Regional Criteria Task Force - UpdateRegional Criteria Task Force - Update

RPIC MeetingRPIC MeetingLoveland, COLoveland, COJuly 29, 2009July 29, 2009

Task Force ParticipantsTask Force Participants

Andrew Gallo, Seattle City LightAndrew Gallo, Seattle City Light Vicken Kasarjian, SMUDVicken Kasarjian, SMUD David Lemmons, Xcel Energy David Lemmons, Xcel Energy

ServicesServices Brian Theaker, DynegyBrian Theaker, Dynegy Donald Watkins, BPADonald Watkins, BPA

TaskTask

How should WECC address the fact How should WECC address the fact that some Regional Criteria do not that some Regional Criteria do not lead to sanctions, while others -- if lead to sanctions, while others -- if created pursuant to a “fill-in-the-created pursuant to a “fill-in-the-blanks” (FITB) reliability standard -- blanks” (FITB) reliability standard -- may lead to sanctionsmay lead to sanctions

ConsiderationsConsiderations

A A newnew WECC document type should be WECC document type should be avoided avoided

Technically, no Regional Criteria, in-and-of Technically, no Regional Criteria, in-and-of themselves, lead to penalties/sanctionsthemselves, lead to penalties/sanctions i.e. i.e. the failure to follow a Regional Criteria will the failure to follow a Regional Criteria will

not lead to penalties/sanctionsnot lead to penalties/sanctions BUT, failure to follow a Regional Criterion BUT, failure to follow a Regional Criterion

may lead to sanctions may lead to sanctions for violation of a for violation of a Reliability StandardReliability Standard

IssuesIssues

What document type should be used to What document type should be used to “fill in the blanks”“fill in the blanks”

What process should be used to develop What process should be used to develop the documents that “fill in the blanks”the documents that “fill in the blanks”

If Regional Criteria are used, how does If Regional Criteria are used, how does WECC ensure that someone reading a WECC ensure that someone reading a Regional Criterion will know the difference Regional Criterion will know the difference between those that may lead to sanctions between those that may lead to sanctions and those that will notand those that will not

ConclusionsConclusions

Issue 1: What document type should be Issue 1: What document type should be used to “fill in the blanks”used to “fill in the blanks” Regional Criteria are defined as Board-Regional Criteria are defined as Board-

approved WECC documents, "whose purpose is approved WECC documents, "whose purpose is to establish mandatory rules which must be to establish mandatory rules which must be followed by all entities within the followed by all entities within the interconnection in order to maintain reliability“interconnection in order to maintain reliability“

All entities in the interconnection must follow All entities in the interconnection must follow the FITB Reliability Standardsthe FITB Reliability Standards

Consequently, "Regional Criteria" are the Consequently, "Regional Criteria" are the proper document type for fulfilling the FITB proper document type for fulfilling the FITB Reliability standardsReliability standards

Conclusions (cont’d)Conclusions (cont’d)

Issue 2: What process should be used Issue 2: What process should be used to develop the documents that “fill in to develop the documents that “fill in the blanks”the blanks” The full Standards Development Process The full Standards Development Process

(SDP) (SDP) The SDP ensures that everyone affected by The SDP ensures that everyone affected by

the Regional Criterion will get notice and an the Regional Criterion will get notice and an opportunity to comment on it (opportunity to comment on it (i.e. i.e. due due process)process)

Conclusions (cont’d)Conclusions (cont’d)

Issue 3: How to ensure that someone reading Issue 3: How to ensure that someone reading Regional Criteria will know the difference Regional Criteria will know the difference between those that may lead to sanctions and between those that may lead to sanctions and those that will notthose that will not Include disclosure language in the "Introduction" of the Include disclosure language in the "Introduction" of the

Regional Criteria Regional Criteria For example: For example:

"This Regional Criterion was developed pursuant to North "This Regional Criterion was developed pursuant to North American Electric Reliability Corporation (NERC) American Electric Reliability Corporation (NERC)

Reliability Standard XXX-XXX-X, Requirement X and, as Reliability Standard XXX-XXX-X, Requirement X and, as such, may lead to penalties or sanctions for violation of such, may lead to penalties or sanctions for violation of

that Reliability Standard if not followed."that Reliability Standard if not followed."

MotionMotion

RPIC recommends that the Board adopt a policy that RPIC recommends that the Board adopt a policy that the documents that “fill in” the “Fill-In-The-Blank” the documents that “fill in” the “Fill-In-The-Blank” Reliability Standards be tagged as Regional Criteria Reliability Standards be tagged as Regional Criteria and include in the introduction the following and include in the introduction the following statement:statement:

"This Regional Criterion was developed pursuant to North "This Regional Criterion was developed pursuant to North American Electric Reliability Corporation (NERC) Reliability American Electric Reliability Corporation (NERC) Reliability Standard XXX-XXX-X, Requirement X and, as such, may lead Standard XXX-XXX-X, Requirement X and, as such, may lead to penalties or sanctions for violation of that Reliability to penalties or sanctions for violation of that Reliability Standard if not followed."Standard if not followed."

One Final Concern….One Final Concern….

Some Regional Criteria (Some Regional Criteria (notnot those those developed pursuant to FITB standards) developed pursuant to FITB standards) deal with “weighty” topics yet carry no deal with “weighty” topics yet carry no penalty for failure to complypenalty for failure to comply The group sees this as a potential problemThe group sees this as a potential problem i.e. i.e. if the subject matter of a Regional Criterion if the subject matter of a Regional Criterion

is important enough to go through the SDP, it is important enough to go through the SDP, it must be a very important issue; must be a very important issue; butbut, a , a member could ignore/violate the Regional member could ignore/violate the Regional Criterion and suffer no adverse consequenceCriterion and suffer no adverse consequence

We didn’t solve this one…….We didn’t solve this one…….

Questions?Questions?