Comment Report Form for WECC-0120

Posting5

The WECC-0120 FAC-501-WECC-1, Transmission Maintenance Five-year Review Drafting Team (DT) thanks everyone who submitted comments on the proposed document.

Posting

This document was posted for a 30-day public comment period fromJune 23 through July 24, 2017.

On June 6, 2017, WECC distributed notice of the posting via the Standards Email List.

The DT asked stakeholders to provide feedback on the proposed document through a standardized electronic template. WECC received comments from two entities as shown in the following table.

Location of Comments

All comments received on the document can be viewed in their original format on the WECC-0120 project page under the “Submit and Review Comments” accordion.

Changes in Response to Comment

In response to comments received in Posting 4 the drafting team made the following non-substantive changes:

Minority View

The drafting team considered…

Effective Date and Implementation Plan

Implementation Plan

The Reliability Standards Development Procedures (Procedures) require that an implementation plan be posted with at least one posting of the project. The Effective Date is proposed as the first day of the first quarter following applicable regulatory approval. The Implementation Plan was posted with Posting 4; no changes to the Implementation Plan were made.

Action Plan

On July 25, 2017, the WECC-0120 FAC-501-WECC-2, Transmission Maintenance Five-year ReviewDrafting Team (DT) agreed by majority vote to….

The posting period will open June 14, 2017 and close July 14, 2017. The drafting team will meet on July 25 and July 27, 2017 from 10:00 a.m. to 12:00 p.m., as needed, to discuss disposition of the project.

Comments can be submitted using the green survey buttons located on the Submit and Review Comments accordion of the WECC-0120 project page.

Contacts and Appeals

If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC Consultant. In addition, the WECC Reliability Standards Appeals Process can be found in the Reliability Standards Development Procedures.

WECC Standards Comment Table

Commenter / Organization
1 / William Franklin / Public Service Company of Colorado (PSCo)
2 / Linda Jacobson-Quinn / Farmington Electric Utility System (FEUS)
3 / Todd Komaromy / Arizona Public Service Company (APS)

Index to Questions, Comments, and Responses

Question

The Drafting Team welcomes comments on all aspects of the document.

  1. Response Summary

Summary Consideration: / See summary in the preamble of this document.
Commenter / Comment / Response
PSCo / ​PSCo appreciates the work of the drafting team and has no further comments.
The drafting team appreciates PSCo’s continued involvement in the standards development process.
FEUS / Changes to the Measure M3.
FEUS proposed the following changes to Measure M3, Sub Parts 1.1 through 1.3:
Currently posted:
1.1The date(s) the work or inspection was performed;
1.2The transmission facility on which the work was performed;
1.3A description of the inspection or maintenance performed.
FEUS Proposed:
1.1The date(s) the patrol, inspection or maintenance was performed;
1.2The transmission facility or Element on which the maintenance was performed;
1.3A description of the inspection results or maintenance performed.
Clarification on Attachment A “and/or” Statement
FEUS would like clarification for the Revised Attachment A. The introductory paragraph states "The maintenance practices in the TMIP may be performance-based, time-based, conditional based, or any combination thereof." This would indicate having a TMIP with only one of the practices would be compliant. However, Section 3d and 4c indicate at performance-based and/or condition-based maintenance must be included for transmission and station maintenance.
FEUS recommends either revising the introduction to clarify either the introduction or section 2d and 4c to be consistent.
Respectfully;
Linda Jacobson-Quinn
Changes to the Measure M3
IF ACCEPTED IT WOULD LOOK LIKE THIS. THIS WOULD BE A SUBSTANTIVE CHANGE AND REQUIRE REPOSTING.:
M3.Each TransmissionOwner will have evidence that it adhered to its TMIP, as required in Requirement R3. Evidence may include, but is not limited to:
1.1Thedate(s)the patrol, inspectionor maintenance wasperformed;
1.2Thetransmissionfacilityor Element onwhichthe maintenance wasperformed;
1.3A description of the inspection results or maintenance performed.
Clarification to Attachment A
The proposed clarifying redraft of Attachment A would look like the embedded object. I do not believe that if the DT accepted the proposal that repost would be warranted SOLELY on Attachment A.

APS / For purposes of clarity, AZPS suggests modifying Attachment A, item 1 as follows:
Currently Posted:
A list of Facilities and associated Elements that apply to all transmission facilities comprising each transmission path identified in Attachment B, Major WECC Transfer Paths in the Bulk Electric System.
Suggested Change
AlistofFacilitiesandthe Elements associated with thosetransmissionFacilitiesthatcompriseeach transmission path(s) identified in Attachment B,Major WECC Transfer Paths in the Bulk Electric System.
The drafting team adopted the suggestion.