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pdfUNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
North American Electric Reliability
Corporation
)
)
Docket No. _______
JOINT PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION AND
WESTERN ELECTRICITY COORDINATING COUNCIL FOR APPROVAL OF
PROPOSED RELIABILITY STANDARD IRO-002-6
Steve Goodwill
Vice President, General Counsel, and
Corporate Secretary
Ruben Arredondo
Senior Legal Counsel
Western Electricity Coordinating Council
155 North 400 West, Suite 200
Salt Lake City, UT 84103
(801) 582-0353
sgoodwill@wecc.org
rarredondo@wecc.org
Lauren Perotti
Senior Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
lauren.perotti@nerc.net
Counsel for the North American Electric
Counsel for the Western Electricity Coordinating Reliability Corporation
Council
May 30, 2019
TABLE OF CONTENTS
I.
SUMMARY ............................................................................................................................ 3
II.
NOTICES AND COMMUNICATIONS ................................................................................ 5
III. BACKGROUND .................................................................................................................... 5
A.
Regulatory Framework ..................................................................................................... 5
B.
WECC Regional Reliability Standards Development Process ........................................ 7
C.
Development of the WECC Variance in Proposed Reliability Standard IRO-002-6 ...... 7
IV. JUSTIFICATION FOR APPROVAL..................................................................................... 8
V.
A.
Purpose and Applicability ................................................................................................ 9
B.
Proposed Requirements .................................................................................................... 9
C.
Enforceability of Proposed Reliability Standard IRO-002-6 ......................................... 11
EFFECTIVE DATE .............................................................................................................. 12
VI. CONCLUSION ..................................................................................................................... 13
Exhibit A
Proposed Reliability Standard IRO-002-6, Reliability Coordination – Monitoring
and Analysis
Exhibit A-1: Clean
Exhibit A-2: Redline to IRO-002-5
Exhibit B
Implementation Plan
Exhibit C
Order No. 672 Criteria
Exhibit D
Analysis of Violation Risk Factors and Violation Severity Levels
Exhibit E
Summary of Development History and Complete Record of Development
Exhibit F
Standard Drafting Team Roster for Project WECC-0135 IRO-002-5 RC—
Monitoring and Analysis—RV
i
UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
North American Electric Reliability
Corporation
)
)
Docket No. _______
JOINT PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION AND
WESTERN ELECTRICITY COORDINATING COUNCIL FOR APPROVAL OF
PROPOSED RELIABILITY STANDARD IRO-002-6
Pursuant to Section 215(d)(1) of the Federal Power Act (“FPA”) 1 and Section 39.5 2 of the
Federal Energy Regulatory Commission’s (“FERC” or the “Commission”) regulations, the North
American Electric Reliability Corporation (“NERC”) 3 and the Western Electricity Coordinating
Council (“WECC”) hereby submit proposed Reliability Standard IRO-002-6 Reliability
Coordination – Monitoring and Analysis for Commission approval. Proposed Reliability Standard
IRO-002-6 reflects the addition of a regional Variance containing additional requirements
applicable to Reliability Coordinators providing service to entities in the Western Interconnection.
None of the continent-wide requirements have been changed from currently effective Reliability
Standard IRO-002-5. 4
NERC and WECC request that the Commission approve proposed Reliability Standard
IRO-002-6 (Exhibit A) as just, reasonable, not unduly discriminatory or preferential, and in the
public interest. NERC and WECC also request approval of the associated implementation plan
1
16 U.S.C. § 824o (2018).
18 C.F.R. § 39.5 (2018).
3
The Commission certified NERC as the electric reliability organization (“ERO”) in accordance with
Section 215 of the FPA on July 20, 2006. N. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062 (2006).
4
The Commission approved currently effective Reliability Standard IRO-002-5 in 2017. N. Am. Elec.
Reliability Corp., Docket No. RD17-4-000 (Apr. 17, 2017) (delegated letter order).
2
2
(Exhibit B), and the associated Violation Risk Factors and Violation Severity Levels (“VSLs”)
(Exhibit D), as detailed in this petition. NERC and WECC further request that the Commission
act to approve the proposed Reliability Standard so it may become effective on January 1, 2020
under the proposed implementation plan.
As required by Section 39.5(a) 5 of the Commission’s regulations, this petition presents the
technical basis and purpose of proposed Reliability Standard IRO-002-6, a summary of the
development proceedings (Section III.C and Exhibit E), and a demonstration that the proposed
Reliability Standard meets the criteria identified by the Commission in Order No. 672 6 (Exhibit
C). Proposed Reliability Standard IRO-002-6 was approved by the WECC Board of Directors on
March 6, 2019 and adopted by the NERC Board of Trustees on May 9, 2019.
I.
SUMMARY
At present, only one Reliability Coordinator, Peak Reliability, provides services in the
Western Interconnection (excepting Alberta). In July 2018, Peak Reliability announced that it
would cease operations at the end of December 2019. Over the course of 2018 and 2019, several
entities have indicated that they will seek certification to perform the Reliability Coordinator
function in their respective footprints in the Western Interconnection.
As the Western Interconnection prepares to transition to an environment in which more
than one Reliability Coordinator will be providing services, focused coordination of these
Reliability Coordinators will be of critical importance. To promote coordination among these
Reliability Coordinators and help ensure reliability in the Western Interconnection, WECC
5
18 C.F.R. § 39.5(a).
The Commission specified in Order No. 672 certain general factors it would consider when assessing
whether a particular Reliability Standard is just and reasonable. See Rules Concerning Certification of the Electric
Reliability Organization; and Procedures for the Establishment, Approval, and Enforcement of Electric Reliability
Standards, Order No. 672, 114 FERC¶ 61,104, at PP 262, 321-37 (“Order No. 672”), order on reh’g, Order No.
672-A, 114 FERC ¶ 61,328 (2006).
6
3
developed the proposed regional Variance reflected in proposed Reliability Standard IRO-002-6.
The WECC Variance consists of two new requirements in the IRO-002 Reliability Standard. These
requirements provide that each Reliability Coordinator providing services in the Western
Interconnection shall: (1) coordinate with other Reliability Coordinators to develop a common
Western Interconnection-wide method to determine the modeling and monitoring of elements
necessary for providing situational awareness; and (2) use the common method.
The regional Variance reflected in proposed Reliability Standard IRO-002-6 would help
ensure coordination and consistency between multiple Reliability Coordinators operating within
the Western Interconnection in 2020 and beyond. The regional Variance adds requirements beyond
those required by the continent-wide Reliability Standard and is necessary for reliability in the
Western Interconnection. For these reasons, and as discussed more fully herein, NERC and WECC
respectfully request the Commission approve proposed Reliability Standard IRO-002-6 and the
associated elements. NERC and WECC further request that the Commission act to approve the
proposed Reliability Standard so it may become effective on January 1, 2020, which is the first
possible effective date under the proposed implementation plan. The following petition presents
the justification for approval and supporting documentation.
4
II.
NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the
following: 7
Steve Goodwill*
Vice President, General Counsel, and
Corporate Secretary
Ruben Arredondo*
Senior Legal Counsel
Steve Rueckert*
Director of Standards
Western Electricity Coordinating Council
155 North 400 West, Suite 200
Salt Lake City, UT 84103
(801) 582-0353
sgoodwill@wecc.org
rarredondo@wecc.org
srueckert@wecc.org
III.
Lauren Perotti*
Senior Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
lauren.perotti@nerc.net
BACKGROUND
The following background information is provided below: (a) an explanation of the
regulatory framework for NERC and Regional Reliability Standards; (b) an explanation of the
WECC Regional Reliability Standards development process; and (c) a summary of the
development process for the proposed Reliability Standard.
A.
Regulatory Framework
By enacting the Energy Policy Act of 2005, 8 Congress entrusted the Commission with the
duties of approving and enforcing rules to ensure the reliability of the Nation’s Bulk-Power
System, and with the duties of certifying an ERO that would be charged with developing and
7
Persons to be included on the Commission’s service list are identified by an asterisk. NERC respectfully
requests a waiver of Rule 203 of the Commission’s regulations, 18 C.F.R. § 385.203, to allow the inclusion of more
than two persons on the service list in this proceeding.
8
16 U.S.C. § 824o.
5
enforcing mandatory Reliability Standards, subject to Commission approval. Section 215(b)(1) 9
of the FPA states that all users, owners, and operators of the Bulk-Power System in the United
States will be subject to Commission-approved Reliability Standards. Section 215(d)(5) 10 of the
FPA authorizes the Commission to order the ERO to submit a new or modified Reliability
Standard. Section 39.5(a) 11 of the Commission’s regulations requires the ERO to file with the
Commission for its approval each Reliability Standard that the ERO proposes should become
mandatory and enforceable in the United States, and each modification to a Reliability Standard
that the ERO proposes should be made effective.
The Commission has the regulatory responsibility to approve Reliability Standards that
protect the reliability of the Bulk-Power System and to ensure that such Reliability Standards are
just, reasonable, not unduly discriminatory or preferential, and in the public interest. Pursuant to
Section 215(d)(2) of the FPA 12 and Section 39.5(c) 13 of the Commission’s regulations, the
Commission will give due weight to the technical expertise of the ERO with respect to the content
of a Reliability Standard.
Similarly, the Commission approves regional differences proposed by Regional Entities,
such as Regional Reliability Standards and Variances, if the regional difference is just, reasonable,
not unduly discriminatory or preferential, and in the public interest. 14 In addition, Order No. 672
requires further criteria for regional differences. A regional difference from a continent-wide
Reliability Standard must either be: (1) more stringent than the continent-wide Reliability
9
10
11
12
13
14
Id. § 824o(b)(1).
Id. § 824o(d)(5).
18 C.F.R. § 39.5(a).
16 U.S.C. § 824o(d)(2).
18 C.F.R. § 39.5(c)(1).
Section 215(d)(2) of the FPA and 18 C.F.R. § 39.5(a).
6
Standard, including a regional difference that addresses matters that the continent-wide Reliability
Standard does not; or (2) necessitated by a physical difference in the Bulk-Power System. 15 The
Commission must give due weight to the technical expertise of a Regional Entity, like WECC, that
is organized on an Interconnection-wide basis with respect to a regional difference to be applicable
within that Interconnection. 16
B.
WECC Regional Reliability Standards Development Process
The WECC regional Variance reflected in proposed Reliability Standard IRO-002-6 was
developed in an open and fair manner and in accordance with the Commission-approved WECC
Reliability Standards Development Procedures (“RSDP”). 17 WECC’s RSDP provides for
reasonable notice and opportunity for public comment, due process, openness, and a balance of
interests in developing Reliability Standards and thus addresses several of the Commission’s
criteria for approving Reliability Standards. The development process is open to any person or
entity that is an interested stakeholder. WECC considers the comments of all stakeholders, and a
vote of stakeholders and the WECC Board of Directors is required to approve a WECC regional
Variance to a Reliability Standard. NERC posts each regional Variance developed by a Regional
Entity for an additional comment period. The NERC Board of Trustees must adopt the regional
Variance before it is submitted to the Commission for approval.
C.
Development of the WECC Variance in Proposed Reliability Standard IRO002-6
As further described in Exhibit E hereto, WECC developed the regional Variance in
proposed Reliability Standard IRO-002-6 in accordance with the WECC RSDP. The drafting team
15
Order No. 672 at P 291.
