Protocol Audit Questionnaire. Protocol Audit Questionnaire. Qualified Scheduling Entity (QSE)

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1 Protocol Audit Questionnaire TABLE OF CONTENTS COMPANY S SUPPORTING DOCUMENTATION... 3 COMPANY S SUBJECT MATTER EXPERT(S)... 3 QUESTIONS... 4 QUESTION # Q01 GENERAL INFORMATION... 4 Question... 4 Company s Response... 4 QUESTION # Q02 RESOURCE INFORMATION... 4 Question... 4 Company s Response... 4 QUESTION # Q03 REACTIVE TESTS... 5 References... 5 Question... 5 Company s Response... 5 QUESTION # Q04 RESOURCE PARAMETERS... 5 References... 5 Question... 5 Company s Response... 5 QUESTION # Q05 SYSTEM PROTECTION... 5 References... 5 Question... 6 Company s Response... 6 QUESTION # Q06 GOVERNOR IN SERVICE... 6 References... 6 Question... 6 Company s Response... 6 QUESTION # Q07 AVR / PSS STATUS... 6 References... 6 Question... 6 Company s Response... 6 QUESTION # Q08 SEASONAL HSL... 7 References... 7 Question... 7 Company s Response... 7 QUESTION # Q09 UNANNOUNCED HSL TESTS... 7 References... 7 Question... 7 Company s Response... 7 QUESTION # Q10 OUTAGE SCHEDULER... 7 References... 7 Question... 7 PAGE 1 OF 44

2 Company s Response... 7 QUESTION # Q11 COP UPDATES... 8 References... 8 Question... 8 Company s Response... 8 QUESTION # Q12 BLACK START TRAINING... 8 References... 8 Question... 8 Company s Response... 9 QUESTION # Q13 OPERATOR TRAINING... 9 References... 9 Question... 9 Company s Response... 9 QUESTION # Q14 TRAINING SIMULATIONS... 9 References... 9 Question... 9 Company s Response... 9 QUESTION # Q15 DIGITAL CERTIFICATE PROCEDURES References Question Company s Response QUESTION # Q16 DIGITAL CERTIFICATE AUDITS References Question Company s Response QUESTION # Q17 QUALIFICATIONS References Question Company s Response QUESTION # Q18 TELEMETRY References Question Company s Response QUESTION # Q19 CONSTANT FREQUENCY References Question Company s Response QUESTION # Q20 VSS DISPATCH INSTRUCTIONS References Question Company s Response QUESTION # Q21 VOLTAGE SUPPORT References Question Company s Response REFERENCES PAGE 2 OF 44

3 Operating Guide (8) Non-Coordinated Reactive Testing Operating Guide (7) Coordinated Reactive Testing Protocol 3.7 Resource Parameters Operating Guide (3) (4) (7) Protective Relay System Failure Response Protocol Reporting Protocol (4) QSE Responsibilities Related to Voltage Support Protocol Changes in Resource Status Operating Guide (1) (2) (5) Power System Stabilizers Protocol (1) General Capacity Testing Requirements Protocol (2) and (3) General Capacity Testing Requirements Protocol Notice of Forced Outage or Unavoidable Extension of Planned or Maintenance Outage Due to Unforeseen Events Protocol Current Operating Plan (COP) Criteria Protocol Black Start Operating Guide (3) Responsibilities Operating Guide (1) System Operator Training Objectives Operating Guide (1) (2) System Operator Training Requirements Operating Guide (3) System Operator Training Requirements Protocol (a) (b) User Security Administrator and Digital Certificates Protocol Market Participant Audits of User Security Administrators and Digital Certificates Protocol (1) Criteria for Qualification as a Qualified Scheduling Entity Protocol (5) Continuous Telemetry of the Real-Time Measurements of Bus Load, Voltages, Tap Position, and Flows Protocol (2) (a) Resource Status Protocol Operational Data Requirements Operating Guide data from QSEs and TSPs to ERCOT Operating Guide ERCOT Loss of AGC Operating Guide (3) Generation Resource Response Time Requirements Protocol QSE Responsibilities Related to Voltage Support COMPANY S SUPPORTING DOCUMENTATION All evidence documents referenced in this Protocol Audit Questionnaire (Questionnaire) must be included in the Protocol Audit Document Submittal List and numbered in accordance with the Protocol Audit Submittal Package Instructions. Responses to the questions must be sufficiently detailed and complete in order to demonstrate compliance. In answers to the questions, please refer to supporting documents by the Doc # as listed in the Protocol Audit Document Submittal List. Citations to multipage supporting documents must clearly reference the applicable parts of the evidence (e.g. Doc #, page #, paragraph #). COMPANY S SUBJECT MATTER EXPERT(S) Topic Name Title Organization / Department PAGE 3 OF 44

4 QUESTIONS QUESTION # Q01 GENERAL INFORMATION Question 1. Please provide your preferred company acronym. 2. Provide a brief company profile. 3. Provide details about your company s footprint in the ERCOT interconnect. 4. List the registrations your company maintains with ERCOT. Include DUNS numbers for each registration. Please use the attached Registrations Template in your response. Include all QSE s and Sub-QSE s and corresponding DUNS numbers for each registration. For each QSE and/or Sub-QSE, please indicate the ERCOT-defined Level of each entity (Level 1 thru Level 4). Describe the functions performed under each ERCOT registration. 5. Please provide physical addresses for each: Corporate Control Center(s) Registrations Template.xlsx Company s Response QUESTION # Q02 RESOURCE INFORMATION Question 1. Please provide a spreadsheet list of each Generation Resource owned and / or managed by your company or represented by your QSE. Please use the attached Resource List Template in your response. 2. Please provide a one-line diagram for each Generation Resource. ResourceList Template.xlsx Company s Response PAGE 4 OF 44

