WECC-0125 PRC-001-WECC-CRT-2 Governor Droop Setting Five-year Review Response to Comments / Posting 2 April 17 through May 17, 2017

1. Posting 2 The WECC-0125, PRC-001-WECC-CRT-2 Governor Drop Setting Five-year Review Drafting Team (DT) thanks everyone who submitted comments on the proposed documents. Posting This project was posted for a 30-day public comment period from April 17 through May 17, 2017. WECC distributed the notice for the posting on April 17, 2017. The DT asked stakeholders to provide feedback on the proposed document through a standardized electronic template. Location of Comments All comments received on the project can be viewed in their original format on the WECC-0125 project page under the “Submit and Review Comments” accordion. Changes in Response to Comment In response to comments received, the WECC-0125 drafting team made the following changes to the project:

No changes were made in response to the single comment submitted. Minority View

AZPS raised concerns of ambiguity in the Facilities section. The section was not changed because it needs to be sufficiently amorphous that it captures technology not yet identified or that does not yet exist but will have the ability to perform. Effective Date The proposed Effective Date for the project is immediately upon approval by the WECC Board of Directors (Board). Justification Because the tasks assigned in the specified Requirements should impose minimal to no new burden, the proposed Effective Date is immediately upon approval by the WECC Board of Directors (Board). Action Plan On June 13, 2017, the WECC-0125 PRC-001-WECC-CRT-2 Governor Droop Five-year Review Drafting Team (DT) agreed via email ballot to forward the project to the WECC Standards Committee (WSC) with a request for ballot. The WSC meets on June 21, 2017. No further drafting team meeting were scheduled. Contacts and Appeals If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC Consultant, at (503) 307-5782. In addition, there is a WECC Reliability Standards Appeals Process.

Commenter Organization 1 Todd Komaromy Arizona Public Service Report Form for WECC-0125

2. Index to Questions, Comments, and Responses Question 3. The Drafting Team welcomes comments on all aspects of the document.

1. The drafting team welcomes comments on all aspects of the document. Summary Considera- See summary in the preamble of this document. tion: Commenter / Comment Response AZPS In section 4.2.2 under Applicability, AZPS believes the wording “having the ability to react or respond” is un- clear, redundant, and confusing. Item 4.2.1 already cov- ers units that have governing function. If a unit does not have a functioning governor, it may not be practical to have a droop. Additionally, bullet 6 in the Rationale/Additional Considerations section points out that up to half of the generation will not re- spond to a frequency event regardless of the droop setting. If an entity can show that a given generator does not respond to frequency events, does that exempt that specific generator from the criterion? To eliminate con- fusion and redundancy, AZPS recommends deleting Item 4.2.2.

Delete 4.2.2 The industry needs to capture traditional and non-traditional technologies as well as those that may not yet exist but will be capable of providing the performance required. As such, the language needs to stay broad enough to capture that which we do not yet know. 4.2.2 was added to capture new technology associated with equipment such as large inverters associated with PV, wind, etc. that when configured correctly can provide drooped Frequency Response in the same manner as a traditional governor on a traditional turbine‐ generator. The NERC Glossary of Terms is silent on the term Governor; the Frequency Regulation definition states “The ability of a Balancing Authority to help the Interconnection maintain Scheduled Frequency. This assistance can include both turbine governor response and Automatic Generation Control.” This covers the traditional turbine governor and excludes other styles of governors. Merriam‐ Webster defines governor as: 4a : an attachment to a machine (such as a gasoline engine) for automatic control or limitation of speed b : a device giving automatic control (as of pressure or temperature) By definition, an inverter can be considered a governor, it is not common practice in our industry to consider equipment such as an inverter a governor; it was determined that this type of equipment should be specifically noted. Facilities 4.2.2 in Posting 2 was reworked from 4.2.3. Asynchronous generation units with Frequency Response capability in the first posting to remove the Asynchronous term and catch all technologies.

Exemption Only those units included in Section 4.2 Facilities are included in the criterion. The generator must fall within the stated Facilities list to be included in the criterion. If it does not fall within the list, the criterion does not apply. The list includes: Report Form for WECC-0125 Summary Considera- See summary in the preamble of this document. tion: Commenter / Comment Response “Facilities 4.2.1. Generating units that have governor function. 4.2.2. Generating units having the ability to react or respond to a change in system frequency. 4.2.3. Generating units being used during blackstart or islanded conditions are excluded from this document.” AZPS’ question regarding exemption from the WECC Criterion is outside of the purview of the drafting team. Exemptions can be sought via the Process for Obtaining an Exemption from a WECC Regional Criterion Requirement (Process). “If an entity to which the Requirement applies seeks an exemption from a Requirement, the requesting entity carries the burden of proof as to the need for that exemption.” See Introduction and Background of the Process.