Id. at P 344.
17
The currently-effective WECC RSDP was approved by the Commission on October 27, 2017. See N. Am.
Elec. Reliability Corp., Docket No. RR17-5-000 (Oct. 27, 2017) (unpublished letter order).
16
7
(Exhibit F) consisted of individuals with relevant expertise in the subject matter area and included
representatives from Peak Reliability and several other entities that had expressed interest by that
time in performing the Reliability Coordinator function in the Western Interconnection. On
February 21, 2019, the WECC ballot body approved the regional Variance with a 100 percent
affirmative vote at 89.7 percent quorum. The WECC Board of Directors approved the regional
Variance on March 6, 2019. NERC posted the regional Variance for a 45-day comment period
from March 7, 2019 through April 22, 2019. Commenters agreed that WECC’s process was open,
inclusive, balanced, transparent, and provided due process. The WECC regional Variance was
added to the NERC IRO-002 Reliability Standard, and the new standard was assigned version
number IRO-002-6. The NERC Board of Trustees adopted proposed Reliability Standard IRO002-6 on May 9, 2019.
IV.
JUSTIFICATION FOR APPROVAL
Due to the unique physical characteristics of the Bulk-Power System in the Western
Interconnection, events in one part of the Interconnection within one Reliability Coordinator Area
can have significant impacts in other parts of the system in other Reliability Coordinator Areas.
These impacts can extend beyond the physical boundaries of the neighboring Reliability
Coordinator Areas. As the Western Interconnection transitions from a single Reliability
Coordinator environment to a multiple Reliability Coordinator environment, it is important that
the Reliability Coordinators employ modeling and monitoring practices to address these unique
situational awareness challenges and that there is an appropriate degree of consistency in modeling
and monitoring strategies and approaches.
Proposed Reliability Standard IRO-002-6 contains a new regional Variance designed to
promote coordination among multiple Reliability Coordinators providing services to entities
8
operating in the Western Interconnection. The regional Variance requires a single Interconnectionwide modeling and monitoring methodology, which creates an effective reliability baseline for
each Reliability Coordinator for its Real-time Assessments and Operational Planning Analyses to
address the unique challenges in the Western Interconnection. The modeling and monitoring
requirements set forth in the Variance represent a more stringent set of requirements for Reliability
Coordinators beyond those found in the continent-wide requirements. The purpose, applicability,
and requirements of the regional Variance are discussed in more detail below.
A.
Purpose and Applicability
The stated purpose of the WECC regional Variance in proposed Reliability Standard IRO002-6 is to “to develop a methodology that creates models for performing Operational Planning
Analyses and Real-time Assessments.” 18 The WECC regional Variance is applicable to those
Reliability Coordinators providing Reliability Coordinator services to entities operating within the
Western Interconnection, regardless of where the Reliability Coordinator is physically located.
B.
Proposed Requirements
The WECC regional Variance in proposed Reliability Standard IRO-002-6 contains two
new requirements to help ensure that each Reliability Coordinator has sufficient operational
awareness to maintain the reliability of its area. These requirements provide as follows:
D.A.7.
Each Reliability Coordinator shall, in coordination with other Reliability
Coordinators, develop a common Interconnection-wide methodology to
determine the modeling and monitoring of BES and non-BES Elements that
are internal and external to its Reliability Coordinator Area, necessary for
providing operational awareness of the impacts on Bulk Electric System
Facilities within its Reliability Coordinator Area, including at a minimum:
D.A.7.1.
18
A method for development, maintenance, and periodic review of
a Western Interconnection-wide reference model to serve as the
See Exhibit A.
9
baseline from which Reliability Coordinator’s operational
models are derived;
D.A.8.
D.A.7.2
The impacts of Inter-area oscillations;
D.A.7.3
A method to determine Contingencies included in analyses and
assessments;
D.A.7.4
A method to determine Remedial Action Schemes included in
analyses and assessments;
D.A.7.5
A method to determine forecast data included in analyses and
assessments; and
D.A.7.6
A method for the validation and periodic review of the
Reliability Coordinator’s operational model for steady state and
dynamic/oscillatory system response.
Each Reliability Coordinator shall use the methodology developed in
D.A.7.
The proposed requirements provide a results-based approach to helping ensure that
Reliability Coordinators model and monitor those Elements necessary in order to provide
operational awareness with their areas. Requirement D.A.7 requires a common Interconnectionwide methodology that shall include, at a minimum, certain features deemed to be necessary for
operational awareness of potential impacts on Facilities within its area. The list of required features
includes impacts of Inter-area oscillations and methods to determine Contingencies, Remedial
Action Schemes, and forecast data included in analyses and assessments. The methodology must
also include a method for the development, maintenance, and review of an Interconnection-wide
reference model to serve as a baseline and a method to validate and review the Reliability
Coordinator’s operational model for steady state and dynamic/oscillatory system response.
Requirement D.A.8 requires each Reliability Coordinator to use the common methodology.
In developing the proposed requirements, WECC considered that the common
methodology approach described above provided significant benefits over and above an approach
that would require each Reliability Coordinator to use a single specified model, such as the
10
Western Interconnection model. The common methodology approach is consistent with NERC’s
results-based approach to Reliability Standards and provides an efficient and effective way of
achieving the reliability objective of the Variance. Further, the proposed approach helps to ensure
that only those essential modeling details are maintained, while allowing any unneeded data to be
culled. The benefits of having Reliability Coordinator models that are no larger than necessary
include: (1) enhanced performance of on-line applications; (2) reduced risk that data problems
with Elements that are insensitive to the Reliability Coordinator footprint will cause convergence
problems; (3) reduced risk that problems with Elements that are insensitive to the Reliability
Coordinator footprint could cause false alarms or consume troubleshooting resources; and (4)
reduced risk that errors from insensitive parts of the Interconnection could mask issues within the
Reliability Coordinator footprint.
For these reasons, NERC respectfully requests that the Commission approve proposed
Reliability Standard IRO-002-6.
C.
Enforceability of Proposed Reliability Standard IRO-002-6
Proposed Reliability Standard IRO-002-6 includes VRFs and VSLs. The VSLs provide
guidance on the way that NERC will enforce the requirements of the proposed Reliability
Standard. The VRFs are one of several elements used to determine an appropriate sanction when
the associated requirement is violated. The VRFs assess the impact to reliability of violating a
specific requirement. The VRFs and VSLs for the continent-wide requirements have not been
changed. As demonstrated in Exhibit D, the VRFs and VSLs for the two new requirements in the
WECC regional Variance comport with NERC and Commission guidelines related to their
assignment.
11
The proposed Reliability Standard also includes measures that support each requirement
by clearly identifying what is required and how the requirement will be enforced. These measures
help ensure that the requirements will be enforced in a clear, consistent, and non-preferential
manner and without prejudice to any party. 19
V.
EFFECTIVE DATE
NERC respectfully requests that the Commission approve the proposed implementation
plan, provided in Exhibit B hereto. NERC and WECC request that the Commission take action on
the proposed Reliability Standard so it may become effective on January 1, 2020 under the
proposed implementation plan. The proposed implementation plan provides that proposed
Reliability Standard IRO-002-6 would become effective on the first day of the first quarter after
regulatory approval, but no sooner than January 1, 2020. This implementation timeframe reflects
consideration of the timeframes for the wind down of Peak Reliability and the start of operations
for other Reliability Coordinators. This proposed timeline balances the need for prompt
implementation of the WECC regional Variance while allowing sufficient time for the new
Western Interconnection Reliability Coordinators to coordinate on the development of the required
common methodology.
19
Order No. 672 at P 327 (“There should be a clear criterion or measure of whether an entity is in compliance
with a proposed Reliability Standard. It should contain or be accompanied by an objective measure of compliance so
that it can be enforced and so that enforcement can be applied in a consistent and non-preferential manner.”).
12
VI.
CONCLUSION
For the reasons set forth above, NERC respectfully requests that the Commission approve:
•
proposed Reliability Standard IRO-002-6 and the other associated elements, including
the VRFs and VSLs, included in Exhibit A and
•
the proposed implementation plan, included in Exhibit B.
Respectfully submitted,
/s/ Lauren Perotti
Steve Goodwill
Vice President, General Counsel, and
Corporate Secretary
Ruben Arredondo
Senior Legal Counsel
Western Electricity Coordinating Council
155 North 400 West, Suite 200
Salt Lake City, UT 84103
(801) 582-0353
sgoodwill@wecc.org
rarredondo@wecc.org
Counsel for the Western Electricity
Coordinating Council
Lauren Perotti
Senior Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
lauren.perotti@nerc.net
Counsel for the North American Electric
Reliability Corporation
Date: May 30, 2019
13
Exhibit A
Proposed Reliability Standard
Exhibit A
Proposed Reliability Standard IRO-002-6 Clean and Redline
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
A. Introduction
1.
Title:
Reliability Coordination – Monitoring and Analysis
2.
Number:
IRO-002-6
3.
Purpose: To provide System Operators with the capabilities necessary to monitor
and analyze data needed to perform their reliability functions.
4.
Applicability:
4.1. Functional Entities:
4.1.1. Reliability Coordinators
5.
Effective Date: See Implementation Plan
B. Requirements and Measures
R1.
Each Reliability Coordinator shall have data exchange capabilities with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
for it to perform its Operational Planning Analyses. [Violation Risk Factor: Medium]
[Time Horizon: Operations Planning]
M1. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, a document that lists its data exchange capabilities with
its Balancing Authorities and Transmission Operators, and with other entities it deems
necessary, for it to perform its Operational Planning Analyses.
R2.
Each Reliability Coordinator shall have data exchange capabilities, with redundant and
diversely routed data exchange infrastructure within the Reliability Coordinator's
primary Control Center, for the exchange of Real-time data with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
for performing its Real-time monitoring and Real-time Assessments. [Violation Risk
Factor: High] [Time Horizon: Same-Day Operations, Real-time Operations]
M2. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, system specifications, system diagrams, or other
documentation that lists its data exchange capabilities, including redundant and
diversely routed data exchange infrastructure within the Reliability Coordinator's
primary Control Center, for the exchange of Real-time data with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
as specified in the requirement.
R3.
Each Reliability Coordinator shall test its primary Control Center data exchange
capabilities specified in Requirement R2 for redundant functionality at least once
every 90 calendar days. If the test is unsuccessful, the Reliability Coordinator shall
initiate action within two hours to restore redundant functionality. [Violation Risk
Factor: Medium ] [Time Horizon: Operations Planning]
Page 1 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
M3. Each Reliability Coordinator shall have, and provide upon request, evidence that it
tested its primary Control Center data exchange capabilities specified in Requirement
R2 for redundant functionality, or experienced an event that demonstrated the
redundant functionality; and if the test was unsuccessful, initiated action within two
hours to restore redundant functionality as specified in Requirement R3. Evidence
could include, but is not limited to: dated and time-stamped test records, operator
logs, voice recordings, or electronic communications.
R4.
Each Reliability Coordinator shall provide its System Operators with the authority to
approve planned outages and maintenance of its telecommunication, monitoring and
analysis capabilities. [Violation Risk Factor: High] [Time Horizon: Operations Planning,
Same-Day Operations, Real-time Operations]
M4. Each Reliability Coordinator shall have, and provide upon request evidence that could
include, but is not limited to, a documented procedure or equivalent evidence that
will be used to confirm that the Reliability Coordinator has provided its System
Operators with the authority to approve planned outages and maintenance of its
telecommunication, monitoring and analysis capabilities.
