Process for Developing and Approving WECC Regional Criteria Preschedule Process Regional Criteria Drafting Team Meeting Conference Call - Webinar October.

Process for Developing and Approving WECC Regional

Criteria

Preschedule Process Regional Criteria Drafting Team Meeting

Conference Call - WebinarOctober 7, 2008

Topics

● WECC’s Regional Criteria Development Process

● Regional Criteria Drafting Team (RDT) Roles

● Structure of an Excellent Regional Criteria

● Miscellaneous

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WECC Development Process Overview

SRRC Authorize Posting SR

SRRC Authorize Posting SR

Submit Standard

Request (SR)

Submit Standard

Request (SR)

Draft Standard

Draft Standard

Postfor Comment

Postfor Comment Field TestField Test

Standing Committee

Ballot

Standing Committee

Ballot

WECCBoard

Approves

WECCBoard

ApprovesImplementImplement

SR Complete?SR Complete?

Notify SRRCNotify SRRC

Assign to Standing

Committee

Assign to Standing

Committee

Assign to SubgroupAssign to Subgroup

SR

Post for Ballot

Post for Ballot

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Process for Developing and Approving WECC Regional Criteria

Important to Remember

● Must follow this process to the letter Failure to do so is basis for appeal

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Process for Developing and Approving WECC Regional Criteria

Steps

● Request● Validation and Routing

Notify WECC Membership● Drafting

Notify WECC Members of DT meetings● Post for Comment● Address Comments● Post for Standing Committee Vote● Standing Committee Vote● Appeals Process● Board Approval ● Implementation

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Process for Developing and Approving WECC Regional Criteria

Request (1)

● Submit request Using WECC Standards/Regional Criteria Request Form

● Individual or Group may request

● WECC membership is not required

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Process for Developing and Approving WECC Regional Criteria

Validation and Routing (2)

● WECC Staff will review for completeness Assign a Tracking Number

● WECC Staff may assist in completion of the form or seek guidance from the Standards Request Routing Committee (SRRC)

● Request sent to Membership for comment● SRRC decides whether request in scope

and assigns to Standing Committee● Drafting Team formed

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Process for Developing and Approving WECC Regional Criteria

Begin Drafting Phase (3)

● DT Begin Drafting work 30 Day Meeting Notice Required

● Drafting team meetings are open to interested stakeholders

● Applicability identified to NERC Functional Model entities

● Review request for need

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Process for Developing and Approving WECC Regional Criteria

Post Draft Regional Criteria (4)

● First Draft posted for 45 days Comments accepted from members and non-

members alike Comments accepted from individuals or

organizations

● Impact assessment report required also

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Process for Developing and Approving WECC Regional Criteria

Address Comments (5)

● Comments must be addressed Within 30 days of close of comment period Not mandatory to implement

● Implementation of significant comments requires another posting for comments

● Majority vote of RDT is required to move to Standing Committee

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Process for Developing and Approving WECC Regional Criteria

Submit for Standing Committee Vote (6)

● Post to WECC web site

● Official Notification to Standing Committee

● Report of RDT/Subgroup final vote

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Process for Developing and Approving WECC Regional Criteria

Standing Committee Vote (7)

● 30-day notice required BOD may shorten period if Urgency is determined

● Standing Committee may modify or remand Requires 10-day posting for comments

● Standing Committee Members and Industry Stakeholders may change their original vote or vote for the first time

● Majority vote (per WECC Bylaws) Required to approve

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Process for Developing and Approving WECC Regional Criteria

Appeals (8)

● Appeal Process is available Rejection of request by SRRC Due Process Technical

● Made to Standing Committee or Appeals Committee Must be made within 15 days of Standing

Committee decision

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Process for Developing and Approving WECC Regional Criteria

Board Approval (9)

● Must be posted for 30 days prior to Board consideration Send to NERC at this time for NERC posting and

review (NERC process)

● BOD will consider Standing Committee recommendation and minority opinions

● BOD may only make nonmaterial changes● BOD may remand back to Standing Committee

or terminate● BOD majority required (per WECC Bylaws) for

approval

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Process for Developing and Approving WECC Regional Criteria

Implementation of Regional Criteria (10)

● Regional Criteria become effective in the WECC upon BOD approval Not mandatorily enforceable through

sanctions All applicable industry participants in the

WECC are expected to abide

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Key Roles in Regional Criteria Process

