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Comments on Underfrequency Load Shedding Characteristics— Project 2008-05Individualor group.NameOrganizationRegistered Ballot body segment (check all industry segments in which your company isregistered)2.John ShafferFlorida Power & LightFRCC13.John OdomFRCCFRCC104.Fabio RodriguezProgress EnergyFRCC15.Don GIlbertJEAFRCC56.Alan GaleCity of TallahasseeFRCC57.Don McInnisFlorida Power & LightFRCC18.Art NordlingerTampa Electric CompanyFRCC19.FRCC System Protection & Control Subcommittee FRCCFRCC1017.GroupBob JonesSouthern CompanyServices, Inc. - TransAdditional Member Additional Organization1 - Transmission OwnersRegionSegmentSelection1.Rick FosterAmerenSERC12.Anthony WilliamsDuke Energy CarolinasSERC13.Greg DavisGeorgia Transmission Corp.SERC14.Ernesto PaonMunicipal Electric Authority of GeorgiaSERC15.Andrew FuscoNC Municipal Power Agency #1SERC16.John O'ConnorProgress Energy CarolinasSERC17.Pat HuntleySERC Reliability Corp.SERC108.Jonathan GlidewellSouthern Company Services, Inc. - Trans SERC19.Tom CainTennessee Valley dualGroupKevin KoloiniRick WhiteHoward RulfJohn WShafferEricMortensonD. Bryan GuyKirit ShahKenGoldsmithSERCBuckeye Power, Inc.Northeast UtilitiesWe EnergiesFlorida Power & LightCo.Exelon3 - Load-serving Entities, 4 - Transmission-dependent Utilities, 5 - Electric Generators1 - Transmission Owners5 - Electric Generators, 4 - Transmission-dependent Utilities, 3 - Load-serving Entities1 - Transmission OwnersProgress EnergyCarolinas, Inc.AmerenAlliant Energy3 - Load-serving Entities, 5 - Electric Generators, 1 - Transmission Owners1 - Transmission Owners, 3 - Load-serving Entities6 - Electricity Brokers, Aggregators , 3 - Load-serving Entities, 1 - Transmission Owners4 - Transmission-dependent Utilities7

Comments on Underfrequency Load Shedding Characteristics— Project 2008-05Individualor group.NameOrganizationRegistered Ballot body segment (check all industry segments in which your company isregistered)(MRO NERCStandardsReviewSubcommittee)Additional Member Additional Organization RegionSegmentSelection1.Neal BaluWPSMRO3, 4, 5, 62.Terry BilkeMISOMRO23.Carol GerouMPMRO1, 3, 5, 64.Jim HaighWAPA MRO1, 65.Tom MielnikMECMRO1, 3, 5, 66.Pam SordetXcelMRO1, 3, 5, 67.Dave RudolphBEPCMRO1, 3, 5, 68.Eric RuskampLESMRO1, 3, 5, 69.Joseph KnightGREMRO1, 3, 5, 610.Joe DePoorterMGEMRO3, 4, 5, 611.Larry BrusseauMROMRO10MROMRO12.Michael gtsonKris ManchurSandraShaffer10E.ON U.S.6 - Electricity Brokers, Aggregators , 3 - Load-serving Entities, 5 - Electric Generators, 1 Transmission Owners5 - Electric Generators, 6 - Electricity Brokers, Aggregators , 3 - Load-serving Entities, 1 Transmission Owners1 - Transmission Owners, 5 - Electric Generators, 3 - Load-serving EntitiesManitoba HydroPacifiCorpAdditional Member Additional OrganizationRegionSegmentSelection1.Mike VilesTransmission Technical OperationsWECC12.Kelly JohnsonTransmission Customer Service Engineering WECC13.Terry DoernTransmission Technical OperationsWECC14.Gregory VasalloTransmission Customer Service Engineering WECC15.Stephen HitchensTransmission Technical OperationsWECC16.Rebecca BerdahlPower Long Term Sales and PurchasesWECC329.GroupDenise KoehnTransmission Reliability3 - Load-serving Entities, 5 - Electric Generators, 1 - Transmission Owners, 6 - Electricity Brokers,8