R5.
Each Reliability Coordinator shall monitor Facilities, the status of Remedial Action
Schemes, and non-BES facilities identified as necessary by the Reliability Coordinator,
within its Reliability Coordinator Area and neighboring Reliability Coordinator Areas to
identify any System Operating Limit exceedances and to determine any
Interconnection Reliability Operating Limit exceedances within its Reliability
Coordinator Area. [Violation Risk Factor: High] [Time Horizon: Real-Time Operations]
M5. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, Energy Management System description documents,
computer printouts, SCADA data collection, or other equivalent evidence that will be
used to confirm that it has monitored Facilities, the status of Remedial Action
Schemes, and non-BES facilities identified as necessary by the Reliability Coordinator,
within its Reliability Coordinator Area and neighboring Reliability Coordinator Areas to
identify any System Operating Limit exceedances and to determine any
Interconnection Reliability Operating Limit exceedances within its Reliability
Coordinator Area.
R6.
Each Reliability Coordinator shall have monitoring systems that provide information
utilized by the Reliability Coordinator’s operating personnel, giving particular
emphasis to alarm management and awareness systems, automated data transfers,
and synchronized information systems, over a redundant infrastructure. [Violation
Risk Factor: High] [Time Horizon: Real-time Operations]
M6. The Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, Energy Management System description documents,
computer printouts, SCADA data collection, or other equivalent evidence that will be
used to confirm that it has monitoring systems consistent with the requirement.
Page 2 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
C. Compliance
1.
Compliance Monitoring Process
1.1. Compliance Enforcement Authority:
“Compliance Enforcement Authority” means NERC or the Regional Entity, or any
entity as otherwise designated by an Applicable Governmental Authority, in
their respective roles of monitoring and/or enforcing compliance with
mandatory and enforceable Reliability Standards in their respective
jurisdictions.
1.2. Evidence Retention:
The following evidence retention period(s) identify the period of time an entity
is required to retain specific evidence to demonstrate compliance. For instances
where the evidence retention period specified below is shorter than the time
since the last audit, the Compliance Enforcement Authority may ask an entity to
provide other evidence to show that it was compliant for the full-time period
since the last audit.
The applicable entity shall keep data or evidence to show compliance as
identified below unless directed by its Compliance Enforcement Authority to
retain specific evidence for a longer period of time as part of an investigation.
•
•
•
The Reliability Coordinator shall retain its current, in force document and
any documents in force for the current year and previous calendar year for
Requirements R1, R2, and R4 and Measures M1, M2, and M4.
The Reliability Coordinator shall retain evidence for Requirement R3 and
Measure M3 for the most recent 12 calendar months, with the exception of
operator logs and voice recordings which shall be retained for a minimum of
90 calendar days.
The Reliability Coordinator shall keep data or evidence for Requirements R5
and R6 and Measures M5 and M6 for the current calendar year and one
previous calendar year.
1.3. Compliance Monitoring and Enforcement Program
As defined in the NERC Rules of Procedure, “Compliance Monitoring and
Enforcement Program” refers to the identification of the processes that will be
used to evaluate data or information for the purpose of assessing performance
or outcomes with the associated Reliability Standard.
Page 3 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
Violation Severity Levels
R#
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
R1.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with one applicable entity, or
5% or less of the applicable
entities, whichever is greater.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with two applicable entities, or
more than 5% or less than or
equal to 10% of the applicable
entities, whichever is greater.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with three applicable entities,
or more than 10% or less than
or equal to 15% of the
applicable entities, whichever is
greater.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with four or more applicable
entities or greater than 15% of
the applicable entities,
whichever is greater.
R2.
N/A
N/A
The Reliability Coordinator had
data exchange capabilities with
its Balancing Authorities and
Transmission Operators, and
with other entities it deems
necessary, for performing Realtime monitoring and Real-time
Assessments, but did not have
redundant and diversely routed
data exchange infrastructure
within the Reliability
Coordinator's primary Control
Center, as specified in the
requirement.
The Reliability Coordinator did
not have data exchange
capabilities with its Balancing
Authorities and Transmission
Operators, and with other
entities it deems necessary, for
performing Real-time
monitoring and Real-time
Assessments as specified in the
requirement.
R3.
The Reliability Coordinator
tested its primary Control
Center data exchange
The Reliability Coordinator
tested its primary Control
Center data exchange
The Reliability Coordinator
tested its primary Control
Center data exchange
The Reliability Coordinator
tested its primary Control
Center data exchange
Page 4 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
R#
R4.
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 90 calendar days but less
than or equal to 120 calendar
days since the previous test;
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 120 calendar days but less
than or equal to 150 calendar
days since the previous test;
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 150 calendar days but less
than or equal to 180 calendar
days since the previous test;
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 180 calendar days since
the previous test;
OR
OR
OR
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in
more than 2 hours and less
than or equal to 4 hours.
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in
more than 4 hours and less
than or equal to 6 hours.
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in
more than 6 hours and less
than or equal to 8 hours.
N/A
N/A
N/A
OR
The Reliability Coordinator did
not test its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality;
OR
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
did not initiate action within 8
hours to restore the redundant
functionality.
The Reliability Coordinator
failed to provide its System
Operator with the authority to
approve planned outages and
Page 5 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
R#
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
maintenance of its
telecommunication, monitoring
and analysis capabilities.
R5.
N/A
N/A
N/A
The Reliability Coordinator did
not monitor Facilities, the
status of Remedial Action
Schemes, and non-BES facilities
identified as necessary by the
Reliability Coordinator, within
its Reliability Coordinator Area
and neighboring Reliability
Coordinator Areas to identify
any System Operating Limit
exceedances and to determine
any Interconnection Reliability
Operating Limit exceedances
within its Reliability
Coordinator Area.
R6.
N/A
N/A
N/A
The Reliability Coordinator did
not have monitoring systems
that provide information
utilized by the Reliability
Coordinator’s operating
personnel, giving particular
emphasis to alarm
management and awareness
systems, automated data
transfers, and synchronized
Page 6 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
R#
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
information systems, over a
redundant infrastructure.
Page 7 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
D. Regional Variance
A. Regional Variance for the Western Electricity Coordinating Council Region
The following Interconnection-wide variance shall be applicable in the Western Electricity
Coordinating Council (WECC) region.
Purpose
To develop a methodology that creates models for performing Operational Planning
Analyses and Real-time Assessments.
Applicability
As used in this WECC Regional Variance, Reliability Coordinator is specific to those Reliability
Coordinators providing Reliability Coordinator service(s) to entities operating within the
Western Interconnection, regardless of where the Reliability Coordinator may be located.
Requirements and Measures
D.A.7.
Each Reliability Coordinator shall, in coordination with other Reliability
Coordinators, develop a common Interconnection-wide methodology to
determine the modeling and monitoring of BES and non-BES Elements that are
internal and external to its Reliability Coordinator Area, necessary for providing
operational awareness of the impacts on Bulk Electric System Facilities within its
Reliability Coordinator Area, including at a minimum: ([Violation Risk Factor:
High] [Time Horizon: Operations Planning])
D.A.7.1.
A method for development, maintenance, and periodic review of
a Western Interconnection-wide reference model to serve as the
baseline from which Reliability Coordinator’s operational models
are derived;
D.A.7.2.
The impacts of Inter-area oscillations;
D.A.7.3.
A method to determine Contingencies included in analyses and
assessments;
D.A.7.4.
A method to determine Remedial Action Schemes included in
analyses and assessments;
D.A.7.5.
A method to determine forecast data included in analyses and
assessments; and
D.A.7.6.
A method for the validation and periodic review of the Reliability
Coordinator’s operational model for steady state and
dynamic/oscillatory system response.
M.D.A.7. Each Reliability Coordinator will have evidence that it developed a common
Western Interconnection-wide methodology, addressing modeling and
Page 8 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
monitoring, in coordination with other Reliability Coordinators, that includes the
features required in D.A.7.
D.A.8.
Each Reliability Coordinator shall use the methodology developed in D.A.7.
([Violation Risk Factor: High] [Time Horizon: Operations Planning])
M.D.A.8. Each Reliability Coordinator will have evidence that it uses the methodology
developed in D.A.7., as required in D.A.8. above.
Compliance
Evidence Retention:
•
The Reliability Coordinator shall keep data or evidence for Requirements R5, R6, and
the WECC Regional Variance, and Measures M5, M6, and the WECC Regional
Variance for the current calendar year and one previous calendar year.
Violation Severity Levels for the WECC Regional Variance
R#
Lower VSL
Moderate VSL
High VSL
Severe VSL
D.A.7.
The Reliability Coordinator
did not develop the
methodology as required in
D.A.7.
D.A.8.
The Reliability Coordinator
did not implement the
methodology as required in
D.A.8.
E. Associated Documents
The Implementation Plan and other project documents can be found on the project page.
Page 9 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
Version History
Version
Date
Action
0
April 1,
2005
0
August 8,
2005
1
November Adopted by Board of Trustees
1, 2006
Change Tracking
Effective Date
New
Removed “Proposed” from Effective
Date
Errata
Revised
1
April 4,
2007
Replaced Levels of Non-compliance
with the Feb 28, BOT approved
Violation Severity Levels (VSLs)
Corrected typographical errors in
BOT approved version of VSLs
Revised to add missing
measures and compliance
elements
2
October
17, 2008
Adopted by NERC Board of Trustees
Deleted R2, M3 and
associated compliance
elements as conforming
changes associated with
approval of IRO-010-1.
Revised as part of IROL
Project
2
March 17,
2011
Order issued by FERC approving IRO002-2 (approval effective 5/23/11)
FERC approval
2
February
24, 2014
Updated VSLs based on June 24,
2013 approval.
VSLs revised
3
July 25,
2011
Revised under Project 2006-06
Revised
3
August 4,
2011
Approved by Board of Trustees
Retired R1-R8 under Project
2006-06.
4
November Approved by Board of Trustees
13, 2014
Revisions under Project
2014-03
4
November FERC approved IRO-002-4. Docket
19, 2015 No. RM15-16-000
FERC approval
5
February
9, 2017
Adopted by Board of Trustees
5
April 17,
2017
FERC letter Order approved IRO-0025. Docket No. RD17-4-000
Revised
Page 10 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
6
May 9,
2019
Adopted by the NERC Board of
Trustees
WECC Regional Variance
Page 11 of 13
Supplemental Material
Rationale
During development of IRO-002-5, text boxes are embedded within the standard to explain the
rationale for various parts of the standard. Upon Board adoption of IRO-002-5, the text from
the rationale text boxes will be moved to this section.
Rationale text from the development of IRO-002-4 in Project 2014-03 follows. Additional
information can be found on the Project 2014-03 project page.
Changes made to the proposed definitions were made in order to respond to issues raised in
NOPR paragraphs 55, 73, and 74 dealing with analysis of SOLs in all time horizons, questions on
Protection Systems and Special Protection Systems in NOPR paragraph 78, and
recommendations on phase angles from the SW Outage Report (recommendation 27). The
intent of such changes is to ensure that Real-time Assessments contain sufficient details to
result in an appropriate level of situational awareness. Some examples include: 1) analyzing
phase angles which may result in the implementation of an Operating Plan to adjust generation
or curtail transactions so that a Transmission facility may be returned to service, or 2)
evaluating the impact of a modified Contingency resulting from the status change of a Special
Protection Scheme from enabled/in-service to disabled/out-of-service.
