Comment Form Reliability Coordination Project 2006-06

Comment Form — Reliability Coordination Project 2006-06

Comment Background and Questions

for Reliability Coordination — Project 2006-06

Comments must be submitted by September 16, 2008. If you have questions please contact Stephen Crutchfield at or by telephone at 609-651-9455.

Background Information:

The Reliability Coordination Standards Drafting Team was tasked with ensuring that the reliability-related requirements applicable to the Reliability Coordinator are clear, measurable, unique and enforceable; and to ensure that this set of requirements is sufficient to maintain reliability of the Bulk Electric System. The SAR also called for revisions to the group of Standards based on FERC Order 693.

During the course of the project, the NERC Standard Staff revised the Reliability Standards Work Plan and noted several areas of overlapping scope between certain projects. The original SAR for Project 2006-6 called for revisions to PER-004 (Reliability Coordination – Staffing) and PRC-001 (System Protection Coordination). Based on the scope overlap of the teams involved, it was determined that PER-004 would best be served by moving all of the proposed scope to Project 2006-1, System Personnel Training. Similarly, it was determined that PER-004 would best be served by moving all of the proposed scope to Project 2007-6, System Protection.

The RCSDT has Standards that are impacted by the work of the IROL Standards Drafting Team and the standards that they have developed and the modifications they’ve proposed to some of the IRO standards. The RCSDT is recommending further revisions to the IRO standards and coordinated these changes with the IROL SDT. We have noted revisions made to the standards by the IROL SDT in our documents.

A summary of the proposed revisions to the Standards remaining in Project 2006-06 is:

COM-001-2

The RCSDT revised the standard and is proposing retiring three requirements (R1, R5 and R6). Changes were made to eliminate redundancies between standards (existing and proposed), align with NERC’s Rules of Procedure and to address issues in FERC Order 693.

COM-002-3

The RCSDT proposes retiring this standard. The RCSDT contends that COM-002-2, R1 and its subrequirements are low level facilitating requirements that are more appropriately and inherently monitored under various higher level performance-based reliability requirements for each entity throughout the body of standards. The Operations Communications Protocols SDT is addressing R2. They plan to modify the requirement and place the modified requirement in a new standard, COM-003-1. Requirement 2 will remain in place until COM-003-1 is approved.

IRO-001-2

The RC SDT revised the standard and is proposing retiring several requirements (R1, R2, R4, R5, R6, R7 and R10). Changes were made to eliminate redundancies between standards (existing and proposed), align with NERC’s Rules of Procedure and to address issues in FERC Order 693.

IRO-002-2

The RCSDT revised the standard and is proposing retiring several requirements (R1, R3, R4, R5, R6, R7 and R8). Changes were made to eliminate redundancies between standards (existing and proposed), to align with NERC’s Rules of Procedure and to address issues in FERC Order 693.

IRO-005-2

Many of the requirements in this standard will be retired under the IROL SDT work plan. The RCSDT proposes retiring other requirements and moving R6 and R15 to IRO-001-2. This will retire or move all requirements in this standard. The RCSDT proposes retiring the standard.

IRO-014-2

The RCSDT revised the standard and is proposing retiring two requirements (R3 and R4). New requirements were brought into this standard from IRO-015-1 (R1-R3) and IRO-016-1 (R1 and its sub requirements). Changes were made to eliminate redundancies between standards (existing and proposed), eliminate administrative items, align with NERC’s Rules of Procedure and to address issues in FERC Order 693.

IRO-015-2

The RCSDT recommends retiring Standard IRO-015 and moving all requirements to IRO-014-2.

IRO-016-2

The RCSDT recommends retiring this Standard. The requirements listed in R1 and its sub-requirements were incorporated into IRO-014-2 as new requirements. The RCSDT recommends retiring R2 because it is a measure of performance of R1.

The Reliability Coordination Drafting Team would like to receive industry comments on the Requirements, Measures and Violation Severity Levels of this group of standards. Accordingly, we request that you submit your comments electronically bySeptember 16, 2008.

Do you agree with the revisions to the Requirements in COM-001-2 as shown in the posted Standard and Implementation Plan? If not, please explain in the comment area.

Yes

Comments:

Do you agree with the revisions to the Measures in COM-001-2 as shown in the posted Standard and Implementation Plan? If not, please explain in the comment area.

Yes

Comments:

Do you agree with the Violation Severity Levels proposed in COM-001-2 as shown in the posted Standard and Implementation Plan? If not, please explain in the comment area.

Yes

Comments:

Do you agree with the revisions to the Requirements in COM-002-3 as shown in the posted Standard and Implementation Plan? If not, please explain in the comment area.

Yes

Comments:

Do you agree with the revisions to the Measures in COM-002-3 as shown in the posted Standard and Implementation Plan? If not, please explain in the comment area.

Yes

Comments:

Do you agree with the Violation Severity Levels proposed in COM-002-3 as shown in the posted Standard and Implementation Plan? If not, please explain in the comment area.

Yes

Comments:

Do you agree with the revisions to the Requirements in IRO-001-2 as shown in the posted Standard and Implementation Plan? If not, please explain in the comment area.

Yes

Comments:

Do you agree with the revisions to the Measures in IRO-001-2 as shown in the posted Standard and Implementation Plan? If not, please explain in the comment area.

Yes

Comments:

Do you agree with the Violation Severity Levels proposed in IRO-001-2 as shown in the posted Standard and Implementation Plan? If not, please explain in the comment area.

Yes

Comments:

Do you agree with the revisions to the Requirements in IRO-002-2 as shown in the posted Standard and Implementation Plan? If not, please explain in the comment area.

Yes

Comments:

Do you agree with the revisions to the Measures in IRO-002-2 as shown in the posted Standard and Implementation Plan? If not, please explain in the comment area.

Yes

Comments:

Do you agree with the Violation Severity Levels proposed in IRO-002-2 as shown in the posted Standard and Implementation Plan? If not, please explain in the comment area.

Yes

Comments:

Do you agree with the revisions to IRO-005-1 as shown in the posted Standard and Implementation Plan? The RC SDT is recommending retiring or moving all of the requirements and retiring this standard. If not, please explain in the comment area.

Yes

Comments:

Do you agree with the revisions to the Requirements in IRO-014-2 as shown in the posted Standard and Implementation Plan? If not, please explain in the comment area.

Yes

Comments:

Do you agree with the revisions to the Measures in IRO-014-2 as shown in the posted Standard and Implementation Plan? If not, please explain in the comment area.

Yes

Comments:

Do you agree with the Violation Severity Levels proposed in IRO-014-2 as shown in the posted Standard and Implementation Plan? If not, please explain in the comment area.

Yes

Comments:

Do you agree with the RC SDT recommendation to retire IRO-015-2 and move the requirements into IRO-014-2? If not, please explain in the comment area.

Yes

Comments:

Do you agree with the revisions to IRO-016-2 as shown in the posted Standard and Implementation Plan? If not, please explain in the comment area.

Yes

Comments:

If you have any other comments, not expressed in questions above, on this set of revisions, please provide your comments here.

Comments:

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