Comment Report Form for WECC-0119B

Posting 1

The WECC-0119B PRC-(012 through 014)-WECC-CRT-2.1, Remedial Action Scheme Review and Assessment Plan (WECC PRC) Drafting Team (DT) thanks everyone who submitted comments on the proposed documents.

Posting

This document was last posted for a 45-day public comment period from May 17 through July 1, 2016.

On May 11, 2016, WECC distributed notice of the posting to approximately 625 individuals via the Standards Email List.

The DT asked stakeholders to provide feedback on the proposed document through a standardized electronic template. WECC received comments from two companies as shown in the following table.

Location of Comments

All comments received on the document can be viewed in their original format on the WECC-0119Bproject page under the “Submit and Review Comments – RA Removal PRC-(012 through 014)-WECC-CRT-2.1” accordion.

Changes in Response to Comment

Both commenters agreed with the DT that: 1) the identified Requirements should be retired because they are redundant, and 2) retirement of the Requirements would not cause a reliability gap.

After consideration of the comments received, the DT made no changes to its recommendation. Based on its analysis and consensus from the field, the DT concluded Requirements WR1, 3, 5, 6 and 7 of Version 2.2 should be retired because the WRs are redundant to peripheral NERC and WECC documents. The applicable entity for each of these Requirements is the Reliability Assurer/WECC (RA).

Additional references to the RA in Version 2.2 are located in the predicate of WR2, WR8, WR11, as well as WM12and other associated Measures. Although placement of the reference does not impute any responsibilities for the RA, those references were also deleted to ensure clarity.

Measures and sentence structure were conformed to current drafting conventions.

The defined term “Database” was converted to lower case and the WECC Glossary will be adjusted accordingly.

For those WRs in which WECC or the applicable entity is assigned an administrative task such as reporting, the specific protocols of those Requirements have deliberately been left undefined in order to allow the parties the needed flexibility to use the best administrative means available to meet the task.

Effective Date and Implementation Plan

The proposed effective date is immediately on approval by the WECC Board of Directors (Board).

Justification

The WECC PRC and all of the supporting documents are currently in effect. There should be on change in operations or business practices as a result of the proposed changes.

Action Plan

A redlined version and a proposed clean version of the document will be provided for Posting 2. Posting 2 is targeted for July 11 through August 11, 2016. The DT will meet to address comments August 18 and again on August 25, 2016, as needed. If Posting 2 raises no new substantive issues, the DT will request that the WSC approve the document for ballot with subsequent disposition by the WSC and the WECC Board of Directors. The WSC meets in September 2016.

Contacts and Appeals

If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC Consultant, at . In addition, there is a WECC Reliability Standards Appeals Process that can be found in the Reliability Standards Development Procedures.

Commenter / Organization
1 / Karen Hedlund / Tacoma Power
2 / Sergio Banuelos / Tri-State Generation and Transmission Association

Index to Questions, Comments, and Responses

Question

  1. Do you agree the specified WRs should be retired?

1a. If you answers “No” to question 1, please identify which WR(s) should not be retired and explain why it should not be retired.

1b. If you answered “No” to question 1, please suggest the most appropriate alternate document into which the affected content should be relocated. Please explain your answer.

2. Will retirement of any of the specified WERs cause a reliability gap?

2a. If you answer “Yes” to question 2, please explain your answer.

The drafting team welcomes comments on all aspects of the document.

  1. Response Summary

Summary Consideration: / See summary in the preamble of this document.
Commenter / Comment / Response
Tacoma Power
Tacoma Power responded
“Yes”, the specified WRs should be retired.
“No” retirement of any of the specified WRs will not cause a reliability gap.
No further comments were submitted. / The DT thanks Tacoma Power for its continued participation in the standards development process, and is in accord with Tacoma’s positions.
Tri-State
Tri-State responded
“Yes”, the specified WRs should be retired.
“No” retirement of any of the specified WRs will not cause a reliability gap.
Tri-State also commented:
The SAR for this project states "This​Standards Authorization Request (SAR) would remove from all WECC Criteria any references to WECC as the Reliability Assurer.” However, in the document posted for comment​ the references to the Reliability Assurer in WR2, WR8, WR11, and WM12 remain. What is the drafting team proposing to do with those references? / The DT thanks Tri-State for its continued participation in the standards development process, and is in accord with Tri-State’s positions.
The references in WR2, WR8, WR11, and WM12 to WECC as the RA are all located in the predicate of the Requirement and/or the Measure and are drafted such that the reference imputes no direct task or responsibility to WECC. To ensure greatest clarity these references have been deleted.