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ERCOT Level 3 Emergency Alerts May Become More Common, Not Because of Grid Conditions, But Feds
March 23,2017 ERCOT issued a market notice informing stakeholders of a change in the threshold for Level 3 Energy Emergency Alerts (EEA), due to changes from the North American Electric Reliability Corporation, in which the federal government has vested reliability authority ERCOT said in the market notice that, on April 1, 2017, ERCOT will modify its operating procedures for declaration of Energy Emergency Alert (EEA) Level 3 to align with North American Electric Reliability Corporation (NERC) Reliability Standard EOP-011-1 Requirement 6 and Attachment 1-EOP-011-1, Energy Emergency Alerts, which become effective on that date. ERCOT said in the market notice that NERC Reliability Standard EOP-011-1 will require ERCOT, as the Reliability Coordinator for the ERCOT Region, to declare an EEA Level 3 when "the energy deficient Balancing Authority is unable to meet minimum Contingency Reserve requirements." ERCOT’s minimum Contingency Reserve is 1375 MW. However, ERCOT noted in the market notice that paragraph (3) of Protocols Section 6.5.9.4.2, EEA Levels, currently requires ERCOT to declare an EEA Level 3 only when Physical Responsive Capability (PRC) falls below 1000 MW or when frequency cannot be maintained at a minimum of 59.8 Hz. "As the Protocols recognize in paragraph (1) of Section 6.5.2, Operating Standards, '[t]he requirements of the NERC Reliability Standards shall prevail to the extent there are any inconsistencies with these Protocols or Good Utility Practice," ERCOT said in the market notice "Thus, ERCOT must observe the higher 1375MW EEA Level 3 threshold required in the NERC Reliability Standard, notwithstanding the lower 1000MW trigger reflected in the ERCOT Protocols and the current operating procedures. ERCOT will therefore introduce revisions to its operating procedures -- to be effective April 1, 2017 -- to align with the NERC Reliability Standard," ERCOT said in the market notice "In the near future, ERCOT will also submit a Nodal Protocol Revision Request (NPRR) to align the ERCOT Protocols with applicable NERC Reliability Standards," ERCOT said in the market notice ERCOT stressed that although the threshold for declaring a Level 3 EEA must change, the 1000 MW Physical Responsive Capability level will remain as the trigger for firm load shed while in an EEA Level 3. "ERCOT notes that the 1000MW PRC level reflected in paragraph (3) of Protocols Section 6.5.9.4.2 will remain the trigger for firm Load shed while in an EEA Level 3. This is consistent with the position of the Standard Drafting Team for NERC Reliability Standard EOP-011-1, which concluded that the NERC Reliability Standard does not require firm Load shed to maintain Contingency Reserves, and that each Balancing Authority must determine how to respond to these conditions (See NERC Project 2009-03, Emergency Operations, October 28, 2014 Consideration of Comments at 38). As ERCOT has previously determined, the 1000MW PRC level is an appropriate trigger for firm Load shed because the ERCOT System is expected to be able to withstand the loss of its single largest contingency at PRC levels above 1000MW," ERCOT said in the market notice "ERCOT will also propose revisions in this same NPRR to Section 6.5.9.4.2 to more accurately describe ERCOT’s implementation of NERC Reliability Standard BAL-001-2, which became effective July 1, 2016. Requirement R2 of NERC Reliability Standard BAL-001-2 requires ERCOT to ensure that system frequency does not fall below 59.91 Hz for more than 30 consecutive minutes. Before the July 1, 2016 effective date of this NERC Reliability Standard, ERCOT modified its desk procedures to reflect the series of steps that ERCOT would take, including directing Transmission Service Providers (TSPs) to shed firm Load, in the event frequency is expected to stay below 59.91 Hz for more than 30 minutes. While these procedures are not inconsistent with the Protocol language associated with EEA Level 3, which allows firm Load shed to maintain frequency at a minimum of 59.8 Hz, in the interest of clarity, ERCOT intends to propose revisions to Section 6.5.9.4.2 to align the frequency trigger in EEA Level 3 in Protocols with the 59.91 Hz trigger currently used in desk procedures and with NERC Reliability Standard BAL-001-2," ERCOT said in the market notice
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