Comment Report Form for WECC-0117 Procedures Redraft
Posting 3
The WECC Standards Committee (WSC), acting in its role as the WECC-0117 Reliability Standards Development Procedures Redraft Drafting Team (DT) thanks thosewho submitted comments on the proposed document.
Posting
This document was posted for a 30-day public comment period on June 27 through August 1, 2016.
The notice of the posting was distributed onJune 21, 2016. The DTrequested that stakeholders provide feedback on the proposed document through a standardized electronic template. WECC received two comments in response to Posting 3.
Location of Comments
All comments received on the document can be viewed in their original formaton the WECC-0117project page under the “Submit and Review Comments” accordion.
Changes in Response to Comments
Clarifications were made regarding the scope of the WSC’s authority to retire WECC Criteria or subsets thereof.
Minority View
No minority views were noted.
Effective Date
The Reliability Standards Development Procedures require approval by the WECC Board of Directors, the North American Electric Reliability Corporation(NERC)Board of Trustees, and the Federal Energy Regulatory Commission (FERC).The effective date is subject to regulatory approvals.
Action Plan
On September 6, 2016, the WSC approved Posting 4 for a 30-day comment period. The project will be posted for an iterative comment period onSeptember 13 through October 14, 2016.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC Consultant. In addition, there is a WECC Reliability Standards Appeals Process.
The WECC Standards Voting Sectors are:
1 — Transmission Sector
2 — Generation Sector
3 — Marketers and Brokers Sector
4 — Distribution Sector
5 — System Coordination Sector
6 — End Use Representative Sector
Commenter / Organization / WECC Standards Voting Sectors1 / 2 / 3 / 4 / 5 / 6 / 7 / 8
Michelle Amarantos on behalf of Kristie Cocco, Arizona Public Service Company (APS) / Arizona Public Service Company / X / X / X / X / X
W. Shannon Black / WECC / X
7 — State and Provincial Representatives Sector
8 — Other Non-Registered WECC Members and Participating Stakeholders Sector
Index to Questions, Comments, and Responses
Question
- The drafting team invites comments on all aspects of the proposed document.
Summary Consideration: / See summary in the preamble of this document.
Commenter / Yes / No / Comment
Michelle Amarantos on behalf of Kristie Cocco, Arizona Public Service Company / Once an entity has selected its most applicable SVS, AZPS believes that – absent an organizational or structural modification to the organization that impacts its ability to meet the criteria for its current SVS – the initially applicable/selected SVS should be retained in perpetuity. That being said, AZPS agrees that affiliates should only get one vote where there are multiple affiliates in a segment.
The WSC appreciates APS’s participation and viewpoint. Noting that APS has not requested any changes, no changes were made.
W. Shannon Black / As proposed, Posting 3 at Step 13 states:
"Upon determining that the subject matter of a CRT is duplicated in a NERC Reliability Standard, another CRT, or other regulatory document, and that retirement of the CRT will not cause a reliability gap after the effective date of the associated retirement, the WSC may retire a WECC CRT on its own initiative."
The language should be changed to include the following italicized language:
"Upon determining that the subject matter of a CRT is duplicated in a NERC Reliability Standard, regulatory document,WECCCRT,or other approved WECC document, and that retirement of all or part of the CRT will not cause a reliability gap after the effective date of the associated retirement, the WSC may retire all or part of a WECC CRT on its own initiative."
The addition of other approved WECC documents provides leeway to include documents such as charters that address administration functions that are not best suited for inclusion in a WECC CRT.
The addition of all or part clarifies that the WSC can retire just a part of a document as opposed to being required to retire the entire document.
The WSC appreciates WECC’s participation in the standards development process. The requested changes have been incorporated.