or his designee shall prepare the NYISO daily status report twice daily, in anticipation ofthe 

### morning peak and evening peak load. If deficiency in Operating Reserves is stil forecasted, 

### or if Real-Time Commitment (RTC) forecasts a shortge of reserve or energy for the next hour, the SS wil take the steps not taken in the DAM that time permits, to meet reserve

requirements. Additionally the SS wil take any or all of 

### the following actions as required 

### based on the category of Operating Reverse Shortge: In all ofthe following steps where additional capacity resources are being evaluated, the SS shall determine if each step is sufficient to eliminate the deficiency. In additional all 

### notifications made to TOs shall include approximate starting time and duration associated with each curtailment step. 1. Perform an SRE Request from the MIS database of unaccepted/uncommitted bids 

### for additional Reserve for the hours specified and commit/schedule the generation. 2. Initiate an e-mail to all Market Participants requesting additional (bids) generation 

### for the specific category required. Declare Warning State 

### 1. Determine the amount of energy recallable from external ICAP resources that was 

### not selected in the DAM. Count energy available from external NYCA ICAP 

### providers from other control areas to NYCA as NYISO Operating Reserve. Advise 

### the affected external CA accordingly. 2. Count energy associated with exports from NYCA to other control areas by NYISO 

### ICAP providers as NYISO Operating Reserve. Advise the affected external CA accordingly. 

### 3. Count NYISO Special Case Resources (ICAP) as NYISO Operating Reserve. 4. NotifY NYISO Special Case Resources (ICAP) that they are counted toward NYISO Operating Reserves, and may be required to be activated dunng a specified 

### penod oftime. (Estimated start and end time as announced.) 5. Count NYISO EDRP as NYISO Operating Reserves. 6. NotifY EDRP that they are counted toward NYISO Operating Reserves, and may be

requested to be activated during a specified period of 

### time. (Estimated start and end 

### time as announced.) 

### 7. NotifY NYISO Market Relations of predicted system conditions. 8. NotifY the TOs, via hot line, to notifY Market Participants to be prepared for a 

### maximum generator capabilty alert for the day and direct all Market Participants to follow basepoints. 

# 4-6 NYISO Dispatch Operations
Version 6.7 05//4/20/0NYISO EMERGENCY OPERATIONS MANUAL


### 9. Initiate an "Emergency Energy Alert" in accordance with NERC Appendix 5C, "Energy Emergency Alerts" for today via the SCIS; follow NPCC notification requirements (C-19); and notify Communications Division, PSC, and DEC. 10. Direct Market Participants to activate Special Case Resources (lCAP) to start at XXXX hrs and end at XXXX hrs. 11. Direct Market Participants to activate EDRP to start at XXXX hrs and end at XXXX hrs.
Declare Alert State 

### 1. Direct the TOs, via hot line, to curtail non-essential company loads and to notify appropriate Market Participants to curtail non-essential company loads. • Direct the TOs, via hot line, to curtail interruptible customers in accordance with contractual agreements. • Direct the TOs with Manual Voltage reduction equipment, via hot line, to begin procedures to reduce voltage by 5%. • Direct the TOs, via hot line, to contact large industrial and commercial customers to request voluntary curtailment of load. • Direct the TOs, via hot line, to make general radio and TV appeals to public to request voluntary curtailment of electric power. 2. Count load reliefthat can be implemented within 10 minutes using direct load control measures as NYISO 10-minute reserve. 

### 4.4.3 Shortage Operating Reserve - Real Time TheSS will monitor the total Operating Reserve of the NYISO using the Real-Time Dispatch programs. IfRTC forecasts a shortage of reserve or energy for next hour, the SS will count external ICAP available, SCR and EDRP as time permits to take any ofthe following steps that have not already been taken. Additionally, the SS will take any or all of the following actions as required based on the category of reserve shortage:
Declare Alert State 

### 1. If deficient of 10-minute reserve, direct all Market Participants to convert 30- minute reserve to energy or 10-minute reserve. 2. If deficient of 10-minute synchronized reserve, direct all Market Participants to convert 10-minute non-synchronized reserve to energy or 10-minute synchronized reserve. Declare Major Emergency 

### Direct TOs, via hot line, to notify the appropriate Market Participants that the NYISO has gone to a maximum generator alert and to make all generator capability available. 1. Recall external energy sales made by NYCA ICAP providers. 2. Notify the appropriate Market Participants to activate NYISO Special Case Resources (ICAP) if possible.

NYISO Dispatch Operations Version 6.7 051/4120/0 4-7 

### NYISO EMERGENCY OPERATIONS MANUAL

9. Initiate an "Emergency Energy Alert" in accordance with NERC Appendix 5C, 

### "Energy Emergency Alerts" for today via the SCIS; follow NPCC notification requirements (C-19); and notify Communications Division, PSC, and DEC. 

### 10. Direct Market Participants to activate Special Case Resources (lCAP) to start at XXXX hrs and end at XXXX hrs. 

### 11. Direct Market Participants to activate EDRP to start at XXX hrs and end at XXXX hrs. Declare Alert State

i . Direct the TOs, via hot line, to curtail non-essential company loads and to notify 

### appropriate Market Participants to curtail non-essential company loads. 

### · Direct the TOs, via hot line, to curtail interrptible customers in accordance with contractual agreements. 

### · Direct the TOs with Manual Voltage reduction equipment, via hot line, to begin procedures to reduce voltage by 5%. 

### · Direct the TOs, via hot line, to contact large industrial and commercial customers to request voluntary curtailment of load. 

### · Direct the TOs, via hot line, to make general radio and TV appeals to public to 

### request voluntary curailment of electric power. 2. Count load reliefthat can be implemented within 10 minutes using direct load 

### control measures as NYISO 10-minute reserve.


### 4.4.3 Shortage Operating Reserve - Real Time

TheSS wil monitor the total Operating Reserve of 

### the NYISO using the Real-Time

Dispatch programs. IfRTC forecasts a shortge of 

### reserve or energy for next hour, the SS 

### wil count external ICAP available, SCR and EDRP as time permits to take any ofthe following steps that have not already been taken. Additionally, the SS wil take any or all of 

### the following actions as required based on the category of reserve shortage:

Declare Alert State

1. If deficient of 10-minute reserve, direct all Market Participants to convert 30- 

### minute reserve to energy or 10-minute reserve. 2. If deficient of 10-minute synchronized reserve, direct all Market Participants to 

### convert 10-minute non-synchronized reserve to energy or 10-minute synchronized reserve. Declare Major Emergency 

### Direct TOs, via hot line, to notify the appropriate Market Participants that the NYISO has gone 

### to a maximum generator alert and to make all generator capaQilty available.

1. Recall external energy sales made by NYCA ICAP providers. 2. Notify the appropriate Market Participants to activate NYISO Special Case 

### Resources (ICAP) if possible.

NYISO Dispatch Operations Version 6.7 05/14/2010 4-7

# Attachment 12

NYISO: Called Events & 

# Tests 

# Attachment 12



# NYISO: Called Events & TestsNYISO - Called Events & TestsTHRU2/17/10*~-~7b~1~~~t~~-~~~~j:":.. /End.·Zone,.-..;~..;.-.,-~-----....,.--~-~--~-~.•.----A-----r----B-----·----C-----~-----D-----r-----E-----T-----i=-----r----'G-----r-----H-----·-----T-----·-----j-----~-----K----[)~tE:! ....yTimE:!SCRlEDRP EventSn/2001 1S:00Sn/2001I19:00YesYes YesYes YesYesIYesYes Yes YesYesIIIISCRlEDRP EventS/S/200113:00S/S/2001I17:00Yes Yes YesYesYes YesIYes YesYes Yes YesIIIISCRlEDRP EventS/9/200111:00S/9/2001I19:00YesYes YesYesYes YesIYes YesYes Yes YesIIIISCRlEDRP EventS/10/200113:30 S/10/2001I1S:00YesIYesYes YesYes YesISCRTest12/1S/200117:0012/1S/2001I1S:00YesYes Yes YesYesYes YesYes YesYes YesIISCRTest2/261200216:002/26/2002I17:00Yes YesYes YesYesYes YesYes YesYes YesISCRTest3/12/200216:003/12/200217:00YesYes Yes YesYesYes YesYes YesYes YesSCRlEDRPEvent4/171200212:004/17/20021S:00YesYes YesYes YesSCRlEDRPEvent4/1S/2002 12:004/1S/20021S:00Yes YesYes YesYesSCRlEDRP Event7/30/200213:007/30/20021S:00YesYes YesYes YesIYes YesYes YesYes YesSCRlEDRP EventS/14/200213:00S/14/20021S:00YesYes YesYes YesIYesYes Yes YesYes Yes!SCR Test6/19/2003I13:006119/200314:00YesYes YesSCRTest6/20/200313:006/20/200314:00Yes YesYes YesYesIYesIYesYesIIIISCRlEDRP EventSI1S/20039:00S/1S/200323:00YesYes YesYes YesIYesIYesYesIYesIYes;YesIIIIIIIIIYesYesIYesIYesYesIYesIYesIYesSCRlEDRP EventS/16/200312:00S/161200320:00Yes YesYesIIIIIIIIIISCRTest1/27/200413:001/27/2004I14:00YesYes YesYesISCR Test1/2S/200413:001/2S/2004I14:00YesIIiiiiiSCR Test1/29/200413:001/29/2004I14:00YesYesYes YesYesYesI!!I·ISCR Test3/19/200413:003/19/2004.14:00Yes•ISCR Test3/2S/200413:003/2$12094I14:00YesYesiYesIYesSCR Test3/301200413:003/30/2004I14:00YesYesIYesIYesYesiYesIII!I·ISCR Test5/251200413:005/25/2004I14:00YesYesIYesIYesIISCR Test5/27/200411:005/27/200412:00YesSCR Test5/27/200413:005/2712064.14:00YesYesiYes YesYesiYesII7/28/2()04IISCR Test7/2S/2004I13:0014:00YesYes•YesYesYesIYesI·7/29/2004ISCRTest7/29/2004i13:0014:00Yes Yes·YesYesYes•SCRTest9/21/2004I13:009/21/200414:00Yes YesIYesYes YesiYes•YesIYes•YesIYesIYesIIIIIIIIIIIIISCR Test1/13/200516:001/t31200517:00YesYesIIIIIIIYesI•IIII!··.IIISCRTest1/14/200513:001/14/200514:00IYesYesYesIYesIYesIYesIYesIYesI!!!!!ISCR Test3/30/200513:003/361206s14:00Yes YesIYesYes YesIISCR Test3/30/200S 14:003/30/20051S:00IiYesiYesiYesiYesiYesiYes!·I·II.SCRTest5/17/200511:00S/111200S12:00YesSCR Test5/17/200513:005/17/200514:00iiYesiYesiYesiYesiYesIYesIIIIIIIISCRTest5/17/200514:005/171200515:00YesYesYesIYesIIIiiIIIISCRlEDRPEvent7/27/200514:007/27/2005I1S:00IYes YesYesYesYesII•!!!!!IIISCRTestS/25/200514:00S/25/2005r15:00Yes YesYesYesIYes•Yes!SCRTest4/5/200613:004/5/2006I14:00YesYesYes YesYesSCRTest4/6/2006I14:00IYesIYes·YesiYesiYesiYes4/6/200613:00IIIIIIIIIIIIIII·IYesIYesSCRlEDRP Event7/1S/200613:007/1S/2006I22:00IIIYes•YesIIIIIIIIIIIIIISCRlEDRP Event7i19/200610:007/19/200619:00IIIIIYesIIIIIIII•IISCRlEDRP EventS/1/200614:00S/1/2006I19:00IIIIIYesiYesIIIIIIIIIIIIISCRlEDRP EventS/2/200613:00S/2/2006I19:00IIIIIYesIYesIIIIIIISCRlEDRP EventS/2/2006I14:00S/2/2006I19:00YesYesYesISCRlEDRP EventS/3/2006I13:00S/3/2006I19:00iIIIIIIYes.YesIIIII!!!!!!Page 10f 2NYISO - Called Events & TestsTHRU2/17/10*~-~7bái~~~t~~-~~éJ~j:'....../End.'Zone,.-~~~~-..-..----_....--~-~--..-~..----A-----r----Š-----.----ë-----~-----Õ-----r-----E-----.-----¡=-----r----G-----r-----i=-----.-----ï-----.-----j-----~-----K----. . .Oste . .+ ,TimeSCRlEDRPEvent8n/200115:008n/2001i19:00YesYes YesYes YesYesiYesYesYes YesYesiIIiSCRlEDRPEvent8/8/200113:008/8/2001i17:00YesYes YesYesYesYesiYes YesYesYesYesiIIiSCRlEDRPEvent8/9/200111:008/9/2001i19:00YesYes YesYesYesYesiYes YesYes Yes YesiIIiSCRlEDRPEvent8/10/200113:308/10/2001I18:00YesiYesYes YesYes YesiSCRTest12/18/200117:0012/18/2001i18:00YesYes Yes YesYesYes YesYesYesYes YesiiSCRTest2/26/200216:002/26/2002i17:00YesYesYes YesYesYes YesYesYesYes YesiSCRTest3/12/200216:003/12/200217:00YesYesYes YesYesYesYesYesYesYes YesSCRlEDRPEvent4/171200212:004/17/200218:00YesYesYesYesYesSCRlEDRPEvent4/18/200212:004/18/200218:00YesYesYes YesYesSCRlEDRPEvent7/30/200213:007/30/200218:00.. YesYesYesYesYesiYesYesYesYesYes YesSCRlEDRPEvent8/14/200213:008/14/200218:00YesYesYesYes YesiYes YesYes YesYesYes!SCRTest6/19/2003 i13:006119/200314:00YesYes YesSCRTest6/20/200313:006/20/200314:00YesYesYes YesYesiYesiYesYesiIIiSCRlEDRPEvent8115/20039:008/15/200323:00YesYes YesYesYesiYesiYesYesiYes,Yes;YesiIIIIIIIIYesYesiYesiYesYesiYesiYesiYesSCRlEDRPEvent8/16/200312:008/161200320:00YesYesYesiIIIIIIIIiSCRTest1/27/200413:001/27/2004i14:00YesYes YesYesiSCRTest1/28/200413:001/28/2004I14:00YesiIiiiiiSCRTest1/29/2004 13:001/29/2004i14:00YesYesYesYesYesYesi!!i.iSCRTest3/19/200413:003/19/2004i14:00YesiiSCRTest3/25/200413:003/2al2094i14:00YesYesiYesiYesSCRTest3/301200413:003/30/2004I14:00Yes YesiYesIYesYes¡YesiiI!iIiSCRTest5/251200413:005/25/2004i14:00YesYesiYesiYesi!SCRTest5/27/200411:005/27/200412:00YesSCRTest5/27/200413:005/2712ÖÓ4.14:00Yes YesiYes YesYesiYesii7/28/2004iiSCRTest7/28/2004 i13:0014:00Yes YesiYesYesYesiYesii7/29/2004iSCRTest7/29/2004 i13:0014:00Yes YesiYesYes YesiSCRTest9/21/2004 I13:009/21/200414:00Yes YesIYesYesYesiYesiYesiYesiYesiYesiYesiIIIIIIIIIIIiSCRTest1/13/200516:0011t3/200517:00YesYesiIIIIIIYesiIIIII!iI.IIiSCRTest1/14/200513:001/14/200514:00iYesYesYesiYesiYesiYesiYesiYesi!!!!!iSCRTest3/30/200513:003/30/200514:00YesYesiYesYesYesiiSCRTest3/30/200514:003/30/200515:00iiYes¡Yes¡Yes¡YesiYesiYes!.i,IIiSCRTest5/17/200511:005/111200512:00YesSCRTest5/17/200513:005/17/200514:00¡iYesiYesiYesiYes¡YesiYesiIIIIIIiSCRTest5/17/200514:005/17100515:00YesYesYesiYesiIIíiiIIiSCRlEDRPEvent7/27/200514:007/27/2005i18:00iYesYesYesYesYesiI.!!!!!iIiSCRTest8/25/200514:008/25/2005r 15:00Yes YesYesYesiYes.Yes!SCRTest4/5/200613:004/5/2006i 14:00YesYesYes YesYesSCRTest4/6/2006i14:00iYes,YesiYeslYes¡Yes¡Yes4/6/200613:00iiIIIIIIIIIIIIIIIYesiYesSCRlEDRPEvent7/18/200613:007/18/2006i22:00iiIYesiYesiIIiIIIIIIIIIiSCRlEDRPEvent7i19/200610:007/19/200619:00iiIIIYesiIIIIIIIIIiSCRlEDRPEvent8/1/200614:008/1/2006i19:00iiIIIYesiYesIiIIIIIIIIIIiSCRlEDRPEvent8/2/200613:008/2/2006i19:00iiIIIYesiYesiIIIIIiSCRlEDRPEvent8/2/2006I14:008/2/2006i19:00YesYesYesiSCRlEDRPEvent8/3/2006i13:008/3/2006i19:00¡iIIIIIYes,YesiIiII!!!!!!Page 10t 2SCRSCRSCRTDRPTDRPSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRTestTestTestEventEventTestTestTestTestTestTestTestTestTestTestfe.StTestJ't;l$.tTestTE;lslTestTestTest'TestTestfest1"e$(9/13/20061 13:00411$/2007111:0D4/13/2007i13:007:!191aQ07!~:QO8/3/2007j19:301q/1~jgQQ7'i11:0010/18/20071 13:00~,"2*i~()()81"11:DD3/~7/2gq~ 113:009j2?J20b~cltJ:()O9/25/20()8 113:00"4Y2~)200~;11Q:004/23/2()09I11:004/23120691"· 12:064/23/20091 13:007i2$/~q()9·1 10;007128/2009I11:00········712.alZ()()s·'11,2:007/28/2009 113:00.tJZ8121109114!OOT011$12Qilg;,1 11:0.02113/2010I10:00~~tiI2(}jQI.;1():()02117/20101 11:002!'~:1r~~1;()'1,'·•·.•·~.?:P9fl,1?!2P1Q .113:00'2Z;!C71t~.!M·c9!14:00.~~----Da~e~J§!l~i!r-~Tlme~Zone----A----r----B---~T----c----T----D----r----E----T----F"---T----G----r----A----T----r---T----j""--T----R----Yes,Yes,Yes,Yes,,,,Yes,Yes,Yes,Yes,Yes,Yes,,,,!ii,,,,Yes,Yes,Yes,Yes Yes,,,,!!,,,,,,,!!!,,J3'j8.Yes, ,YesIYesiYesYes,,Yes,,!!II,YesiYesiYesiYesiYesi,I,.I,,,,,,IYesYesYesYesYesYesll!!!!YesIYes,YesiYesiYes!,,II,I.I.I,,IIYesYesYesYesYes!YesI,,,l,I,II,,Yes.Yes,Yes,Yes,Yes,,!!I,Yes,Yes,!,I,YesiYes,,,,,iYesiYesiYesiYesiYes,,,,II,I,I,II,I,ii,,,,,,,YesYes,l!!!!,I,,Yesi,I,IYes,YesII,IYes.,,I,IiYesiYesiYesiYesiYes,,I,..YesiYesIYes!Yes.YesIYes,Yes,YesiYesiYesiYesYes,YesI!,,,,I,!!!II.YesYesi,IIYesIYes.Ii.,Yes!YesYesYesYesYesYes9/13/2006 14:004/13/2007 12:004113/2007 14:007119/2007 23:008/3/2007j23:5910Ji8/2()D7!12:00.. ,-".", " ,,,. I.10/18/2007I 14:003/2i(zQQ8 112:003/27/2008114:0091251Z0Q8112:009/25/20081 14:004!2;31~()09i.it:po4/23/2009I12:00412~/2Q09;i13:004/23i20()9!14:007j2~{:?0()SI11:DO7/28/2009!12:007/2~/2Qi}$!lS:D()7/28/2009!14:00"i12~t2()()9115(QO~-.--..',- ..,.-~ ',":- -.::, ....-:--,' ,'I ..,;-, ".,.: "',1.01151~()09 . , .12:002/13/2'01'6I11:00g/17i?q1olff:po2/17/2010I 12:00.gli"il:glMpi'13:.0012117/2010!14:002/1712(:110!1.1$;00Page 2 of2Zone--~-jr---r----a---~T----e----T----õ----r----E----T----¡=---T----G----r----A----T----r---T----T--T----¡C--YesiYesiYesiYesiIIIYesiYesiYesiYesiYesiYesiIII!íiiIIIYesiYesiYesiYesYesiIII!,IIIIIII!!,IiJ3'j.YesiIYesiYesiYesYesiIYesiI!,IIIYesiYesiYesiYesiYes¡iII.IIIIIIIIYesYesYesYesYesYesi!!!!!YesiYesiYesíYesjYes!iIIIII.IIIIIIIYesYesYesYesYes!YesiIIIiIIIIIIIYes.YesiYesiYesiYesiII!iIYesiYesi!iIIYesiYesiIIIIiYesiYesjYesiYesíYesiIIIIIIIIIIIIIIIíiiIIIIIIYesYesii!I!!iIIIYesíiIIIYesiYesiIIIYes~ iIIIIIYes¡YesIYes¡Yes¡YesiIII..YesiYesiYes!Yes.YesiYesiYesiYesiYesiYesiYesYesiYesiIiIIIII!!!iI.YesYes¡iIIYesiYes.i¡IIYes!YesYesYesYesYesYesSCRSCRSCRTDRPTõSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRSCRTestTestTestEventËVTestTestTestTestTestTestTestTestTestTestfêstTestreslTestTøslTestTestTest~TestTestfest,-esf9/13/2006411?lgpOt4/13/20077:!19/ãOQl8/312007lÇ/1$/gQQ7~10118/2007~~27/~p(jŠ31271200891?~~Qnß9/25/2008..4Y2~lgQQØ4/23/2009ttigal~Ppe4/23/20097¡2ß/~l:jØ97/28/2009........'7'lg.sk~Øt'$.7/28/2009~tj21'Ó1121131201041l7!gQ1Q2i1iì2ó1ó2!~:11g~~;r:2117'i2010.21ilZigt'hg13:001MO13:00S;QQI 19ji1:001 13:00i .'1i:ooi/13:00:lt1:00113:00'11Ò:po1 11:00j 12:ÖÓ! 13:00.!1Ó:OOI 11:0011;2:PØj 13:00J14tooö,j 11:Ö.o! 10:001,....;..-;...,.;.,...1'10:00i11:00i '.~.?:PQI 13:00/14:00l1/1 ,)/ ¿006 I4/13/2007 i411312007 !7119/200718/3/200710íjS/2QQ710/18/20073/2itlQQa3/27/20089/25/20089/25/20084!2ßl~()OØ4/23/200941?~i?Oo:ø4/23/2009'¡iisl:?óp$7/28/20097Î21312QQG7/28/2009il2šJ2Ò091¡jh1.ak?,gp~2/13/2010~¡17i2Øl02/17/2010.gilt!:?Q1p12117/20102iii12Gi1QIII!iIIiiI¡1iIJIi!!iiIiIIIiiiIiIPage 2 ot2