Rationale for Requirements:
The data exchange elements of Requirements R1 and R2 from approved IRO-002-2 have been
added back into proposed IRO-002-4 in order to ensure that there is no reliability gap. The
Project 2014-03 SDT found no proposed requirements in the current project that covered the
issue. Voice communication is covered in proposed COM-001-2 but data communications needs
to remain in IRO-002-4 as it is not covered in proposed COM-001-2. Staffing of communications
and facilities in corresponding requirements from IRO-002-2 is addressed in approved PER-0042, Requirement R1 and has been deleted from this draft.
Rationale for R2:
Requirement R2 from IRO-002-3 has been deleted because approved EOP-008-1, Requirement
R1, part 1.6.2 addresses redundancy and back-up concerns for outages of analysis tools. New
Requirement R4 (R6 in IRO-002-5) has been added to address NOPR paragraphs 96 and 97:
“…As we explain above, the reliability coordinator’s obligation to monitor SOLs is important to
reliability because a SOL can evolve into an IROL during deteriorating system conditions, and for
potential system conditions such as this, the reliability coordinator’s monitoring of SOLs provides
a necessary backup function to the transmission operator….”
Rationale for Requirements R1 and R2:
The proposed changes address directives for redundancy and diverse routing of data exchange
capabilities (FERC Order No. 817 Para 47).
Redundant and diversely routed data exchange capabilities consist of data exchange
infrastructure components (e.g., switches, routers, servers, power supplies, and network
cabling and communication paths between these components in the primary Control Center for
the exchange of system operating data) that will provide continued functionality despite failure
Page 12 of 13
Supplemental Material
or malfunction of an individual component within the Reliability Coordinator's (RC) primary
Control Center. Redundant and diversely routed data exchange capabilities preclude single
points of failure in primary Control Center data exchange infrastructure from halting the flow of
Real-time data. Requirement R2 does not require automatic or instantaneous fail-over of data
exchange capabilities. Redundancy and diverse routing may be achieved in various ways
depending on the arrangement of the infrastructure or hardware within the RC's primary
Control Center.
The reliability objective of redundancy is to provide for continued data exchange functionality
during outages, maintenance, or testing of data exchange infrastructure. For periods of planned
or unplanned outages of individual data exchange components, the proposed requirements do
not require additional redundant data exchange infrastructure components solely to provide
for redundancy.
Infrastructure that is not within the RC's primary Control Center is not addressed by the
proposed requirement.
Rationale for Requirement R3:
The revised requirement addresses directives for testing of data exchange capabilities used in
primary Control Centers (FERC Order No. 817 Para 51).
A test for redundant functionality demonstrates that data exchange capabilities will continue to
operate despite the malfunction or failure of an individual component (e.g., switches, routers,
servers, power supplies, and network cabling and communication paths between these
components in the primary Control Center for the exchange of system operating data). An
entity's testing practices should, over time, examine the various failure modes of its data
exchange capabilities. When an actual event successfully exercises the redundant functionality,
it can be considered a test for the purposes of the proposed requirement.
Rationale for R4 (R6 in IRO-002-5):
The requirement was added back from approved IRO-002-2 as the Project 2014-03 SDT found
no proposed requirements that covered the issues.
Page 13 of 13
IRO-002-65 - Reliability Coordination - Monitoring and Analysis
A. Introduction
1.
Title:
Reliability Coordination – Monitoring and Analysis
2.
Number:
IRO-002-65
3.
Purpose: To provide System Operators with the capabilities necessary to monitor
and analyze data needed to perform their reliability functions.
4.
Applicability:
4.1. Functional Entities:
4.1.1. Reliability Coordinators
5.
Effective Date: See Implementation Plan
B. Requirements and Measures
R1.
Each Reliability Coordinator shall have data exchange capabilities with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
for it to perform its Operational Planning Analyses. [Violation Risk Factor: Medium]
[Time Horizon: Operations Planning]
M1. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, a document that lists its data exchange capabilities with
its Balancing Authorities and Transmission Operators, and with other entities it deems
necessary, for it to perform its Operational Planning Analyses.
R2.
Each Reliability Coordinator shall have data exchange capabilities, with redundant and
diversely routed data exchange infrastructure within the Reliability Coordinator's
primary Control Center, for the exchange of Real-time data with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
for performing its Real-time monitoring and Real-time Assessments. [Violation Risk
Factor: High] [Time Horizon: Same-Day Operations, Real-time Operations]
M2. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, system specifications, system diagrams, or other
documentation that lists its data exchange capabilities, including redundant and
diversely routed data exchange infrastructure within the Reliability Coordinator's
primary Control Center, for the exchange of Real-time data with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
as specified in the requirement.
R3.
Each Reliability Coordinator shall test its primary Control Center data exchange
capabilities specified in Requirement R2 for redundant functionality at least once
every 90 calendar days. If the test is unsuccessful, the Reliability Coordinator shall
initiate action within two hours to restore redundant functionality. [Violation Risk
Factor: Medium ] [Time Horizon: Operations Planning]
Page 1 of 14
IRO-002-65 - Reliability Coordination - Monitoring and Analysis
M3. Each Reliability Coordinator shall have, and provide upon request, evidence that it
tested its primary Control Center data exchange capabilities specified in Requirement
R2 for redundant functionality, or experienced an event that demonstrated the
redundant functionality; and if the test was unsuccessful, initiated action within two
hours to restore redundant functionality as specified in Requirement R3. Evidence
could include, but is not limited to: dated and time-stamped test records, operator
logs, voice recordings, or electronic communications.
R4.
Each Reliability Coordinator shall provide its System Operators with the authority to
approve planned outages and maintenance of its telecommunication, monitoring and
analysis capabilities. [Violation Risk Factor: High] [Time Horizon: Operations Planning,
Same-Day Operations, Real-time Operations]
M4. Each Reliability Coordinator shall have, and provide upon request evidence that could
include, but is not limited to, a documented procedure or equivalent evidence that
will be used to confirm that the Reliability Coordinator has provided its System
Operators with the authority to approve planned outages and maintenance of its
telecommunication, monitoring and analysis capabilities.
R5.
Each Reliability Coordinator shall monitor Facilities, the status of Remedial Action
Schemes, and non-BES facilities identified as necessary by the Reliability Coordinator,
within its Reliability Coordinator Area and neighboring Reliability Coordinator Areas to
identify any System Operating Limit exceedances and to determine any
Interconnection Reliability Operating Limit exceedances within its Reliability
Coordinator Area. [Violation Risk Factor: High] [Time Horizon: Real-Time Operations]
M5. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, Energy Management System description documents,
computer printouts, SCADA data collection, or other equivalent evidence that will be
used to confirm that it has monitored Facilities, the status of Remedial Action
Schemes, and non-BES facilities identified as necessary by the Reliability Coordinator,
within its Reliability Coordinator Area and neighboring Reliability Coordinator Areas to
identify any System Operating Limit exceedances and to determine any
Interconnection Reliability Operating Limit exceedances within its Reliability
Coordinator Area.
R6.
Each Reliability Coordinator shall have monitoring systems that provide information
utilized by the Reliability Coordinator’s operating personnel, giving particular
emphasis to alarm management and awareness systems, automated data transfers,
and synchronized information systems, over a redundant infrastructure. [Violation
Risk Factor: High] [Time Horizon: Real-time Operations]
M6. The Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, Energy Management System description documents,
computer printouts, SCADA data collection, or other equivalent evidence that will be
used to confirm that it has monitoring systems consistent with the requirement.
Page 2 of 14
IRO-002-65 - Reliability Coordination - Monitoring and Analysis
C. Compliance
1.
Compliance Monitoring Process
1.1. Compliance Enforcement Authority:
“Compliance Enforcement Authority” means NERC or the Regional Entity, or any
entity as otherwise designated by an Applicable Governmental Authority, in
their respective roles of monitoring and/or enforcing compliance with
mandatory and enforceable Reliability Standards in their respective
jurisdictions.
1.2. Evidence Retention:
The following evidence retention period(s) identify the period of time an entity
is required to retain specific evidence to demonstrate compliance. For instances
where the evidence retention period specified below is shorter than the time
since the last audit, the Compliance Enforcement Authority may ask an entity to
provide other evidence to show that it was compliant for the full-time period
since the last audit.
The applicable entity shall keep data or evidence to show compliance as
identified below unless directed by its Compliance Enforcement Authority to
retain specific evidence for a longer period of time as part of an investigation.
•
•
•
The Reliability Coordinator shall retain its current, in force document and
any documents in force for the current year and previous calendar year for
Requirements R1, R2, and R4 and Measures M1, M2, and M4.
The Reliability Coordinator shall retain evidence for Requirement R3 and
Measure M3 for the most recent 12 calendar months, with the exception of
operator logs and voice recordings which shall be retained for a minimum of
90 calendar days.
The Reliability Coordinator shall keep data or evidence for Requirements R5
and R6 and Measures M5 and M6 for the current calendar year and one
previous calendar year.
1.3. Compliance Monitoring and Enforcement Program
As defined in the NERC Rules of Procedure, “Compliance Monitoring and
Enforcement Program” refers to the identification of the processes that will be
used to evaluate data or information for the purpose of assessing performance
or outcomes with the associated Reliability Standard.
Page 3 of 14
IRO-002-65 - Reliability Coordination - Monitoring and Analysis
Violation Severity Levels
R#
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
R1.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with one applicable entity, or
5% or less of the applicable
entities, whichever is greater.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with two applicable entities, or
more than 5% or less than or
equal to 10% of the applicable
entities, whichever is greater.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with three applicable entities,
or more than 10% or less than
or equal to 15% of the
applicable entities, whichever is
greater.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with four or more applicable
entities or greater than 15% of
the applicable entities,
whichever is greater.
R2.
N/A
N/A
The Reliability Coordinator had
data exchange capabilities with
its Balancing Authorities and
Transmission Operators, and
with other entities it deems
necessary, for performing Realtime monitoring and Real-time
Assessments, but did not have
redundant and diversely routed
data exchange infrastructure
within the Reliability
Coordinator's primary Control
Center, as specified in the
requirement.
The Reliability Coordinator did
not have data exchange
capabilities with its Balancing
Authorities and Transmission
Operators, and with other
entities it deems necessary, for
performing Real-time
monitoring and Real-time
Assessments as specified in the
requirement.
R3.
The Reliability Coordinator
tested its primary Control
Center data exchange
The Reliability Coordinator
tested its primary Control
Center data exchange
The Reliability Coordinator
tested its primary Control
Center data exchange
The Reliability Coordinator
tested its primary Control
Center data exchange
Page 4 of 14
IRO-002-65 - Reliability Coordination - Monitoring and Analysis
R#
R4.
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 90 calendar days but less
than or equal to 120 calendar
days since the previous test;
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 120 calendar days but less
than or equal to 150 calendar
days since the previous test;
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 150 calendar days but less
than or equal to 180 calendar
days since the previous test;
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 180 calendar days since
the previous test;
OR
OR
OR
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in
more than 2 hours and less
than or equal to 4 hours.
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in
more than 4 hours and less
than or equal to 6 hours.
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in
more than 6 hours and less
than or equal to 8 hours.
