WECC-0117 Proposed Reliability Standards Development Procedures - Change Highlights

2017 Proposed Changes to WECC Reliability Standards Development Procedures

Request for 45-Day Posting at NERC1

MEMO

Date:March 16, 2017

To:NERC, Howard Gugel, Senior Director, Standards and Education

Subject:WECC Reliability Standards Development Procedures (Procedures)

Developed as WECC-0117

Under the WECC Standards Committee (WSC) Charteras well as the existing Procedures, the WSC is charged with maintenance of the Procedures. If the WSC “determines that a change to [the Procedures] should be pursued, the WSC shall draft the proposed changes and post the proposed changes to the WECC website for comment, accompanied by a notice to the [Standards Email List] soliciting comments on the proposed changes.”[1] The WSC shall then “consider all comments received and shall redraft changes as it deems necessary. Once the WSC approves the proposed changes, those changes shall be submitted to the [WECC] Board [of Directors (Board)] for approval. Changes to [the] Procedures approved by the Board shall be submitted to NERC for NERC and FERC approval.”[2]

Notices required under the existing Procedures are posted on the WECC-0117 Standards Development Procedures Redraft project page at the Procedural Notices accordion. The project was posted four times for comment as follows:[3]

Posting 1December 8, 2015 through January 25, 2016
Posting 2February 8 through February 29, 2016
Posting 3June 27 through August 1, 2016
Posting 4September 13 through October 14, 2016

On December 6, 2016, after considering all comments and making changes it deemed necessary, the WSC approved the project for Board approval. On March 8, 2017, the Board approved the project for NERC/FERC disposition. In accordance with NERC Rules of Procedure, WECC is requesting that NERC post the proposed Procedures for a 45-day comment period.

A summary of the proposed changes is included in Attachment A.

If you have questions, please feel free to contact me.

Sincerely,

Steven Rueckert

WECC Director of Standards

1-801-883-6878

Attachment A

Proposed Changes to the Existing FERC-Approved Procedures

Definitions in the following documents have been incorporated by reference:[4]
NERC Glossary of Terms Used in Reliability Standards
WECC Bylaws
NERC Rules of Procedure
The following definitions have been substantially altered or deleted:
Ballot Body
Day
Electricity Line of Business
Other Projects (in favor of Regional Criteria)
Non-Substantive Changes
Participating Stakeholders
Regional Reliability Standard
Substantive Changes
The existing WECC Standards Voting Sectors have been replaced in favor of the NERC Standards Voting Segments.[5]
A specific requirement was added that all new Standard Authorization Requests (SAR) be vetted during a WSC meeting.[6]
The WSC’s time window to approve a SAR was extended from 60 to 90 days, and to approve a drafting team from 60 to 120 days.[7]
The WSC’s authority to address the scope of a SAR at any point during development has been clarified.[8]
Notice of drafting team meetings and Standards Briefings has been shortened from 15 days to 14 days, as has the default window for balloting.[9]
WECC, its committees and subgroups, have been explicitly excluded from the Applicability section of both Regional Reliability Standards (RRS) and WECC Criteria to avoid conflicts of interest.[10]
The initial 45-day posting period has been streamlined to 30-days.[11]
Clarification was added that Interpretations do not require an Implementation Plan.[12]
The closing hour of posting was extended from 5:00 p.m. to 6:00 p.m. (Mountain).[13]
A streamlined approval process for non-substantive changes has been added for WECC Criterion and the NERC process adopted for an RRS.[14]
A stipulation was added requiring that application to join a Ballot Body must precede a Ballot Pool by no less than five days.[15]
Clarification was added that once the Ballot Pool approves a project, the WSC is obligated to forward the project to the WECC Board of Directors; however, the WSC is not obligated to recommend approval of the project.[16]
Additional Standards Briefings are explicitly allowed.[17]
Participating Stakeholders have been deleted.[18]
The Director of Standard’s discretion has been broadened regarding late entrance into a Ballot Pool.[19]
The entire Step 10 appeals process has been redrafted.[20]
A 14-day notice period has been added as a precursor to retirement of a WECC Criterion when based on a finding of redundancy.[21]
The Interpretation section has been redrafted to effectively mirror that of the NERC interpretation process.[22]
A new section for Field Tests has been added.[23]

Western Electricity Coordinating Council

[1] The full process for making changes to the Procedures is contained in the WECC Reliability Standards Development Procedures, Maintenance of the Procedures, FERC approved December 23, 2014.

[2] Loc. Cit.

[3] Although the Procedures do not require the WSC to respond to comments, it did so, posting its responses on the WECC-0117 project page at the Submit and Review Comments accordion.

[4] Procedures, Definitions. Where definitions varied between multiple sources, the source document from which the definition is gleaned has been annotated.

[5] Procedures, WECC Standards Voting Sectors

[6] Procedures, Step 2 – Complete SAR and Present to the WSC

[7] Procedures, Step 2 – Complete SAR and Present to the WSC

[8] Procedures, Step 3 – Convene a Drafting Team; see also Treatment of Substantive Changes

[9] Procedures, Step 4 – Begin Drafting Phase and Submit Draft to WSC; see also Step 8 – Convene a Standards Briefing; Step 9 – Form the Ballot Pool and Ballot the Standards; Step 13 – Retire a CRT

[10] Procedures, Step 4 – Begin Drafting Phase and Submit Draft to WSC;

[11] Procedures, Step 5 – Post for Comment

[12] Procedures, Step 5 – Post for Comment

[13] Procedures, Step 5 – Post for Comment

[14] Procedures, Treatment of Non-Substantive Changes

[15] Procedures, Step 9 – Form the Ballot Pool and Ballot the Standard

[16] Procedures, Step 6 – Respond to Comments

[17] Procedures, Definitions

[18] Procedures, Definitions

[19] Procedures, Step 9 – Form the Ballot Pool and Ballot the Standard

[20] Procedures, Step 10 – Initiate the Appeals Process – If Needed

[21] Procedures, Step 13 – Retire a CRT

[22] Procedures, Step 14 – Submit a Request for Interpretation

[23] Procedures – Field Tests