# Attachment 13

PJMZoneMap 

# Attachment 13



# PJMZoneMapLegend PJM Zone Allegheny Power American Electric Power Co., Inc. Atlantic City Electric Company Baltimore Gas and Electric Company Commonwealth Edison Company Delmarva Power and Light Company Duquesne Light Company Jersey Central Power and Light Company Metropolitan Edison Company PECO Energy Company PPL Electric Utilities Corporation Pennsylvania Electric Company Potomac Electric Power Company Public Service Electric and Gas Company Rockland Electric Company The Dayton Power and Light Co. Virginia Electric and Power Co.

# Attachment 14

ISO New England 2011 Emergency DR Dispatch Zones 

# Attachment 14

iso New England 2011 Emergency DR 

# Dispatch Zones

## Copyrighted page/s removed. Copyrighted ma terial is not available in Regulations.gov since it may not be reproduced without consent of the copyright holder. Contact the EPA Docket Center’s P ublic Reading Room to view or receive a copy of this document. Requests for copies may be made as follows: In person/writing: Environmental Protection Agency, Docket Center 1301 Constitution Ave NW, 2822T, Room 3334 Washington, DC. 20004 Telephone: 202-566-1744
Fax: 202-566- 9744
Email: docket-customerservice@epa.gov

# Attachment 15

Comments on Proposed Rule, National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines, Submitted by DRSP Coalition, May 29, 2009 Attachment 15

Comments on Proposed Rule, National Emission 

# Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines, Submitted by DRSP Coalition, May 29, 2009

### CO~ ON PROPOSED RULE National Emission Standards for Hazardous Air Pollutants for Reciprocating Intemal Combustion Engines
Docket ID No. EPA-HQ-OAR-2008-0708 

### May 29, 2009

On March S, 2009 the Environmental Protection Agency (,"EPA,,) proposed JUltional emission standards fur hazardous air pollutants, for existing stationary reciprocating internal combustion engines ("RICE,,)l that are located at area sources of hazardous air pollutant emissions. or that have a site rating of less or equal to 500 brake horsepower and are located at major sources of hazardous air pollutants. The EPA asked for, and seeks, public participation in arriving at its final decision, and strongly encouraged comments on all aspects of the proposed rules from all interested parties. The below demand response service providers, whom operate throughout the U.S. and Canada, respectfully submit the following comments. Demand Response Service Providers ("DRSP Coalition") . Innoventive Power, LLC. CPower, Inc.
The DRSP Coalition has a strong interest in the National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines proposed rules. The proposed NBSaAP rules have a number of proposed areas that concern the· DRSP Coalition, which are outlined in the below comments.

Comment 1- Section 

### VIL-Statutory and Executive Order, (H) Executive Order 13211: Actions Concerning Regulations That Significantly Affect Energy Supply, Distribution, or Use:

I 

### Auacbmeot 1. Terminology DcfiDitioos



## COMM ON PROPOSED RULE 

## National Emion Stada for Hazous Air Pollut for 

## Reiprng In Combuon Engin

Doke ID No. EPA-HQ-OAR-200S-Q70S

May 

### 29,2009 

### On Mah S, 2009 the Envinmenta Protetion Agency ('EPA") prpose 

# JUona emion stda fur haous ai pollutats, for existg stona reiprog inte combon engine ("RICE'')l that ar locte at ar sour of

haous air pollut emissions, or th have a site rag of less or equa to 500 bra horswer an ar loc at major sowces of hazous ai pollutts. The EPA ased 

## for, and seks public paicipaon in arvin at its fial deision. and stngly enur 

## comments on all asts of the propose rules frm al intere pas. The below 

## demd rens sece providers, whm ope thugout the U.S. an Ca
iey subm the followig comment. 

### Demand Rens Serce Prviders ("DRSP Coaltion")

, Imvenve Powe, LLC. CPowe, In. 

## Th DRSP Coon ha a st inte in the Natona Emission Stada for
Haous Air Pollut for Recipro Intern Combuson Engies propo rues. 

## The prpo NBRA rues have a numbe of prpo ar that conc the. DRS Cotion, whch ar outined in the below corments.


# Comm 1. Sen VI.St and Executve Orer, (H Execute Orer 13211: 

# Act Co Retion Th Signcatly Afec Ener Suply, Distbuon. or Use: 

# i Auaeo i. Tcrog Dc

### Under section VII, Statutory and Executive Order the proposed rule states the following, "This action is nota "significant energy action" asdefmed in Executive Order 13211, because it is not likely to have a significant adverse effect on the supply, distribution, or use ofenergy." The DRSP Coalition believes the proposed rule, will have a significant negative impactupon the supply of energy. Through demand response program participation nonemergency RICE units are valuable resources in minimizing and/or preventing power grid disruptions that lead to system-wide brown-outs and black-outs, which can and have occurred in the highly populated Northeast U.S. Additionally, the number of operating hours for which these engines actually run, to provide this safety net to f4e public, is quite small. The DRSP Coalition demonstrates below that the most active RTO demand response program has averaged around 16 hours of operating participating, for these RICE units, per year. Should the proposed Rule be adopted without change, it will have a significant impact on RICE units. RICE units 'were installed to supply emergency backup service to support the reliability of the facilities' energy s~pply, within their locality. Not only do these RICE units provide their own energy supply reliability, but a sub-set of these units also participates in regional capacity markets to support the reliability of the regional transmission system. RICE units, which participate in demand response programs administered by ISOIRTOs, will be negatively affected by the proposed Rule should the Rule make it necessary to retrofit HAPS control technology. Retrofitting these units Will be the only way to allow RICE units the ability to continue their participation in ISOIR1'O capacity markets. More importantly, the ISOIRTOs will be adversely affected by the proposed rule. ISOIRTO's have modeled into their Reliability Studies, and built into the Resource Plauning analysis, planned participation by these demand response ·resources. Should RICE units incur the additional costs associated with installation of HAPS control technology many of the RICE units will opt out of demand response programs, which will leave ISOIRTO's with critical missing demand response resources. Without the inclusion of RICE resources, for demand response, many ISOIRTO's will have less available I'eSOUlCeSto tap during critical peak energy days, leaving ISOIRTO's with inadequate reliability. The DRSP Coalition proposes that this proposed Rule be modified to enable RICE units to participate in demand response programs, which support fP,e reliability of ISOIRTO's capacity markets. The DRSP Coalition's proposed Change would modify the ruleas follows:
Delete the text in Section 

# m, Summary of This Proposed Rule, Sub-Section E, What are the Reporiing and Recordkeeping Requirements?, page 9, of the proposed Rule, which states the following: "In addition, owners and operators are allowed to operate their stationary emergency RICE for non-emergencypurposes for SO hours per year, but those 50 hours are counted towards the tota1100 hours provided for operation other than for true emergencies and owners and operators may not engage in income-generating activities during those 50 hours." 

## Und seon VI, Stary and Executve Orer the propose nde stte the followig,

"Ts action is nota "signcat energy action" asdefmed in 

### Executve Orer 1321 I, 

### be it is not likely to have a signifcat advers effec on the supply, distributon or us ofenerg." 

## The DRSP Coition believes th propose rue, wi have a signcat negative imup th suply of energy. Thugh demad repons progr pacipation nonemerency RICE unts ar valuale reur in minmig and/or prventi power grd dions tht lea to systm-wide brown,.ut and blak-out, which caand have 

## oc in the highy populat Nor U.S. Additionly, the numbe of opeti hour for whch thes engies acy rt to prvide th saety net to f4e public, is quite sm. The DRSP Coaition demonsat below tht the mos aeve RTO dean re pr has averged ard 16 hour of opeg pacipatig, for these RICE 

# un pe yea.

Should the prpose Rue be adopt 

## withut chae, it wil have a signifcat imact ón RICE un. RICE unts 'were inled to supply emrgecy ba serce to sup the 

## reliilit of th facilties' energ sllpply, wi their locty. Not only do thes RICE 

## un prvide their own ener suply reßabilit, but a sub-set of the unts also pacipa in regiona caacity mats to suport the reliabili of th regiona trion syst RICE unts whch pacipa in demad rense progr 

## ad by ¡SOIRTOs, will be negatively afecte by the propo Rue should the 

## Rule ma it necesar to retrfit HAS contl tehnolog. Retfittng thes unts Will be th ony way to alow RICE unts the abilit to contiue their parciption in ISOlRtO 

## ca makets. 

# Mor ùnrty, the ISOIRTOs will be advely afec by the prse rule. ISOIRTO's have moled into thir Relibilty Studies and built in the Resou 

# Plag anysis, plaed paicipaton by thes ded ree ,reurs. Shoul RICE unts incur the adona cots asiat wi inon of HA contrl 

## telogy may of the RICE unts wi opt ou of demd rense pro which wil leae ISOIRTO's wi crtica miss ded ree resour. Witut th inluion 

### of RICE reou for ded re, may ISOIRTO's wi have les avble re to tap du cntica pe energ das, leavin ISOIRTO's with inadua 

# reliil. Th DRSP Coon prpo tht th prpose Rule be moded to enble RICE ui to 

## paci in ded repons prgr whch suprt tle reliabilit of ISOIRTO's ca maet Th DRSP Coation's prse mange would modi the ru.as follows:

Delet 

### th te in Seon m, Sum of Th Prpose Rule. Sub-Secion E, Wh ar 

# th Re an Rerdeein Rets?, page 9, of the prose Ru, whh st the followi 

## "I adition, ow and opetors ar allowed to opete thir stna emergecy RICE 

## for non-gecypu for SO hour pe yea. but those 50 hou ar counte towar th tota100 hour prvide for opon other th for tre emerencies an owner and operars may not engage in incomegeerg acvities dug those 50 hour."