5 QUESTION # Q03 REACTIVE TESTS References Operating Guide (8) Non-Coordinated Reactive Testing Operating Guide (7) Coordinated Reactive Testing Question 1. Provide a spreadsheet listing all QSE-represented Generation Resources required to provide Voltage Support Service (as defined in Protocol 3.15) that indicates dates for each Generation Resource of the two most recent Leading Reactive tests and the two most recent Lagging Reactive tests to demonstrate compliance with the two year testing requirement. 2. Provide documentation of each test, including results and any follow-up actions taken. 3. For any tests not performed in accordance with the requirement to test every two years, please provide an explanation. 4. Provide documentation that all test results were submitted to ERCOT in accordance with Protocols and Operating Guides. 5. If tests were performed but not submitted to ERCOT, please explain why they were not submitted. Company s Response QUESTION # Q04 RESOURCE PARAMETERS References Protocol 3.7 Resource Parameters Question 1. Provide Company's procedures for scheduling, testing, and submittal of test results for Net Dependable Capability and Reactive Capability by the QSE for QSE-represented Generation Resources. 2. Provide documentation that the Resource Parameters were updated using the Resource Asset Registration Form (RARF) to reflect the test results and were reported to ERCOT during the Audit Scope Period. Company s Response QUESTION # Q05 SYSTEM PROTECTION References Operating Guide (3) (4) (7) Protective Relay System Failure Response PAGE 5 OF 44

6 Question 1. During the Audit Scope Period, have any of QSE-represented Generation Resources had a protection system failure associated with the generator or step-up transformer? 2. If so, provide details of each instance, including reason, dates and duration. 3. Include documentation to demonstrate failure and restoration was properly communicated by the QSE to ERCOT. Company s Response QUESTION # Q06 GOVERNOR IN SERVICE References Protocol Reporting Question For the Audit Scope Period, provide a spreadsheet listing all QSE-represented Generation Resources that indicates dates and times (start and end) for each Resource when the governor was out of service except during Generation Resource start-up, shutdown, outage, or testing. For each item on the list include the reason for governor out of service and provide documentation to show that the QSE promptly notified ERCOT of all instances of governor out of service. Company s Response QUESTION # Q07 AVR / PSS STATUS References Protocol (4) QSE Responsibilities Related to Voltage Support Protocol Changes in Resource Status Operating Guide (1) (2) (5) Power System Stabilizers Question 1. During the Audit Scope Period, have any of QSE-represented Generation Resources had instances where the AVR or PSS has been "off" or in "manual" while the generator was online and at or above the Low Sustained Limit (LSL)? 2. If so, provide details of each instance, such as reason, dates and duration. 3. Include documentation to demonstrate status was properly communicated by the QSE to ERCOT and the Transmission Operator (TO), where required. Company s Response PAGE 6 OF 44

7 QUESTION # Q08 SEASONAL HSL References Protocol (1) General Capacity Testing Requirements Question 1. Provide a spreadsheet listing all QSE-represented Generation Resources that indicates dates of submittal of Seasonal HSL values for each Generation Resource to ERCOT for each Season during the Audit Scope Period. 2. Provide dated documentation of each submittal. Company s Response QUESTION # Q09 UNANNOUNCED HSL TESTS References Protocol (2) and (3) General Capacity Testing Requirements Question 1. Provide a spreadsheet listing all QSE-represented Generation Resources with a capacity greater than 10 MW that indicates dates of all Unannounced Generation HSL tests during the Audit Scope Period. 2. Provide documentation of each Unannounced Generation HSL test, including results and any follow-up actions taken including retesting requested by QSE. Company s Response QUESTION # Q10 OUTAGE SCHEDULER References Protocol Notice of Forced Outage or Unavoidable Extension of Planned or Maintenance Outage Due to Unforeseen Events Question 1. Provide documentation that, for the Audit Scope Period, the QSE entered Forced Outages (QSE-represented Generation Units or Load Resources) into the ERCOT Outage Scheduling System for all Forced Outages when the Forced Outage lasted longer than 2 hours. 2. Please provide a spreadsheet showing the time and date of the start and end of each Forced Outage. Then provide a copy of the corresponding entry into the ERCOT Outage Scheduling System if the Forced Outage was longer than 2 hours. Company s Response PAGE 7 OF 44

8 QUESTION # Q11 COP UPDATES References Protocol Current Operating Plan (COP) Criteria Question Provide documentation that, for the Audit Scope Period, the QSE updated the Current Operating Plan (COP) within the required 60 minutes after each Forced Outage of QSErepresented Generation Units or Load Resources. Please provide COP data in XLS format instead of XML format. Please prepare and submit a summary spreadsheet with the following four column headings: Time and date of the start of each Forced Outage Time and date of the related update of the COP to reflect the Forced Outage The difference between the two times to demonstrate compliance within the required 60 minutes per Protocol The file name of the supporting data (XLS format)showing the COP update Company s Response QUESTION # Q12 BLACK START TRAINING References Protocol Black Start Operating Guide (3) Responsibilities Question If your QSE-represented Generation Resources are presently contracted for Black Start Service, or have been contracted for Black Start Service during the Audit Scope Period: 1. Describe your procedures for verifying that associated personnel are proficient in their implementation and use of the QSE Black Start plan as required by Operating Guide (3)(a). 2. If you have written procedures, please provide a copy. 3. Include the following information: a) How associated personnel are identified. b) When the required verification occurs. c) What steps are taken if you determine that the associated personnel are not proficient in the implementation and use of the Black Start Plan. 4. Provide the date of your last QSE-led Black Start Drill or Training Exercise, including a roster of attendees and your lessons learned from the QSE-led drill or exercise. 5. Provide documentation that your QSE participated in any ERCOT-led Black Start Drills and ERCOT Black Start Training, including a roster of attendees. Include your lessons learned from the ERCOT-led drill or exercise. PAGE 8 OF 44

