NERC ATC Standards Update W. Shannon Black Manager, Business Practices and Standards Processes April 22, 2009
FERC ATC NOPR ● The Commission Approved all of the ACT Suite Subject to modification Issues a NOPR March 19, 2009 Created some “challenges” To MOD Others 2
FERC ATC NOPR ● Issue Spotting: MOD “Remove” MOD R2.7 Eliminate protection of Existing Path ratings 69 “Existing Rating” Paths in WECC oPath Rating Catalogue Require re-rating Changes all contracts and models upon which the Existing Path ratings are predicated Compliance in “one year” questionable Need to respond WECC and multiple entities! 3
FERC ATC NOPR ● Issue Spotting: “Mission Creep” Make Implementation Documents available to broader range of entities “Mission Creep” Using NAESB Business Practices oFERC has no jurisdiction over “non-jurisdictionals” Using Standards oFERC can sweep in “non-jurisdictionals” Slippery slope Infusing non-reliability issues into reliability standards 4
FERC ATC NOPR ● Issue Spotting: Counterflows Would require greater detail in describing counter flows WECC uses “counter schedules” ● Issue Spotting: Treatment of Network Resource Designation Would require greater detail Ramifications to members are unclear 5
FERC ATC NOPR ● Issue Spotting: Transparency FERC would require NERC Quickly audit the documents Replication of results is essential ● Issue Spotting: TRM FERC says “to vague” Lock down the ambiguities 6
FERC ATC NOPR ● Informational VSL and VRF will be filed later Process under review at NERC Can’t be lower than before drafting Must be consistently applied Based on a single violation and not on a cumulative number of violations 7
FERC ATC NOPR ● Informational Other MODs and FAC NERC / FERC agree oRetire MODs 1-9; Changes top oOutside scope of the NERC ATC Drafting Team oMore work to come NERC / FERC disagree oFERC says polish FAC-12 oKeep FAC -13 MODs are “operational” (through 13 months) FACs are “planning” (14 months and beyond) 8
Questions 9