TOP-001-1a: Reliability Responsibilities and Authorities

Purpose
To ensure reliability entities have clear decision-making authority and  capabilities to take appropriate actions or direct the actions of others to return the transmission system to normal conditions during an emergency.

Applicability

  • Balancing Authorities
  • Transmission Operators
  • Generator Operators
  • Distribution Providers
  • Load Serving Entities

Effective Date
Immediately after approval of applicable regulatory authorities.

Requirements
R1. Each Transmission Operator shall have the responsibility and clear decision-making authority to take whatever actions are needed to ensure the reliability of its area and shall exercise specific authority to alleviate operating emergencies.

R2. Each Transmission Operator shall take immediate actions to alleviate operating emergencies including curtailing transmission service or energy schedules, operating equipment (e.g., generators, phase shifters, breakers), shedding firm load, etc.

R3. Each Transmission Operator, Balancing Authority, and Generator Operator shall comply with reliability directives issued by the Reliability Coordinator, and each Balancing Authority and Generator Operator shall comply with reliability directives issued by the Transmission Operator, unless such actions would violate safety, equipment, regulatory or statutory requirements.  Under these circumstances the Transmission Operator, Balancing Authority or Generator Operator shall immediately inform the Reliability Coordinator or Transmission Operator of the inability to perform the directive so that the Reliability Coordinator or Transmission Operator can implement alternate remedial actions.

R4. Each Distribution Provider and Load Serving Entity shall comply with all reliability directives issued by the Transmission Operator, including shedding firm load, unless such actions would violate safety, equipment, regulatory or statutory requirements.  Under these circumstances, the Distribution Provider or Load Serving Entity shall immediately inform the Transmission Operator of the inability to perform the directive so that the Transmission Operator can implement alternate remedial actions.

R5. Each Transmission Operator shall inform its Reliability Coordinator and any other potentially affected Transmission Operators of real time or anticipated emergency conditions, and take actions to avoid, when possible, or mitigate the emergency.

R6. Each Transmission Operator, Balancing Authority, and Generator Operator shall render all available emergency assistance to others as requested, provided that the requesting entity has implemented its comparable emergency procedures, unless such actions would violate safety, equipment, or regulatory or statutory requirements.

R7. Each Transmission Operator and Generator Operator shall not remove Bulk Electric System facilities from service if removing those facilities would burden neighboring systems unless:

R7.1. For a generator outage, the Generator Operator shall notify and coordinate with the Transmission Operator.  The Transmission Operator shall notify the Reliability Coordinator and other affected Transmission Operators, and coordinate the impact of removing the Bulk Electric System facility.

R7.2. For a transmission facility, the Transmission Operator shall notify and coordinate with its Reliability Coordinator.  The Transmission Operator shall  notify other affected Transmission Operators, and coordinate the impact of  removing the Bulk Electric System facility.

R7.3. When time does not permit such notifications and coordination, or when immediate action is required to prevent a hazard to the public, lengthy customer service interruption, or damage to facilities, the Generator Operator shall notify the Transmission Operator, and the Transmission Operator shall notify its Reliability Coordinator and adjacent Transmission Operators, at the earliest possible time.

R8. During a system emergency, the Balancing Authority and Transmission Operator shall immediately take action to restore the Real and Reactive Power Balance.  If the Balancing Authority or Transmission Operator is unable to restore Real and Reactive Power Balance it shall request emergency assistance from the Reliability Coordinator.  If corrective action or emergency assistance is not adequate to mitigate the Real and Reactive Power Balance, then the Reliability Coordinator, Balancing Authority, and Transmission Operator shall implement firm load shedding.

Measures
M1. Each Transmission Operator shall have and provide upon request evidence that could include, but is not limited to, signed agreements, an authority letter signed by an officer of the company, or other equivalent evidence that will be used to confirm that it has the authority, and has exercised the authority, to alleviate operating emergencies as described in Requirement 1.