9 Company s Response QUESTION # Q13 OPERATOR TRAINING References Operating Guide (1) System Operator Training Objectives Operating Guide (1) (2) System Operator Training Requirements Question 1. Describe your operator training program, specifically addressing how your program meets the requirements in Operating Guide (1) and the goals listed in Operating Guide (2). 2. Provide, in spreadsheet format, a list of all persons who have at any time during the Audit Scope Period, served as operators for your company responsible for Day-Ahead and/or Real- Time operation of the ERCOT Transmission Grid. 3. Identify which operators, if any, represent Generation and Load Resources. 4. In the same spreadsheet, for each operator, list and describe all training attended. Include, at a minimum, the training topic, training method, entity that provided the training, location of training, and duration of training. 5. Indicate which operators are required to obtain 32 hours (annually) of training of which at least eight hours must be from simulations or realistic drills. Indicate how these requirements were fulfilled for each operator. 6. Provide documentation in support of the information provided in the spreadsheet prepared for Question 2. Documentation should include brochures or other descriptive information about the course contents and proof of attendance or participation. Company s Response QUESTION # Q14 TRAINING SIMULATIONS References Operating Guide (3) System Operator Training Requirements Question Describe how any training simulations used during the Audit Scope Period were appropriate to each class of operator. Provide supporting documentation. Company s Response PAGE 9 OF 44

10 QUESTION # Q15 DIGITAL CERTIFICATE PROCEDURES References Protocol (a) (b) User Security Administrator and Digital Certificates Question 1. Describe your procedure for ensuring that potential Digital Certificate holders meet the requirements of Protocol (a)(i) (v). If you have written procedures, you may provide a copy in lieu of a narrative description. Ensure that your description or procedures address the specific requirements of each paragraph of Protocol (a). Describe when your procedures were first created and how they are maintained. 2. Describe your procedure for ensuring that requests for revocation of Digital Certificates are completed in accordance with Protocol (b). If you have written procedures, you may provide a copy in lieu of a narrative description. Ensure that your description or procedures address the specific requirements of each paragraph of Protocol (b). Describe when your procedures were first created and how they are maintained. 3. Describe how electronic equipment on which Digital Certificates reside are physically and electronically secured to prevent improper use. 4. Please provide a spreadsheet list of each Digital Certificate Holder by year for 2011, 2012, 2013, and Spreadsheet column headings should include the type (RE, QSE, etc.), year, person s name, company employed by, job function performed using certificate, ERCOT system access, date issued or renewed, date revoked. Company s Response QUESTION # Q16 DIGITAL CERTIFICATE AUDITS References Protocol Market Participant Audits of User Security Administrators and Digital Certificates Question 1. Were annual audits of User Security Administrators and Digital Certificates performed during the Audit Scope Period as required by Protocol ? Describe any discrepancies or instances of non-compliance. Describe how each discrepancy was resolved. 2. Provide copies of the attestations that were submitted to ERCOT at the conclusion of each audit. Company s Response QUESTION # Q17 QUALIFICATIONS References Protocol (1) Criteria for Qualification as a Qualified Scheduling Entity PAGE 10 OF 44

11 Question 1. During the Audit Scope Period, were there any instances of failure to maintain personnel, facilities, or services including SCADA communications to fulfill (k)? If so, provide details including root cause, mitigation plan, and steps taken. 2. Provide evidence that the QSE operational personnel have sufficient authority to bind and commit the resources (load and generation) that the QSE represents. Company s Response QUESTION # Q18 TELEMETRY References Protocol (5) Continuous Telemetry of the Real-Time Measurements of Bus Load, Voltages, Tap Position, and Flows Protocol (2) (a) Resource Status Protocol Operational Data Requirements Operating Guide data from QSEs and TSPs to ERCOT Question Provide documentation which demonstrates how you, in your QSE role, monitor and maintain the telemetry of data with ERCOT and other appropriate entities, if applicable. Company s Response QUESTION # Q19 CONSTANT FREQUENCY References Operating Guide ERCOT Loss of AGC Question 1. If you are a provider of Regulation Services (Regulation Up or Regulation Down), provide your procedure for operating your Generation Management System in "Constant Frequency Mode". 2. Provide dates and times you were requested by ERCOT to operate in Constant Frequency Mode during the Audit Scope Period. 3. Provide dates and times of any instances during the Audit Scope Period when you were requested by ERCOT to operate in Constant Frequency Mode but were unable to do so. Provide a sequence of events including root cause and mitigation steps taken. Company s Response PAGE 11 OF 44