N/A
N/A
N/A
OR
The Reliability Coordinator did
not test its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality;
OR
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
did not initiate action within 8
hours to restore the redundant
functionality.
The Reliability Coordinator
failed to provide its System
Operator with the authority to
approve planned outages and
Page 5 of 14
IRO-002-65 - Reliability Coordination - Monitoring and Analysis
R#
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
maintenance of its
telecommunication, monitoring
and analysis capabilities.
R5.
N/A
N/A
N/A
The Reliability Coordinator did
not monitor Facilities, the
status of Remedial Action
Schemes, and non-BES facilities
identified as necessary by the
Reliability Coordinator, within
its Reliability Coordinator Area
and neighboring Reliability
Coordinator Areas to identify
any System Operating Limit
exceedances and to determine
any Interconnection Reliability
Operating Limit exceedances
within its Reliability
Coordinator Area.
R6.
N/A
N/A
N/A
The Reliability Coordinator did
not have monitoring systems
that provide information
utilized by the Reliability
Coordinator’s operating
personnel, giving particular
emphasis to alarm
management and awareness
systems, automated data
transfers, and synchronized
Page 6 of 14
IRO-002-65 - Reliability Coordination - Monitoring and Analysis
R#
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
information systems, over a
redundant infrastructure.
Page 7 of 14
IRO-002-65 - Reliability Coordination - Monitoring and Analysis
2.D.
Regional Variances
A. Regional Variance for the Western Electricity Coordinating Council Region
The following Interconnection-wide variance shall be applicable in the Western Electricity
Coordinating Council (WECC) region.
Purpose
To develop a methodology that creates models for performing Operational Planning
Analyses and Real-time Assessments.
Applicability
As used in this WECC Regional Variance, Reliability Coordinator is specific to those Reliability
Coordinators providing Reliability Coordinator service(s) to entities operating within the
Western Interconnection, regardless of where the Reliability Coordinator may be located.
Requirements and Measures
D.A.7.
Each Reliability Coordinator shall, in coordination with other Reliability
Coordinators, develop a common Interconnection-wide methodology to
determine the modeling and monitoring of BES and non-BES Elements that are
internal and external to its Reliability Coordinator Area, necessary for providing
operational awareness of the impacts on Bulk Electric System Facilities within its
Reliability Coordinator Area, including at a minimum: ([Violation Risk Factor:
High] [Time Horizon: Operations Planning])
D.A.7.1.
A method for development, maintenance, and periodic review of
a Western Interconnection-wide reference model to serve as the
baseline from which Reliability Coordinator’s operational models
are derived;
D.A.7.2.
The impacts of Inter-area oscillations;
D.A.7.3.
A method to determine Contingencies included in analyses and
assessments;
D.A.7.4.
A method to determine Remedial Action Schemes included in
analyses and assessments;
D.A.7.5.
A method to determine forecast data included in analyses and
assessments; and
D.A.7.6.
A method for the validation and periodic review of the Reliability
Coordinator’s operational model for steady state and
dynamic/oscillatory system response.
M.D.A.7. Each Reliability Coordinator will have evidence that it developed a common
Western Interconnection-wide methodology, addressing modeling and
Page 8 of 14
IRO-002-65 - Reliability Coordination - Monitoring and Analysis
monitoring, in coordination with other Reliability Coordinators, that includes the
features required in D.A.7.
D.A.8.
Each Reliability Coordinator shall use the methodology developed in D.A.7.
([Violation Risk Factor: High] [Time Horizon: Operations Planning])
M.D.A.8. Each Reliability Coordinator will have evidence that it uses the methodology
developed in D.A.7., as required in D.A.8. above.
Compliance
Evidence Retention:
•
The Reliability Coordinator shall keep data or evidence for Requirements R5, R6, and
the WECC Regional Variance, and Measures M5, M6, and the WECC Regional
Variance for the current calendar year and one previous calendar year.
Violation Severity Levels for the WECC Regional Variance
R#
Lower VSL
Moderate VSL
High VSL
Severe VSL
D.A.7.
The Reliability Coordinator
did not develop the
methodology as required in
D.A.7.
D.A.8.
The Reliability Coordinator
did not implement the
methodology as required in
D.A.8.
None.
D.E.
Associated Documents
The Implementation Plan and other project documents can be found on the project page.
Page 9 of 14
IRO-002-65 - Reliability Coordination - Monitoring and Analysis
Version History
Version
Date
Action
0
April 1,
2005
0
August 8,
2005
1
November Adopted by Board of Trustees
1, 2006
Change Tracking
Effective Date
New
Removed “Proposed” from Effective
Date
Errata
Revised
1
April 4,
2007
Replaced Levels of Non-compliance
with the Feb 28, BOT approved
Violation Severity Levels (VSLs)
Corrected typographical errors in
BOT approved version of VSLs
Revised to add missing
measures and compliance
elements
2
October
17, 2008
Adopted by NERC Board of Trustees
Deleted R2, M3 and
associated compliance
elements as conforming
changes associated with
approval of IRO-010-1.
Revised as part of IROL
Project
2
March 17,
2011
Order issued by FERC approving IRO002-2 (approval effective 5/23/11)
FERC approval
2
February
24, 2014
Updated VSLs based on June 24,
2013 approval.
VSLs revised
3
July 25,
2011
Revised under Project 2006-06
Revised
3
August 4,
2011
Approved by Board of Trustees
Retired R1-R8 under Project
2006-06.
4
November Approved by Board of Trustees
13, 2014
Revisions under Project
2014-03
4
November FERC approved IRO-002-4. Docket
19, 2015 No. RM15-16-000
FERC approval
5
February
9, 2017
Adopted by Board of Trustees
5
April 17,
2017
FERC letter Order approved IRO-0025. Docket No. RD17-4-000
Revised
Page 10 of 14
IRO-002-65 - Reliability Coordination - Monitoring and Analysis
6
May 9,
2019
Adopted by the NERC Board of
Trustees.
WECC Regional Variance
Page 11 of 14
Supplemental Material
Guidelines and Technical Basis
None
Page 12 of 14
Supplemental Material
Rationale
During development of IRO-002-5, text boxes are embedded within the standard to explain the
rationale for various parts of the standard. Upon Board adoption of IRO-002-5, the text from
the rationale text boxes will be moved to this section.
Rationale text from the development of IRO-002-4 in Project 2014-03 follows. Additional
information can be found on the Project 2014-03 project page.
Changes made to the proposed definitions were made in order to respond to issues raised in
NOPR paragraphs 55, 73, and 74 dealing with analysis of SOLs in all time horizons, questions on
Protection Systems and Special Protection Systems in NOPR paragraph 78, and
recommendations on phase angles from the SW Outage Report (recommendation 27). The
intent of such changes is to ensure that Real-time Assessments contain sufficient details to
result in an appropriate level of situational awareness. Some examples include: 1) analyzing
phase angles which may result in the implementation of an Operating Plan to adjust generation
or curtail transactions so that a Transmission facility may be returned to service, or 2)
evaluating the impact of a modified Contingency resulting from the status change of a Special
Protection Scheme from enabled/in-service to disabled/out-of-service.
Rationale for Requirements:
The data exchange elements of Requirements R1 and R2 from approved IRO-002-2 have been
added back into proposed IRO-002-4 in order to ensure that there is no reliability gap. The
Project 2014-03 SDT found no proposed requirements in the current project that covered the
issue. Voice communication is covered in proposed COM-001-2 but data communications needs
to remain in IRO-002-4 as it is not covered in proposed COM-001-2. Staffing of communications
and facilities in corresponding requirements from IRO-002-2 is addressed in approved PER-0042, Requirement R1 and has been deleted from this draft.
Rationale for R2:
Requirement R2 from IRO-002-3 has been deleted because approved EOP-008-1, Requirement
R1, part 1.6.2 addresses redundancy and back-up concerns for outages of analysis tools. New
Requirement R4 (R6 in IRO-002-5) has been added to address NOPR paragraphs 96 and 97:
“…As we explain above, the reliability coordinator’s obligation to monitor SOLs is important to
reliability because a SOL can evolve into an IROL during deteriorating system conditions, and for
potential system conditions such as this, the reliability coordinator’s monitoring of SOLs provides
a necessary backup function to the transmission operator….”
Rationale for Requirements R1 and R2:
The proposed changes address directives for redundancy and diverse routing of data exchange
capabilities (FERC Order No. 817 Para 47).
Redundant and diversely routed data exchange capabilities consist of data exchange
infrastructure components (e.g., switches, routers, servers, power supplies, and network
cabling and communication paths between these components in the primary Control Center for
the exchange of system operating data) that will provide continued functionality despite failure
Page 13 of 14
Supplemental Material
or malfunction of an individual component within the Reliability Coordinator's (RC) primary
Control Center. Redundant and diversely routed data exchange capabilities preclude single
points of failure in primary Control Center data exchange infrastructure from halting the flow of
Real-time data. Requirement R2 does not require automatic or instantaneous fail-over of data
exchange capabilities. Redundancy and diverse routing may be achieved in various ways
depending on the arrangement of the infrastructure or hardware within the RC's primary
Control Center.
The reliability objective of redundancy is to provide for continued data exchange functionality
during outages, maintenance, or testing of data exchange infrastructure. For periods of planned
or unplanned outages of individual data exchange components, the proposed requirements do
not require additional redundant data exchange infrastructure components solely to provide
for redundancy.
Infrastructure that is not within the RC's primary Control Center is not addressed by the
proposed requirement.
Rationale for Requirement R3:
The revised requirement addresses directives for testing of data exchange capabilities used in
primary Control Centers (FERC Order No. 817 Para 51).
A test for redundant functionality demonstrates that data exchange capabilities will continue to
operate despite the malfunction or failure of an individual component (e.g., switches, routers,
servers, power supplies, and network cabling and communication paths between these
components in the primary Control Center for the exchange of system operating data). An
entity's testing practices should, over time, examine the various failure modes of its data
exchange capabilities. When an actual event successfully exercises the redundant functionality,
it can be considered a test for the purposes of the proposed requirement.
Rationale for R4 (R6 in IRO-002-5):
The requirement was added back from approved IRO-002-2 as the Project 2014-03 SDT found
no proposed requirements that covered the issues.
Page 14 of 14
Exhibit B
Implementation Plan
Implementation Plan
WECC-0135 IRO-002-5
Reliability Coordination – Monitoring and Analysis
Request for WECC Regional Variance
Standards Authorization Request (SAR)
The original SAR is located here.
The SAR with expanded scope is located here.
Approvals Required
•
•
•
WECC Board of Directors
NERC Board of Trustees
FERC
March 6, 2019
May 9, 2019
Pending
Applicability
As used in this WECC Regional Variance, Reliability Coordinator is specific to those Reliability
Coordinators providing Reliability Coordinator service(s) to entities operating within the
Western Interconnection, regardless of where the Reliability Coordinator may be located.
Conforming Changes to Other Standards
No conforming changes to other standards are required.
Proposed Effective Date
The proposed effective date for the WECC Regional Variance is “The first day of the first quarter
after regulatory approval, but no sooner than January 1, 2020.”
Justification
A January 1, 2020 effective date allows time for the winding down of Peak Reliability, the startup of other Reliability Coordinators, and creates a window during which the Reliability
Coordinators may create the methodology required.
