June 24, 2014

To:WECC Standards Committee (WSC)

Subject:Request for Change in Scope

WECC-0100 (SAR)

TPL-001-WECC-RBP-2.1

System Performance Criteria

The WECC-0100 Drafting Team (DT) is recommending that Requirement WR3 of TPL-001-WECC-RBP-2.1 (WECC TPL), System Performance Criteria, a Regional Business Practice, and the substance of Requirements R5 and R6 of NERC TPL-001-4, Transmission System Planning Performance Requirements (NERC TPL), be drafted into a WECC Guideline as opposed to a WECC Regional Business Practice, or its successor document type.

If approved, drafting of the WECC Guideline would take place under the auspices ofthe Standing Committee and afforded due process under the rules of that committee. Once the WECC Guideline is complete, the Standing Committee would ensure that all substantive aspects of the WECC TPL and the NERC TPL were addressed prior to making a recommendation to the WSC that the remainder of the WECC TPL (Requirement WR3) be balloted for retirement coincide with the Effective date of the NERC TPL or thereafter pending final completion of the guideline.

The Standards Authorization Request (SAR) would remain in abeyance until that time, unless the WSC requests an earlier review.

It should be noted that after eight months of debate, drafting team members remain steadfast on each side of this debate making forward progress unlikely without resolution.

Background

The initial scope of the SAR called for review of the WECC TPL to determine whether it should be developed as a WECC Regional Reliability Standard (RRS). As a result of the review, the DT recommended and the WECC Board of Directors (Board) approved retirement of Requirements WR1, WR2, WR4, and WR5 coincident with the Effective Date of the NERC TPL. The DT continued its review and is now recommending retirement of the balance of the document (WR3), coincide with the Effective Date of the NERC TPL, but only after development of a WECC Guideline to augment WR3 and NERC TPL Requirements R5 and R6.

The DT concluded that reliability could best be served through a WECC Guideline as opposed to a WECC Regional Business Practice, or its successor, because:

  • The dynamics of the Bulk-Electric System (BES) are constantly and quickly changing. A WECC Guideline would allow for a quick and flexible response at the Standing Committee level as opposed to the more cumbersome due process afforded under the WECC Reliability Standards Development Procedures (Procedures).
  • A WECC Guideline is better suited to address the vast permutations of the individual elements within the Interconnection as opposed to the more stringent drafting conventions of a WECC Regional Business Practice or its successor document type.
  • A WECC Guideline is better suited for incorporation by reference of supporting documents and studies that change from time-to-time.
  • A WECC Guideline is best suited to address the substance in terms of best practices and a general procedural description as opposed to mandating a specific consistent application of technical, documentation, and administrative procedures.
  • The NERC TPL does not mandate a single, uniform, Interconnection-wide set of criteria in order to be in compliance with Requirements R5 and R6. A WECC Guideline would allow individual entities to seek guidance from WECC while still taking into consideration the specific operational attributes of its internal system and any multi-lateral arrangements it may make with systems external to its own.

Minority Opinion

The minority opinionis well summarized by Mr. Hari Singh and Mr. Sushant Barave.

The DT appreciates the WSC’s consideration of the proposed disposition and looks forward to its disposition.

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

Sincerely,

Mr. Chuck Matthews

WECC-0100

Drafting Team Chair

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