### The DRSP Coalition requests that the deleted textbe replaced with the following: "In addition, owners and operators are allowed to operate their stationary emergency RICE for non-emergency purposes for 50 hours per year, but those 50 hours are counted towards the total 100 hours provided for operation other than for true emergencies.and owners and operators may not engage in income-generating activities during those 50 hours. Notwithstanding the preceding text, hours of operation. in response to activation calls from an ISOIRTO organization, ele~o power delivery company, and demand response programs, are not counted toward the total 100 hours provided for operation other than for true emergencies. Tests called as part of participation in such demand response programs shall be counted towards the 100 hours provided for operation other than for true emergencies," Impacts associated with the proposed Rule, should the DRSP Coalition proposed change not be made, are out1ined and discussed below.
IMPACT OF THE RULE IF THE PROPOSED CHANGE IS NOT MADE RICE units participate in Demand Response programs administered by the NYISO, ISONE, PJM and ERCOT. These ISOIRTO's manage the bulk electric power transmission system(s), which supply more than 100,000,000 people with reliable supply and delivery of electrical power. lSOIRTO's markets, with the active encouragement of Federal Energy Regulatory Commission (FERC), have initiated demand response progtams that allow these resources to participate in their capacity markets, including the use of on-site RICE units, to support the reliability of the regional transmission systems. The primary reason for creation of these Demand Response programs, is to ensure ISOIRTO's have sufficient capacity available to meet their electric reliability goals. RICE units that participate in regional ISOIRTO's capacity markets provide critical support for these regional transmissi()n systems, and assist them in maintaining reliability. ISOIRTO's embed the participation of RICE units which in some cases enables the delay of new electric peaking power plant construction. PERC bas been a strong influence in the creation of these demand response programs. administered by ISO/RTO's organizations, which enable RICE units to participate in the regional capacity markets. In addition, local electric delivery networks have created d~d response programs within their service ·tenitory to support their service territory electric reliability, that allow RICE units to participate within these programs. The DRSP Coalition will demonstrate below, that this vital demand response service does not entall a significant number of operating hours. RICE units receive reservation payments for agreeing to provide support to ISOIRTO's electric transmission and distribution n~ in the event of system emergencies. RICE units operate, not only infrequently, but except for testing, only during electric power system emergencies, when there are insufficient conventional reserves to support the reliability of the ISOIR1O's networks. These units often operate to supply power, which would otherwise have been supplied by conventional sources, in the absence of the electric power system emergency. The DRSP Coalition reest tht the delet textbe replac with the followig: 

### "In addition, owner and opetor ar allowed to opete their stona emergency RICE for non-merncy purses for 50 hour per yea, but those 50 hour ar counte towa 

### the tota 100 hour provided for opeon oth than for tre emercies ,an owner and 

## òpe may not engage in income-genering acvities durg those 50 hour. 

## Notwding the preng te hour of opeon. in respo to acvation cas frm an ISOIRTO organon, eleçto power deliver company, and demad respons prgr, ar not counted towa the tota 100 hour prvided for opeon other th for 

## tre emerencies. Tes caled as pa of parcipation in such demd respons prgr shall be counte towa th 100 hour prvided for opion oth th for tre 

### eiergencies. "
Impa assoiate wi the prpose Rule, should the DRSP Coaition proposed chage 

### not be ma ar outed and discus below. IMACT OF TH RULE IF TH PROPOSED CHAGE IS NOT MAE

## RICE units parcipa in Deand Resns prgr adsterd by th NYSO, isoNE PJM and ERCOT. Thes ISOIRTO's maag the bu electrc power trision 

## sym(s), whch suly more th 100,00,00 people wi reliable suply an deliver

of electrica powe. lSOIRTO's makets with th actve encurment of 

# Fede Ene Reguatry Common (FC), have initat delnd respnse progt th allow

thes reour to parcipate in thir caacit market, including the us of on-site 

### RICE

unts to support th reliabilit of 

## the reional trssion sys. 

# The pri ren for creon of thes Demd Rens prgr, is to en ISOIRTO's hae sucient caity avaiable to mee their electrc reliabilit goas. RICE un th pacipat in regiona ISOIRTO's caity mats prvide crca support for th regional trsion sys, and assist them in maita reliailty. ISOIRTO's 

### em the pacipaon of RICE unts whch in some cas enale the delay of new 

# elecc peg powe pla conscton. PEC ha ben a stng iruence in the cron of thes demd rens prgr adst by ISOIRTO's orgons, whch enable RICE unts to parcipa in th reona cait maet. In addion, loc 

# elecc delier netork have cr d~d reons prgr with their sece ,teto to surt thir sece tetory elecc reliabilty, that alow RICE units to 

# pacipa wi thes progr The DRSP Coaiton will demons below, th this vita demand respns serice doe 

# not ental a signcat numbe of opeg hour RICE muts reeive retion payments for agin to prvide supprt to ISOIRTO's elecc trssion and distribuon n~ in the even of syste emernces. RICE unts opera, not ony inuentl, bu excet for teg, only durg elecc power syst emerncies when 

## th ar incient convenona rees to support the reliabilit of the ISOIR1O's netwrk. Thes unts oft opera to suply power, whch would othrwise have be sulied by convenona sour in th absnce oftl elecc power systm emerency.

### As noted, RICE units, to date, have provided critical support for the reliability of a number oflSOIRTO's, since PERC's open access orders were implemented beginning about 2000. The initial demand response program to provide this electric power grid support was through the N¥ISO; which is the regional transmission organization serving New York State. The NYISO opened their capacity IilaIket tc'demand response resources starting in 2001. The NYISO capacity market has historically been robust, in terms of demand response participation. One reason for the NYISO's robust demand response program is due to high capacity prices, which have signaled to demand response participants that supply of capacity is in short supply and hence reliability in New York State could be compromised. In addition, to the DRSP Coalitions knowledge, the NYISO demand response program has had the moSt activation calls to date, of all the ISOIRTO'sdemand response programs. whic~ indicates in part a greater need for demand response resource participation in New York State. New York State's lower Hudson Valley is a highly congested area, with IM.jor impediments to the delivery of electricity. and therefore demand response programs help to assist the NYI~O with emergency eleCtric system needs that might arise from highly congested transmission and distribution. The peak load forecast, according to the NYISO, for the summer 2009 is 33,400 MWs. The capacity available from conventional sources is about 38,200 MW. and capacity available from special case resources (demand response participants in NYISOs demand response market) participating in the NYISO Installed Capacity market is 1,760 MW. The NYlSO market rules do not mandate how demand response participants accomplish their load curtailQtenl However. the NYISO does include a sub-category, which directs participants to indicate if they have on-site generators. These on-site generators are all RICE units, which to date has a registered MW value of 350 MWs. Although the NYISO teports 350 MWs of on-site generation being used in their demand response market; there are controversies about whether more than half of the NYISO' s demand response program is comprised of on-site generation (RICE lDlits). In order to maintain teliabUity in New York State about 40,000 MWs of resources is needed. therefore the 350 to 880 MWs of RICE units provide 

## a critical resource in assisting with and supporting the NYISO's reIiabilit¥ goals. Additionally. demand response resources. including RICE units, assist in lowering capacity prices for all ratepayers in New York State. ..A 19S5 

### of these critical RICE units would not only jeopardize electric teliability t 

### but would also increase electric rates for all New York State electric ratepayers. The DRSP Coalition estimates that RICE unit participation, as a percentage of system peak demand, in other ISOIRTO's is proportional to the participation in the NYISO. Of the one million CI engines estimated by EPA, only several thousand participate in Demand Response programs.
As we noted above, the estimated number of curtailment hours,logged in other ISOIRTO's demand response programs are less than those logged in the NYISO demand response program. Below is a table which shows the frequency of demand res~e activation events. as posted by the NYISO (publicly available date on NYISO website)2:

2 www.nviso.com 

### As note RICE un, to da, have prvided critical support for the reliabilty of a num

ofISOIRTO's, since PEC's open acc ordrs were implemented beging ab 

### 2000. 

## The inial demand rens pr to provide this elecc power grd suport wa

thug th NlS0; which is the regiona trion organtion se 

### New York State. The NYSO opened their caity i: to'demad reponse reurs stag in 

## 200L.The NYSO caity maet ha hisricaly ben robus in tes of demand rens paicipaton. One ren for the NYO's robus demd rens prgr is

due to high cacity prce, whch have signed to demand 

# repons pacipats tht
suly of capity is in short supply and hence reliabilty in New York State could be compmi. In adition. to th DRSP Coalitions knowledge, the NYSO demad
repons progr ha had the moSt activation cals to date, of all 

### the ISOIRTO'sdemad re prgr, whicn indicate in pa a gr need for dema rense reur

pacipaon in 

### New York Sta. New York State's lower Hudsn Valley is a highy 

## cong ar with I1jor impeents to the deliver of electrcity, and therore

ded rens prgr help to asist 

### the NYSO with emerency eleèc system nee 

## tht might ar frm highy conge trission and dibuon.
The pe loa fore accrd to the NYSO, for the sumer 2009 is 33,40 MWs. 

### The capacity available frm conventiona soures is about 38,200 MW, and capacit 

## avalable frm speia cas reur (demd respns parcipan in NYSOs demad re mat) pacipating in the NYSO Inled Capacity mart is 1,760 MW. Th 

### NYSO ma rues do not madate how dema tespns paipats acclis thir 

## load cuni Howeve, th NYSO doe includé a sub-atgory, which dirts pacipats to indica if they have on-si genertors. Thes on-sit generators ar all 

### RICE un whch to date ha a rere MW value of 350 MWs. Alough the NYO 

### tepo 350 MWs of on-site genon bein use in their demand rense maket th 

## ar coveries abut wheter more th half of the NYSO's demad rens progr is compri of on-site genration (RCE imits). In order to mata teliabUity in New

York Sta abut 40,00 MWs of reur is 

### neeed therfore the 350 to 880 MWs of RICE un prvide a critical reur in asistg wi and supportg the NYSO's 

### reli go. Additionaly. demd rens reur, inludig RICE unts asst in 

## lowe caacity pres for al rateyer in New York St. .' A 19S5 of these crcal RICE unts would not ony jeopa elecc teliabilit, but would al incr elecc ra for all New York Sta elecc rateyer. The DRSP Coaltion es th RICE unt pacipaon, as a penta of system pe

de in other ISOIRTO's is proportona to the pacipation in the NYSO. Of 

## the on 

# mion CI engies esma by EPA, only severl thousd pacipa in Ded Resonse progr As we noted above, the esat numbe of culment hoW', logged in other ISOIRTO's 

### ded rens progr ar les th those logged in the NYSO ded rens pr. Below is a table whch shows the frency of dema re~e actvation 

## events, as po by th NYSO (plicly available dat on NYO website)2:

2 www.nvìso.com

### ANNUAL QPEBATING 

### tRURS 

## ptrVEAR fpr EVENT' 2001 2002 2003 2004 2005 2006 2007 2008 20.5 22 22 0 4 

### 40 19.5 0 

### AV 16 

### ANtflltb QPE8&lNG 

## 'Pug "YEAR 

## 'rIElD 2001 2002 2003 2004 2005 2006 2007 2008 1 2 0 1 3 1 2 1 

### AV 1.375 

### The following salient features can be observed from the results: • The annual number of operating hours 

### Is very small, as would be expected for a program that operates to alleviate power system emergencies, which are triggered by random events. • Events are more likely to be triggered by emergencies, which occur during the summer months; a few (16 out of 145 over eight years) of the hours of event operations occur during the winter or even the shoulder periods when electric demand is not at its maximum. • Even if extrapolated to the other ISOIRTO regions, which· administer demand response programs, the emission of HAPS triggered by these events nationally is not very significant. More importantly, emissions associated with RICE units are off-set by avoided emissions of displaced power plants that would have been called upon to operate if demand response was not available. 

### • Perhaps even more importantly, the "operation of RICH units has helped prevent the failure of the ISOIRTO's ttansmission system on numerous occasions. Wrthout this critical supply, blackouts would have occurred; as will certainly be 

### the result should this proposed rule go into effect • Should the 

### propose rule not be changed blackouts and brownouts caused by RICE units not participating in demand response programs, additional RICE units and engines will be operating, for many more hours, in order to supply critical services in the absence of the regional transmission systems, thus defeating the very purpose of this proposed rule. • The number of test hourS is even smaller, but more predictable, as would be expected. Further, the testing requircdto participate in a demand response program off-sets the same number of testing hours that would otherwise occur. Comment 2: Table 2-Emission Standards and RequirementS for Existing Stationary RICE Located at Area Sources The proposed Rule, according to Table 2, requires that CI greater than 500 

### hp, which are used for emergency purposes only, be limited to 40 

### ppmvd of CO. Most of the current installed 

### emergency generators would need to install retrofit technology to make these units capable of reducing emissions by 9()OA" in order to comply with the proposed requiremcnt. The proposed requirement would impose significant costs for owners of &citities, who maintain these units for emergency purposes, and would have minimal impact upon the health conc:ems, which motivate the proposed Rule. Additionally, demand 

### response participants would likely opt out of demand response programs should they be fiu:ed with costly installation of retrofit technologyt given the current economic climate. ANNUAL QPBAING tpy. perVEAR fpr EVES 

# 201 202 20 20 200 200 2007 2008 

# 20.5 22 22 0 4 40 19.5 0 AV 16 

## ANNlIlb QPB&G 'Pug .YEAR $rIElD 

# 201 202 20 200 20 200 2007 208 

# 1 2 0 1 3 1 2 1 AV 1.375

The followi saien fea ca be obsrved from the results: 

### . The anua numbe of opeting hour is. ver smll, as would be expe for a progr th opete to alleviat power systm emerencies, which ar trgg 

### by radom events. . Events ar mor liely tn be trgg by emergencies, whch occu dug the 

### suer month; a few (16 out of 145 over eigt yea) of the hour of event 

## opetions ocur dur the wint or even the shoulde peod wh elecc demd is no at its maum 

# . Even if exla to the other ISOIRTO reons, whch' adr ded rens progr the emssion of HAS trgg by thes events naonaly is not ve signfica More importtly, emons asiat with RICE unts ar 

### off-se by avoided emions of displace power plants th would have be caed 

## upn to opee if demd reponse wa not avalable. . Per even more imrt, the'opeon ofRICB Wlits has helpe prent the faur of th ISOITO's ttssion sy on numerus ocasons. Wrtout this 

## crica suly, blakout would have ocur as will certnly be the relt should th pro mle go into effect . Shd th prop mle not be chaged blackout and brwnout causd by RICE 

### unts not pacipa in ded rens prgr, adtiona RICE unit and 

## engies wi be op, for may more hour in orde to suly crtica sece 

## in th abce of the regiona trion system, th defeag th very purse 

# of th prpo nie. . The numbe of te hour is even smler, bu more prectle, as would be 

# ex. Furer, th tes reuito pacipa in a ded rens pr

off-s th sa numbe of 

### te hour tht would oter ocur.


### Coent 2: Table 2-Emsson Sta and Reuimets for Exst Stona RICE 

# Loed at Ar So
Th prpoed Rule, acrd to Table 2, re th CI gr th 500 hp, whch ar 

## us for emcy pu only, be lite to 40 ppmd of CO. Mos of the cu 

# inled em geor would ne to in refi teology to ma thes unts cale of ieing emons by 9QAi in order to coly with the prpo re Th prpose reuimen would impo significat cost for own of 

# fiilties who mata th unts for emery pur an would have mial impa up th Ii conc whch motiva the prpo Rul. Addtiona, 

# ded re pacip wod likly opt ou of demd rens prgr should 

# thy be fà wi coy inon of refi teology, given the curt ecnoc 

# cli.

### The DRSP Coalition proposes that Table 2, of the proposed Rule, be modified to require CI greater than 500 hp, which are used for emergency purposes only, to limit emissions to 400ppmvd The impact of the proposed Rule, should the above proposed language change not be made, is described and discussed' below.
IMPACT.OF THE RULE IF TIlE PROPOSED CHANGE IS NOT MADE If the current proposed rule is not changed to the above recommendatlon, for users of emergency generators, an extremely high cost, for very little environmental benefit, will occur. The DRSP Coalition believes the reason why such a small benefit will occur is that CI engines have limited operation, except for the few hours of testing annually and in operation hours only associated with ISOIRTO electric power grid emergencies. Furthermore. there is even a greater impact, RICE units are installed for emergency purposes and requiring the installation of retrofit technology is bound to have a negative impact upon the operation of these RICE units. This will diminish the value of the RICE units as a backup source. Additionally, the intent of the installation ofan emergency RICE unit is to increase the reliability of service, perfonned by 

### these RICE units. It is important to consider, when designing such a rule that RICE units are installed in many locations where life-saving functions are critical The DRSP Coalition believes it is not in the best interest of the public to compromise their ability to supply such a critical service. RECOMMENDATION We recommend that the proposed Rules be modified as follows: Delete. the text in Section HI, Summary of This Proposed Rule, SulrSection E. What are the Reporting and Recordkeeping Requirements?, page 9, of the proposed Rule, which states the following: "In addition, owners and. operators are allowed to operate their stationary emergency RICE for non-emergency purposes 

### tor 

# so hours per year, but those SO 

### hours are counted towards the total 100 hours provided for operation other than for true emergencies and owners and operators may not engage in income-generating activities during those SO 

### hours." The DRSP Coalition requests that the deleted text be replaced with the following: "In addition, owners and operators are allowed to operate their stationary emergency RICE for DOIHD1ergency purposes for SO 

### hOurs per year, but those SO 

### hours are counted towards the total 100 hours provided for operation other than for true emergencies and owners and operators may not engage in income-generating activities during those 50 hours. Notwithstanding the preceding text, hours of operation in response to activation calls from an ISOIRTO organizatio~ electric power delivery company. and demand response programs, are not counted toward the total 1 00 hours provided for operation other tbarl for true emergencies. Tests called as part of participatiQn in sucli demand response programs sbaU be counted towards the 100 hours provided for operation other than' for true emergencies." 

