FERC on Thursday gave NERC and WECC the go-ahead to introduce regional reliability standard BAL-002-WECC-3, but it also ordered the organizations to return in 2023 with a progress report on its effects on the bulk power system (RM19-20).
The new standard takes the place of BAL-002-WECC-2a, approved by FERC in January 2017 as the regional equivalent of the continent-wide BAL-002-3 (Contingency reserve for recovery from a balancing contingency event) and successor to the original regional standard BAL-002-WECC-2. The standards specify the “quantity and types of contingency reserve required to ensure reliability under normal and abnormal conditions.”
The WECC standard includes a more stringent deadline for entities to restore contingency reserves following a disturbance recovery period: 60 minutes compared to 90 for the NERC equivalent. In addition, the WECC-mandated method for calculating minimum contingency reserves is more stringent than that given in the NERC standard because it requires “minimum contingency reserve levels that will be at least equal to the reliability standard minimum … and more often will be greater.”
Regional Requirement to be Removed
NERC and WECC originally submitted the new regional standard to FERC last September, arguing that some aspects of BAL-002-WECC-2a had been made redundant by the BAL-003-1 standard introduced in 2014.
In particular, the organizations claimed that requirement R2 of the regional standard — mandating that balancing authorities and reserve sharing groups in the WECC region maintain at least half the minimum contingency reserves as operating reserves — was no longer necessary. Requirement R1 of BAL-003-1 “addresses the same frequency response components … but in a results-based manner” because of its requirement that BAs “achieve an annual frequency response measure that is equal to or more negative than its frequency response obligation.”
To address any potential concerns about reliability impacts from retiring the 50% spinning reserve requirement, WECC performed a field test from May 2017 to April 2018 in which it obtained data from each BA and reserve sharing group on disturbance control standard (DCS) performance and frequency response in the Western Interconnection. In their petition to FERC, NERC and WECC said that “all 66 DCS events occurring during the field test period had a 100% pass rate, showing no degradation to DCS performance.”
Not satisfied with the submission, FERC issued a data request in February 2020 to the organizations seeking further data from May 2018 to September 2019, along with NERC’s frequency response records for the Western Interconnection from May 2017 to September 2019. The updated information was submitted in May 2020.
Standard Approved; Monitoring to Continue
With the expanded data set continuing to support NERC and WECC’s assertion, FERC gave its approval to the standard as “just, reasonable … and in the public interest.” However, the commission indicated it still holds reservations about “unique aspects of contingency reserves in the Western Interconnection [that] raise concerns about deliverability of contingency reserves within reserve sharing groups.”
Specifically, FERC noted that both the Northwest Power Pool and the Southwest Reserve Sharing Group contain BAs that have hydroelectric resources, which “represent a significant share of … contingency reserves.” The commission expressed concern that transmission constraints or limits on the hydroelectric system may constrain the ability of member BAs to access these resources.
As a result, FERC ordered that NERC and WECC submit an additional informational filing 27 months after the implementation of BAL-002-WECC-3, covering the same categories of data from the February 2020 data request for the 24 months following implementation. The commission also mandated that the organizations inform it immediately of “any adverse impacts resulting from the retirement of requirement R2” that are observed during the reporting period, along with any corrective actions that are taken or considered.