12 QUESTION # Q20 VSS DISPATCH INSTRUCTIONS References Operating Guide (3) Generation Resource Response Time Requirements Question 1. If the QSE or Sub-QSE received Voltage Support Service (VSS) Dispatch Instructions (from ERCOT or the TSP) during the Audit Scope Period, provide verification of compliance with any such instructions. 2. Provide evidence that specific VSS Dispatches (if received by the QSE during the Audit Scope Period) were complied with in the required 5 minute (or less) time frame. Company s Response QUESTION # Q21 VOLTAGE SUPPORT References Protocol QSE Responsibilities Related to Voltage Support Protocol Changes in Resource Status Question 1. Please refer to the list of Generation Resources and dates provided for use with this question. (List is provided in Audit Submittal Package) Provide hourly data (1 value per hour for 24 hours) in Excel format for actual BUS Voltages for each unit requested by Texas RE for the dates listed below. For the single BUS Voltage value for each hour, please use the historical data at 15 minutes after the top of each hour (xx:15:00). Please use the attached Voltage Template to record your data. Please create a new sheet in the Workbook for each date requested. Voltage Template.xlsx 2. For the dates selected, identify times when the unit was off-line or otherwise unable to maintain the Seasonal Voltage Profile (within +/- 2%). 3. List any exceptions (BUS Voltage outside the +/- 2% requirement with unit on-line and controlling). 4. Provide explanation for the exception(s). 5. For any exceptions listed, indicate whether the TO/TSP and/or ERCOT were notified. Company s Response PAGE 12 OF 44

13 REFERENCES Operating Guide (8) Non-Coordinated Reactive Testing (8) The QSE representing a Generation Resource shall be responsible for the timely and accurate reporting of test results to ERCOT. The QSE representing a Generation Resource shall be responsible for the timely submittal to ERCOT of an updated CURL reflecting any known changes in the reactive output of the Generation Resource. A QSE must properly complete all required data fields on the MIS Certified Area for a test to be considered valid. Operating Guide (7) Coordinated Reactive Testing (7) The QSE representing a Generation Resource shall be responsible for scheduling reactive tests in accordance with the conditions outlined above, and for the timely and accurate reporting of test results to ERCOT. All test documents (the CURL and the CURL with the test point indicated) shall be submitted by the Resource Entity s QSE. The Resource Entity must properly complete all required data fields on the MIS Certified Area for a test to be considered complete. Back to Question # Q03 PAGE 13 OF 44

14 Protocol 3.7 Resource Parameters (1) A Resource Entity shall register Resource Parameters for its Resources with ERCOT. (2) ERCOT shall provide each that represents a Resource the ability to submit changes to Resource Parameters for that Resource. (3) The QSE may revise Resource Parameters only with sufficient documentation to justify a change in Resource Parameters. (4) ERCOT shall use the Resource Parameters as inputs into the Day-Ahead Market (DAM), Reliability Unit Commitment (RUC), Security-Constrained Economic Dispatch (SCED), Resource Limit Calculator, Load Frequency Control (LFC), and other ERCOT business processes. (5) The Independent Market Monitor (IMM) may require the QSE to provide justification for the Resource Parameters submitted. (6) The QSE or Resource Entity must update any Resource Parameter for a specific Resource: (a) (b) (c) (d) Within ten Business Days of completion of a Net Dependable Capability test to reflect the results of the test; Within ten Business Days of completion of a reactive capability test to reflect the results of the test; Within ten Business Days of a request by ERCOT to check or update a specific Resource Parameter; and Within ten Business Days of a known change to any Resource Parameter. Back to Question # Q04 PAGE 14 OF 44

15 Operating Guide (3) (4) (7) Protective Relay System Failure Response (3) The owner of protective relay systems will immediately notify the appropriate Qualified Scheduling Entity (QSE) and Transmission Operator (TO) via phone call, when the owner has determined that the protective relay system has failed. (4) The affected QSE or TO shall immediately notify the ERCOT Shift Supervisor via phone call and initiate prompt corrective action. These corrective actions are to address reliability issues for the systems that the QSE and TO monitor and/or operate. (7) The affected QSE and TO shall promptly notify the ERCOT Shift Supervisor via phone call of the return to service of the previously identified protective relay systems. Back to Question # Q05 Protocol Reporting (1) Each Generation Entity shall conduct applicable generating Governor tests on each of its Generation Resources as specified in the Operating Guides. Test results and other relevant information shall be reported to ERCOT and ERCOT shall forward results to the appropriate Transmission Service Providers (TSPs). (2) Generation Resource Governor modeling information required in the ERCOT planning criteria must be determined from actual Generation Resource testing described in the Operating Guides. Within 30 days of ERCOT s request, the results of the latest test performed must be supplied to ERCOT and the connected TSP. (3) When the Governor of a Generation Resource is out-of-service while the Resource is On-Line, the QSE shall promptly inform ERCOT. The QSE shall also supply Governor status logs to ERCOT upon request. (4) If a Generation Resource trips Off-Line during a disturbance, as described by the North American Electric Reliability Corporation (NERC), while providing Primary Frequency Response, the QSE shall report the cause of the failure to ERCOT as soon as the cause has been identified. Back to Question # Q06 PAGE 15 OF 44