### Th DRSP Coaliton prpose that Table 2, of the prpoed Rule, be modifed to requre CI gr th 500 hp, which ar us for emergency puses only, to liit emisions to 

# 40ppvd The impa of the propo Rule, shuld the above prose languge chage not be mae, is describe and dise' below. IMACT,OF TI RULE IF TI PROPOSED CHGE is NOT MAE
If th cunnt prpo rue is not chaged to the above remmenQatioD, for usrs of 

### emerency generars, an exly high cost for ver litte envirnmenta benefit, will ocur. Th DRSP Coon believes the reon why such a sml beefit will ocur is th 

### ci enes have limed operaon, exce for th few hoW's of teing anuay and in operaon hour only asia wi ISOIRTO elecc power grd emerencies. 

### Furermore, ther is even a gr impa RICE un ar inled for emergency pur and reui the inlaon of retrfit technlogy is bound to have a negave impa upon the opertion oftles RICE units. Ths will dinih the value of the RICE unts as a bakup sour. Addonly, the intet of the inlaon ofan etnergency RICE 

### unt is to inas the reliabilit of seice peonned by thes RICE unts. It is import to conside, when designg such a rue th RICE units ar inlled in ma loctions 

## wher lie-savin fuctons ar crtica Th DRSP Coalition believes it is not in the best

bi of 

### the public to compr their abilit to suply suh a crtical sece. 

# REOMMATION We remmend th the prse Rules be modfied as follows: 

## Delete. the text in Secon HI Sum of Th Prpo Rule, SulrSeeon E, Wh ar 

## th Reng and Recrding Reuirnt?, page 9, of the pro Rule, whch st th followig: 

### "I adon owner an oprs ar allowe to ope thir stona emeency RICE

for non-ernç pur to so hour 

## pe yea, but those SO hour ar coun to th tota 100 hour prvide for opeon other than for tre emergencies and owner and 

## oprs may not enge in income-geerg activiti dung those SO hour." The DRSP Coition reues tht th delete te be relac with th following:
"I additin, own and ope ar alowed to opeat thei stona emergency RICE fo Ilrgncy puse for SO hO pe yea, but those SO hour ar counte towa th tota 100 hour prvided for opra oth th for tr emerenies and owner and 

# opera may not eng in inme-gengaevities dug thos 50 hour.

Notdig the prg text hou of 

### opon in re to acvaton calls frm an ISOITO orgaon, elecc power deliver 

## compay, and demd rens prgr ar not cowite toward th tota 100 hour prvided for opeon other tb for 

## ti emies Tes called as par of paçipaQn in sucli demd rens pr sb be cowite towa the 100 hour prvided for opon other th' for tre 

# emecies."

### Comment 2: Table 2-Emission Standards and Requirements for Existing Stationary RICE Located at Area 

### Sources The proposed Rule, according to Table 2, requires that CI greater than 500 hp, which are used for emergency purposes only, be limited to 40 ppmvd of CO. Most of the current installed emergency generators would need to install retrofit technology to make these units capable of reducing emissions by 9()0.4, 

### in order to comply with the proposed requirement. The proposed requirement would impose significant costs for owners of facilities, who maintain these units for emergency purposes, and would have minimal impact upon the health concerns, which motivate the proposed Rule. Additionally. demand response participants would likely opt out of demand response programs should they be faced with costly installation of retrofit technology, given the current economic climate. The DRSP Coalition proposes that Table 2, of the proposed Rule, be modified to require CI greater than SOO 

### hp, which are used for emergency purposes only, to limit emissions to 400ppmvd
Respectfully submitted,

CPower, Inc. June2,2009 Innoventive Power, LLC June 1,2009 Comment 2: Table 2-Emission Stadads and Reqen for Existig Stationa RICE 

## Locate at Ar Sour The prpoed Rule, acrdg to Table 2, requirs th CI grte than 500 hp, which ar 

## us for emergency puses only, be limit to 40 ppmvd of CO. Most of the cur 

## insled emergency generars would need to instll refrt tehnology to ma thes unts capable of reucing emissions by 9(.4, in order to comply with the prpo reuient. The propose reuient would imse signcat cost for owner of 

## faciities, who matan these unts for emergncy puise, an would have mi imct upn the hea conces, whch motivat the propose Rue. Addtionay, 

## demd rens pacipa would likly op out of demd respns progr should they be fa with costy inaton of refi tehnology, given the curnt ecomic 

# clim. The DRSP Coition propose that Table 2, of the prose Rule, be moded to re CI grr th SOO hp, which ar used for emergncy purse only, to lit emisiòns to 

### 400ppmvd 

## Respely submittd, 

# fh"'¿~ 

# -¡~._

CPower, Inc.

June 2, 

## 200 Inoventive Powe, LLC 

## Jun 1,200

## ATTACHMENT 

## ! Terminology Definitions Reciprocating Internal Combustion Engines (RICE) Emergency Compression Ignition (CI) Emergency Sparl< Ignition (SI) National Emissions Standards for Hazardous Air Pollutants (NESHAP) Maximum Achievable Control Technology (MACI) Non-Selective Catalytic Reduction (NSCR) Oxidation Catalyst (OC) Regional Transmission OperatorslIndcpendent System Operator (lSOIRTO's) 

# ATlACB i

Terminology Defiitions
Recipr Inernal Combuson Engines (RCE) 

### Emerency Compreion Igntion (CI) 

### Emerenc Spa Igntion (SI) 

## Natona Emissions Stada for Haous Air Pollutats (NSHA) 

## Maum Achievale Contrl Techniogy (MCI
Noiilective Catytc Redon (NSCR) 

### Oxdaon Catays (OC) 

## Regiona Trasmission Oprscpdent Systm Opr (ISOIRTO's)

# Attachment 16

EPA's Response to Public Comments Attachment 16



# EPA's Response to Public Comments

## MEMORANDUM

Subject: Response to Public Comments on Proposed National Emission Standards for

Hazardous Air Pollutants for Existing Stationary Reciprocating Internal Combustion Engines Located at Area Sources of Hazardous Air Pollutant Emissions or Have a Site Rating Less Than or Equal to 500 Brake HP Located at Major Sources of Hazardous Air Pollutant Emissions
From: Melanie King, Energy Strategies Group
To: EPA Docket EPA-HQ-OAR-2008-0708 On March 5, 2009, the Environmental Protection Agency (EPA) proposed national emission standards for hazardous air pollutants (NESHAP) for stationary reciprocating internal combustion engines (RICE) that are either located at area sources of hazardous air pollutant (HAP) emissions or that have a site rating of less than or equal to 500 brake horsepower (HP) and are located at major sources of HAP emissions in 40 CFR part 63, subpart ZZZZ. EPA also proposed national emission standards for hazardous air pollutants for existing stationary compression ignition (CI) engines greater than 500 brake HP that are located at major sources of HAP emissions. It is important to note that the proposed rule covered both CI and spark ignition (SI) engines. The final rule will be promulgated in two parts. The first action will cover CI engines only. The purpose of this document is to present a summary of the public comments that EPA received on the proposed standards for CI engines and the responses developed. This summary of comments and responses serves as the basis for revisions made to the standards between proposal and promulgation. The comments on the proposed standards for SI engines and the responses to those comments will be summarized in a separate document that will be made available at the time that the final rule for 81 engines is promulgated, which is expected to be in August 2010. EPA received 199 public comments on the proposed rule. A listing of all persons submitting comments, their affiliation, and the Document ID for their comments is presented in Table 1. The comments can be obtained online from the Federal Docket Management System at http://www.regulations.gov. The docket number for this rulemaking is EPA-HQ-OAR-2008- 0708. In this document, commenters are identified by the last three digits of the Document ID of their comments. Note that as stated above, this document includes the comments related to CI engines only, therefore the comments that pertain to SI engines will be summarized and responded to in a separate document.

1 

## MEMORAUM
Subject: Response to Public Comments on Proposed National Emission Stadads for



### Hazdous Air Pollutats for Existing Stationa Reciprocating Internal

Combustion Engies Located at Area Sources of Hazardous Ai Pollutat 

### Emissions or Have a Site Ratig Less Than or Equal to 500 Brae HP Located at

Major Sources of Hazardous Air Pollutat Emissions 

### From: Melanie King, Energy Strategies Group


### To: EPA Docket EPA-HQ-OAR-2008-0708 

### On Marh 5, 2009, the Environmental Protetion Agency (EPA) proposed national emission 

### stadads for hazous air pollutats (NSHA) for stationa reciprocating internal

combustion engines (RICE) that are either located at ara sources of 

### haardous air pollutat (H) emissions or that have a site rating of less than or equal to 500 brae horsepower (HP) and are located at major sources of HA emissions in 40 CFR par 63, subpar ZZZZ. EPA also 

### proposed national emission stada for hazardous air pollutants for existig stationar compression igntion (CI) engies grater than 500 brae HP that ar located at major soures of HA emissions. It is importt to note that the proposed rule covered both CI and spark ignition (SI) engies. The fial rule will be promulgated in two par. The fit action wil cover CI engies only. The purose of ths docuent is to present a summar of 

### the public comments that 

### EPA received on the proposed stadads for CI engines and the responses developed. This 

### sumar of comments and responses serves as the basis for revisions made to the stadads between proposal and promulgation. The comments on the proposed stadads for SI engines 

### and the responses to those comments wil be sumarzed in a separte document tht wi be made available at the time that the fmal role for 81 engies is promulgated, which is expeted to 

### be in Augut 2010. EPA received 199 public comments on the proposed rue. A listig of all persons submitting 

### comments, their afliaton, and the Document ID for their comments is presente in Table 1. The comments ca be obtaed online from the Federal Docket Management System at

http://www.regulations.gov. The docket number for 

### ths rolemakg is EPA-HQ-OAR-2008-

0708. In this document, commenters ar identified by the last thee digits of 

### the Document ID of their comments. Note that as stated above, ths document includes the comments related to CI 

### engies only, therefore the comments that pertin to SI engies will be sumared and responded to in a separte document.

1

### Reliability Studies, and built into the Resource Planning analysis, planned participation by these

demand response resources. Should RICE units incur the additional costs associated with installation of HAP control technology, the commenter (85) believes that many of the RICE units will opt out of demand response programs, which will leave ISOIRTO's with critical missing demand response resources. According to the commenter (85), without the inclusion of RICE resources for demand response, many ISOIRTO's will have less available resources to tap during critical peak: energy days, leaving ISOIRTO's with inadequate reliability. The commenter (85) recommended that the proposed rule be modified (using the language of the proposal preamble as the basis for the revision) to enable RICE units to participate in demand response programs. The commenter (85) recommended that the description of the rule in section III, "Summary of This Proposed Rule," Subsection E, "What are the Reporting and Recordkeeping Requirements?" be modified as follows: "In addition, owners and operators are allowed to operate their stationary emergency RICE for non-emergency purposes for 50 hrsIyr, but those 50 hours are counted towards the total 100 hours provided for operation other than for true emergencies and owners and operators may not engage in income-generating activities during those 50 hours. Notwithstanding the preceding text, hours of operation in response to activation calls from an ISOIRTO organization, electric power delivery company, and demand response programs, are not counted toward the total 100 hours provided for operation other than for true emergencies. Tests called as part of participation in such demand response programs shall be counted towards the 100 hours provided for operation other than for true emergencies." The commenter (85) noted that many ISOIRTO markets, with the active encouragement of Federal Energy Regulatory Commission (FERC), have initiated demand response programs,

308 Reliabilty Studies, and built into the Resoure Planing analysis, planed paricipation by these demand response resoures. Should RICE unts incur the additional costs associated with

installation of HA control technology, the commenter (85) believes that many of 

### the RICE unts 

### wil opt out of demand response programs, which wil leave ISOIRTO's with critical missing

demd response resources. Accordig to the commenter (85), without the inclusion of 

### RICE

resources for demand response, many ISOIRTO's wil have less available resoures to tap durg 

### critical peak energy days, leaving ISOIRTO's with inadequate reliabilty. The commenter (85) recommended that the proposed rule be modified (using the

language of 

### the proposal preamble as the basis for the revision) to enable RICE units to 

### paricipate in demand response programs. The commenter (85) recommended that the

description of the rue in section II, "Sum of 

### Ths Proposed Rule," Subsection E, "What are 

### the Reporting and Recrdeeping Requirements?" be modified as follows: 

### "In addition, owner and operators ar allowed to operate their stationar emergency RICE for 

### non-emergency puroses for 50 hryr, but those 50 hour are counted towards the tota 100

hour provided for opertion other than for tr emergencies and owners and operators may not 

## engage in income-genertig actvities dug those 50 hour. Notwthtadig the precedig text hour of operation in response to activation calls from an ISOIRTO organiztion, electrc

power delivery company, and demad response progrs, ar not counted towar the tota 100 

### hours provided for operation other than for tre emergencies. Tests called as par of parcipation 

### in such demand response progr shall be counted towards the i 00 hour provided for operation other than for tre emergencies." 

