Peak Reliability SUMMARY DOCUMENT FOR STAKEHOLDER COMMENT. ECC Final State Design. Jeremy West. Manager, Interconnection Reliability Initiatives

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1 Peak Reliability SUMMARY DOCUMENT FOR STAKEHOLDER COMMENT ECC Final State Design Jeremy West Manager, Interconnection Reliability Initiatives November 22, 2017 Vancouver, Washington Loveland, Colorado

2 2 Introduction Peak Reliability s Enhanced Curtailment Calculator (ECC) tool has been under development by Peak since The primary driver for building the ECC is to provide a reliability tool that also is able to consider the contributing flows to System Operating Limit (SOL) exceedances, thus allowing the ECC and its users to make decisions about system changes aimed at reducing the flows. As the Western Interconnection evolves, there exists a need to provide an orderly and efficient means to address reliability issues that will arise. Historically, Balancing Authority (BA) areas primarily consisted of generation assets owned and managed by a single parent company. As additional types of resources and varied ownership and operating structures of those resources arise within the native BAs, it will become more difficult for the native BA operator to efficiently resolve reliability issues independently, using its own assets. Rather than being forced to resolve issues unilaterally, BAs, Transmission Operators (TOP) and Market Operators now can more effectively resolve reliability issues while also preserving the ability of those with appropriate rights to use their transmission systems. Also, as organized markets and consolidation of operations between BAs continues to develop, new system dispatches will result in new seams reliability issues. The reliability issues will occur on a transmission system that was not designed for the resulting flows nor for which transmission service was studied and sold. Those impacted entities will either need to address seams issues through separate, uncoordinated processes or rely on a common interconnection-wide relief methodology. The ECC will provide that common coordinated process by performing an orderly, efficient allocation of relief between impacting parties based on previously coordinated criteria. The result will be an interconnection that continues to operate in an orderly and efficient manner. Peak is requesting that entities review and provide comment on the following design elements of the white paper that has been posted with this document: Element definition Business rules for ECC relief obligation assignment Description of various flow layers and their treatment within the ECC, including ACE contributions, tagged flow contributions and untagged flow contributions Relief obligation duration

3 3 Element Definition Element Any ECC-created single equipment or grouping of equipment that is being monitored for situational awareness. Impact Threshold The percentage of flow contribution that, when exceeded, allows for shared mitigation responsibilities through the ECC. Elements can be monitored pre-contingency against equipment limits or post-contingency for loss of other Bulk Electric System (BES) equipment. While any equipment on the BES modeled in the ECC can be visualized, only certain Elements that have an Impact Threshold above a certain level will be subject to relief obligation requirements. All other Elements will use existing TOP and Peak practices when exceeding and mitigating an SOL exceedance. The Elements in ECC will be defined in accordance with Peak s SOL methodology. Does your entity agree with these Element definitions for ECC usage? Relief Obligation Calculation Impact Layer Consists of the various sources of flow on an element, including e- Tags, Dynamic Transfers, ACE and BA generation serving native load. Relief Obligation Allocation The sum of all individual impact layers as contributed by a single entity. The ECC relief obligation allocation will be calculated as the sum of all individual impact layer components that are above the Impact Threshold including e-tags, Dynamic Transfers, ACE and generation serving load (GTL) for a given BA. ECC will present the most effective relief options, but the BAs and TOPs may utilize alternate means to provide their required relief. The Impact Threshold will be set at 10 percent for ECC Elements. This threshold would be subject to periodic review and could be set to non-default values for a given Element with justification. Does your entity agree that a 10 percent Impact Threshold is appropriate to identify the impact layer components that are impactful to an Element exceeding its limit? How much relief obligation should ECC target (e.g. return flows to 100 percent of the Element s monitored limit, some lower value, etc.)?

4 4 e-tag and Dynamic Transfer Impact Layers Generation Distribution Factor (GDF) This factor represents the percent of flow from a generation resource that will flow over a specific ECC-defined Element. Load Distribution Factor (LDF) This factor represents the percent of flow serving a load that will flow over a specific ECC-defined Element. The e-tag and Dynamic Transfer impact layer components will calculate based on the realtime value from the tag or from the telemetry provided by Peak. When e-tags or Dynamic Transfers are used to assign relief obligation, the ECC will respect transmission priorities so that non-firm relief obligations are requested prior to firm relief obligations. All non-firm transmission rights would alternate between Off-Element and On-Element prioritization, and then the firm transmission priorities would remove this Off versus On Element distinction; this 15-bucket approach is consistent with what has been used for the Western Interconnection Unscheduled Flow Mitigation Plan (WIUFMP). On-Element priorities are assigned when any e-tag or Dynamic Transfer uses transmission rights for the Transmission Service Provider (TSP) related to the Element s TOP. Once an e-tag or Dynamic Transfer is identified above the Impact Threshold, the ECC will assign the relief obligation to the source or sink BA based on which entity s ECC distribution factor is greater. For example, an e-tag where the ECC calculates a 25 percent generation factor (GDF) versus a 10 percent load factor (LDF) will assign the e-tag s obligation for relief to the source BA. Does your entity agree with the 15-bucket assignment methodology? Does your entity agree with assigning relief obligation for tagged flows to the more impactful source or sink BA? o If not, is it more consistent to assign relief obligations for tagged flows equally to each BA, proportional to each BA s impact, or always to either the source or sink BA? ACE Impact Layer ACE Impact The resulting flow on an Element due to positive (over generation) or negative (under generation) BA ACE. The ACE impact layer components will assign any BA above the Impact Threshold a relief obligation. The ACE impact layer components will be assigned to the zero transmission priority so that they are aligned with the first e-tags when determining relief obligation.