16 Protocol (4) QSE Responsibilities Related to Voltage Support (4) Each QSE s Generation Resource providing VSS shall operate with the unit s Automatic Voltage Regulator (AVR) in the voltage control mode unless specifically directed to operate in manual mode by ERCOT, or when the unit is going On-Line or Off-Line or the QSE determines a need to operate in manual mode in the event of an Emergency Condition at the generating plant. Each QSE shall send to ERCOT via telemetry, the AVR and Power System Stabilizer (PSS) status of each Generation Resource providing VSS. For AVRs, an On status will indicate the AVR is on and set to regulate the Resource s terminal voltage in the voltage control mode, and an Off status will indicate the AVR is off or in a manual mode. Each QSE shall monitor the status of their regulators and stabilizers, and shall report abnormal status changes to ERCOT. Protocol Changes in Resource Status (1) Each QSE shall notify ERCOT of a change in Resource Status via telemetry and through changes in the Current Operating Plan (COP) as soon as practicable following the change. (2) Each QSE shall promptly inform ERCOT when the operating mode of its Generation Resource s Automatic Voltage Regulator (AVR) or Power System Stabilizer (PSS) is changed while the Resource is On-Line. The QSE shall also provide the Resource s AVR or PSS status logs to ERCOT upon request. (3) Each QSE shall immediately report to ERCOT and the TSP any inability of the QSE s Generation Resource required to meet its reactive capability requirements in these Protocols. Back to Question # Q07 Back to Question # Q21 Operating Guide (1) (2) (5) Power System Stabilizers (1) Generation Resources with Power System Stabilizers (PSSs) shall keep their PSSs in-service ( On or energized and performing as designed by the manufacturer) unless the PSS is installed but not in service as described in paragraph (4)(a)(ii) below. When available, the PSS shall be active and responsive at all times the generator is synchronized to the ERCOT Transmission Grid and operating at or above its Low Sustained Limit (LSL). However, if the PSS of a Generation Resource is set to be active and responsive at a point above the LSL for technical reasons, the Generation Resource may request ERCOT to allow an exception to the requirement that the PSS be active anytime the Generation Resource is at or above its LSL. In order to obtain the exception, the Generation Resource shall notify ERCOT and provide the necessary technical information to ERCOT to justify a higher activation point for the PSS. (2) Generation Entities shall notify their QSEs of any change in PSS status (e.g. PSS unavailability due to maintenance or failure and when the PSS returns to normal operation). PAGE 16 OF 44

17 QSEs shall notify ERCOT and the TO at the POI of any change in PSS status and shall supply PSS status logs to ERCOT upon request per Protocol Section , Changes in Resource Status. Back to Question # Q07 Protocol (1) General Capacity Testing Requirements (1) Within the first 15 days of each Season, each QSE shall provide ERCOT a Seasonal High Sustained Limit (HSL) for any Generation Resource with a capacity greater than ten MW that will be operated during that Season. ERCOT shall provide an appropriate form for QSEs to submit their Seasonal HSL data. The Seasonal HSL form shall take into account auxiliary Load and gross and net real power capability of the Generation Resource. Each QSE shall update its COP and telemetry, as necessary, to reflect the HSL of each of its Generation Resources in a given operating interval as well as other operational limitations. The HSL shown in the COP for a Generation Resource may not be ramp rate-limited while the Real- Time telemetered value of HSL for the Generation Resource may be ramp rate-limited by the QSE representing the Generation Resource in order for the Generation Resource to meet its HSL using the testing process described in paragraph (2) below. Back to Question # Q08 PAGE 17 OF 44

18 Protocol (2) and (3) General Capacity Testing Requirements (2) To verify that the HSL reported by telemetry is achievable, ERCOT may, at its discretion, conduct an unannounced Generation Resource test. At a time determined solely by ERCOT, ERCOT will issue a Verbal Dispatch Instruction (VDI) to the QSE to operate the designated Generation Resource at its HSL as shown in the QSE s telemetry at the time the test is initiated. The QSE shall immediately upon receiving the VDI release all Ancillary Service obligations carried by the unit to be tested and shall telemeter Resource status as ONTEST. The QSE shall not be required to start the designated Generation Resource if it is not already On-Line when ERCOT announces its intent to test the Resource. If the designated Generation Resource is operating at its Low Sustained Limit (LSL) when ERCOT sends the VDI to begin the test, the QSE shall have up to 60 minutes to allow the Resource to reach 90% of its HSL as shown by telemetry and up to an additional 20 minutes for the Resource to reach the HSL shown by telemetry at the time the test is initiated. This time requirement does not apply to nuclear-fueled Generation Resources. If the designated Generation Resource is operating between its LSL and 50% of its HSL shown by telemetry when ERCOT begins the test, the QSE shall have 60 minutes for the Resource to reach its HSL. If the Resource is operating at or above 50% of its HSL shown by telemetry when ERCOT begins the test, the QSE shall have 30 minutes for the Resource to reach its HSL. Once the designated Generation Resource reaches its HSL, the QSE shall hold it at that output level for a minimum of 30 minutes. The HSL for the designated Generation Resource shall be determined based on the Real-Time averaged MW telemetered by the Resource during the 30 minutes of constant output. After each test, the QSE representing the Generation Resource will complete and submit the test form using the Net Dependable Capability and Reactive Capability (NDCRC) application located on the Market Information System (MIS) within two Business Days. (3) ERCOT may test multiple Generation Resources within a single QSE within a single 24-hour period. However, in no case shall ERCOT test more than two Generation Resources within one QSE simultaneously. All Resources On-Line in a Combined-Cycle Configuration will be measured on an aggregate capacity basis. All QSEs associated with a jointly owned unit will be tested simultaneously. Hydro and wind generation will be excluded from unannounced generation capacity testing. ERCOT shall not perform an unannounced Generation Resource test during a Watch or Energy Emergency Alert (EEA) event. If an unannounced Generation Resource test is underway when a Watch or EEA event commences, ERCOT may cancel the test. Back to Question # Q09 PAGE 18 OF 44

