W. Shannon Black Manager, Standards Processes Results Based Drafting 2013.
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W. Shannon BlackManager, Standards Processes
Results Based Drafting 2013
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• Who?oDefine the DT
The team is subject to open
• What?oDraft a WECC Regional Reliability
Standard• When?oSix months or six years
The Basics
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• Where?oRarely face-to-faceoUsually Webinar
• Why?oReliabilityoWear your “WECC Hat” not your “Firm Hat”
• How?o In accordance with the “Procedures” and NERC
Rules
Why are we Here?
Who Does What?
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• Chairo Primary
Create work product Ensure the team keeps moving forward Facilitate within the four-corners of the Procedures “Voice” of the team
o Secondary Subject Matter Expert
• Team Memberso SME with a WECC purpose
The Chair and the Team
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• WECC StaffoManage the Procedures
Stay within the Procedures Keep the team moving
oManage the document Document control First tier quality review Facilitator plus Technical Writer Language and Procedure SME
oManage the website
WECC Staff
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• Procedural OversightoNeed approval for most everything
Scope Posting of work product (Versions/Response) Forward to WECC Board
• The Standing Committee no longer control the development process.
The WSC
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• NERCoQuality Review
• Boardo Approves, remands or rejects
• NERC – againo Board of Trusteeso Legal – multiple reviews of the filing
• FERCo Approve, remand or rejecto Their own calendar
Board / NERC / FERC
“Procedures” And
Principles
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• WECC/NERC/FERC Approved Document• Exhibit “C” of the Delegation Agreement
o Basically a ContractoContains specifics of delegated authorityo Is not all inclusive
Needs interpretation Staff will assist
The “Procedures”
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• Meetings require 15 days notice• Comment
o 45 days followed by 30 days – until done
• Responseo 30 days to respond
• Impact Statemento Addresses Costs & “Other”
• Don’t forget the WSCo Allow WSC “Time”
Procedural Mandates
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• Posted 30 days before a Ballot Pool • Posted 30 days before the Board• Ballot Body/Ballot Pool• Joint Session – 3 days notice• Vote “at least” 7 days after Session• Vote covers 15 “Business” days• “No” votes require a reason
o Added to the record
Procedural Mandates
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• Each Comment oRequires a ResponseoCan be aggregated
• Forwarded to WSCo They officially approve and posto 30 days to get Responses posted
• Repeat until done
Responses
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• Requires 2/3 quorum of “Pool”o Abstentions and incomplete votes counto Vote “at least” 7 days after Sessiono Vote 15 calendar days or extended as needed
• If acceptedo To the Board “via” the WSC
• If rejectedoWSC can rewrite, re-ballot or recycle to
Session, terminate
Vote
Development Principles
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• The Procedures do not require a quorum of the DT to be present before a DT vote is taken.
• The Procedures do not require notice that a DT subset group will meet.
• It takes only a simple majority to carry a vote on any DT issue.
Development Principles
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• All meetings of the DT shall be open to the public and broad participation is encouraged.
• Nothing in these Development Principles shall infringe on an individual’s rights to appeal o Among other reasons…
Can appeal for procedural or technical error
• All DT members are encouraged to always be present; proxy voting by a DT member is not allowed.
Development Principles
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• DT voting may take place face-to-face, electronically, in real-time or within a scheduled window.
• Voting on which position to adopt on a drafting issue is reserved for the DT members.
• Voting on inclusion or exclusion of specific language in the document under development is reserved for the DT members.
• Voting on minutes and related business motions is reserved for the DT members.
• Straw Polls are of excellent advisory value but the DT is not obligated to abide by a straw poll.
Development Principles
A Note on Drafting
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• Follow the ERO or RRO templates• Applicable Entities
oNERC Functional Model dictates
• Requirement and Measureso Each X shall do Y. Evidence may include…
• Avoido Adjective, pronouns, adverbsoDo not incorporate by referenceoDon’t use “C”aps unless defined
Regulatory - Speak
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• Review the SAR and other documents• Draft the Purpose
o This overall document is designed to…. Fill in that blank The body should match the Purpose statement
• Draft a set of goalso Things we want entities to do
• Draft the tasks that need to be doneo Can assign entities later
• Draft the sequence of those tasks
Where do we start?
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oNow we can draft
Pen to Paper
Questions?
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