Comments on Underfrequency Load Shedding Characteristics— Project 2008-05Individualor group.Name30.IndividualRon Falsetti31.Individual32.GroupWayneKemperSam CicconeOrganizationProgramIndependent ElectricitySystem OperatorCenterPoint EnergyFirstEnergy Corp.Additional Member Additional OrganizationRegistered Ballot body segment (check all industry segments in which your company isregistered)Aggregators2 - RTOs and ISOs1 - Transmission Owners1 - Transmission Owners, 5 - Electric Generators, 3 - Load-serving Entities, 6 - Electricity Brokers,AggregatorsRegionSegmentSelection1.Doug HohlbaughFirstEnergy RFC1, 3, 5, 62.Dave FolkFirstEnergy RFC1, 3, 5, 63.Art BuannoFirstEnergy RFC14.Jim DetweilerFirstEnergy RFC15.Bob McFeatersFirstEnergy RFC16.Ken DresnerFirstEnergy RFC57.Bill Duge33.GroupJason Shaver34.IndividualScott Berry35.Individual36.GroupGregRowlandGreg Davis37.Individual38.39.IndividualGroupGreg Ward /Darryl CurtisEd DavisRobertRhodesFirstEnergy RFCAmerican TransmissionCompanyIndiana Municipal PowerAgencyDuke EnergyGeorgia TransmissionCorporationOncor Electric DeliveryEntergySouthwest Power PoolAdditional Member Additional Organization51 - Transmission Owners4 - Transmission-dependent Utilities5 - Electric Generators, 6 - Electricity Brokers, Aggregators , 3 - Load-serving Entities, 1 Transmission Owners1 - Transmission Owners1 - Transmission Owners1 - Transmission Owners, 2 - RTOs and ISOs, 3 - Load-serving Entities, 4 - Transmissiondependent Utilities, 5 - Electric GeneratorsRegionSegmentSelection1.Bill BatemanEast Texas Electric Coop.SPP3, 42.John BoshearsCity Utilities of SpringfieldSPP1, 3, 53.Brian BerkstresserEmpire District ElectricSPP1, 3, 54.Mike GammonKansas City Power & LightSPP1, 3, 59

Comments on Underfrequency Load Shedding Characteristics— Project 2008-05Individualor group.NameOrganizationRegistered Ballot body segment (check all industry segments in which your company isregistered)5.Don HargroveOklahoma Gas & ElectricSPP1, 3, 56.Danny McDanielCLECOSPP1, 3, 57.Kyle McMenaminSouthwestern Public Service Company SPP1, 3, 58.Eddy ReeceRayburn Country Electric CoopSPP3, 49.Robert RhodesSouthwest Power PoolSPP210

Comments on Underfrequency Load Shedding Characteristics— Project 2008-051. The SDT determined that there is no need to have a continent-wide standard, and proposes that all UFLS requirements be contained withinthe regional UFLS standards developed in accordance with the Characteristics of UFLS Regional Reliability Standards. The SDT developed aset of characteristics which each of the regional entities will be directed to include in its UFLS regional reliability standard. The SDT developedthese characteristics in an attempt to direct the regional entities to develop requirements based on system performance, without prescribingspecifics of how to meet the specified performance. Do you agree with the drafting team?OrganizationCity Water, Light &Power Springfield, ILNPCCGrand River DamAuthorityERCOTFlorida Power &LightManitoba HydroAmerican ElectricPower (AEP)PPL GenerationQuestion 1: Question 1 Comments:YesIn the Eastern Interconnection, it's probably good that not all regions shed load and the same frequencies.Doing so could lead to unstable conditions when the grid is already stressed.Southwest PowerPoolYesBandera ElectricCooperativeYesYesYesYesYesYesYesYes and NoPPL Corporation agrees with the SDT that a continent-wide standard is not practical and having the regionalentities develop a process and appropriate requirements consistent with the "Characteristics of UFLS RegionalReliability Standards" is the most effective way to ensure a reliable transmission system. We also agree it isnecessary for the standard to establish specific limits. However, rigid adherence to the stated characteristicsmay not be possible for certain generating facilities because of equipment limitations or manufacturerrecommended over/under frequency protection requirements. Such limitations or requirements can not beignored. As such, provisions to deviate from stated characteristics in these instances must be included in anyregional entity standard developed. The expectation is that the generator would provide documentation as towhy a specific characteristic can not be met and the regional entity would review the issue and determine if miscoordination with the UFLS program exists. If mis-coordination does exist, the regional entity, with input fromthe host TO/TSP and the generator, would then be responsible for appropriate mitigation measures (i.e.shedding of additional load).The Regional Entity intent is to address the performance characteristics as recommended by the NERC SDT,but not necessarily include those specific characteristics as requirements in the Regional Standard.The Texas Regional Entity Regional Underfrequency Standard Drafting Team (TRE UFLS SDT) agrees with thedirection that the NERC team is proposing. Performance outcomes should be the focus of the regionalstandards development to allow for the proper integration of practices that have long been based on regional11