19 Protocol Notice of Forced Outage or Unavoidable Extension of Planned or Maintenance Outage Due to Unforeseen Events (1) If a Planned or Maintenance Outage is not completed within the ERCOT-approved timeframe and the Transmission Facilities or Resources are in such a condition that they cannot be restored at the Outage schedule completion date, the requesting party shall submit to ERCOT a Forced Outage (unavoidable extension) form describing the extension of the Outage and providing a revised return date. (2) Any Forced Outage that occurs in Real-Time must be entered into the Outage Scheduler if it is to remain an Outage for longer than two hours. (3) If the QSE is to receive the exemption described in paragraph (5)(d) of Section , Regulation Service and Generation Resource/Controllable Load Resource Energy Deployment Performance, the QSE will notify ERCOT Operators by voice communication of every Forced Outage, Forced Derate, or Startup Loading Failure within 15 minutes. Back to Question # Q10 PAGE 19 OF 44

20 Protocol Current Operating Plan (COP) Criteria (1) Each QSE that represents a Resource must submit a COP to ERCOT that reflects expected operating conditions for each Resource for each hour in the next seven Operating Days. (2) Each QSE that represents a Resource shall update its COP reflecting changes in availability of any Resource as soon as reasonably practicable, but in no event later than 60 minutes after the event that caused the change. (3) The Resource capacity in a QSE s COP must be sufficient to supply the Ancillary Service Supply Responsibility of that QSE. (4) Load Resource COP values may be adjusted to reflect Distribution Losses in accordance with Section , General Capacity Testing Requirements. (5) A COP must include the following for each Resource represented by the QSE: (a) (b) The name of the Resource; The expected Resource Status: (i) Select one of the following for Generation Resources synchronized to the ERCOT System that best describes the Resource s status. These Resource Statuses are to be used for COP and/or Real-Time telemetry purposes. (A) ONRUC On-Line and the hour is a RUC-Committed Hour; (B) ONREG On-Line Resource with Energy Offer Curve providing Regulation Service; (C) ON On-Line Resource with Energy Offer Curve or Off-Line Quick Start Generation Resource (QSGR) available for Security-Constrained Economic Dispatch (SCED) Dispatch; [NPRR272: Replace paragraph (4)(b)(i)(C) above with the following upon system implementation:] (C) ON On-Line Resource with Energy Offer Curve; (D) ONDSR On-Line Dynamically Scheduled Resource (DSR); (E) ONOS On-Line Resource with Output Schedule; (F) ONOSREG On-Line Resource with Output Schedule providing Regulation Service; (G) ONDSRREG On-Line DSR providing Regulation Service; (H) ONTEST On-Line blocked from SCED for operations testing (while ONTEST, a Generation Resource may be shown on Outage in the Outage Scheduler); PAGE 20 OF 44

21 (I) ONEMR On-Line EMR (available for commitment or dispatch only for ERCOTdeclared Emergency Conditions; the QSE may appropriately set LSL and High Sustained Limit (HSL) to reflect operating limits); and (J) ONRR On-Line as a synchronous condenser (hydro) providing Responsive Reserve (RRS) but unavailable for Dispatch by SCED and available for commitment by RUC; [NPRR416: Insert paragraph (4)(b)(i)(K)below upon system implementation and renumber accordingly:] (K) ONOPTOUT On-Line and the hour is a RUC Buy-Back Hour; (K) SHUTDOWN The Resource is On-Line and in a shut-down sequence, and has no Ancillary Service Obligations. This Resource Status is only to be used for Real- Time telemetry purposes; (L) STARTUP The Resource is On-Line and in a start-up sequence and has no Ancillary Service Obligations. This Resource Status is only to be used for Real- Time telemetry purposes; [NPRR272: Insert paragraph (4)(b)(i)(M) upon system implementation:] (M) OFFQS Off-Line but available for SCED deployment. Only qualified QSGRs may utilize this status. (ii) Select one of the following for Off-Line Generation Resources not synchronized to the ERCOT System that best describes the Resource s status. These Resource Statuses are to be used for COP and/or Real-Time telemetry purposes. (A) OUT Off-Line and unavailable; (B) OFFNS Off-Line but reserved for Non-Spinning Reserve (Non-Spin); (C) OFF Off-Line but available for commitment in the Day-Ahead Market (DAM) and RUC; and (D) EMR Available for commitment only for ERCOT-declared Emergency Condition events; the QSE may appropriately set LSL and HSL to reflect operating limits; and (iii) Select one of the following for Load Resources. These Resource Statuses are to be used for COP and/or Real-Time telemetry purposes. (A) ONRGL Available for Dispatch of Regulation Service; (B) ONRRCLR Available for Dispatch of RRS Service as a Controllable Load Resource; (C) ONRL Available for Dispatch of RRS Service or Non-Spin, excluding Controllable Load Resources; and PAGE 21 OF 44

22 [NPRR532: Replace paragraph (5)(b)(iii)(C) above with the following upon system implementation:] (C) ONRL Available for Dispatch of Non-Spin or under-frequency relay-type RRS Service; and (D) OUTL Not available; [NPRR555: Replace paragraph (5)(b)(iii) above with the following upon system implementation:] (iii) Select one of the following for Load Resources. These Resource Statuses are to be used for COP and/or Real-Time telemetry purposes. (A) ONRGL Available for Dispatch of Regulation Service by Low Frequency Control (LFC) and, for any remaining Dispatchable capacity, by SCED with an Real-Time Market (RTM) Energy Bid; (B) ONCLR Available for Dispatch as a Controllable Load Resource by SCED with an RTM Energy Bid; (C) ONRL Available for Dispatch of RRS Service, excluding Controllable Load Resources; and (D) OUTL Not available; (c) (d) (e) (f) (g) The HSL; The LSL; The High Emergency Limit (HEL); The Low Emergency Limit (LEL); and Ancillary Service Resource Responsibility capacity in MW for: (i) (ii) (iii) (iv) Regulation Up (Reg-Up); Regulation Down (Reg-Down); RRS Service; and Non-Spin. (6) For Combined Cycle Generation Resources, the above items are required for each operating configuration. In each hour only one Combined Cycle Generation PAGE 22 OF 44

