Comment Report Form for WECC-0117 Procedures Redraft

Posting 1

The WECC Standards Committee (WSC) acting in its role as the WECC-0117 Reliability Standards Development Procedures Redraft Drafting Team (DT) thanks everyone who submitted comments on the proposed document.

Posting

This document was last posted for a 45-day public comment period fromDecember 8, 2015 through January 25, 2016.

WECC distributed the notice for the posting onDecember 8, 2015.The DT asked stakeholders to provide feedback on the proposed document through a standardized electronic template. WECC received comments from two companies representing five of the eight Standards Voting Sectors (SVS), as shown in the following table.

Location of Comments

All comments received on the document can be viewed in their original formaton the WECC-0117project page under the “Submit and Review Comments” accordion.

Changes in Response to Comments

After consideration of comments received, the DT made the following changes:

  • Reference styles were changed.Styles will be finalized by WECC Communications.
  • A weighted 2/3 majority to approve an RRS or CRT was accepted.

Minority View

A request to broaden the potential list of Applicable Entities was not accepted.To the extent possible, this filing seeks to decouple the Procedures from NERC documents to avoid unintended consequences as a result of incorporation by reference.

A request to apply a 45-day appeal window to all bulleted items on page 19 was not accepted.The 45-day appellate window was not applied for an appeal based on an incorrect Standards Voting Section classification.If the 45-day appellate window is applied to that fact pattern, it is possible for a project to be approved by the WSC, a WECC Ballot Pool andthe WECC Board of Directors, and filed with NERC before the appeal was brought.The shorter period was retained.

Effective Date

The Reliability Standards Development Procedures require approval by the WECC Board of Directors, the North American Electric Reliability Corporation Board of Trustees, and the Federal Energy Regulatory Commission.The effective date is subject to regulatory approvals.

Justification

The initial redraft was triggered by a change to the NERC Compliance matrix.NERC/FERC removed the Purchasing-Selling Entity and the Load-Serving Entity from the NERC Compliance Registry.When that occurred it left those entities within WECC without a vote in their assigned Standards Voting Sector.The WSC agreed to continue the existing SVSs until the Procedures could be redrafted.

Action Plan

On January 28, 2015, the WECC-0117 DT agreed by majority vote to post Posting 2 for comment.

The WSC is scheduled to meet on March 8, 2016 to consider further disposition.

Contacts and Appeals

If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC Consultant, at . In addition, there is a WECC Reliability Standards Appeals Process.

The WECC Standards Voting Sectors are:

1 — Transmission Sector

2 — Generation Sector

3 — Marketers and Brokers Sector

4 — Distribution Sector

5 — System Coordination Sector

6 — End Use Representative Sector

7 — State and Provincial Representatives Sector

8 — Other Non-Registered WECC Members and Participating Stakeholders Sector

Commenter / Organization / WECC Standards Voting Sectors
1 / 2 / 3 / 4 / 5 / 6 / 7 / 8
1 / Diana McMahon / Salt River Project / X / X / X / X / X
2 / Michelle Amarantos / Arizona Public Service (APS) / X / X / X / X / X

Index to Questions, Comments, and Responses

Question

  1. The drafting team invites comments on all aspects of the proposed document.
  1. The drafting team invites comments on all aspects of the proposed document.

Summary Consideration: / See summary in the preamble of this document.
Commenter / Yes / No / Comment
Diana McMahon / Salt River Project would like to that the Drafting Team for all their efforts to build a document that is consistent with current industry practices and future direction.
The following comments are based on the red-linedcopy posted.
Page 1: Footnote 1 – Defined terms that are used should site the source. Although there has been an effort to clean up inconsistencies between the NERC Glossary of Terms and the Rules of Procedure, they are not always the same.
Page 19: Paragraph 2- Defined terms should site the source if there are multiple source documents to avoid confusion.
Page 19: Paragraph 3 – This is inconsistent with the NERC ROP Appendix 3. This is very limiting in that it does not allow for facilities to be included or excluded.
Page 19: Last paragraph – "For bullets one through four, the appeal must be brought no later than 45 days after the closing of the project's ballot."I believe based on the remainder of the section that this is applicable to any ballot.SRP recommends rewording to avoid confusion.
Styles and Formats
Footnotes, annotations, styles and formatting will be finalized at the end of the project via WECC Communications.
Over-Limiting Language
A request to change “Page 19, Paragraph 3” was not accepted.The paragraph identified states:
“In drafting the applicability section of a RRS, only functions in the NERC Compliance Registry will be used.To avoid conflict of interest, WECC, its committees and subgroups, shall not be listed as the applicable entity in a RRS or CRT.” (This language is subject to final tech writing.)
This draft is designed to decouple the Procedures from NERC documents, where feasible.This decoupling is targeted to avoid unintended consequences such as those occurring when NERC/FERC removed the Purchasing-Selling Entity and the Load-Serving Entity from the NERC compliance registry.Because the Standard Voting Sectors within the WECC Procedures are tied by reference to the NERC compliance registry.When NERC/FERC made those unilateral changes,entities within WECC were inadvertently disenfranchised.Further, the NERC Functional Model includes a number of identified entities that are not currently intended for use in a NERC Standard or a Regional Reliability Standard, such as the Interchange Authority and the Reliability Assurer.The Posting 1 language avoids this pitfall.
Bullets One through Four
SRP requested clarity on the applicability of “bullets one through four” on page 19.
A stray bullet was identified in Posting 1 and removed for Posting 2.That section now shows only four bullets.A 45-day appellate window applies to the first three; a 10-day appellate window applies to the fourth.The 45-day appellate window was not applied to the fourth bullet (assignment of an SVS) because the 45th day could occur well after the project had been approved by the WECC Ballot Pool, the WSC, the WECC Board of Directors, and the project handed off to NERC.The 10-day window prevents having to unwind all approvals.
APS / AZPS requests that the WECC Reliability Standards Development Procedures and their associated SAR be modified to include a revision of the threshold needed to approve the modification, retirement, and interpretation of Regional Reliability Standards (RRS) and the WECC Regional Criteria (CRT).Currently, a weighted majority vote of the Ballot Pool is required; however, the FRCC, MRO, NPCC, SERC, SPP, and Texas RE Regional Entities and NERC all require a two-thirds majority for the approval of Standards. To better align the practices of WECC with the above listed entities, AZPS believes a weighted two-thirds majority is appropriate for WECC.
A weighted 2/3 majority is included in Posting 2.