WECC-0119, Removal of Reliability Assurer1

MEMO

Date:June 1, 2016

To:WECC Standards Committee (WSC)

Subject:WECC-0119, Removal of Reliability Assurer (SAR)

RC-006-WECC-CRT-2 Underfrequency Load Shedding

WECC CRT

This memo requests retirement of the following WECC Requirements (WR) included in the WECC CRT because the WRs are either addressed in peripheral WECC documents or are better suited as a WECC Guideline.[1]

Retirement of the WRs will have no impact on the reliability of the Interconnection because the assigned tasks can continue to be achieved through either of the above requested means.

Deletion of the WRs will address the goals of the SAR by eliminating the current conflict of interest whereby WECC serves both as the entity responsible to complete the assigned tasks as well as the entity responsible for monitoring the adherence to the assigned task.

The WRs requested for retirement are WR1, WR2, WR3, WR13, and WR14. The applicable entity of each of these requirements is the Reliability Assurer/WECC. WECC CRT WRs 4 and 5 through 12 are not proposed for retirement.

Overview

The WECC CRT was developed in support of PRC-006-1/2[2], Automatic Underfrequency Load Shedding (UFLS). Version 2 has an enforcement date of October 1, 2015. PRC-006-1/2 calls for the Planning Coordinator to develop, maintain, review, implement, share, communicate and ensure the specific content of the UFLS Plan(AKA: Coordinated Plan). The WECC CRT was not drafted to specifically address Fill-in-the-Blank requirements contained in a NERC Standard. If the WRs are retired, that retirement will have no direct impact on WECC’s obligations under a NERC Fill-in-the-Blank Standard.

Redundant to the Role of WECC Joint Guidance Committee (JGC)[3]

Because of the unique role of the JGC and its oversight for the Under Frequency Load Shedding Review Group (Group), that committee is best suited to complete the tasks assigned to WECC in the WECC CRT; therefore, the requirements can be deleted from the WECC Criterion. They need not be retained in a WECC Criterion.

The affected WRs dictate administrative interaction between WECC as a corporation and the Group. The Group consists of functional entities spanning multiple WECC Standing Committees[4] and is answerable to the JGC. The JGC generally addresses “communication and collaboration among the Standing Committees”[5], and specificallyaddresses “cross-functional reliability issues [while] making appropriate work assignments and creating cross-functional task forces.”[6] The WRs directly address the Coordinated Plan, owned by the Operating Committee and produced in conjunction with the Planning Coordinating Committee.[7] If WECC as the RA were removed entirely from the equation, the tasks associated with the WRs could still be performed. This position is buttressed by a review of the associated WECC Measures. When reviewed en toto, the evidence that the tasks were performed can be 100% provided by either the JGC or the Group itself. The construction of Measures shows that if WECC were completely removed from the Applicability section of the WECC CRT, the JGC and the Group could perform the associated tasks and also provide any required evidence of performance.

Restated, WECC can be eliminated from the WRs, all tasks could continue under the auspice of the JGC and the Group, and where any evidence of performance was needed for accountability it could be obtained from either the JGC or the Group without involving WECC as the RA.

Re-Categorize the Content of the Affected WRs

If retained, the affected WRs are best addressed in a WECC Guideline and not a WECC Criterion; therefore, if the substance is retained it should be moved to or reclassified as a WECC Guideline.

The content of the WRs explains the ministerial and executive processes whereby WECC is to interact with the Group.[8] Unlike a categorical Fill-in-the-Blank WECC Criterion[9], these WRs are not mandated by any specific RRO-related requirements contained in any NERC Standard. As such, they are a better match to a WECC Guideline that is “a process, procedure or set of requirements created to address technical issues”[10] then they are to a WECC Criterion that must be “necessary to implement, to augment, or to comply with NERC Reliability Standards”.[11]

Because WECC can be removed from the WECC CRT WRs without impact to reliability; and whereas, the assigned tasks are within the purview of the Joint Guidance Committee; and whereas the content of the requirements is best suited for a WECC Guideline, the WRs can either be retired as redundant to the JGC activities or extracted and classified as a WECC Guideline.

Attachment A

WECC Requirement / Is Met BY
WR1. The [RA] shall designate the [Review Group]…to review the Coordinated Plan…
WR2. The [RA] shall verify the Coordinated Plan contains [specified data]…
WR3. The [RA] shall instruct the Review group…
WR4. The [RA] shall verify that the Review Group conducts a review…
WR13. The [RA] shall designate the Review Group to coordinate…
WR14. The [RA] shall instruct the Review group…to review…. / The roles and assignments of WECC, the Standing Committees, the Joint Guidance Committee, and the WECC Board of Directors are all designated by the WECC Bylaws, WECC Policies, and the charters of the associated groups.
These roles and assignments need not be specifically re-stated in the WECC CRT.
The Joint Guidance Committee’s Charter specifies that it will coordinate WECC projects and facilitate communication between Standing Committees.

Western Electricity Coordinating Council

[1] Pursuant the Reliability Standards Development Procedures, Step 13 – Retire [a WECC Criterion], “Upon determining that the subject manner of [a WECC Criterion] is duplicate in a NERC Reliability Standard, and that retirement of the [WECC Criterion] will not cause a reliability gap after the effective date of the associated NERC Reliability Standard, the WSC may retire [a WECC Criterion] on its own initiative without further due process.”

[2]PRC-006-2 in response to FERC Order 763. Developed as WECC-0065 and WECC-0116.

[3]The JGC is a “board committee established in accordance with Section 7.7.3 of the WECC Bylaws”. JGC Charter.

[4]WECC Underfrequency Load Shedding Review Group (Group) – A joint regional group comprised of WECC Balancing Authorities, Planning Coordinators, Transmission Operators, and Transmission Planners created by the WECC Joint Guidance Committee to review and maintain an accurate underfrequency load shedding database and simulation models reflecting the WECC Off-Nominal Frequency Load Shedding Plan. The Review Group shall also be responsible for conducting simulations of the Coordinated Plan to ensure the Coordinated Plan meets all the requirements of NERC Reliability Standard PRC-006-1.

[5] Ibid.

[6] Ibid, (a)

[7]WECC Off-Nominal Frequency Load Shedding Plan is owned by the WECC Operating Committee. AKA: the Coordinated Plan.

[8] Attachment A

[9] E.g., PRC-(12 through 14)-WECC-CRT-2.1, Remedial Action Scheme Review and Assessment Plan

[10] WECC Document Categorization Policy, 2.4 WECC Guidelines.

[11] NERC Rules of Procedure, Section 313, Regional Criteria.