Consideration of Early Compliance
Earlier compliance should not be pursued. If an earlier effective date is imposed, the time
window could encompass the active operation of multiple Reliability Coordinators for which a
coordinated hand-off of responsibilities had not yet occurred. Further, as proposed the
1|Page
Implementation Plan
WECC-0135 IRO-002-5
Reliability Coordination – Monitoring and Analysis
Request for WECC Regional Variance
effective allows the Reliability Coordinators a time window to create the required
methodology. An earlier effective date may not accommodate that need.
Required Retirements
No other retirements are required to implement this project.
2|Page
Exhibit C
Order No. 672 Criteria
Order 672 Criteria
WECC-0135 IRO-002-5
RC—Monitoring and Analysis—RV
Introduction
The North American Electric Reliability Corporation (NERC) is responsible for ensuring that the
Reliability Standards, Violation Risk Factors (VRF), Violation Severity Levels (VSL), definitions,
Variances, and Interpretations developed by drafting teams are developed in accordance with NERC
processes. These standards must also meet NERC’s benchmarks for Reliability Standards, as well as
criteria for governmental approval.
In Federal Energy Regulatory Commission (FERC) Order No. 672, 1 FERC identified criteria that it will
use to analyze proposed Reliability Standards for approval to ensure they are just, reasonable, not
unduly discriminatory or preferential, and in the public interest. The discussion below identifies these
factors, and explains how the proposed Reliability Standard meets or exceeds the criteria.
For purposes of this filing, the use of the term Reliability Standard is synonymous with Regional
Variance, unless otherwise specified.
Designed for a Specific Goal
Proposed Reliability Standards must be designed to achieve a specified reliability goal.
The proposed Reliability Standard must address a reliability concern that falls within the requirements
of Section 215 of the Federal Power Act. That is, it must provide for the reliable operation of BulkPower System facilities. It may not extend beyond reliable operation of such facilities or apply to other
facilities. Such facilities include all those necessary for operating an interconnected electric energy
transmission network, or any portion of that network, including control systems. The proposed
Reliability Standard may apply to any design of planned additions or modifications of such facilities
that is necessary to provide for reliable operation. It may also apply to Cybersecurity protection. Order
No. 672 at P 321.
Further, NERC Reliability Standards are based on certain reliability principles that define the
foundation of reliability for North American bulk power systems. Each Reliability Standard shall
enable or support one or more of the reliability principles, thereby ensuring that each standard serves a
1
FERC Order 672
155 Nort h 400 West | Suit e 200 | Salt Lake Cit y, Ut ah 84103
www. we cc.org
purpose in support of reliability of the North American bulk power systems. Each Reliability Standard
shall also be consistent with all of the reliability principles, thereby ensuring that no standard
undermines reliability through an unintended consequence. NERC Reliability Principles 2
The purpose of the proposed WECC Regional Variance is:
“To develop a methodology that creates models for performing Operational Planning Analyses and
Real-time Assessments.”
Of the eight NERC Reliability Principles, this standard addresses Reliability Principle 1, which states:
“Interconnected bulk power systems shall be planned and operated in a coordinated manner to
perform reliably under normal and abnormal conditions as defined in the NERC Standards.”
Technically Sound
Proposed Reliability Standards must contain a technically sound method to achieve the goal.
The proposed Reliability Standard must be designed to achieve a specified reliability goal and must
contain a technically sound means to achieve this goal. Although any person may propose a topic for a
Reliability Standard to the Electric Reliability Organization (ERO), in the ERO’s process, the specific
proposed Reliability Standard should be developed initially by persons within the electric power
industry and community with a high level of technical expertise and be based on sound technical and
engineering criteria. It should be based on actual data and lessons learned from past operating
incidents, where appropriate. The process for ERO approval of a proposed Reliability Standard should
be fair and open to all interested persons. Order No. 672 at P 324.
Standard Development
This proposed Reliability Standard was developed using the NERC and Western Electricity
Coordinating Council (WECC) Reliability Standards Development Procedures (Procedures) approved
by FERC and in effect at each point in the process. Among other things, these processes include
drafting of the standard by a drafting team composed of subject matter experts (SME); biographies of
those SMEs are provided with this filing.
These processes also include repeated public iterative comment/response cycles whereby comments are
received from the industry, and responses to those comments are provided by the drafting team.
Technically Sound
The proposed Regional Variance addresses the changing business climate wherein the Western
Interconnection (WI) is transitioning from a single Reliability Coordinator (RC) located within the
2
NERC Reliability Principles
2
footprint of the WI to an unspecified number of RCs potentially operating anywhere across the
continent. To address this change, the proposed Regional Variance has two requirements. Each RC
providing services in the WI shall coordinate with other RCs to (1) develop and (2) use “a common
Interconnection-wide methodology to determine the modeling and monitoring of BES and non-BES
Elements” necessary for providing operational awareness of the impacts on Bulk Electric System
Facilities.
In keeping with NERC’s goal to create performance-based standards, the proposed Regional Variance
does not state how the RCs are to develop the methodology, nor does it state the required content. 3
These attributes are vested in the RCs directly, as the RC SMEs have the technical knowledge to
address the myriad permutations of modeling and monitoring.
Applicability
Proposed Reliability Standards must be applicable to users, owners, and operators of the bulk
power system, and not others.
The proposed Reliability Standard may impose a requirement on any user, owner, or operator of such
facilities, but not on others. Order No. 672 at P 322.
The Applicability section of the proposed standard is as follows:
“As used in this WECC Regional Variance, Reliability Coordinator is specific to those Reliability
Coordinators providing Reliability Coordinator service(s) to entities operating within the Western
Interconnection, regardless of where the Reliability Coordinator may be located.”
Clear and Unambiguous
Proposed Reliability Standards must be clear and unambiguous as to what is required and who is
required to comply.
The proposed Reliability Standard should be clear and unambiguous regarding what is required and
who is required to comply. Users, owners, and operators of the Bulk-Power System must know what
they are required to do to maintain reliability. Order No. 672 at P 325.
Requirement D.R1 of the proposed Regional Variance requires the RC to develop a modeling and
monitoring methodology that identifies internal and external Elements “necessary for providing
operational awareness of the impacts of Bulk Electric System Facilities.” In Posting 2 of the project, the
“Performance-Based—defines a particular reliability objective or outcome to be achieved. In its simplest form, a
results-based requirement has four components: who, under what conditions (if any), shall perform what action,
to achieve what particular result or outcome?” Results Based Standards,
https://www.nerc.com/pa/Stand/Pages/ResultsBasedStandards.aspx.
3
3
drafting team grappled with the question as to what constitutes that which is “necessary” for inclusion.
The drafting team’s response to that concern is as follows:
Finally, the drafting team [DT] recognizes that what constitutes “necessary” in [D.R1] is not
specifically stated in the language of the [Regional Variance]. That was intentional. The DT was
faced with the impossible task of defining the complete universe of what is “necessary” for each
RC – present and future, known and unknown, and under all circumstances.
Since that which is necessary for one RC may not be the same as that which is necessary for
another RC; and, whereas that which is necessary for one RC may vary over time, the DT
concluded the best forum for that determination was during the coordinated development of
the methodology.
In reaching this conclusion, the DT was also concerned that if “necessary” was defined in full, the final
methodology would include more information than some RCs needed. The volume of data would slow
computer processing and create the potential for models to go unsolved due to minutia (data noise).
The solution was to require the RCs to coordinate their efforts and define what was necessary for each
RC in that inclusive setting. Finally, the DT recognized that because the Regional Variance is forwardlooking, the applicable RCs have not yet been identified. Rather than limit the reliability task to the
knowledge base of the assigned DT, the Regional Variance will allow the full knowledge base of
present and future RCs to be included in the development of the modeling and monitoring
methodology.
Understandable Consequence
Proposed Reliability Standards must include clear and understandable consequences and a range of
penalties (monetary and/or non-monetary) for a violation.
The possible consequences, including range of possible penalties, for violating a proposed Reliability
Standard should be clear and understandable by those who must comply. Order No. 672 at P 326.
Violation Risk Factors (VRF) and Violation Severity Levels (VSL) were assigned for each of the two
proposed requirements.
The VRFs for the proposed variance are as follows:
D.R1. ([Violation Risk Factor: High] [Time Horizon: Operations Planning])
D.R2. ([Violation Risk Factor: High] [Time Horizon: Operations Planning])
After reviewing the NERC Violation Risk Factors guidelines, the WECC-0135 Drafting Team set the
VRF for both proposed requirements as “High.”
4
The “High” rating was set because failure to complete the assigned task could “directly cause or
contribute to bulk electric system instability, separation, or a cascading sequence of failures, or could
place the bulk electric system at an unacceptable risk of instability, separation, or cascading failures.”
The VSLs for the proposed variance are as follows:
D.R1. Severe
D.R2. Severe
The WECC-0135 DT set a “Severe” level because the assigned tasks are binary. It either must be
performed or not; so, a graded level of severity is not warranted.
Measurability for Compliance
Proposed Reliability Standards must identify a clear and objective criterion or measure for
compliance, so that it can be enforced in a consistent and non-preferential manner.
There should be a clear criterion or measure of whether an entity is in compliance with a proposed
Reliability Standard. It should contain or be accompanied by an objective measure of compliance so
that it can be enforced and so that enforcement can be applied in a consistent and non-preferential
manner. Order No. 672 at P 327.
The measures for D.R1 and D.R2 are as follows:
D.M1. Each Reliability Coordinator will have evidence that it developed a common Western
Interconnection-wide methodology, addressing modeling and monitoring, in coordination with
other Reliability Coordinators, that includes the features required in D.R1.
D.M2. Each Reliability Coordinator will have evidence that it uses the methodology developed in
D.R1, as required in D.R2. above.
Effective and Efficient
Proposed Reliability Standards should achieve a reliability goal effectively and efficiently - but
does not necessarily have to reflect “best practices” without regard to implementation cost.
The proposed Reliability Standard does not necessarily have to reflect the optimal method, or “best
practice,” for achieving its reliability goal without regard to implementation cost or historical regional
infrastructure design. It should however achieve its reliability goal effectively and efficiently. Order
No. 672 at P 328.
During the two posting periods, no concerns were raised regarding implementation costs or historical
regional infrastructure.
5
The proposed Regional Variance reaches its goals effectively and efficiently by using existing business
practices. As of this filing, forums are already created and actively pursuing the tasks required in the
variance.
Lowest Common Denominator
Proposed Reliability Standards cannot be “lowest common denominator,” i.e., cannot reflect a
compromise that does not adequately protect bulk power system reliability.
The proposed Reliability Standard must not simply reflect a compromise in the ERO’s Reliability
Standard development process based on the least effective North American practice — the so-called
“lowest common denominator” — if such practice does not adequately protect Bulk-Power System
reliability. Although the Commission will give due weight to the technical expertise of the ERO, we
will not hesitate to remand a proposed Reliability Standard if we are convinced it is not adequate to
protect reliability. Order No. 672 at P 329.
The proposed Regional Variance addresses an area not currently codified in NERC Standards.
Costs
Proposed Reliability Standards may consider costs to implement for smaller entities but not at
consequence of less than excellence in operating system reliability.
A proposed Reliability Standard may take into account the size of the entity that must comply with the
Reliability Standard and the cost to those entities of implementing the proposed Reliability Standard.