M2. If an operating emergency occurs the Transmission Operator that experienced the emergency shall have and provide upon request evidence that could include, but is not limited to, operator logs, voice recordings or transcripts of voice recordings, electronic communications, or other equivalent evidence that will be used to determine if it took immediate actions to alleviate the operating emergency including curtailing transmission service or energy schedules, operating equipment (e.g., generators, phase shifters, breakers), shedding firm load, etc. (Requirement 2)

M3. Each Transmission Operator, Balancing Authority, and Generator Operator shall have and provide upon request evidence such as operator logs, voice recordings or transcripts of voice recordings, electronic communications, or other equivalent evidence that will be used to determine if it complied with its Reliability Coordinator’s reliability directives.  If the Transmission Operator, Balancing Authority or Generator Operator did not comply with the directive because it would violate safety, equipment, regulatory or statutory requirements, it shall provide evidence such as operator logs, voice recordings or transcripts of voice recordings, electronic communications, or other equivalent evidence that it immediately informed the Reliability Coordinator of its inability to perform the directive. (Requirement 3)

M4. Each Balancing Authority, Generator Operator, Distribution Provider and Load Serving Entity shall have and provide upon request evidence such as operator logs, voice recordings or transcripts of voice recordings, electronic communications, or other equivalent evidence that will be used to determine if it complied with its Transmission Operator’s reliability directives.  If the Balancing Authority, Generator Operator, Distribution Provider and Load Serving Entity did not comply with the directive  because it would violate safety, equipment, regulatory or statutory requirements, it  shall provide evidence such as operator logs, voice recordings or transcripts of voice recordings, electronic communications, or other equivalent evidence that it immediately informed the Transmission Operator of its inability to perform the directive. (Requirements 3 and 4)

M5. The Transmission Operator shall have and provide upon request evidence that could include, but is not limited to, operator logs, voice recordings or transcripts of voice recordings, electronic communications, or other equivalent evidence that will be used to determine if it informed its Reliability Coordinator and any other potentially affected Transmission Operators of real time or anticipated emergency conditions, and took actions to avoid, when possible, or to mitigate an emergency. (Requirement 5)

M6. The Transmission Operator, Balancing Authority, and Generator Operator shall each have and provide upon request evidence that could include, but is not limited to, operator logs, voice recordings or transcripts of voice recordings, electronic communications, or other equivalent evidence that will be used to determine if it rendered assistance to others as requested, provided that the requesting entity had implemented its comparable emergency procedures, unless such actions would violate safety, equipment, or regulatory or statutory requirements.  (Requirement 6)

M7. The Transmission Operator and Generator Operator shall each have and provide upon request evidence that could include, but is not limited to, operator logs, voice recordings or transcripts of voice recordings, electronic communications, or other equivalent evidence that will be used to determine if it notified either their Transmission Operator in the case of the Generator Operator, or other Transmission Operators, and the Reliability Coordinator when it removed Bulk Electric System facilities from service if removing those facilities would burden neighboring systems. (Requirement 7)

Appendix

Requirement Number and Text of Requirement
R8. During a system emergency, the Balancing Authority and Transmission Operator shall immediately take action to restore the Real and Reactive Power Balance. If the Balancing Authority or Transmission Operator is unable to restore Real and Reactive Power Balance it shall request emergency assistance from the Reliability Coordinator. If corrective action or emergency assistance is not adequate to mitigate the Real and Reactive Power Balance, then the Reliability Coordinator, Balancing Authority, and Transmission Operator shall implement firm load shedding.
Question
For Requirement R8 is the Balancing Authority responsibility to immediately take corrective action to restore Real Power Balance and is the TOP responsibility to immediately take corrective action to restore Reactive Power Balance?
Response
The answer to both questions is yes. According to the NERC Glossary of Terms Used in Reliability Standards, the Transmission Operator is responsible for the reliability of its “local” transmission system, and operates or directs the operations of the transmission facilities. Similarly, the Balancing Authority is responsible for maintaining load-interchange-generation balance, i.e., real power balance. In the context of this requirement, the Transmission Operator is the functional entity that balances reactive power. Reactive power balancing can be accomplished by issuing instructions to the Balancing Authority or Generator Operators to alter reactive power injection. Based on NERC Reliability Standard BAL-005-1b Requirement R6, the Transmission Operator has no requirement to compute an Area Control Error (ACE) signal or to balance real power. Based on NERC Reliability Standard VAR-001-1 Requirement R8, the Balancing Authority is not required to resolve reactive power balance issues. According to TOP001-1 Requirement R3, the Balancing Authority is only required to comply with Transmission Operator or Reliability Coordinator instructions to change injections of reactive power.

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