Second Supplemental Technical Comment of L.M. Marlowe on the Frequency-Response Absorption Standard and Coupling-Discrimination Protocol
Read topic-matched comments in EL26-67
Topics in the text: Cost allocation
Responses and related views
No section-specific public response is linked for this document.
Source sections
Printed headings where available; page ranges otherwise. Excerpts below are selected from the text by keyword.
Opening text
opening text · Topic match: Cost allocation
It provides additional technical detail responsive to the reliability and observability questions raised in these proceedings, and asks that all submissions be evaluated against the full requirements of the Commission’s Show Cause Orders.Read this passage Filed comments: Cost allocation
I. The Standard of Evaluation Respectfully Urged
printed heading · Topic match: Cost allocation
Commenter asks that each submission — including Commenter’s own — be measured against that complete standard, so that the resolution the Commission adopts rests on frameworks that fulfill the whole of what reliability and consumer protection require, not a part.Read this passage Filed comments: Cost allocation
II. The Binding Contingency Has Shifted
printed heading
The Binding Contingency Has Shifted Reserve adequacy and frequency-response planning have historically been sized against an enumerated largest credible contingency — typically the loss of the single largest generating unit — treated as physical and independent.Read this passage
III. The Frequency-Response Absorption Standard (Minimum-Inertia Condition)
printed heading
Stability requires two conditions simultaneously: the initial RoCoF must remain below the protection threshold at which relays trip generation, and the frequency excursion before PFR arrests it must remain within the trip band.Read this passage
IV. The Coupling-Discrimination Protocol
printed heading
The Coupling-Discrimination Protocol A rigorous standard must distinguish the true common-mode risk from legitimate distributed flexibility, because both produce correlated load movement.Read this passage
V. Remediation Is Intrinsic to the Measurement, Not Appended to It
printed heading
Remediation Is Intrinsic to the Measurement, Not Appended to It This section states an engineering property of the architecture, not a policy position.Read this passage
VI. Relationship to the Record and Reservation
printed heading
Relationship to the Record and Reservation This Comment supplements and does not supersede Commenter’s prior filings.Read this passage
VII. Conclusion
printed heading
Conclusion Commenter respectfully requests that the Commission consider these technical considerations, and that it hold each framework, methodology, and tariff before it — including Commenter’s own — to the full rigor of what the Show Cause Orders require.Read this passage