StandingCommittee

Stakeholders

Drafting Teams

WECC Members

Board of Directors

WECCStaff

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Responsibilities of Chair

● Leads the Team in a neutral capacity

● Ensures the Team makes progress

● Conducts meetings of the Team

● Represents the Team to other bodies

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Responsibilities of all Members

● Provide knowledge and expertise

● Participate actively

● Provide contributions, drafts, comments

● Represent the interests of the Interconnection as a whole, not individual companies

● Attend meetings

● Participate in Industry Forums

● Provide feedback on Regional Criteria Development activities

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Responsibilities of WECC Staff

● Advises the Team in a neutral capacity

● Monitors, facilitates, reports on, ensures active progress

● Prepares and circulates Team documents

● Maintains membership records

● Prepares for and assists at meetings

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Structure of an Excellent Regional Criterion

Benchmarks of Excellent Regional Criteria

1. Applicability2. Purpose3. Performance requirements4. Technical basis5. Completeness6. Clear language7. Practicality8. Consistent terminology

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Excellent Regional Criteria

WhoShall do what?

To whatresult or

outcome?

Under whatconditions

How?Prescribeelements

Technicaladequacy

Clear, focusedapplicability

Unambiguousrequirements

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Definitions

● Limit terms to those with unique definitions

● Capitalize already defined terms

● Don’t include explanatory information

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Introduction Section

● Title – Keep it short; main topic and modifiers; minimize verbs

● Purpose – from SR (condense into a sentence or two); clear indication of reliability value/benefit; no ‘shall’ or ‘must’ requirements

● Applicability: Functions - lists the “functional entities” that must comply with

the standard’s requirements along with any specific qualifications (i.e., that own UVLS programs)

Facilities – lists any qualifications to limit the scope of facilities addressed (i.e., 100 kV and above)

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Requirements Section● Requirements specifically state the technical, performance, and

preparedness details that each entity must meet using the NERC reliability benchmark.

● The benchmark for a performance requirement is measured by the question: "Who shall do what, under what conditions and to what level, for what reliability result?" The benchmark breaks down into 5 construction elements that follow the sequence below:

Who (1) + “shall” do what (2) + under what conditions (3) and to what level (4) + for what expected reliability result (5)?

• The word shall is used before the verb to modify the meaning of the main verb, in this case to express necessity. Using the 5 construction elements of the benchmark – with one and two in sequence – ensures that the performance requirement is written in active voice and clearly states the expected reliability objective.

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Requirements

● Write in “active voice” (“shall be” is passive)● Identify any qualifying conditions (if any) under

which the performance is required● Identify the responsible entity or entities● Include the word “shall”● Identify the required performance or outcome● Identify what the performance will achieve● Write as simply as possible

Avoid use of “negatives” ● Avoid use of ambiguous or subjective terms● Don’t tell “how”

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Avoid Use of Ambiguous Words

● Adequate

● Data

● Immediately

● Timely

● Detailed

● Sufficient

● Comprehensive

● As appropriate

● Coordinate27

Miscellaneous

Comment Forms

● Ask very pointed questions

● If you’ve made changes, ask for feedback

● Ask for feedback on implementation plan

● Ask if field testing is needed

● Ask if there are any Variances

● Ask if there are any known conflicts with existing regulations

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Consideration of Comments

● Read through comments to get a ‘sense’ of stakeholders’ reactions

● Consider and respond to every comment Responses must be respectful Responses should provide a justification

● Develop a ‘summary response’ to each form question● Add an overview of the changes made – including the

issues resolved and those that weren’t resolved● Make conforming changes to the standard● Can’t expand scope of SR but can develop a standard

that is smaller than the scope of the SR – if needed, revise the SR to expand the scope

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What Is “Consent of the Industry?”

1

2

3

Comments

Comments

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Field Tests

● As needed to validate concepts, methods, measures in a regional criteria

● Drafting team develops field test plan

● Standards Committee approves and oversees field test

● Complete tests before ballot

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Implementation Plan

● Part of final regional criterion going to ballot

● Must be posted for comment at least once

● Includes Proposed effective date(s) and implementation into

compliance program (Must become effective on the first day of a calendar quarter.)

Withdrawal or modification of existing regional criteria Any tools, training, or other implementation

considerations

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Process for Developing and Approving WECC Regional Criteria

Questions

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