Comment Report Form for WECC-0121C
Posting 1
The WECC-0121C, INT-016-WECC-CRT-2 Data Submittal Drafting Team (DT) thanks everyone who submitted comments on the proposed documents.
Posting
This project was posted for a 45-day public comment period fromOctober 21 through December 5, 2016.
WECC distributed the notice for the posting onOctober 18, 2016. The DT asked stakeholders to provide feedback on the proposed document through a standardized electronic template. WECC received comments from one company as shown in the following table.
Location of Comments
All comments received on the project can be viewed in their original format on the WECC-0121C project page under the “Submit and Review Comments” accordion.
Changes in Response to Comment
After consideration of comments received, the DT took the following action:
Deletion of WR2
The Drafting Team believes the requirements contained in WR2 are included in WR1, Posting 2. As such, the team holds that WR2 can be deleted. The team added in mention of the interchange tool, keeping the tool’s designation generic.
PSE Applicability
The drafting team removed the Purchasing-Selling Entity (PSE) from the Applicability section noting that if the PSE is deleted, the Balancing Authority will continue to perform the required task. This step was also taken to better align the document with NERC’s trend of removing the PSE and the Load-Serving Entity (LSE) from the Applicability section of its documents.
For WECC Criteria in which the PSE and LSE are retained, monitoring and adherence are addressed in the Process for Monitoring and Adherence to Regional Criteria (Process).
The Process does not require that a non-adhering entity be listed in the NERC Compliance Registry (e.g. PSE/LSE); rather, the non-adhering entity is simply referred to as the “Alleged Non-Adhering Party”. (WECC Document Categorization Policy, Section 2.2, WECC Regional Criteria, Monitoring and Enforcement (pages 5-6); see also WECC’s Process for Monitoring Adherence to WECC Regional Criterion Requirements.)
Effective Date
The proposed Effective Date for the project is immediately upon approval by the WECC Board of Directors (Board).
Justification
Because the tasks assigned in the specified Requirements should impose no new burden, the proposed Effective Date is: “The first day of the second quarter following applicable regulatory approval.”
NERC/FERC approval is not required for this project.
Action Plan
The WECC-0121 drafting team agreed by a majority vote of those present to post the project for an iterative posting. Posting 2 of the project will open on February 21, 2017 and close on March 24, 2017. The drafting team will meet to respond to comments on March 30, 2017 from 2:00 p.m. to 4:00 p.m., and again on April 6, 2017, from 2:00 p.m. to 4:00 p.m., as needed. Stated times are Mountain Time.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC Consultant, at (503) 307-5782. In addition, there is a WECC Reliability Standards Appeals Process.
Commenter / Organization1 / Kristie Cocco / Arizona Public Service Company (APS)
Index to Questions, Comments, and Responses
Question
- The drafting team invites comments on all aspects of the proposed document.
- The drafting team invites comments on all aspects of the proposed document.
Summary Consideration: / See summary in the preamble of this document.
Commenter / Comment / Response
APS
As originally written, WR1 requires the PSE and BA to designate either the PSE or BA as responsible for electronically submitting an RFI; WR2 requires the designated entity to submit the e-Tag. The proposed revisions eliminate WR2, resulting in no requirement stating that someone submits the tag. To ensure the purpose of the criterion remains intact, AZPS recommends reinstating WR2 to require the designated entity to submit the e-Tag.
Additionally, this criterion still lists the PSE function as an applicable Functional Entity, and includes the PSE in WR1 and WM1. Considering there are no entities registered as PSEs, how does the Drafting Team propose holding PSEs accountable? / Reinstatement of WR2
The Drafting Team believes the requirements contained in WR2 are included in WR1. As such, the team holds that WR2 can be deleted. The team added in mention of the interchange tool.
PSE Applicability
The drafting team removed the Purchasing-Selling Entity (PSE) from the Applicability section noting that if the PSE is deleted, the Balancing Authority will continue to perform the required task. This step was also taken to better align the document with NERC’s trend of removing the PSE and the Load-Serving Entity (LSE) from the Applicability section of its documents.
For WECC Criteria in which the PSE and LSE are retained, monitoring and adherence are addressed in the Process for Monitoring and Adherence to Regional Criteria (Process).
The Process does not require that a non-adhering entity be listed in the NERC Compliance Registry (e.g. PSE/LSE); rather, the non-adhering entity is simply referred to as the “Alleged Non-Adhering Party”. (WECC Document Categorization Policy, Section 2.2, WECC Regional Criteria, Monitoring and Enforcement (pages 5-6); see also WECC’s Process for Monitoring Adherence to WECC Regional Criterion Requirements.)