5 This is consistent with Peak s current practices. When ACE is determined to be contributing to an SOL exceedance today, the Reliability Coordinator will request that the ACE be brought within L10 or other agreed-upon levels. Does your entity agree that ACE contribution effectively has a zero transmission priority so that ACE impacts are the first impacts addressed? Generation to Load Impact Layer Key Definitions Generation to Load (GTL) The flow impact on an Element due to a BA s generation serving the BA s own load. 5 The Generation to Load (GTL) impact layer components reflect the ECC s calculation to balance generation and load within a BA or market area once e-tags, Dynamic Transfers and ACE are served. The ECC will assign GTL components above the Impact Threshold to the highest transmission priority so that they are aligned with the most firm e-tags when determining relief obligation. Does your entity agree that GTL contribution effectively has the highest transmission priority (same as firm level 7) so that GTL impacts are the last impacts addressed at the same time as firm tagged flow adjustments? Relief Obligation Duration Relief obligations will be effective immediately upon issuance from the ECC and terminate at the end of the next clock 15-minute interval assuming the assigned relief has been achieved. For example, a relief obligation assignment issued at 09:07 would terminate at 09:30. The longest duration for a single ECC relief obligation issued is 30 minutes. The ECC will track to ensure that entities with a relief obligation assignment meet that request; if an Element does not receive the required relief and extension of the ECC relief obligation is deemed infeasible, then Peak would likely issue an operating instruction if necessary to ensure the Element exceedance is mitigated. No relief obligation assignments will be made from the future time points ECC calculates; all relief obligation will be for pre-contingency and post-contingency Element exceedances occurring in real-time. Does your entity support a relief obligation duration that begins immediately and ends at the end of the following clock 15-minute interval?

6 6 Regulatory Enforcement of ECC Relief Obligation To be effective, the ECC relief obligation requests must be enacted by all entities in the Western Interconnection. Peak believes there is enforcement under the current NERC IRO and TOP standards, specifically with the following standards: IRO-001-4, R4 This standard requirement states that the Reliability Coordinator shall address the reliability of its area via direct actions or Operating Instructions. IRO-002-5, R5 This standard requirement states that each Reliability Coordinator shall monitor Facilities within its area and within neighboring Reliability Coordinator Areas to identify any SOL exceedances and to determine any IROL exceedances. TOP-001-3, R1 This standard requirement states that each TOP shall address the reliability of its area via its own actions or by issuing Operating Instructions. TOP-001-3, R2 This standard requirement states that each BA shall address the reliability of its area via its own actions or by issuing Operating Instructions. TOP-001-3, R7 This standard requirement states that TOPs must support their neighbors after they have implemented comparable Emergency procedures. IRO-006-WECC-2 This standard continues to address the treatment of Qualified Paths under the Unscheduled Flow Mitigation Plan for the Western Interconnection. While the current NERC standards provide enforcement, a NERC Standards Authorization Request (SAR) should be initiated to ensure that ECC has the proper standards support to ensure adherence and compliance with relief obligation requirements. Does your entity agree that the current NERC standards enforce the ECC relief obligation requirements? Western Interconnection Unscheduled Flow Mitigation Plan Support The ECC will continue to support the business requirements of the WIUFMP and issuance of events for Elements configured as Qualified Paths. The business rules presented within these documents would apply to other Elements defined within the ECC; the Qualified Paths will continue to be treated in accordance with the WIUFMP. Final Thoughts and Deadlines Please provide any comments on the proposed design for the ECC by Friday, December 15, 2017 at 5 p.m. Pacific time. Comments are to be submitted via the ECC Project discussion page on peakrc.com HERE. All comments are public. Peak is happy to work with any group of entities or individual entities to discuss the concepts defined within these papers. Please contact Jeremy West (jwest@peakrc.com).