Comments on Underfrequency Load Shedding Characteristics— Project 2008-05OrganizationLouisianaGenerqting, LLCOrrville UtilitiesMidwest ISOQuestion 1: Question 1 Comments:differences and practices. Those practices, where they obviously lend themselves to achieving the expectedreliability outcomes, should be respected and incorporated in the development of these new regional standards.YesYesYes and NoSouthern Company YesServices, IncPJMNoFlorida Reliability YesCoordinatingCouncilSouthern Company YesServices, Inc. TransBuckeye Power,YesInc.Northeast Utilities YesWe EnergiesYesFlorida Power &Light Co.ExelonNoWe agree with the drafting team's approach in developing a set of system characteristics rather than a continentwide standard. We are concerned though that when standards PRC-006, PRC-007, and PRC-009 are replacedthat information and requirements could be lost that are important to UFLS. Regional standards drafting teamsshould review the content of these existing standards to determine what should be transferred to theirstandards. We believe that the characteristics are a good starting point and should set a minimum level ofperformance expected. The drafting team should consider whether there are any special systems (such as apeninsula) that may warrant different criteria and allow the regional standards to consider other criteria for thosesystems. To better assess the quality of the characteristics, the drafting team should provide the history behindthese characteristics. Where did they come from? How were they derived? Did they come from old regionalreliability organization (from MAIN, MAPP, ECAR, etc) criteria?This approach allows each region to develop requirements that meet the specific needs of the region while stillmaintaining a continent-wide level of reliability.UFLS should be used as a safety net, based on installation requirements rather than performancerequirements. As it is currently worded, if your UFLS load shedding does not arrest a blackout, you couldpotentially be found non-compliant.This approach allows each region to develop requirements that meet the specific needs of the region while stillmaintaining a continent-wide level of reliability.This document, 'Characteristics of UFLS Regional Reliability Standards' is not a NERC Standard, yet it containsrequirements for adherence by parties other than NERC or a Region. This new kind of requirement listingcircumvents the Standard Development Procedure. It is not clear how this could ever be revised or what rolestakeholders have in this. The creation of a new class of Standards creates confusion and is contrary to the12

Comments on Underfrequency Load Shedding Characteristics— Project 2008-05OrganizationProgress EnergyCarolinas, Inc.AmerenAlliant EnergyQuestion 1: Question 1 Comments:well developed process that has been established. Why couldn't this be a NERC Standard, with all of therecognized checks and balances provided with that process, while at the same time leaving the fewrequirements that really need to be 'fill in the blank' up to a more detailed Regional Standard?YesThis approach allows each region to develop requirements that meet the specific needs of the region while stillmaintaining a continent-wide level of reliability.Yes and No We agree that there is no need for a continent-wide UFLS standard. However, numerous system conditionswould need to be studied to identify potential islands (Characteristic #2), and we doubt that the analyses to beperformed would often accurately predict how the system would separate with any certainty. Also, it is likelythat any separation would not be along company or regional lines. Therefore, we suggest that each regioninvolve and coordinate neighboring regions in these studies and in the development of the regional UFLSstandard and its requirements.Yes and No The MRO believes that the Regions should determine the details of the UFLS. We believe the regions are bestsituated to perform the studies and determine the total amount of load shed required, how many blocks, at whatfrequency, etc. This includes setting regional performance objectives for UFLS design, and deciding ongenerator under/over frequency minimum time delays and frequency setpoints.The MRO believes that the Under Frequency Load Shedding Standard Drafting Team is headed in the rightdirection as far as allowing the regions to create their own UFLS program within continental widecharacteristics. It’s the MRO’s contention that while the 11 general characteristics are reasonable they may betoo specific to accommodate the needs of every region or they may be too extreme for every region. The MROasks that the UFLS SDT allow the regions a reasonable amount of time to determine the specific number whichwould accommodate the general NERC objectives but would address regional conditions.There are some inconsistencies in the document as the Characteristics listed in the “UFLS Regional ReliabilityStandard Characteristics” document do not match with those listed in this comment form in the “Characteristicsof UFLS Regional Reliability Standards” section. Specifically, 1) What is the technical justification for thefrequency overshoot limit of 61 Hz? (third bullet) 2) What is the technical justification for the time durations forthe Volts/Hz? (Fourth Bullet)The MRO interprets that the STD is proposing the withdrawal of the PRC-006-0, PRC-007-0, and PRC-009-0standards when applicable Regional replacement standard(s) are established and become effective. The MROalso interprets that the STD is proposing UFLS Regional Reliability Standard Characteristics, rather thanrevising the NERC UFLS standards, because NERC standards cannot be applicable to Regional Entities andthe Characterizes may be a means for NERC to require the Regions to develop appropriate Regional standardsthat share key continent-wide characteristics.13