### The commenter (85) noted that many ISOIRTO markets, with the active encouragement

of Federal Energ Reguatory Commission (FERC), have intiated demand response progrs,



### 308

# Attachment 17

Letters from CPower and Innoventive Power to Ms. Melanie King, EPA, March 26 and May 21, 2010 

# Attachment 17



# Letters from CPower and Innoventive Power to Ms. Melanie King, EPA, March 26 and May 21, 2010

# cpower:

March.~. 2010 

## Ms. Melanie l'<irig EPAED.efJJY Strategies Group SectOrPonti~tuid,~~ ·Pivision.·(DUj~l) Researeh triimgle p~ N~rth 

## CSroun. 27711 SUbj~ .DOcltet 

# to No.. EP~-aQ()AR-~00&-0108t 

### N'ational.Emission-StandardsJor ~QU$ 

### AirPollutants for 

### Recip.iocatlngIntcri.laJ Cotnbu-'on EDgi.n~ 

## Re~: (1) ·Bl.»A-liQ-oAR~2008;;()708..oo8S: CO~S ONPROPOSJ3DRULE wm Demand 

### ~_S"ervice Providers (.DRSPCoalitionofCPower. ro,c,~Jnl1ovE\Iiti~e POwer, 

### LtC) NlI4iODBl EmilfSion ~4aJ:dS for Haza,rdous 

## Air Pollutants 

### for Reciproc81ing Intemal Combustion Enaines (2) RespoliSC to,P\Jblic·



### Co~tiJ ()nPtO~,Nl\tio:r;WJ~tnission Standards 

# fo,. . ~OU$·AirPonutarJt$.for~StationaryR.ecl~ J.~ Combusti~ EiJgiiles ~ 

### at AreaS9~ of 

### .HazardOus Air 

### Pollutant Emissions 

### or Ha~a:Sitel~ating Less 

## Than Ot'~" 

## to 500 BrakeJIP L~ 

### at Magor~of~us Air Po'llutant SmiliSions

Under this subject docket, 

## et>ower, Inc~ and.biD.q~tive, 

### LLO submitte4'con;ul1eD1S.on behalf of 

## the J)RSJl 

## CoaJiti(m (R.fenm9c 

## 1). Ii1 

## Part- we,fiied'in support of.811o~~ engi'ricsJo. continue 

## to 

## 'quaiity

fot.emergeac, 

## o~ in~.~ponse propms,citing as 

## exsnipl~ 

## me parlicip8tion or.emergency gcIie1'atOrs hi -the NYISO ~abiJit1.~gr8U1. While weare 

### p1easedtbat the EPA 

# m it;S tinall\ll~.~ ~gni2;e4 tl]e.inlpo~of allowing ~ ~tQ opeta(e 

### m'deJnaod response 

## propms, we 

### bdi,ev¢ ~ EPA. unfotJwJately bas 'W1~' 

### int---.t 

### our c:oD1D1ents,. d '.' . 'bed.' .• 

## Rete ., : and are • this -r..,.,-..Y -..tA"""f- . ,I$~. 

### ..m ere.nee~. USUJg 

### 'mis~cfation 

## ~.i1Btmeaiionorthe 15-hour limit 

## In ~,FinaI 

### Rule. In Kcfenmce I,. commentersprovided a tabl~ of ~ ~ 

# opn.q holUS.for demand respQnSe.~ency~ 

### participating in 

### the NYISo IiistaJled ~ty ~~ ($pe¢ial ~ 

### resourees). ·That table shows that 

## over ~ ejgbt-~ 

### peri.04,bet,wecn 2001 rm4 2008. 

### emergency cqi;~es operated an,average 0'16 hours per year. 1bat table alJO ShoWa up tQ 

### 40 

# ."'0_ of operation in a 

## specitie,.. (2006),. wbich;.intideiltalIYi waso.ne 

### olthe hottestsummcrs 

### on 

# cpower: c:~ in 

# ~~~Sù1t AI.PA18103 

# T.(8"~ ~~.'ll~ 

# ~ .~
MáI,~. 2010 

### Ms Melae I( 

# EPAED. StrgiesGrùp Seør Polle$lJ,~8r 'PivisìoJl-(Dj~l) 

# Re tiigie p~ Nørt ealü 27711 SUj~ .Dei io No.. EPA-aQ(AR~00&108l N'ationa.Ëmisson-S1:sJor ~Q1 ÁiPølluts for Reip.li Cobùston EDges 

# Re~: (1) '~A-liQ-AR~2008;;7Ò8..8S: CO~S ONPROPOSED RUL fim De Re_S_erIce Prvide (.DRSP CoalitionofCPower. ro,,ltJnl1ové\~e POw, 

## LtC) NlIöD Emiasob. St4a for Hazous Ai Pollutts for Recipr 

## In Cobuson Eies 

# (2) Respo to,P\lic- Conmti ()i.Pt~,Nato:r..~inion Sta fór 

# - Øàou'AiPoHut.for £x StaonR.~ J.~ Combuor Eìgi ~ at ArS9~ of.HdO Ai :Pollutt Emons or Ha~a:Sitl&ting Ï.1Î Ot'~" fo SOO BrJlP L~ at 

# Major ~ofHaus Ai PO,llut Sm4ion De ML Ki
Un th suec doet ePOW, In~ and.l~tive, LLO suit'COrn.on bef of 

# th J)RS Co (Rfe 1). Ii Pa we,ñied'i supo of.811oWÎ~ enncJo. cc toc¡ fòr.emerea ò~ in ~,iepo prgr,ci as exl~ me 

# pacion or em gC hi -th NYSO ~àbitý,~gr Wbe wear p1etb th EPA Ú1 it ti1\~.~ rcgi tl-inportof alowi 

# ~ ~lQ ope m.'de rens prgrs, we bdevt ~ EPA unorily 

# ba ,wi~' ini---. our c: " d '.' "be.- .' Rc ., : an ar · th 

# -r.,Y -"l'-- _ ,lIes. , ,in er ~_ us 'mi~et as.iætücaønofthe 15-h lit În ~.Fii Rue. 

# In Kc I" çoenerprde a tal~ of ~ ev opltq ho"Q.for ded 

# re-~en~ paci ir th NY Iiled Oqty itet ($p ça reur). 'Th tale shws th over ~ élgb-~ pe04.be 2001 ru 2008. etêrcy eø~es op an.av 01'16 ho pe yea. 1b tale al SlWa up tQ 40 ,"'Q_ of 

## ope in a spectie ye (200 wJcl.iñtdetaly¡ wao.e olth hoesSUef on

### record in the'nortbea$t, setting'record systetn 

### peakconditions and 

## severely ~~~

'electric ': •••..•.••••~ " , ., '" ,SY.--.uR!


### Wt 

## ~t that n~ 

## in me Re~ 1 DttsP"CoaIiti(m~merits' su,Ii.POrtstife 

### EPA jUStificadOfi fot 

### the lS:,ho.li:( 

### CQP.. DllSP,qiq,~9tt 

## ',and.d~Aot npwj ~,n~ a 15~ 

## limit. RatheI;'~mmente('s letferstated ibatemergencydemand 

## response,was di$~~ iJiNewY~ ~ 0 

## ,~4 4O.~Ui$'p'er 

# _ov~.an If':year 

## bistory to'address 

# system eJJJers eDcies , with 'an average of 16 hnutSfper 

# year. We,belleVe 

## the:F.iiJa1,aule W9\lJd ~qgep81:tic~tion. pf 

### em~~y ~~in,the,refCrenced NYISOdemand response capaclt.y 

## marketa 8ndin fact.:pteCIUdej)4itticipfttlon~Ut'JmlnY~ itm;t ~6st;: 

### c)t~etre&i01ial ~y ~1U¥.J~:QSe 

### ~s.. Although 

## outside the scope,otthis 

## letter, CPowetwould be;happy to ptovi.:the 

## 2rA w.it1t·e~l~tatifflangQilgEt~rting this DO ' po , ,!II,. 

### We appreciaw the opportUnity to clarify themeatlfu&;ofoqr :$ubJ;niUCd Com.rilerits;, ~ 

### feel tbat ~s i,OformatiQJ1 is imPQttaIil 

### in any ~tioDa.l ~ussiODSthe 

### EPA-may have in further 

### CODSiderationofthC 'Fma'l Ruld. 

## We.do'not want o.u, CQJDin¢n1s~intelpteted ..by the t;PA tobe ~~iS:tQX 

## tbis ~ Qftbe FinalRUIeJhat would, in effec~ 

## severely restrict the'participiltiQi1 Qf eDt«gency 

### cngiijeSin 'tIlese,regio~ 

# e.n~ demand response 

## progrems, 

# reJd in th.nor seg.tØcord syst pecondtIons an severly ~~f\ 

# 'è1ecè . :......~ '. . ., " --, .SY-.R! 

# Wt ~t th n~ in me Re~ i Dtl"CoatiÒIcømêi' sulí.Prttlf EPA jUScaOf fot th lS:,höti cap..DllSl.qiQ,A9t. ',and~Aot npwj t,nQQ a 15hP limt. Ra 'r:JDte's letstte lb enerydéd tepoti'Was disi-~ iJNewYôr 

## ~ 0 .il4 4O.~ùì'p'er _ov~.ài llj.ea bistor to' ~dress syte emeieniéS, with 'an avere of 16 hnutpe Yëà.
We,beeve th:F.w,Rülè W9Wd ~qg,PaiciPtiòn. pf ei~eny en¡ùin.th,refèrce 

# NYISOdema re ca maet åDin fac:preìUdJ'cîpon~Ui'Jy~ Itff 

# ~Ô8 c)~etre&i01 ~y dean~:Q pls'. Althug outside th sc,òtths let, CPoweiwould bë;ha to pivi.:the 2lA w.t1'e~l~taffi8igggé,~rt tñÎs 

# SÎo .

po , . 

## !I 

## We apíaw th opprt to cla thèmea;ofo1lr :$ùbJttd èoi:ts, a: fe.I tbt ~s RíorøtiQli is imPQit in any agtiona.l diusonsthe EPA-may have in- tù COdertionofth 'F'mâ Rull!. We.c!íiot wai o. èQnitn1asmtted..by th EPA to'be

~~iS:QX tb pl Qftb FinRUeJhat would, 

## in efec~ sevérly retrct thé'pacipà9ii Qf 

# eDcy ciin tlese,regiòna en1et deman rense prolP.

### May 21,2010

Ms. Melanie King EPA Energy Strategies Group Sector Policies and Programs Division 90243-01 Research Triangle Park, North Carolina 27711 RE: Docket 10 No. EPA-HQ-OAR-2008-0708, National Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines
References: 1. EPA-HQ-OAR-2008-0708-0085: COMMENT ON PROPOSED RULE from Demand Response Service Providers (DRSP Coalition of CPower, Inc. and Innoventive Power LLC) National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines 2. Response to Public Comments on Proposed Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines Located at Area Sources of Hazardous Air Pollutant Emissions or Have a Site Rating Less Than or Equal to 500 Brake HP Located at Major Sources of Hazardous Air Pollutant Emissions

Dear Ms. King, Under this subject docket, Innoventive power LLC and CPower, Inc. submitted comments on behalf of the DSRP Coalition (Reference 1). In part, we filed in support of allowing the use of emergency engines for participation in demand response programs which are vital to the reliability of the electric grid. EPA referred to our comments in its justification of the 15 hour limit on participation by emergency engines in demand response programs in Reference 2. EPA's comments state: 'The commenter's information indicates that no engine has needed more than 

### 15 hours per year to meet their requirements under their DR program. This alleviates the concerns expressed by the commenter. These engines will still be able to parlicipate in DR programs and the final rule will not impact the energy supply 

### or grid reliability by providing disincentives for facilities to parlicipate in these programs". EPA's conclusion is in error since our comments did not, in any way, "indicate that no engine has needed more than 15 hours per year to meet their requirements under their DR program". In fact, in Reference 1, commenters provided a table showing the average number of hours that engines ran for participation in the New York Independent System Operator (NYISO) Special Case Resource program over the

973.762.5510 fax 

### 973.762.0810 70 DuffieidDrive,Suite 305 • South Oranqe, NJ 07079

www.innoventivepower.com May 21,2010

Ms. Melanie King 

### EPA Energy Strategies Group 

### Sector Policies and Programs Division 90243-01 

### Research Triangle Park, North Carolina 27711 RE: Docket 10 No. EPA-HQ-OAR-2008-0708, National Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines 

### References: 1. EPA-HQ-OAR-2008-0708-0085: COMMENT ON PROPOSED RULE from Demand Response Service Providers (DRSP Coalition of CPower, Inc. and 

### Innoventive Power LLC) National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines
2. Response to Public Comments on Proposed Emission Standards for Hazardous 

### Air Pollutants for Reciprocating Internal Combustion Engines Located at Area Sources of Hazardous Air Pollutant Emissions or Have a Site Rating Less Than 

### or Equal to 500 Brake HP Located at Major Sources of Hazardous Air Pollutant 

### Emissions

Dear Ms. King, 

## Under this subject docket, Innoventive power LLC and CPower, Inc. submitted comments on behalf of the DSRP Coalition (Reference 1). In part, we filed in support 

## of allowing the use of emergency engines for participation in demand response

programs which are vital 

### to the reliabilty of the electric gnd. EPA referred to our comments in its justification of the 15 hour limit on participation 

### by emergency engines in demand response programs in Reference 2. EPA's

comments state: 'The com 

### menter's information indicates that no engine has needed 

### more than 15 hours per year to meet their requirements under their DR program. This alleviates the concerns expressed by the commenter. These engines will still 

### be able to parlicipate in DR programs and the final rule will not impact the energy supply or grid reliabilty by providing disincentives for faciliies to parlicipate in these 

### programs". EPA's conclusion is in error since our comments did not, in any way, "indicate that no 

### engine has needed more than 15 hours per year to meet their requirements under 

### their DR program". In fact, in Reference 1, commenters provided a table showing the average number of hours that engines ran for participation in the New York Independent System Operator (NYISO) Special Case Resource program over the

973.762.5510 fax 973.762.0810 70 Duffeid Drive, Suite 305 . South Orange, NJ 07079



### ww.innoventivepower.com

### eight years, 2001 through 2008. The same table also showed operation for as much as 40 hours in 2006, during which the electric grid was extraordinarily stressed. EPA further states in Reference 2 that with the 15 hour cap, these engines would not be prevented from being able to supply a vital demand response resource. However, there are demand response programs that require a resource to be able to respond to more than 15 hours, if called. The 15 hour cap could preclude resources from participating in these programs. Demand response programs, such as the NYISO Special Case Resource, are reliability based tools that are used during high grid stress. The number of activations, while sometimes few, is unpredictable but the above referenced table was meant to provide a guide. Nothing in reference 1 supports a cap of 15 hours, however the commenters did suggest allowing operation of these engines as part of the 100 hours for operation other than for true emergencies which was in the proposed rule. We appreciate the opportunity to clarify how we believe EPA incorrectly referenced our original comments. Our position has not changed and we believe the limitation of emergency engine participation in demand response programs will have a detrimental effect on the reliability of the electric grid. Further, we did not want our comments (Reference 1) to be incorrectly used as the justification of a rule that could severely restrict the participation of emergency engines in regional emergency demand response programs. Sincerely,

//'
, 

# ()/ 

# C1~/{l /E:::.: ... 

# J (--1 

### / Craig ruber General Manager

Page 2 of2 

### eight years, 2001 through 2008. The same table also showed operation for as much as 40 hours in 2006, during which the electric grid was extraordinarily stressed. 

### EPA further states in Reference 2 that with the 15 hour cap, these engines would not 

## be prevented from being able to supply a vital demand response resource. However, there are demand response programs that require a resource to be able to 

### respond to more than 15 hours, if called. The 15 hour cap could preclude resources from participating in these programs. 