However, the ERO should not propose a “lowest common denominator” Reliability Standard that
would achieve less than excellence in operating system reliability solely to protect against reasonable
expenses for supporting this vital national infrastructure. For example, a small owner or operator of the
Bulk-Power System must bear the cost of complying with each Reliability Standard that applies to it.
Order No. 672 at P 330.
During the development of the project, the industry raised no such concerns.
Continent-wide and Regional Variations
Proposed Reliability Standards must be designed to apply throughout North America to the
maximum extent achievable with a single reliability standard while not favoring one area or
approach.
A proposed Reliability Standard should be designed to apply throughout the interconnected North
American Bulk-Power System, to the maximum extent this is achievable with a single Reliability
Standard. The proposed Reliability Standard should not be based on a single geographic or regional
model but should take into account geographic variations in grid characteristics, terrain, weather, and
6
other such factors; it should also take into account regional variations in the organizational and
corporate structures of transmission owners and operators, variations in generation fuel type and
ownership patterns, and regional variations in market design if these affect the proposed Reliability
Standard. Order No. 672 at P 331.
In the Order 740 Remand at P4, the Commission states that:
“Reliability Standards that the ERO proposes to the Commission may include Reliability Standards that
are proposed to the ERO by a Regional Entity… When the ERO reviews a regional Reliability Standard
that would be applicable on an interconnection-wide basis and that has been proposed by a Regional
Entity organized on an interconnection-wide basis, the ERO must rebuttably presume that the regional
Reliability Standard is just, reasonable, not unduly discriminatory or preferential, and in the public
interest. In turn, the Commission must give “due weight” to the technical expertise of the ERO and of a
Regional Entity organized on an interconnection-wide basis.”
Further, regional entities may propose Regional Reliability Standards that set more stringent reliability
requirements than the NERC Reliability Standard or cover matters not covered by an existing NERC
Reliability Standard. NERC Rules of Procedure, Section 312, Regional Reliability Standards.
The proposed Regional Variance is applicable only in the Western Interconnection.
The proposed Regional Variance covers matters not covered in an existing NERC Reliability Standard
by requiring the development of an RC-coordinated methodology for Interconnection-wide system
modeling and monitoring.
No Undue Negative Effect
Proposed reliability standards should cause no undue negative effect on competition or restriction
of the grid.
As directed by section 215 of the FPA, the Commission itself will give special attention to the effect of a
proposed Reliability Standard on competition. The ERO should attempt to develop a proposed
Reliability Standard that has no undue negative effect on competition. Among other possible
considerations, a proposed Reliability Standard should not unreasonably restrict available transmission
capability on the Bulk-Power System beyond any restriction necessary for reliability and should not
limit use of the Bulk-Power System in an unduly preferential manner. It should not create an undue
advantage for one competitor over another. Order No. 672 at P 332.
The assigned drafting team does not foresee any negative impacts on competition resulting from the
proposed Regional Variance.
During the development phase of this project, the industry raised no concerns regarding competition or
restrictive use of the grid.
7
Implementation of New Requirements (Effective Date)
The implementation time for the proposed Reliability Standards must be reasonable.
In considering whether a proposed Reliability Standard is just and reasonable, the Commission will
consider also the timetable for implementation of the new requirements, including how the proposal
balances any urgency in the need to implement it against the reasonableness of the time allowed for
those who must comply to develop the necessary procedures, software, facilities, staffing or other
relevant capability. Order No. 672 at P 333.
In accordance with the WECC Reliability Standards Development Procedures, an implementation plan
for the proposed Regional Variance was included with Posting 1 of this project. The Implementation
Plan is included as Attachment F of this filing.
The proposed effective date for the WECC Regional Variance is “The first day of the first quarter after
regulatory approval, but no sooner than January 1, 2020.” A January 1, 2020 effective date allows time
for the winding down of Peak Reliability (serving as the primary Interconnection RC until December
31, 2019), other RCs to start up, and creates a window during which the RCs may create the
methodology required.
Earlier compliance should not be pursued. If an earlier effective date is imposed, the time window
could encompass the active operation of multiple RCs for which a coordinated handoff of
responsibilities had not yet occurred. As proposed, the effective date allows the RCs a period to create
the required methodology. An earlier effective date may not accommodate that need. No other
retirements are required.
Fair and Open Process
The Reliability Standard development process must be open and fair.
Further, in considering whether a proposed Reliability Standard meets the legal standard of review, we
will entertain comments about whether the ERO implemented its Commission-approved Reliability
Standard development process for the development of the particular proposed Reliability Standard in a
proper manner, especially whether the process was open and fair. However, we caution that we will
not be sympathetic to arguments by interested parties that choose, for whatever reason, not to
participate in the ERO’s Reliability Standard development process if it is conducted in good faith in
accordance with the procedures approved by the Commission. Order No. 672 at P 334
WECC followed the WECC Reliability Standards Development Procedures (Procedures) approved by
FERC in effect at the time of each step in the process.
In accordance with the Procedures, all drafting team meetings are open to the public.
8
All drafting team meetings were announced via the WECC Standards Email List for the period
prescribed in the Procedures. Notice of the meetings was provided to NERC and posted on the WECC
Calendar along with meeting minutes.
All meetings were supported by a telephone conference bridge associated with an on-line internet
visual capability allowing all participants to see the document(s) as they were being developed.
Further, this team held an open-mic Standards Briefing prior to balloting affording the industry an
additional opportunity to have its questions addressed.
This project was posted twice for public comment at WECC.
Comments and the associated responses are currently posted on the WECC website, on the WECC-0135
project page, under the Submit and Review Comments accordion. 4 Response to Comments forms were
provided with this filing.
In addition to posting under the WECC Procedures, this project was also posted by NERC for 45-days
in accordance with NERC’s Rules of Procedure and NERC’s internal business practices.
Balanced with Other Vital Interests
Proposed Reliability Standards must balance with other vital public interests.
Finally, we understand that at times development of a proposed Reliability Standard may require that
a particular reliability goal must be balanced against other vital public interests, such as environmental,
social and other goals. We expect the ERO to explain any such balancing in its application for approval
of a proposed Reliability Standard. Order No. 672 at P 335.
WECC is not aware of any other vital public interests. No such balancing concerns were raised or
noted.
Consideration of Other Facts
Proposed Reliability Standards must consider any other relevant factors.
In considering whether a proposed Reliability Standard is just and reasonable, [FERC] will consider
[several] general factors, as well as other factors that are appropriate for the particular Reliability
Standard proposed. Order No. 672 at P 323.
WECC is not aware of any other general factors in need of consideration.
4
https://www.wecc.org/Standards/Pages/WECC-0135.aspx
9
Exhibit D
Analysis of Violation Risk Factors and Violation Severity Levels
Violation Risk Factors
Violation Severity Levels
WECC-0135 IRO-002-5
RC—Monitoring and Analysis—RV
Violation Risk Factors
The Violation Risk Factors (VRF) for the proposed variance are as follows:
D.R1. ([Violation Risk Factor: High] [Time Horizon: Operations Planning])
D.R2. ([Violation Risk Factor: High] [Time Horizon: Operations Planning])
After reviewing the North American Electric Reliability Corporation (NERC) Violation Risk Factors
guidelines, the WECC-0135 Drafting Team set the VRF for both proposed requirements as “High.”
The “High” rating was set because failure to complete the assigned task could “directly cause or
contribute to bulk electric system instability, separation, or a cascading sequence of failures, or could
place the bulk electric system at an unacceptable risk of instability, separation, or cascading failures.” 1
Violation Severity Levels
The Violation Severity Levels (VSL) for the proposed variance are as follows:
D.R1. Severe
D.R2. Severe
The WECC-0135 DT set a “Severe” level because the assigned task is binary. It must either be
performed or not performed. Thus, a graded level of severity is not warranted.
Violation Severity Levels for the WECC Regional Variance
D.R #
D.R1.
Lower VSL
Moderate VSL
High VSL
Severe VSL
The Reliability Coordinator
did not develop the
methodology as required in
D.R1.
D.R2.
1
The Reliability Coordinator
did not implement the
https://www.nerc.com/pa/Stand/Resources/Documents/Violation_Risk_Factors.pdf
155 Nort h 400 West | Suit e 200 | Salt Lake Cit y, Ut ah 84103
www. we cc.org
Violation Severity Levels for the WECC Regional Variance
D.R #
Lower VSL
Moderate VSL
High VSL
Severe VSL
methodology as required in
D.R2.
2
Exhibit E
Summary of Development History and Complete Record of Development
Summary of Development History
Summary of Development History
The development record for the WECC regional Variance reflected in proposed
Reliability Standard IRO-002-6 is summarized below.
I.
Overview of the Standard Drafting Team
When evaluating a proposed Reliability Standard, the Commission is expected to give
“due weight” to the technical expertise of the ERO. 1 The technical expertise of the ERO is
derived from the standard drafting team selected by the WECC Standards Committee to lead
each project in accordance with Step 3 of the WECC Reliability Standards Development
Procedures. 2 For this project, the standard drafting team consisted of industry experts, all with a
diverse set of experiences. A roster of the Standard Drafting team members is included in
Exhibit F.
II.
Standard Development History
A. Standard Authorization Request
Project WECC-0135 IRO-002-5 RC – Monitoring and Analysis – Regional Variance was
initiated on June 8, 2018 with receipt of a proposed Standards Authorization Request (“SAR”).
The WECC Standards Committee formally approved the SAR on June 19, 2018.
B. First Posting – Comment Period
On October 5, 2018, the standard drafting team agreed by majority vote to post a
proposed regional Variance to Reliability Standard IRO-002-5 for a 30-day comment period. 3
1
Section 215(d)(2) of the Federal Power Act; 16 U.S.C. § 824o(d)(2)
(2018). The currently-effective WECC RSDP is available at
http://www.nerc.com/FilingsOrders/us/Regional%20Delegation%20Agreements%20DL/WECC%20RSDP_201710
27.pdf.
3
Posting materials for this posting and subsequent postings are available on the WECC project page,
https://www.wecc.org/Standards/Pages/WECC-0135.aspx.
2
1
The proposed Variance was posted for a 30-day comment period from October 9, 2018 through
November 8, 2018.
C. Second Posting – Comment Period
The proposed regional Variance was posted for another 30-day public comment period
from November 19, 2018 through December 19, 2018. On November 28, 2019, WECC extended
the deadline for comments through January 2, 2019 to accommodate a modification to the
Implementation Plan.
D. Final Ballot
On January 17, 2018, the WECC Standards Committee approved the proposed regional
Variance to Reliability Standard IRO-002-5 to be posted for ballot. The ballot pool opened on
January 22, 2019 and closed on February 5, 2019. WECC held a standards briefing on February
6, 2019. The ballot was open from February 7, 2019 through February 21, 2019. Twenty-nine
individuals joined the ballot pool. Twenty-six votes were cast, providing quorum at 89.7 percent.
The standard obtained 25 affirmative votes which was 100 percent of the weighted segment vote.
E. WECC Board of Directors Approval
On March 6, 2019, the WECC Board of Directors approved the proposed regional Variance
to Reliability Standard IRO-002-5. 4
F. NERC Comment Period and Board of Trustees Adoption
NERC posted the proposed regional Variance to Reliability Standard IRO-002-5 for a 45day public comment period from March 7, 2019 through April 22, 2019. Following the posting
period, the proposed Variance was added to the IRO-002 Reliability Standard and assigned
4
See https://www.wecc.org/Administrative/March%20Board%20Meeting%20Book.pdf.