23 Resource in a Combined Cycle Train may be assigned one of the On-Line Resource Status codes described above. (a) (b) (c) During a RUC study period, if a QSE s COP reports multiple Combined Cycle Generation Resources in a Combined Cycle Train to be On-Line for any hour, then until the QSE corrects its COP, the On-Line Combined Cycle Generation Resource with the largest HSL is considered to be On-Line and all other Combined Cycle Generation Resources in the Combined Cycle Train are considered to be Off-Line. Furthermore, until the QSE corrects its COP, the Off-Line Combined Cycle Generation Resources as designated through the application of this process are ineligible for RUC commitment or decommitment Dispatch Instructions. For any hour in which QSE-submitted COP entries are used to determine the initial state of a Combined Cycle Generation Resource for a DAM or Day- Ahead Reliability Unit Commitment (DRUC) study and the COP shows multiple Combined-Cycle Generation Resources in a Combined Cycle Train to be in an On-line Resource Status, then until the QSE corrects its COP, the On-Line Combined Cycle Generation Resource that has been On-Line for the longest time from the last recorded start by ERCOT systems, regardless of the reason for the start, combined with the COP Resource Status for the remaining hours of the current Operating Day, is considered to be On-Line at the start of the DRUC study period and all other COP-designated Combined Cycle Generation Resources in the Combined Cycle Train are considered to be Off-Line. ERCOT systems shall allow only one Combined Cycle Generation Resource in a Combined Cycle Train to offer Off-Line Non-Spin in the DAM or Supplemental Ancillary Services Market (SASM). (i) (ii) If there are multiple Non-Spin offers from different Combined Cycle Generation Resources in a Combined Cycle Train, then prior to execution of the DAM, ERCOT shall select the Non-Spin offer from the Combined Cycle Generation Resource with the highest HSL for consideration in the DAM and ignore the other offers. Combined Cycle Generation Resources offering Off-Line Non-Spin must be able to transition from the shutdown state to the offered Combined Cycle Generation Resource On-Line state and be capable of ramping to the full amount of the Non-Spin offered. (d) The DAM and RUC shall honor the registered hot, intermediate or cold Startup Costs for each Combined Cycle Generation Resource registered in a Combined Cycle Train when determining the transition costs for a Combined Cycle Generation Resource. In the DAM and RUC, the Startup Cost for a Combined Cycle Generation Resource shall be determined by the positive PAGE 23 OF 44

24 transition cost from the On-Line Combined Cycle Generation Resource within the Combine Cycle Train or from a shutdown condition, whichever ERCOT determines to be appropriate. (7) ERCOT may accept COPs only from QSEs. (8) For the first 48 hours of the COP, a QSE representing a Wind-powered Generation Resource (WGR) must enter an HSL value that is less than or equal to the amount for that Resource from the most recent Short-Term Wind Power Forecast (STWPF) provided by ERCOT. (9) For hours 49 to 168 of the COP, a QSE representing a WGR shall enter an HSL value equal to their best estimate, which may be based on the wind power profile as published on the ERCOT website. (10) A QSE representing a Generation Resource that is not actively providing Ancillary Services may only use a Resource Status of SHUTDOWN to indicate to ERCOT through telemetry that the Resource is operating in a shut-down sequence or a Resource Status of ONTEST to indicate in the COP and through telemetry that the Generation Resource is performing a test of its operations either manually dispatched by the QSE or by ERCOT as part of the test. A QSE representing a Generation Resource that is not actively providing Ancillary Services may only use a Resource Status of STARTUP to indicate to ERCOT through telemetry that the Resource is operating in a start-up sequence requiring manual control and is not available for Dispatch. (11) If a QSE has not submitted a valid COP for any Generation Resource for any hour in the DAM or RUC Study Period, then the Generation Resource is considered to have a Resource Status as OUT thus not available for DAM awards or RUC commitments for those hours. (12) If a COP is not available for any Resource for any hour from the current hour to the start of the DAM period or RUC study, then the Resource Status for those hours are considered equal to the last known Resource Status from a previous hour s COP or from telemetry as appropriate for that Resource. Back to Question # Q11 PAGE 24 OF 44

25 Protocol Black Start (1) Each Generation Resource providing BSS must meet the requirements specified in North American Electric Reliability Corporation (NERC) Reliability Standards and the Operating Guides. (2) Each Generation Resource providing BSS must meet technical requirements specified in Section 8.1.1, QSE Ancillary Service Performance Standards, and Section , Ancillary Service Qualification and Testing. (3) Bids for BSS are due on or before June 1 st of each two year period. Bids must be evaluated based on evaluation criteria attached as an appendix to the request for bids and contracted by December 31 st for the following two year period. ERCOT shall ensure BSSs are arranged, provided, and deployed as necessary to reenergize the ERCOT System following a Blackout or Partial Blackout. (4) ERCOT shall schedule random testing or simulation, or both, to verify BSS is operable according to the ERCOT System restoration plan. Testing and verification must be done under established qualification criteria. (5) QSEs representing Generation Resources contracting for BSSs shall participate in training and restoration drills coordinated by ERCOT. (6) ERCOT shall periodically conduct system restoration seminars for all TSPs, Distribution Service Providers (DSPs), QSEs, Resource Entities and other Market Participants. (7) ERCOT shall periodically determine and review the location and number of Black Start Resources required, as well as any special transmission or voice communication needs required. ERCOT and providers of this service shall meet the requirements as specified in the Operating Guides and in NERC Reliability Standards. (8) A Resource Entity representing a Black Start Resource may request that an alternate Generation Resource which is connected to the same black start primary and secondary cranking path as the original Black Start Resource be substituted in place of the original Black Start Resource during the two year term of an executed Standard Form Black Start Agreement (Section 22, Attachment D, Standard Form Black Start Agreement) if the alternate Generation Resource meets testing and verification under established qualification criteria to ensure BSS. (a) ERCOT, in its sole discretion, may reject a Resource Entity s request for an alternate Generation Resource and will provide the Resource Entity an explanation of such rejection. PAGE 25 OF 44