### Demand response programs, such as the NYISO Special Case Resource, are 

### reliabilty based tools that are used during high grid stress. The number of activations, while sometimes few, is unpredictable but the above referenced table was meant to provide a guide. Nothing in reference 1 supports a cap of 15 hours, however the commenters did suggest allowing operation of these engines as part of 

## the 100 hours for operation other than for true emergencies which was in the proposed rule. 

### We appreciate the opportunity to clarify how we believe EPA incorrectly referenced 

### our original comments. Our position has not changed and we believe the limitation 

### of emergency engine participation in demand response programs wil have a 

### detrimental effect on the reliabilty of the electric grid. Further, we did not want our comments (Reference 1) to be incorrectly used as the justification of a rule that could 

## severely restrict the participation of emergency engines in regional emergency demand response programs. 

### Sincerely, 

# I/' , ()/ C.1~/t/ /E::. .,. vi (-- 

# /
Craig ruber 

### General Manager



### Page 2 of2

# Attachment 18

How New England States Handle Emergency DR Attachment 18



# How New England States Handle 

# Emergency DR

### How New England States Handle Emergency DR

Massachusetts The entire definition of emergency in the Massachusetts Department of Environmental Protection ("MassDEP") regulation in 310 CMR 7.03(1O)(a)4. is as follows (the highlighted portion is what was added for the ISO-NE emergency DR Program):



### a The normal maintenance and testing procedure as recommended by the manufacturer; and b. Periods of electrical power outage due to failure of the grid, in whole or in part, on-site disaster, local equipment failure, flood, fire or natural disaster; and c. 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 3% above or 5% below standard voltage, 

### or periods during which the 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. (emphasis added) 

## How New England States Handle Emergency DR

Massachusett The entire defintion of emergency in the Massachusett Deparent of Environmental Protection ("MassDEP") reguation in 310 CMR 7.03(1O)(a)4. is as follows (the highighted 

### porton is what was added for the ISO-NE emergency DR Progr):

a The normal maintenance and testing procedure as recommended by the 

### manufactuer; and b. Perods of electncal power outage due to failure of the grd, in whole or in par, 

## on-site disater, local equipment faiure, flood, fie or natu disaster; and

c. When the imment theat of a power outage is likely due to failur of 

### the 

### electncal supply or when capacity deficiencies result in a deviation of voltae from the electcal supplier to the premises of 3% above or 5% below stadad

voltae, or periods during which the regional transmission organization directs 

### the implementation of voltage reductions, voluntar load curtailments by

cutomers, 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 emergenc conditions.

(emphais added)

### Massachusetts does not limit the hours of participation by emergency engines in ISO New

England's emergency DR program. Emergency engines in Massachusetts are typically limited to 300 hours per rolling 12 months.

Connecticut The entire definition of emergency in the Connecticut Department of Environmental Protection ("CTDEP") regulation in R.C.S.A. §22a-174-22( a)(4) is as follows (item (E), as highlighted, was added for the ISO-NE emergency DR Program)

"Emergency" means an unforeseeable condition that is beyond the control of the owner or operator of an emergency engine and that: (A) Results in an interruption of electrical power from the electricity supplier to the premises; (B) Results in a deviation of voltage from the electricity supplier to the premises of three percent (3%) above or five percent (5%) below standard voltage in accordance with subsection (a) of section 16-11-115 of the Regulations of Connecticut State Agencies; (C) Requires an interruption of electrical power from the electricity supplier to the premises enabling the owner or operator to perform emergency repairs; (0) Requires operation of the emergency engine to minimize damage from fire, flood, or any other catastrophic event, natural or man-made; or (E) 

### Notwithstanding section 22a-174-22(a)(3) of the Regulations of Connecticut State Agencies, requires operation of the emergency engine under an agreement with the New England Region System Operator during the period of time the New England Region System Operator is implementing voltage

2 Massachusett does not limt the hours of paricipation by emergency engines in iso New England's emergency DR program. Emergency engines in Massachusetts are tyically limited to 

### 300 hours per rolling 12 month.

Connecticut

The entire defition of emergency in the Connecticut Deparent of 

### Environmenta Protection ("CTDEP") reguation in R.C.S.A. §22a- 1 74-22( a)( 4) is as follows (item (E), as 

### highighted, was added for the ISO-NE emergency DR Program)
"Emergency" mean an unoreseeable condition tht is beyond the control of the owner or operator of an emergency engie and that: 

## (A) Results in an interrption of electrcal power from the electrcity supplier to the premises;

(B) Results in a deviation of 

### voltage frm the electrcity supplier to the premises of thee percent (3%) above or .fve percent (5%) below stadad voltage in 

### accordance with subsetion (a) of section 16-11-115 of the Regulations of Connecticut State Agencies; 

## (C) Requies an interrption of electrcal power frm the electrcity supplier to the premises enaling the owner or operator to perform emergency repais;

(0) Requires operaon of the emergency engie to minie daage from fire, 

### flood, or any other cataophic event, natual or man-made; or

(E) Notwithstanding section 22a-174-22(a)(3) of the Regulations of 

### Connecticut

State Agencies, requires operation of the emergency 

### engine under an 

### agreement with the New England Region System Operator during the period of time the New England Region System Operator is implementing voltage

2

### reductions or involuntary load interruptions within the Connecticut load zone due to a capacity deficiency. (emphasis added). Connecticut does not limit the hours of participation by emergency engines in ISO New England's emergency DR program. Emergency engines in Connecticut are typically 1 

### limited to 300 hours per rolling 12 months.

Rhode Island Effective May 15,2007, the Rhode Island Department of Environmental Management ("RIDEM") has modified its definition of emergency to allow emergency engines to operate under the ISO-NE's emergency DR program. Air Pollution Control Regulation No.9 now defines emergency in Section 9.1.15 as (emphasis added):"Emergency" means an electrical power outage due to a failure of the electrical grid, onsite disaster, local equipment failure, or public service emergencies such as flood, fire or
natural disaster. Emergency shall also mean periods during which ISO New England, or any successor Regional Transmission Organization, directs the implementation of operating procedures for voltage reductions, voluntary load curtailments by customers or automatic or manual load shedding within Rhode Island in response to unusually low frequency, equipment overload capacity or energy deficiency, unacceptable voltage levels or other such emergency conditions. (emphasis added)

I 

### Emergency engines in Connecticut are permitted under R.C.S.A. § 22a-174-3a (with an individual air permit), § 

### 22a-174-3b limiting the hours of operation to 300 per year; § 

### 22a-174-3c limiting the annual fuel usage; or fallout of the regulations if 

### the potential to emit (based on 8,760 hours per year) is less than 15 tons per year of any criteria pollutant.

3 

### reductions or involuntary load interruptions within the Connecticut load zone 

### due to a capacity deficiency. (emphasis added). Connecticut does not limit the hour of paricipation by emergency engies in iso New

Englan's emergency DR program. Emergency engines in Connecticut are tyically i 

### limted to 

## 300 hour per rollng 12 month.

Rhode Island

Effective May 15,2007, the Rhode Island Deparment of 

### Environmental Management 

### ("RIEM") has modified its defition of emergency to allow emergency engines to operae 

## under the ISO-NE's emergency DR progr. Air Pollution Control Reguation No.9 now defies emergency in Section 9.1.15 as (emphasis added):"Emergency" mea an electrcal power outage due to a failure of the electrical grid, on

### site disaster, local equipment failure, or public service emergencies such as flood, fire or

na disater. Emergenc shall also mean periods during which iso New England or 

### any successor Regional Transmission Organization, directs the implementation of

operating procedures for voltage reductions, voluntary load curtailments by customers or

automatic or manual 

### load shedding within Rhode Islan in response to unusually low frequency, equipment overload capacity or energy deficiency, unacceptable voltage levels or other such emergenc conditons. (emphais added)

i Emergency engies in Connecticut are permtt under R.C.S.A. § 22a-174-3a (with an 

## individua ai permt), § 22a-174-3b limtig the hour of operation to 300 per yea; § 22a- i 74-3c litig th anua fuel use; or fallout of the regutions if the potenti to emit (based on 8,760 hour per year) is less th 15 tons per year of any crteria pollutat.



### 3

### RIDEM does not limit the hours of participation by emergency engines in ISO New

England's emergency DR program. Emergency engines in Rhode Island are typically limited to 500 hours per-rolling 12 months.

4 RIEM does not limit the hours of paricipation by emergency engines in iso New England's emergency DR progr. Emergency engines in Rhode Island are typically limited to 

### 500 hours per'rolling 12 months.



### 4

### The NHDES does not limit the hours of participation by emergency engines in ISO New

England's emergency DR program. Emergency engines in New Hampshire are typically limited to 500 hours per rolling 12 months.

Vermont The Vermont Department of Environmental Conservation ("VT DEC") does not define emergency in its regulations. To allow emergency engines to operate in the ISO-NE emergency DR program, the VT DEC developed "A Department Procedure On Operation of Emergency Engines During a Grid Capacity Event" in December, 2005 and revised in January, 2007.
Vermont does not limit the hours of participation by emergency engines in ISO New England's emergency DR program. Emergency engines in Vermont are limited to 200 hours for testing and maintenance and unlimited use for emergencies.

Maine The Maine Department of Environmental Protection ("ME DEP") handles the permitting of emergency engines in the ISO-NE emergency DR 

### program on a case-by-case basis either by modifying individual air permits or issuing air permits for engines that require a permit.

5 The NHDES does not limit the hour of 

### paricipation by emergency engines in iso New England's emergency DR program. Emergency engines in New Hampshire are typically limited to 500 hours per rolling 12 months.



### Vennont

The Vennont Deparent of 

### Environmenta Consrvation ("VT DEC") does not define emergency in its regulations. To allow emergency engines to operate in the ISO-NE emergency

DR program, the VT DEC developed "A Deparent Procedure On Operation of 

### Emergency Engines Durng a Grd Capacity Event" in December, 2005 and revised in Janua, 2007.


### Vennont does not limit the hour of paricipation by emergency engines in iSO New England's emergency DR program. Emergency engines in Vennont are limted to 200 hours for

testig and maitenance and unlimited use for emergencies.



### Maine

The Maine Deparent of 

### Environmenta Protection ("ME DEP") handles the pennitting of

emergency engies in the ISO-NE emergency DR progr on a cae-by-cas bais either by 

## modifg individua ai permts or issuig ai permts for engines that reuire a permt.

5

# Attachment 19

How PJM States Handle Emergency DR Attachment 19



# How PJM States Handle Emergency DR

## How PJM States Handle Emergency DR

Maryland On April 15, 2009 the Maryland Secretary of the Environment adopted amendments of Regulation .01 under COMAR 26.11.09 Control of Fuel-Burning Equipment, Stationary Internal Combustion Engines, and Certain Fuel Burning Installations. The adopted amendments became effective on May 18,2009. Specifically, the Maryland Department of the Environment ("MDE") enacted the following language in its regulations as part of its definition of emergency (emphasis added): 26.11.09.01 B. (2-1) (b) "Emergency" includes a PlM declared emergency. (2-2) "Emergency generator" means: (b) 

### An engine that operates during an emergency according to the procedures in the PJM Emergency Operations Manual for a PJM declared emergency. (4-4) "PJM Declared Emergency" means a condition that exists where the PJM Interconnection, LLC notifies electric distributors that an emergency exists or may occur and it is necessary to implement the procedures in the PJM Manuall3 Emergency Operations, as revised Emergency engines greater than 500 hp are required to obtain a Construction Permit from MDE. These permits typically do not specify any limits on emergency operation nor do they have any specific limits for operation during the ELRP. Pennsylvania The Pennsylvania DEP does not define emergency in its regulations but is supportive of using emergency engines in the ELRP. Engines covered under the DEP's regulations can 

## How PJM States Handle Emergency DR

Marland

On April 15,2009 the Marland Secreta of 

### the Environment adopted amendments of

Reguation .01 under COMA 26.1 1.09 Control of 

## Fuel-Burg Equipment, Stationa Internal

Combusion Engines, and Certn Fuel Burng Instaations. The adopted amendments became

effective on May 18,2009. Specifically, the Marland Deparent of 

### the Envionment ("MDE") 

## enated the followig languge in its reguations as par of its defirtion of emergency (emphais added): 26.1 1.09.01 B. (2-1) (b) "Emergency" includes a PlM declar emergency. (2-2) "Emergency generator" mean: (b) An engine that operates during an emergency according to the procedures in 

### the P JM Emergency Operations Manual for a P JM declared emergency. 

### (4-4) "P JM Declared Emergency" means a condition that exists where the P JM Interconnection, LLC notifies electric distributors that an emergency exists or may

occur an it is necessar to implement the procedures in the PJM Manual 

### 13 Emergency 

### Operations, as revised
Emergency engines grter th 500 hp ar requid to obta a Consttion Pert from 

## MDE. These permts tyicaly do not speify any limits on emergency operaon nor do they have any specific limts for operation durg the ELRP. 

## Pennylvana The Pennlvana DEP does not defie emergency in its reguatons but is supportive of 

### using emergency engines in the ELRP. Engies covered under the DEP's reguations ca

### operate under a permit by rule, general permit, or individual permit depending on emissions.

The Pennsylvania DEP does not limit the hours of participation in the ELRP other than through its normal permitting mechanisms (e.g., permit by rule, general permit, or individual permit).
Virginia The Virginia Department of Environmental Quality ("DEQ") has adopted a policy (DEQ memo dated May 15,2009 from Michael G. Dowd - (see Attachment to this Section) expanding the definition of "emergency" as currently defined under 9 VAC 5-80-1110 C to incorporate operation as part of an Independent System Operator's ("ISO") ELRP. The DEQ allows a maximum of 60 hours per year operation of emergency engines in the ELRP.

Ohio The Ohio EPA ("OH EPA") is in the process of changing its definition of emergency to allow for use in the ELRP. On April 24, 2009 the OH EPA issued for public comment the following change to its definition of emergency in OAC Chapter 3745-31-01 (MM) (3): Conditions where a 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. The OH EPA did not propose an hour limit for engines operating in the ELRP.

2 

### operate under a permit by rule, general perit, or individua permit depending on emissions. 

### The Pennylvana DEP does not limt the hour of parcipation in the ELRP other than though its normal permittng mechansms (e.g., permt by rule, general permt, or individua permit). 

# Virgia

The Virgia Deparent of 

### Environmenta Quaity ("DEQ") ha adopted a policy (DEQ memo dated May 15,2009 from Michael G. Dowd - (see Attchment to this Section) expanding

the defintion of 

### "emergency" as curently defined under 9 VAC 5-80-1110 C to incorporate 

### operation as par of an Independent System Operator's ("ISO") ELRP. The DEQ allows a 

### maxum of 60 hours per year operation of emergency engines in the ELRP.

Ohio The Ohio EPA ("OH EPA") is in the process of changing its defition of emergency to 

### allow for use in the ELRP. On Apnl24, 2009 the OH EPA issued for public coinent the 

### followig change to its definition of emergency in OAC Chapter 3745-31 -0 1 (MM (3): 

## Conditions where a regional trmission organtion notifies electrc distributors than an emergency exist or may occur and it is necessar to implement emergency 

## procdures for volunta load curlments by customers with Ohio, in response to unusualy low frequency, equipment overload capacity or energy deficiency, uneptale voltage levels, or other emergency conditions leadng to a potential

eleccal blackout. 

### The OH EPA did not propose an hour limit for engies operatig in the ELRP.

2

### Illinois

The Illinois EPA ("IEPA") endorses the use of emergency engines in the ELRP and has determined that change to its regulations is not required to allow this. Emergency engines greater than 1,500 hp are required to obtain a Construction Permit from IEPA. These permits typically limit emergency operation to 500 hours per year and do not require modification to allow for operation during the ELRP. West Virginia The West Virginia DEP endorses the use of emergency engines in the ELRP and has determined that change to its regulations is not required to allow this. Allegheny County The Allegheny County Health Department ("ACHD") handles the permitting of emergency engines in the ELRP on a case-by-case basis either by modifying individual air permits or issuing air permits for engines. To date the ACHD has issued permits with a 60 hours per year limit for engines participating in the ELRP.
Indiana
The Indiana Department of Environmental Management ("IDEM") requires a filing be made for emergency engines that want to enroll in the ELRP so that a Notice of Exempt Construction and Operation Status can be made. The IDEM does not limit the hours of participation by emergency engines in the ELRP. Emergency engines in Indiana are typically limited to 500 hours per rolling 12 months.

3 

## Ilinois The Ilinois EPA ("IEP A") endorses the use of emergency engines in the ELRP and has 

### determned that change to its reguations is not required to allow ths. Emergency engines greater than 1,500 hp are required to obtan a Constrction Permit from IEP A. These permits 

### tyicaly limit emergency operation to 500 hour per year and do not require modification to allow for operation durng the ELRP.

West Virgina 

### The West Virgina DEP endorses the use of emergency engines in the ELRP and has 

## determined that chage to its reguations is not requied to alow ths. Allegheny County The Allegheny County Health Deparent ("ACHD") handles the permttg of emergency 

## engines in the ELRP on a case-by-cas basis either by modg individua ai permts or issuig air permits for engines. To date the ACHD has issued permts with a 60 hour per year limt for engines paricipating in the ELRP.
Indiana

The Indian Deparent of 

## Envionmenta Magement ("IDEM") reuies a fiing be made

for emergency engines that wat to enroll in the ELRP so that a Notice of Exempt Constction 

### and Operation Stas can be made. The IDEM does not limit the hours of parcipation by 

## emergency engies in the ELRP. Emergency engies in Indiana ar tyically liited to 500 

## hour per rollig 12 month.

3L PrestOIl Bryant. Jr.

