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Notice of Proposed Rulemaking on Standards

Notice of Proposed Rulemaking on Standards. WECC Board of Directors Meeting December 7-8, 2006. Presentation Overview. NOPR Review Identify Policy Issues for Board Discussion Review of WECC Comments. Standards-Three Categories. Approved (28) Acceptable in submitted form

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Notice of Proposed Rulemaking on Standards

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  1. Notice of Proposed Rulemaking on Standards WECC Board of Directors Meeting December 7-8, 2006

  2. Presentation Overview • NOPR Review • Identify Policy Issues for Board Discussion • Review of WECC Comments

  3. Standards-Three Categories • Approved (28) • Acceptable in submitted form • Includes six regional differences • Approved – Direct Modification (61) • 83 of 107 Standards approved • Pending (24) • None Remanded

  4. Approved -- Direct Modification • 61 Standards and the Glossary • Accepted for the purpose of being improved – would be mandatory • FERC identified what needs to be fixed or modified • Follow NERC Process • May lack measures and/or levels of non-compliance • Contain clear and enforceable requirements?? • Include “high priority” standards that should be fixed in one year

  5. Pending -- “Good Utility Practice” • 24 Standards, two Regional Differences • NERC is Requesting additional information

  6. Comments • Comments are due January 3, 2007 • WECC schedule is to have comments prepared and submitted by December 20, 2006 • Seeking BOD input on Policy Issues and approval or agreement on comment items

  7. Policy Issues • Standard Validation and Improvement Period (Trial Period) • Less Subjective Penalty process • Compliance through education and outreach vs. process • Clarification of Standards applicable to Reliability Coordinators • Collaboration with Canada and Mexico

  8. Standard Validation and Improvement Period • All or some of the approved standards • All approved standards • Only for 61 approved: direct modification standards • Ambiguities exist (61 standards) • How do we enforce • Allow for development of necessary documentation • Public disclosure • Reduce appeals • Consistency

  9. Approved -- Direct Modification • 61 Standards and the Glossary • Accepted for the purpose of being improved – would be mandatory • FERC identified what needs to be fixed or modified • Follow NERC process • May lack measures and/or levels of non-compliance • Contain clear and enforceable requirements?? • Include “high priority” standards that should be fixed in one year

  10. Less Subjective Penalty Matrix • Current process is very cumbersome • Many components to consider in determining a penalty • Subjectivity called for on aspects that the information may not be readily available • More time consuming than compliance assessment • Subject to many more appeals • Has this train already left the station?

  11. Compliance through Outreach and Education • Focus on Compliance and Mitigation • Don’t “Zap” entities for an initial non-compliance • Minimize initial penalty unless flagrant • No penalties during approved mitigation periods • No surprises! • Goal is compliance, not collection of dollars

  12. Clarification of Standards Applicable to Reliability Coordinators • Some standards applicable to RC call for the RC to complete a task not currently done by RCs in the west • Task is being done by someone else • Need formal agreements • Not the way business arrangements were developed in the west • Clarification of Standard or Regional Difference

  13. Collaboration with Mexico and Canada • Standard Development • Standard Remand Process • Standard Implementation • Standard Enforcement • Comments to NERC need to ensure NERC understands that the ERO has to address Canadian and Mexican interests in all actions

  14. NOPR Comments • Agree with FERC • No Remands • 22 approved standards are complete • Standard Validation and Improvement Period • Difficult to ensure consistency between Regions • Should Regions be given discretion over which entities standards are applicable too

  15. NOPR Comments • Implementation in Canada • Due to regulatory/legislative requirements, standards may be implemented differently in Canada • Agree that the ERO should submit future changes to the Functional Model to FERC, but any changes should go through NERC Due Process first • NEED for RRO as well as RE

  16. NOPR Comments • Vegetation Management standard should be incorporated in federal agencies construction operation maintenance plans • Deviation from minimum requirements should not be permitted

  17. FERC NOPR on StandardsWECC Board of Directors MeetingDecember 7-8, 2006 Questions?

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