26 (b) If ERCOT accepts the alternative Generation Resource as the substituted Black Start Resource, such acceptance shall not affect the original terms, conditions and obligations of the Resource Entity under the Standard Form Black Start Agreement. The Resource Entity shall submit to ERCOT an Amendment to Standard Form Black Start Agreement (Section 22, Attachment I, Amendment to Standard Form Black Start Agreement) after qualification criteria has been met. (9) For the purpose of the Black Start Hourly Standby Fee as described in Section , Black Start Hourly Standby Fee, the Black Start Service Availability Reduction Factor shall be determined by using the availability for the original Black Start Resource and any substituted Black Start Resource(s), as appropriate for the rolling 4380 hour period of the evaluation. Operating Guide (3) Responsibilities (3) QSEs representing Black Start Resources responsibilities are as follows: (a) (b) Verify that associated QSE personnel are proficient in implementation and use of the appropriate procedures for use in the event of a Partial Blackout or Blackout; and In the event of a Partial Blackout or Blackout of the ERCOT System, QSEs representing Black Start Resources shall: (i) (ii) (iii) (iv) Take immediate steps to initiate and maintain communications with its Black Start Resources; Supply ERCOT and/or the local TO with information on the status of generation, fuel, transmission, and communication facilities; Follow the direction of the local TO or ERCOT in regards to output of its Generation Resources; and Provide available assistance as directed by ERCOT or the local TO. Back to Question # Q12 PAGE 26 OF 44

27 Operating Guide (1) System Operator Training Objectives (1) Each operating Entity within the ERCOT System shall train its operators such that they will possess the necessary knowledge, skills and abilities to perform their assigned tasks in directing the operation of the bulk power system. Instruction provided shall be in accordance with North American Electric Reliability Corporation (NERC) Reliability Standards, the Protocols, these Operating Guides, and ERCOT Procedures, as well as individual Entity operating goals, plans and procedures. (2) For those operators required to obtain 32 hours annually at least eight hours must be from simulations or realistic drills. Operating Guide (1) (2) System Operator Training Requirements (1) The System Operator Training Program applies to all operators who are responsible for the Day-Ahead and Real-Time operation of the ERCOT Transmission Grid. Transmission Operators (TOs) and operators who represent Generation and Load Resources shall participate in 32 hours per year of training and drills on system emergencies. QSE operators who do not represent Generation or Load Resources must participate in at least eight hours per year of training and drills in system emergencies. Back to Question # Q13 Operating Guide (3) System Operator Training Requirements (3) Training should use simulations appropriate to each class of operator and all such training shall meet or exceed established NERC Reliability Standards. Participation in emergency simulations, severe weather drills, ERCOT Black Start training, and portions of the ERCOT Operations Training Seminar that relate to NERC recommended topics may be used to satisfy this requirement. Task specific training carried out internally within an Entity will be considered in full compliance with this requirement. Training documentation, including curriculum, training methods, and individual training records, shall be immediately available during any audit. Back to Question # Q14 PAGE 27 OF 44

28 Protocol (a) (b) User Security Administrator and Digital Certificates The USA and the Market Participant are responsible for the following: (a) Requesting Digital Certificates for authorized potential Certificate Holders (either persons or programmatic interfaces) that the USA has qualified through an appropriate screening process requiring confirmation that the Certificate Holder is an employee or authorized agent (including third parties) of the Market Participant. A Certificate Holder (including the USA) must be qualified as set forth below. The Market Participant shall be liable for ensuring that each of its Certificate Holder(s) meets the requirements of (i) (v) below. (i) (ii) (iii) (iv) (v) For any employee or authorized agent receiving a Digital Certificate, the Market Participant shall confirm that the employee or authorized agent satisfies reasonable background review sufficient for employment or contract with the Market Participant so as to reasonably limit threat(s) to ERCOT s market or computer systems. The Market Participant may not request that Digital Certificates be issued to any employee or authorized agent it determines, after reasonable background review, that the employee or authorized agent poses a threat to ERCOT s market or computer systems. The potential Certificate Holder is aware of the rules and restrictions relating to the use of Digital Certificates. The potential Certificate Holder is eligible to review and receive technology and software under applicable export control laws and regulations. ERCOT shall post links to relevant laws and regulations on the Market Information System (MIS) Public Area. The Market Participant has conducted a reasonable review of the potential Certificate Holder and is not aware that the potential Certificate Holder is one of the persons on any U.S. terrorist watch list, the link to which is located on the MIS Public Area. The Certificate Holder does not violate the conditions of use specified by the software vendor that provides the Digital Certificates for the Market Participant s use and provided to the Certificate Holder. (b) Requesting revocation of Digital Certificates under any of the following conditions: (i) As soon as possible but no later than three Business Days after: PAGE 28 OF 44