Secretary of Natural Reseurces 

# COMMONWEALTH of VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY Street address: 629 East Main Street, Richmond, Virginia 232/9 Mailillg address: P.O. Box 1105. Richmond. Virginia 23218

TDD (804) 698-4021 www.deq. virginia.gov David K. Pa}-ior Director (8041 0<}8-4020 1·8(l()..S9~-5482 

### MEMORANDUM TO: Regional Directors, Director - Air Permits, Director - Air Compliance,

Director - Data Analysis and Planning, Director - Regulatory Affairs. Air Permit Managers, Air Compliance Managers Richard F. Weeks. Chief Deputy Director James J. Golden, Deputy Director for programjVelOpment Michael G. Dowd - Director. Air Division 

# !(~ cc.

FROM: SUBJECT: APG-570: Interim Guidance for Permit Applicability for Emergency

Generators Participating in an Emergency Load Response Program DATE: May 15, 2009

Purpose: 

### This policy provides interim guidance to air permitting and compliance staff concerning permit applicability for emergency generators. The policy expands the definition of "emergency" as currently defined under 9 VAC 5-80-1110C to incorporate operation as part of an Independent System Operator's (ISO) Emergency Load Response Program. This policy does not apply to generators that are used for voluntary load response (i.e. load curtailment, demand response, or peak shaving). This guidance is not intended to cover every possible situation but should be applicable in most scenarios. Check with the regional air permit manager and/or the central office staff if a deviation from the guidance is considered to be necessary.

. Background: 

### The 2009 Acts of the Assembly adds section numbered §10.1-1307.02 to the Code of Virginia, and requires the air board to adopt a general permit or permits for the use of back-up generation. The statute requires the definition of "emergency" to be expanded to include emergency generation sources that operate during periods in which the independent system operator has notified electric utilities that an emergency exists or may occur. The general permit or penn its shall include a definition of "emergency" (developed by the board) that is compatible with the ISO's emergency operations manual. The upcoming general permit andrevisions to Article 6 will include a definition for "emergency generation source" and "ISOdeclared emergency" that was taken verbatim from the underlying legislation and as included in this guidance. L Prestoß Bryant. Jr. Secetry of Natural Rcsource: COMMONWEALTH of 

# VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY Street address: 629 F..'\t Main Street, Rkhmond. Virginia 232/9 Mailiig ai/dress: P.O. Box I LOS. Richmond, Virginia 232 is

TDD (804) 698-4021 www.deq. virginia.guv David K. Pó1)1or Din.'Cior (8041 698-40 1.8059~-5482 

### MEMORANDUM 

### TO: 

### Regional Direcors, Director - Air Permits, Direcor - Air Copliance,

Director - Data Analysis and Planning, Director - Regulatory Affairs, Air 

### Permit Managers, Air Compliance Managers 

### Richard F. Weeks, Chief Deput Director 

## James J. Golen, Dep Direr lo proramjVelOpment Michael G. Dow - Direcor, Air Division l( ¿' 

# cc:

FROM: SUBJECT: APG-570: InterIm Guidance for Permit Applicabilty for Emergency



### Generators Partipating in an Emergency Load Response Program
DATE: 

### May 15, 200 

## Purpse: This policy provides interim guidance to air permiting and compliance stff concerning permit 

### applicabilit for emergency generators. The policy expands the definition of "emergency as currently defined under 9 VAC 5-801110C to incorporate operation as part of an Independent 

### Sytem Oprator's (ISO) Emergency Load Respose Program. This policy does not apply to 

### generators that are used for voluntary load response (i.e. load curtilment, demand respse, or peak shaving). This guidance is not intended to cover every possible situation but should be 

### applicable in most scenario. Chec with the regional air permit manager and/or the central 

## office stff if a deviatio from the guidance is considered to be necessary. . Background: The 20 Acts of the Assembly adds secton numbered §10.1-1307.02 to the Coe of Virginia, and requires the air board to adopt a general perit or permits for the use of back-up geeration. The statue requires the definition of "emergency to be expanded to include 

### emergency generation sources that operate during periods in which the independent system 

### operator has notified electric utilities that an emergency exists or may ocur. The general
permit or penn 

### its shall include a definition of "emergency" (developed by the bord) that is 

### compatible wih the ISO's emergency operations manuaL. The upcoming general permit andrevisions to Artcle 6 will include a definiton for "emergency generation source" and "ISOdeclared emergency" that was taken verbatim from the underlyng legislation and as incuded in this guidance.

### Permit Applicability for Emergency Generators and ISO Emergencies May 15, 2009 Page 2
Applicability: This guidance applies to generators that operate as emergency generators (as stated in 9 VAC 5-80-1110 under "emergency") and that operate in an ISO's emergency load response program. such as Pennsylvania New Jersey Maryland Interconnection, LLC (PJM). Definitions: New definitions: 1. "Emergency" means a condition that arises from sudden and reasonably unforeseeable events where the primary energy or power source is disrupted or disconnected due to conditions beyond the control of an owner or operator of a facility including: a. A failure of the electrical grid, b. On-site disaster or equipment failure, c. Public service emergencies such as flood. fire. natural disaster, or severe weather conditions, d. An ISO-declared emergency, where an ISO emergency is: • An abnormal system condition requiring manual or automatic action to maintain system frequency, to prevent loss of firm load, equipment damage. or tripping of system elements that could adversely affect the reliability of an electric system or the safety of persons or property. • Capacity deficiency or capacity excess conditions. • A fuel shortage requiring departure from normal operating procedures in order to minimize the use of such scarce fuel. • Abnormal natural events or man-made threats that would require conservative operations to posture the system in a more reliable state. • An abnormal event external to the ISO service territory that may require ISO action. 2. "Emergency generation source" means a stationary internal combustion engine that operates according to the procedures in the ISO's emergency operations manual during an lSO-declared emergency. 3. "Independent system operator (ISO)" means a person that may receive or has received, by transfer pursuant to §56-576. any ownership or control of, or any responsibility to operate, aUor part of the transmission systems in the Commonwealth. 4. "ISO-declared emergency" means a condition that exists when the independent system operator (ISO) notifies electric utilities that an emergency exists or may occur and that complies with the definition of -emergency· adopted by the Board pursuant to 10.1- 1307.02 B. Permit Applicabilty for Emergency Generators and ISO Emergencies May 15, 2009

Page 

### 2


### Applicabilit: This guidance applies to generators that operate as emergency generators (as stated in 9 VAC 5-80-1110 under "emergencY') and that operate in an ISO's emergency load response program. such as Pennsylvania New Jersey Maryland Interconnection, LLC (PJM). 

### Definitons: New definitions: 

### 1. "Emergency means a conditon that arises from sudden and reasonably unforeseeable events where the primary energy or power source is disrupted or discnneed due to 

### conditions beyond the control of an owner or operator of a facilit including: a. A failure of the electrical grid, 

### b. On-site disster or equipment failure, c. Public service emergencies such as floo, fire, natural disaster, or severe weather 

### conditions, 

### d. An ISO-declared emergency, where an iSO emergency is: . An abnormal system condition requiring manual or automatic action to maintain system frequenc, to prevent loss of firm load. equipment damage, or tripping of 

### system elements that cold adversely affect the reliabilit of an electrc sytem or the safety of persons or propert.

. Capacity deficienc or capacit excess conditions.
. A fuel shortge requiring departre from normal operating procedures In order to 

### minimize the use of such scrce fueL.

. Abnormal natural events or man-made threats that would require consrvative 

### operations to poture the system in a more reliable state. 

### . An abnormal event external to the ISO servic territory tht may require ISO 

### action. 

### 2. "Emergency generatin source" means a statinary internal cobuston engine that operates according to th procedures in the ISO's emergency operations manual during an ISO"Cecared emergency. 

### 3. "Independent system oprator (ISO)" means a persn that may receive or has recived, 

### by trer pursuant to §56-576, any owership or control of. or any responsibilit to operate, aU or palt of the trnsmissio sysems in the Commonwealt. 4. "ISO"Ceclared emergency means a coition that exists when the independent system operator (ISO) noties eleetc utilities that an emrgenc exists or may ocr and tht complies wih the definiton of "emergency" adopted by the Bord pursuant to 10.1- 1307.02 B.

### Permit Applicability for Emergency Generators and ISO Emergencies May 15, 2009 Page 3
Implementation: As of the date of this document, regional permitting shall use the new definition of "emergency" (as stated above) when evaluating emergency generator permit applicability. This definition will be incorporated in a general permit (required by law) and in Article 6. Uncontrolled emissions should be calculated based on 500 hours of operation as currently specified in 9 VAC 5-80-1320 B.2. Regional permitting shoufd use the following steps: 1. If the unit is determined to be exempt from oel'mittinq; The regional permitting staff should issue a permit exemption letter using the attached boilerplate. This boilerplate was designed to identify to the facility and DEQ that this emergency generator. a. Is participating in an ISO Emergency Response Program. b. Is being registered. c. Shall not be operated voluntarily for the purpose of peak-shaving, demand response, or as part of any other interruptible power supply arrangement with a power provider, other market participant, or system operator. If the unit is subject to NSPS Subpart 1111,NSPS Subpart 

### JJJJ, and/or MACT SUbpart 

### Z:ZZZ, the regional permitting staff should follow guidance document APG-569: Guidance to Implement and Enforce Non-delegated Federal Regulations. The "Example language" paragraph has been placed in the exemption boilerplate as an option. 2. If the unit requires a permit The regional permitting staff must include in the permit a. All necessary conditions to show compliance with the permit and emergency status. b. A statement that the emergency generator is participating in an ISO Emergency Response Program; for example, this may be included in Condition 1 in the equipment list table. If the unit is subject to NSPS Subpart 1111,NSPS Subpart 

### JJJJ, and/or MACT Subpart 

### ZZ;ZZ, the regional permitting staff should follow guidance document APG-569: Guidance to Implement and Enforce Non-delegated Federal Regulations. 3. If the unit was alreadY issued a Dermit because ISO emergencies were not inc1udes;lin the previous "emergency" definition: If requested by the pennittee, the regional permitting staff may consider issuing an exemption letter and rescinding the current permit as long as there Is no backsliding. If an emergency generator was issued a permit with BACT conditions, this permit cannot be rescinded and an exemption cannot be granted. .
Questions or comments on this guidance should be directed to the Office of Air Permit Programs. Permit Applicabilty for Emergency Generators and ISO Emergencies May 15, 2009

Page 

### 3


### Implementation: As of the date of this document, regional permitting shall use the new definition of "emergenc 

### (as stted aboe) when evaluating emergeny generator permit applicabilit. This definition will be 

### incorated in a general permit (required by law) and in Artcle 6. Uncntrolled emissions should

be calculated 

### baed on 50 hors of operatin as currently speifie in 9 VAC 5-80132 B.2. 

### Regional permitng should use the followng steps: 1. If the unit is deterined to be exempt from oermittnq: The regional permitng stff should isse a permit exemption letter using the attched 

### bolerplate. This bolerlate was designed to identi to the facilit and DEQ tht this 

### emerenc generator: a. Is participating in an ISO Emergency Respns Program.

b. Is being registered. 

### c. Shall not be operated voluntarily for the purp of peak-shaving, demand respoe, or as part of any other interrptble power suppy arrangement with a 

### powr proider, oter market participant, or system operator. 

### If the unit is subjec to NSPS Subpart ~I~, NSPS Subpart JJ, and/or MACT SUbpart i:, 

### the reional permiting stff should follo guidan docment APG-569: Guidance to Implement and Enforce No..elegated Federal Regulations. The "Example language" 

### paragraph has been placed in the exemption boilerplate as an option.

2. If the unit requires a permit 

### The reional permitng stff must include in the permit
a. All necssry coditons to show compliance wi the permit and emergeny sttus.
b. A sttement tht th emergency generaor is partcipating in an iSO Emergenc 

### Resp Program; for exaple, this may be included in Coit 1 in the equipmnt list tale. 

### If the unit is subje to NSPS Subarlll, NSPS Subpart JJJJ, and/or MACT Subpart i:, the region permitng st should follow guidance document APG-569: Guidance to 

### Implement and Enforce Non-delegated Federal Regulations.

3. If th unit was alre issed a Dermit beuse ISO emergencies were not inçludes in the 

## pres "emerenc definition: If reuesed by the peittee, th regional permiting staff may considr issuing an exemptin letter and resinding th curren permit as long as th Is no baksliding. If 

### an emerg generator was issued a peit wi BACT conditons, this peit canot be rescind and an exempton canno be granted. '


### Questions or coments on this guidance should be directed to the Ofice of Air Permit 

### Programs.

### Permit Applicability for Emergency Generators and ISO Emergencies May 15,2009 Page 4



### EMERGENCY GENERATOR AND ISO EMERGENCIES BOILERPLATE EXEMPTION LETTER

DATE
«MrMs» ccFlrstName» «Middlelnitial •• «LastName') «Title» ••Company» ccStreetName» «City ••, «State» «Zip» Location: «CountyCity •• [Registration No.: ••RegNo ••] [AFS 10 

### No. 51-. c 

### CountyNo»-«PlantNo»]
Dear «MrMs •• «LastName»: This letter acknowledges receipt of your [permit application][exemption request letter] dated «AppIDate». The Deparbnent of Environmental Quality (DEQ) «Region» staff has completed its initial review of yoUr request to «Construct» and operate (an emergency generator rated at ccRating»][multiple emergency generators rated at «Rating'), respectively] that also participates in PJM's Emergency Load Response Program (ELRP) at «Location».
Based on this review. it has been determined that the proposed project is exempt from the permitting requirements of Chapter 80, Article 

### 6 of the Virginia Regulations for the Control and Abatement of Air Pollution as long as it is constructed and operated as described in your [application][exemption request letter). The proposed project is not subject to Major Source New Source Review under Articles 8 or 

### 9, and:
• {The proposed change does not meet the definition of "«Construction»D in 9 VAC 5- 80-1110 C because {insert reason}.] • {The proposed change Is excluded from the definition of "modification" in 9 VAC 5- 80-1110 C because {insert reason}.] • {The proposed change is a reconstruction of a stationary source or emissions unit and .the uncontrolled emissions based on 500 hours of operation resulting from the reconstruction will not Increase (9 VAC 5-80-1320 A.1.b).] • {The proposed change is a relocation of a portable emissions unit that Is previously permitted and is suitable for the area to which it will be relocated (9 VAC 5-8()..1320 A.1.c}.) 

### Permit Applicabilit for Emergency Generators and ISO Emergencies May 15,2009

Page 

### 4

EMERGENCY GENERATOR AND ISO EMERGENCIES 

### BOILERPLATE EXEMPTION LETTR

DATE

ccMrMs)) ceFirstName)) ..Middlelnitial)) (cLastName.. ccTitle)) ccCompany)) 

### ceStreetName)) "City,., "State" c(Zip)) Lotion: "CountyCit.) (Registration No.: c(RegNo..) 

### (AFS 10 No. 51-ccCountyo"-ccPlantNo).) Dear "MrMs.) "LastName..: This letter acknowedges receipt of your (permit application)(exemption request letter) dated 

### etAppIDate... The Deparnent of Environmental Qualit (DEQ) ((Region)) staff has completed it initial review of yor request to "Construct" and operate (an emergency generator rated at (cRating")(multiple emergenc generators rated at ((Rating.., respecvely) that also partcipates in PJM's Emergency Load Response Program (ELRP) at "Location..,


### Based on this review, it has been determined tht the proposed projec is exempt from the 

### permiting requirements of Chater 80, Aricle 6 of the Virginia Regulations for the Cotrl and Abatement of Air Polluton as long as it is constrcted and operated as described in your (application)(exemptlon request letter). The propsed project is not subjec to Major Source 

### New Sourc Review under Artcles 8 or 9. and:


### . (Te proposed change doe not meet the definition of "(cConstrction))" in 9 VAC 5- 

### 801110 C becuse (insert reason).)

. (Te prop change Is excluded from the definiton of "modification" in 9 VAC 5- 

### 801110 C beause (insert reason).) 

## . (Te propoed change is a reconsio of a sttionry soce or emisio unit and , the unctrolled emissions based on 50 hours of opratin reultng from the recstrution will not Incrase (9 VAC 5-80132 A.1.b).) 

