Automatic Time Error Correction1

Following a ballot period from August 9 through August 28, 2017, the WECC Ballot Pool approved WECC-0124 BAL-004-WECC-3, Automatic Time Error Correction (ATEC).

Development Phase Comments – Minority View

Comment Response forms and comments received during the development phase of this project are included in attachments R1 through R4.

The project was posted for comment on four separate occasions. The drafting team reviewed and considered all comments received. The following minority opinions were expressed by the industry during the development phase but were not accepted by the drafting team.

  • A minority of entities opined that no changes should be made to the standard.

In response, the WECC-0124 BAL-004-WECC-3, Automatic Time Error Correction (ATEC)Drafting Team (DT) referred to FERC’s position that large accumulations of primary inadvertent energy point to an invalid implementation of ATEC, loose control, metering or accounting errors. Further, the DT noted that a Balancing Authority operating out-of-balance for an extended time is “leaning on the system” by relying on external resources to meet its obligations and could affect other entities within an Interconnection, particularly if another entity is reacting to a grid event while unaware that the first entity has not restored its ACE. Left unchecked, this operational practice produces large accumulations of Primary II energy forcing correspondingly sustained Secondary II energy accumulations in other BAs. The proposed BAL-004-WECC-3 contributes to remediation of these concerns.

  • Settlement differences are a matter of equity better settled outside of the standards arena.

The question of equity vs. reliability is outside the scope of this project.

  • An alternative methodology of calculation should be allowed.

The DT disagreed noting the value in standardization. That said, the DT acknowledged that an entity is free to calculate its values using any internal means it choses; however, as to true-up with external entities, a single specified methodology fosters transparency and standardization.

  • An alternative software package should be provided for in the event the WECC Interchange Tool, or its successor, fails.

The DT responded noting that multiple WECC Regional Criteria are in place to address that eventuality. The DT opted not to incorporate those documents by reference noting due process concerns.

Ballot Phase Comments - Minority View

The WECC Reliability Standards Development Procedures (Procedures) do not require a drafting team to respond to comments provided during the balloting phase of a project. Comments provided during the balloting phase can be found in Attachment M.

During the balloting phase, the following minority view(s) was provided in support of a negative vote cast:

  • A Regional Reliability Standard is not needed because existing NERC Reliability Standards are sufficient.

In accordance with the NERC Rules of Procedure, the proposed Reliability Standard addresses two areas not otherwise addressed in NERC Standards. Specifically, Time Error Correction in the Western Interconnection is “automatic” and the proposed Reliability Standard would glean its true up values from a WECC-specific software tool.

Western Electricity Coordinating Council