Notice of Proposed Rulemaking on StandardsNotice of Proposed Rulemaking on Standards

WECC Board of Directors MeetingDecember 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• Includes six regional differences

• Approved – Direct Modification (61)• 83 of 107 Standards approved

• Pending (24)•None Remanded

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

Pending -- “Good Utility Practice”

• 24 Standards, two Regional Differences

• NERC is Requesting additional information

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

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

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

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

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?

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

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

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

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

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

NOPR Comments

• Vegetation Management standard should be incorporated in federal agencies construction operation maintenance plans•Deviation from minimum requirements

should not be permitted

FERC NOPR on Standards

WECC Board of Directors MeetingDecember 7-8, 2006

FERC NOPR on Standards

WECC Board of Directors MeetingDecember 7-8, 2006

Questions?