Regional Standard:
Directory#5 Reserve
Comment Period (4/2/2019 - 5/17/2019)
05/17/2019New Brunswick Power Corporation 
Comments: R1,2,3: There is an implied “or” for these requirements. Suggest using exception sub requirements for clarity. R2: In reviewing BAL-002, the standard does not explicitly allow for a shortage of reserve. This may be an opportunity to implement an allowance for unplanned shortages. Draft versions of BAL-002 had allowed for 99.77% or 5 hours per quarter. This may be considered acceptable from a NERC perspective. R3: R2 at present does not provide a specific reserve recovery time. Consider referencing EEA process when short of reserve. R4,5: Similar to R1,2,3 above.
05/17/2019Ontario Power Generation Inc.View Attachment
Comments: OPG appreciates the opportunity to provide comments on the subject posting. At this time OPG has the following comments for the subject posting (see attached file).
05/17/2019National Grid 
Comments: RE: Section 3. NERC ERO Reliability Standard Requirements: Suggestion to remove the standard version to minimize the need to make future changes for version changes. Example: reference BAL-002 instead of BAL-002-3. RE: Section 5 R1: Is it necessary to include, "NPCC ten-minute reserve meets the requirements for Contingency Reserve requirements within the NERC standards?" If yes, suggestion to reference the specific NERC standards. RE: Section 5 R2: Suggestion to be specific regarding the "appropriate NERC standard." Suggestion to list the standard. RE: Section 5 R11 and R12. The requirements should be specific regarding applicability. Example: "A Balancing Authority shall..."
05/15/2019Consolidated Edison Company of New York, Inc. 
Comments: The SDT has revised Applicability Section 1.6.2 to remove the language that indicates the Directory is only applicable to facilities that are identified as BPS elements. The reason for the removal is based on CO-11 guidance that Directory 5 is assumed to apply on a “System Wide” basis. However the SDT has proposed asset specific changes to the Requirements of the Directory that challenge the “System Wide” assumption. Specifically R11 and R12 are proposed to become asset-specific and apply to resources. Resources are defined by NPCC as generators or demand-side resources. R11 and R12 should be revised as follows: R11 The Balancing Authority shall specify the following criteria for resources to be eligible to provide synchronized reserve, ten-minute reserve, or thirty-minute reserve: R11.1. Requirements for metering and testing R11.2. Requirements for continuously meeting the dispatch instructions R11.3. Requirements for operating capabilities and response rates R12 The Balancing Authority is responsible to ensure that resources allocating inter-Balancing Area reserve do not offer the same reserve to more than one acquiring Balancing Authority for the same scheduling interval.