### . (Te proposd change is a relon of a poble emissions unit tht Is previusly permited an is suitle for th area to whic it will be relocted (9 VAC 5-1320 A.1.c).)

### Permit Applicability for Emergency Generators and ISO Emergencies May 15, 2009 Page 5 • [The proposed change is the reactivation of a previously [permitted source which has not been permanently shutdown and irs applicable permit conditions revokedJ[grandfathered source which has not been permanently shutdown in accordance with 9 VAC 5-20-220 (9 VAC 5-80-1320 A.1.d).] • [The proposed change is the use of an [alternative fueO[raw materiaij for which the emissions resulting from the use of the [alternative fuelJ[raw materiaij have been demonstrated to decrease (9 VAC 5-80-1320 A.l.e).] • [The proposed Change includes {list equipment}, which [is}[are] exempt from permitting by size or source type as listed in 9 VAC 5-80-1320 S.] • [The uncontrolled emissions based on 500 hours of operation of {list pollutants} from [the remainder of] the source for which [constructionJ[relocation] is proposed is {list the "uncontrolled emissions" for each pollutant emitted} which is less that the exempt emission rates for those pollutants listed in 9 VAC 5-80-1320 C.] Additionally, there are no HAPs or toxic pollutant emissions from the source[.][ which would be subject to permitting under Article 6 because:]
• [All applicable HAPs emitted from the source are exempt from permitting under an applicable source·wide MACT standard (9 VAC 5..ao.300 C.5 and 9 VAC 5-80-1320 F.] [Roally, the facility is not subject to any NSPS standards.] [Based on this review, it has been determined that the proposed project is exempt from the permitting requirements of Chapter eo, Article 6 of the Virginia Regulations for the Control and Abatement of Air Pollution as per 9 VAC 5·80-1320 B for generators of your size, fuel type. and number of hours of operation. However, the proposed generator Is an affected facility under [40 CFR 60, New Source Performance Standard (NSPS)] [40 CFR 63, Maximum Achievable Control Technology, (MACT)], Subpart [Subpart 10], therefore subject to owner/operator requirements of the [NSPS) [MACT]. In summary, the unit is required to comply with certain federal emission standards and operating limitations over its useful life. The Department of Environmental Quality (DEQ) advises you to review the attached [NSPS] [MACT] to ensure compliance with applicable emission and operational limitations. As the owner/operator you are also responsible for monitoring. notification, reporting and recordkeeping requirements of the [NSPSJ [MACT]. Notifications shaH be sent to EPA, Region 11/;]
This decision concerning permit applicability is not binding upon the Department and is subject to change upon further review.
Although this «FacilityType» is not subject to permitting requirements, it is still subject to the registration requirements of 9 VAC 5-20-160 of the Regulations and subject to periodic inspections by the Department. [Please submit a completed Form 7 for registration purposes.] The information that you have submitted will be kept on file. Please refer to the Registration Number on all future correspondence dealing with your facility. 

### Permit Applicabilit for Emergenc Generators and ISO Emergencies May 15, 200

Page 

### 5 

### · (The propsed change is the reactvatin of a previously (permitted source which has not been permanently shutdown and its applicable permit conditions revokedJ(grandfathered source which has not been permanently shutdown in 

### accordance with 9 VAC 5-20-220 (9 VAC 5-80132 A.1.d).)
· (The proposed change is the use of an (alternatie fueij(raw materiaij for which the emissions resultng from the use of the (alternatie fuelJfraw materiaij have been 

### demonstrated to decreas (9 VAC 5-80132 A.l.e).)
· (Te proposed change includes (list equipment), which (isJfare) exempt from 

### permiting by size or source tye as listed in 9 VAC 5-801320 S.) 

### · (The uncontrolled emissions based on 500 hours of operation of (list pollutnts) from (the remainder of) the source for which fconstrucionJ(reloctionJ is propsed is (list 

### the "uncotrolled emissions" for each pollutant emited) which is less that the exempt emission rates for those pollutants listed in 9 VAC 5-81320 C.J Additonally, there are no HAPs or toxic pollutant emissions from the source(.)( which would be subject to permitting under Article 6 because:)

· (All applicable HAPs emited from the source are exempt from permitng under an 

### applicable source-wide MACT stndard (9 VAC 5-6300 C.5 and 9 VAC 5-80-1320 F.) 

### (Roally, the facilit is not subjec to any NSPS stadards.J (Based on this review, it has been determined that the proped projec is exempt from the permitng requirements of Chapter eo, 

### Artcle 6 of the Virginia Regulations for the Control and Abatement of Air Pollution as per 9 VAC 

### 5-801320 B for generators of your size, fuel ty, and number of hours of operation. However, 

## the pro generator Is an affeced facilit unde (40 CFR 60, Ne Sorce Perfance Standrd (NSPS)J (40 CFR 63, Maximum Achievle Cotrol Technlo, (MCT)), Subprt 

### (Subart 10), therefore subjec to ower/operator reuiremts of the (NSPS) (MACT). In 

### summary, the unit is required to coply wi certin federal emission stans and operating limittins over it usel life. The Departent of Environment Qualit (DEC) advises you to review the atched (NSPS) (MACT) to ensure compliance wi applicale emiss and
oprational limittion. As the owner/operator you are als reponsible for monitorng, notiftion, reprt and recdkeeing requireent of the (NSPSJ (MACT), Notions shaH be sent to 

### EPA, Regio /I!;J


### This decision coerning permit applicabilit is not binding upon the Departen and is 

### subjec to chang upo furter review.
Although this uFaciltyType)) is not subjec to permitng requirements, it is stil subjec to the registration requirement of 9 VAC 5-20-160 of the Regulations and subj to periodic 

### inspections by th Departent. (Please submit a copleted Form 7 for registrtion purposes.) The informatin that you have submited will be kept on file. Plea refer to the Registration 

### Number on all fure corrpondenc dealing with your facilty.

### Permit Applicability for Emergency Generators and ISO Emergencies May 

### 15,2009 Page 6

You are cautioned that this decision also should not be construed to mean that your operation is automatically in compliance with all aspects of the Regulations for the Control and Abatement of Air Pollution. Regional personnel will be constantly evaluating all sources for compliance with the Regulations.
Other than PJM's ELRP, as presented in the letter request, the engine-generator set shall not be operated voluntarily for the purpose of peak-shaving. demand response, or 

### as part of any other interruptible power supply arrangement with a power provider. other market participant. or system operator, without first receiving permission from the DEQ.
Any owner claiming that a facility is exempt from the provisions of 

### 9 VAC 

### 5. Chapter 

### 80. Article 

### 6 shall keep records in accordance with 

### 9 VAC 

### 5-80-1320 A.4 as may be necessary to demonstrate to the satisfaction of the Department its continued exempt status. Records shall include, but are not limited to, the monthly hours of operation and reason for operation including participation in PJM's ELRP, documentation of a PJM declared emergency, emergency operation. testing of the unit, and!or maintenance. Total combined operating hours of the engine-generator set shall not exceed 

### 500 hours per year.

If you have questions concerning this matter please contact «Engineer» at «RegPhone». Your concern for Virginia's Air Quality is appreciated.
Sincerely.

cAPMName» Regional Air Permit Manager cAPMlntials»! «Engrl nitials»! «FileName» [encl: Form 7]


## cc: file Permit Applicabilty for Emergency Generators and ISO Emergencies May 15,2009

Page 

### 6

You are cautioned that this decision also should not be construed to mean that your 

### operation is automatically in compliance with all aspes of the Regulations for the Conrol and Abatement of Air Pollution. Regional personnel will be constantly evaluating all source for compliance with the Regulations.


### Other than PJM's ELRP, as prsented in the letter request, the engine-generator set shall not be operated voluntarily for the purpse of peak-shaving, demand response, or as part of any other inerrptble power supply arrangement with a power provider, other market participant, or system operator, without firs receiving permission from th DEQ.


### Any owner claiming that a facilit is exempt from the provisions of 9 VAC 5, Chapter 80, Article 6 shall keep records in accordance with 9 VAC 5-0-1320 A.4 as may be necessary to 

### demonstrate to the satisfaction of the Departent its continued exempt status. Records shall include, but are not limited to, the monthly hours of operation and reason for operation including 

### participation in PJM's ELRP, documentation of a PJM declared emergency, emergency 

### operation, testing of the unit, and/or maintenance. Total combined operating hours of the engine-generator set shall not exceed 500 hours per year.
If you have questions concerning this matter please contact ((Engineer~ at ((RegPhone)). 

### Your concern for Virginia's Air Quality is appreciated.


### Sincerely,

cAPMNamelt Regional Air Permit Manager cAPMlntialsi./ ((Engrl nitials,;/ ((FileNamelt

(encl: Form 71 

# cc: file

# Attachment 20

TCEQ Letter Regarding Use of Emergency Engines in ElLS Attachment 20



# TCEQ Letter Regarding Use of Emergency Engines in ElLS

### BudcIy Gacia, CMimum

Lmylt 

### Sowant. ~ Brym W. Sbaw.Pb.D •• ~ GJeml SJwnkIe, EJm:uIiw DIrctDr



## TExAs COMMISSION ON ENvIRONMENTAL QuALITY

Prot#Jctbtg T&ra by 

### RedllclngtllUl ~ Polltdkm



### January 29. 2008
Mr. Don DiCristofaro, CCM President Blue Sky 

### Bnvimmnental u..c 

### 105 Chestnut Street; Suite 37 NcwUmn. MA 02492 Subject Use ofBmergeacy Engines in BRCOT's ElLS Program Dear Mr. DiCristofaro: Thank you for your December 11, 2007 letfa' explaining the BRCOT Emergency 1Dteaupti.b1e Load Service (Iill.S) Program. To eDS1IIewe 1blly understood the program. we discussed it 

### with Mr. Paul Wattles at BRCOT 

### on J8IlU8IY 

### 17,2008. He confirmed that ROOT's ElLS was developed as an additional step (Step 3) in their Emersency Electric Curtailment Plan (EBCP) to .help stabilize the gird and prevent than fiom directing roDiDs blackouts in Step 4. . ElLS is directed ouly durina a grid emergency. After discussing this new information with our legal and rule developmelit stafii, I agn:e that if III GP1ergency 

### lenaator is authorized and operaUnl under Permit by 

### Rule (PBR) 106.511, 

### that PBR 106.511 

### does not prohibit the participation of an emerpncy lenerator in the BRCOT BILS Program. If the poerator is nm whea directed by BaCOT 

### as part of the ElLS declated emergency at Step 3 of their BBCP, they will be in compliance with the intaJt ofPBR 106.511 

### and the ~ generator will not requiJ:e addiCiODBl authorimion. as long as the pnerator continues to meet all requiJanems ofPBR 106.511, inchMting the tatrictions for the Il1IIDber 

### of hours the pnerator may operate. Participation in the ElLS program (and diJection from . BaCOT) 

### wiD DOt 

### provide emeqaacy 

### paerators an 

## acuse to exceed the hours of opemtion requirement (orotherrequiJanems) inPBR, 106.511. Please be advised that this letter in no way authorizes the operation of any specific emergCllCY back-up pnerator caaine opentina UI1de.r the authority ofPBR 106.511 and that any facility that proposes to construct aad operate will be subject to all applicable requirements lU1der 

### CIapters 101,106 and 117.

P.O••• 13017 • ADItiD. Teaa787ll·3087 • '12-239-1000 • 1Dr.mIet1ddlea: www.tc:eq. ••••• tx.ua



# •••••••••••••••••••••••••••••• 

# Bud Ga CM 

# Lmlt So ~ Bi w. Sbw. Ph.. 0m 

# GJe SJ Ei DI 

# f)

TE COMMION ON ENONMAL QuAL Pr Tøa by Redøu ~ Pøll

Jan 29, 2008 

## Mr. Do DiCrfa, CCM 

# Prde Blu Sk Bnvi u. 105 Oies Str Suite 37 

## Ncw. MA 0292 

## Subec Use ofBmer Enes in BRCOT's El Prgr
De Mr. DiCrifa: 

# Th you fo yo Deem II, 200 let exlabng the BRCOT Em IDle Load Sece (I Prgr To ea we 1b un th prgr we di it wi Mr. Pau Wat at BRCO on Jai 17,2008. He coii th ROOs El wa 

# deelop as an adtion st (Ste 3) in th P. Elecc Culmen Pla (E) to 

# 'he stil th gi 8D pr th fi di 1oll bla in Ste 4. . El is di omy du a gr emer. Af di tb new inOlon wi ou leg en rue develop st, I ag th if 

## II eø len is au en opi unde Per by Ru (P) 106.511, th PBR 106.s11 does not prhi th paon of an emcq len in th BRCOT BI 

### Prgr If the poer is nm whea di by BaCO as par of th El dela

emer at Ste 3 of 

### th BB, th wi be in coli wi th in ofPBR 106.511 

# an th eø pner wi no re adou auoi as lo as th pi co to me al re ofPB 106.511, inlu th iacton fo th Il of Ii th pi may op Paaton in th El prgr (an dion fr , BaCO wi DO prvide em pi an ac to ex th hour of opon 

## re (orot re) inPBR 106.511. 

# Plea be ad th tb let in no way au th op of an spifc emerCl ba-u pi ca op ui th auty ofPBR 106.511 ra tb an fa th 

# pi to CO aa op wi be suec to al aplile reents \U Ci
101,106 an 117.



### P.O. Bo 130 · Au Tea 7811.30 · '12-239-100 · ID id: WW.tc..txui



# .............

### Mr. Don DiCrlstofaro, CCM

Page 2 1anuary 29, 2008 Re: Use ofEmerpncy &pes in BaCOT's 

### EILS Program

Thank: you for your cooperation and interest in air pollution contml. If you need fbrther information or have any questions, please contact Mr. fa Linville at 512 239-1261 or write to tho Texas Commission on Environmental Quality, omce of Pemitting, Remediation, and Registration, Air Permits Division (MC-163), P.O. Box 13087, Austin. Texas 78711-3087. Sincerely, 

# ~4>.~~
Richard A. Hyde, P.B., Director Air Permits Division Office of Permitting, Remediation. and. Registration Texas Commission on Environmental Quality RAHI1GUbis

00: 

### Mr.1ay Tonne" CbiefEngineer's Oftice, MC 206 Mr. Vmcent Meiller, ChiefBngineer's 0Bice, MC 206 Booker Harrison, Env:ironmeatal Law Division, 

## Me 173 1anis Hudson, Environmental Law Division, MC .173 Teny Salem, Environmental Law Division, 

## Me 173 Fa 

### Linville, Air Pamits Division, 

## Me 163 Steve Hagle, Air Permits Division, MC 163

<, 

## Mr. Don DiCrfa, CCM

Pag 

### 2 1an 29, 2008 

# Re: Use ofEm Bn in BaCO's mi Prgr 

# Th you fo your coon an in in ai pollon col. If you nee fb inon or hae any quon plea cota Mr. rim Li at 512 239-1261 or wrte to 

# th Tex Coon on Enen Qu, omce of Penit Reedon and Reon Ai Perts Divion (MC-163), P.O. Box 13087, A. Tex 78711-3087. 

# Siny, 

# 'l~.~~

Richa A. Hyd P .B., Dir 

# Ai Perts Di

Ofce of 

# Perttg, Reediaton an Reon 

# Tex Coisson on En Qu RAGUis

00: Mr.1ay Tom CbefEngi's Of MC 206 Mr. Vmc Mei, ChefBnees OBce MC 206 

# Bo Ha Ei La Divion MC 173 

# 1an Hu En La Dion MC .173 Tmy Sal En La Dion MC 173 Tmi Lie, Ai Pei DiOD MC 163 Stee Ha Ai Per DiiOD MC 163 '-