Comments on Underfrequency Load Shedding Characteristics— Project 2008-05OrganizationE.ON U.S.Manitoba HydroQuestion 1: Question 1 Comments:The MRO agrees that the existing NERC standards could be replaced with appropriate Regional standards andbelieve that some UFLS program requirements should be different in different Regions. The MRO disagreesthat the Characteristics should direct Regional Entities to be based on continent-wide system performancevalues. Appropriate system performance levels and appropriate percentage of load shedding will vary for eachpotential island and depend on the composition of load, generation, and system protection within the island. Thecontinent-wide Characteristics should deal with such broader issues such as: identification of potential islands,coordination among accountable entities, identification of appropriate load shedding percentage, identificationand coordination with island-specific generation-related limits and system protection settings, responsibility forUFLS program design and implementation, responsibility for and frequency of UFLS program assessment, etc.YesYes and No Manitoba Hydro agrees that region must have the flexibility to institute a UFLS that meets its region's topologyrequirements. Manitoba Hydro also agrees that the SDT should develop requirements based on systemperformance. However, the performance targets outlined in the characteristics document are not all appropriatefor every region (specifics described in following comments).YesYesPacifiCorpTransmissionReliability ProgramIndependentYesElectricity SystemOperatorCenterPoint Energy NoWe support this approachCenterPoint Energy believes this document has been issued for comments prematurely and recommends thiseffort be postponed until the proposed NERC Reliability Standard PRC-024 (Generator Protective SystemPerformance During Frequency and Voltage Excursions) has been fully developed and vetted by allstakeholders through the NERC process. The prescriptive technical design characteristics proposed in theseCharacteristics of UFLS Regional Reliability Standards are based on parameters contained in the proposedPRC-024 that have not yet been issued to the industry for comments. It is premature to base theseCharacteristics on another standard that is still in the development process. As an alternative to postponing thiseffort, the proposed prescriptive technical characteristics could be deleted. While CenterPoint Energy proposesless restrictive characteristics in response to Questions 2, 3, and 4 below, our recommendation is that they bedeleted or that Project 2007-1 be postponed. All the proposed technical design parameters appear to apply onlyfor “underfrequency conditions resulting from an imbalance between load and generation of at least 25 percent”.This characterization is simplistic and does not address all UFLS needs for other system conditions that canoccur. The imbalance and response to an imbalance can vary dramatically considering not only the amount ofgeneration that’s on-line, but also the type of generation on-line. System response will depend upon governorresponse and system inertia. For example, in order to arrest frequency decay for a 25% load / generationimbalance within prescribed parameters under certain conditions, a region may have to employ aggressive load14

Comments on Underfrequency Load Shedding Characteristics— Project 2008-05OrganizationQuestion 1: Question 1 Comments:shedding that might cause an overshoot beyond prescribed parameters under other conditions. This isespecially true for regions that have significant penetration of wind energy, where system performance can varywidely depending upon system load and the composition of assumed on-line generation under variousconditions. The open ended requirement for arresting frequency after an initial imbalance of at least 25% couldbe interpreted to encompass imbalances of 50%, 75% or even 100% which is infeasible.FirstEnergy Corp. Yes and No We agree with the SDT that there is no need for NERC to develop a continent-wide standard since there isalready much work being done in some regions already creating their own regional standard. And we agree thatNERC should at least specify the minimum expectations of UFLS programs needed by each region so thatthere is continent-wide consistency in the creation and implem

6. John O'Connor Progress Energy Carolinas SERC 1 7. Pat Huntley SERC Reliability Corp. SERC 10 8. Jonathan Glidewell Southern Company Services, Inc. - Trans SERC 1 9. Tom Cain Tennessee Valley Authority SERC 1 18.