2
version number IRO-002-6.The NERC Board of Trustees adopted proposed Reliability Standard
IRO-002-6 on May 9, 2019.
3
Complete Record of Development
Steven Rueckert
WECC Director of Standards
April 30, 2019
Ms. Nasheema Santos
NERC Reliability Standards Department
North American Electric Reliability Corporation
3353 Peachtree Rd. NE, North Tower—Suite 600
Atlanta, GA 30326
Subject:
WECC-0135 IRO-002-5 Reliability Coordination—Monitoring and Analysis
Request for Regional Variance
Dear Nasheema,
WECC is seeking approval by the NERC Board of Trustees, with subsequent disposition by the Federal
Energy Regulatory Commission (FERC), to approve a WECC Regional Variance to IRO-002-5
Reliability Coordination—Monitoring and Analysis. 1
The proposed Regional Variance requires Reliability Coordinators (RC) serving the Western
Interconnection: 1) to develop a common Interconnection-wide methodology to determine the
modeling and monitoring of elements necessary for providing operational awareness, and 2) to use the
methodology.
The proposed variance passed with a 100 percent weighted approval.
Sincerely,
Steven Rueckert
WECC Director of Standards
If approved, the variance will be added to proposed standard IRO-002-6 as part of the ongoing NERC Project
2018-03 Standards Efficiency Retirements.
1
155 North 400 West | Suite 200 | Salt Lake City, Utah 84103
WECC-0135 IRO-002-5 Reliability Coordination—Monitoring and Analysis
Request for Regional Variance
For documentation support please contact W. Shannon Black, at (503) 307-5782.
WECC-0135 IRO-002-5 Reliability Coordination (RC)—Monitoring and Analysis
Request for Regional Variance (RV)
SAR—Standard Authorization Request Attachment A (1)
Regional Reliability Standard(s) (Clean Existing) Attachment B (2)
Regional Reliability Standard(s) (Clean Proposed) Attachment C1 (3)
Regional Reliability Standard(s) (Clean Proposed) Attachment C2 (4)
Regional Reliability Standard(s) (Existing redlined to Proposed) Attachment D (5)
Project Roadmap Attachment E (6)
Implementation Plan Attachment F (7)
VRF & VSL Justification Attachment G (8)
Regional Reliability Standard Submittal Request Attachment H (9)
Order 672 Criteria Attachment I (10)
Drafting Team Roster with Biographies Attachment J (11)
Ballot Pool Members Attachment K (12)
Final Ballot Results Attachment L (13)
Minority Issues Attachment M (14)
WECC Standards Committee Roster Attachment N (15)
Response to Comments Posting One WECC Attachment O1 (16)
Response to Comments Posting Two WECC Attachment O2 (17)
Response to Comments Posting One NERC – Attachment O3 (18)
IRO-002-5
(WECC Variance)
Reliability
Coordination –
Monitoring and
Analysis
Info (19)
IRO-002-5 Regional
Variance* (20)
*Will be added to
proposed standard
2
WECC-0135 IRO-002-5 Reliability Coordination—Monitoring and Analysis
Request for Regional Variance
(WECC Variance)
Standard Under
Development
3/7/2019 –
4/22/2019
IRO-002-6 (part of
the ongoing Project
2018-03 Standards
Efficiency
Retirements, post
final ballot)
Submit Comments
Comments Received
(21)
Unofficial Comment
Form (Word) (22)
3
Response to Comments
Posting 1 Response to Comments
WECC-0135 IRO-002-5
RC—Monitoring and Analysis—RV
Posting 1
The WECC-0135 IRO-002-5, Reliability Coordination—Monitoring and Analysis, Request for WECC
Regional Variance (RV) Drafting Team (DT) thanks everyone who submitted comments on the
proposed document.
Posting
This project was posted for a 30-day public comment period from October 9 through November 8, 2018.
WECC distributed the notice for the posting on October 5, 2018. The DT asked stakeholders to provide
feedback on the proposed document through a standardized electronic template. Five comments were
received on this posting. To facilitate comments, WECC received a redline version of the posting from
four entities. Those redline documents are posted on the WECC-0135 homepage under the “Submit and
Review Comments” accordion.
Location of Comments
All comments received on the project can be viewed in their original format on the WECC-0135 project
page under the “Submit and Review Comments” accordion.
Methodology vs. Model Mandate
The proposed WECC RV addresses a paradigm in which multiple Reliability Coordinators (RC)
provide RC service(s) within the Western Interconnection, regardless of the RC’s geographic location.
RCs require information in the Real-time horizon to ensure the reliability of their RC Areas. The
foundation of the Real-time task(s) occurs during the Operations Planning horizon during which RCs
engage in the coordinated exchange of information with neighboring RCs.
Two primary approaches were considered for this project: 1) a requirement that all RCs use a single,
mandated model, and 2) a requirement that all affected RCs create a coordinated methodology to meet
the reliability goal. The DT opted for the second approach.
The DT opted for the methodology approach over the model mandate for the following reasons:
155 Nort h 400 West | Suit e 200 | Salt Lake Cit y, Ut ah 84103
www. we cc.org
Attachment R1
•
The methodology approach is a better match for NERC’s direction that standards should be
results-based as opposed to mandating how the result should be reached. (See NERC’s ResultsBased Reliability Standard Development Guidance.)
•
Requiring use of a specified model may preclude use of a superior model causing a default to
the lowest common denominator. (FERC Order 672, para. 329.)
•
Requiring use of a specified model may diminish due process in that changes to the model
could occur outside the standards-development process. (FERC Order 672 at para. 334.)
•
If the WECC RV mandated use of a single model “or its successor” until the validity of “its
successor” could be determined, compliance would be in question.
•
The methodology approach conforms with FERC direction in that it allows for the WECC RV to
consider “implementation cost [and] historical regional infrastructure design,” while achieving
the reliability objective “effectively and efficiently.” (FERC Order 672, para. 328 and 330)
Common Methodology
The goal of the common methodology is to ensure that essential modelling details are maintained that
provide an RC with a wide-area view while permitting any unneeded data to be culled. The benefits of
ensuring that the RC models are no larger than necessary include: 1) significantly enhanced
performance of on-line applications such as Transient Stability Analysis, 2) reduced risk that data
problems with elements that are insensitive to the RC footprint will cause convergence problems, 3)
reduced risk that problems with elements that are insensitive to the RC footprint could cause false
alarms or consume troubleshooting resources, and 4) reduced risk that errors from insensitive parts of
the Interconnection could mask issues within the RC footprint.
Changes in Response to Comment
Purpose
A Purpose statement was added as follows: “To develop a methodology that creates models for
performing Operational Planning Analysis and Real-time Assessment.” The intent is to clarify the
purpose for the variance.
Applicability
The word “operating” was inserted into the Applicability section.
Requirement RX1
•
The general syntax was addressed.
•
The word “all” was deleted from Posting 1, RX1.
2
Attachment R1
•
Reference to Operational Planning Analysis and Real-time Assessment were deleted from
Posting 1, RX1 eliminating ambiguity as to the time horizon in which the requirement was to
take place. (See the Purpose statement.)
•
Posting 1, Parts 1.1.1 through 1.1.3 were deleted as unnecessary.
•
Posting 1 RX1, 1.1.4 reference to inter-area oscillations was retained as Posting 2, RX1 1.2.
•
Posting 2, RX1., 1.1 was added creating a requirement to establish a baseline reference model.
•
The defined term “Elements” was adopted.
•
Posting 2, RX1, 1.3-1.5, adjusted syntax and added the phrase “analysis and assessment” for
consistency.
•
The Measure for Posting 2, RX1 was adjusted to reflect the above changes.
Requirement RX2
•
The word “implement” was deleted in favor of “use.”
•
The phrase “modeling and monitoring” was deleted as redundant.
•
The word “described” was deleted in favor of “developed.”
•
The Measure for Posting 2, RX2 was adjusted to reflect the above changes.
Violation Severity Levels and Violation Risk Factors
Violation Severity Levels (VSL) and Violation Risk Factors (VRF) were added.
Compliance
Compliance components were added.
Minority View
Numerous structural and syntax changes were not adopted.
The drafting team did not adopt proposed changes:
•
That would further prescribe how the monitoring of oscillation should occur. The drafting team
opted to retain the methodology approach that meets the results-based concept rather than
defining what must be done.
•
That would delete Posting 1, RX1., 1.5 because its inclusion creates a mandate specific to the RC
that is not present in MOD-33.
•
To adopt a dispute resolution clause requiring that all RCs agree.
•
To adopt inclusion of “voltage” because RX1 addresses stability time frames as opposed to
stability types.
3
Attachment R1
Effective Date
The proposed effective date is no earlier than January 1, 2020. A full implementation plan was posted
with Posting 2.
Action Plan
On November 19, 2018, the WECC-0135 IRO-002-5, Reliability Coordination—Monitoring and
Analysis, Request for WECC Regional Variance Drafting Team agreed by majority vote to post Posting
2 of the project for a 30-day comment period.
The posting period will open November 19, 2018, and close December 19, 2018. The drafting team will
meet on December 20, 2018, from 10:00 a.m. to noon and December 21, 2018, from 10:00 a.m. to noon
MST to respond to comments received.
Once the posting opens, comments can be submitted using the green survey buttons located on the
“Submit and Review Comments” accordion of the WECC-0135.
If you have questions regarding the posting, please contact W. Shannon Black, at (503) 307 5782.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC
Consultant, at (503) 307-5782. In addition, there is a WECC Reliability Standards appeals process.
Commenter
Organization
1
Alan Wahlstrom
Southwest Power Pool (SPP)
2
Robert Cummins
North American Electric Reliability Corporation
(NERC)
3
Saad Malik
Peak Reliability Coordinator (Peak)
4
Adrian Andreoiu / Gordon Dobson-Mack
BC Hydro/Powerex
5
Andrea Jessup
Bonneville Power Administration (BPA)
4
Attachment R1
Index to Questions, Comments, and Responses
Question
1. The Drafting Team welcomes comments on all aspects of the document.
5
Attachment R1
1. The Drafting Team welcomes comments on all aspects of the document.
Summary Consideration: See summary in the preamble of this document.
Commenter
SPP
Comment
Suggested changes:
Applicability
As used in this WECC Regional Variance, Reliability
Coordinator is specific to those Reliability Coordinators
providing Reliability Coordinator service(s) to entities
operating within the Western Interconnection, regardless of
where the Reliability Coordinator may be located.
Requirement and Measures
RX1. Each Reliability Coordinator shall, in coordination
with all [AW1] other Reliability Coordinators, jointly
develop and implement a common Interconnection-wide
modeling and monitoring methodology that all Reliability
Coordinators will use to perform Operational Planning
Analysis and Real-time Assessments, to include at a
minimum, the following:
[AW1] This may be problematic if Canadian entities bow
out. Which standard would Canadian entities follow if not
this one?
1.1
A method [MH2] to determine impacts (both Bulk
Electric System (BES) and non-BES facilities) from internal
and external systems on its Reliability Coordinator Area, to
include:
[MH2] It is self-evident why an RC would have a method
for monitoring. In Rx1.1 "required for awareness: should be
deleted.
1.1.1 Facility Ratings and thermal limits;
1.1.2 Steady state voltage limits;
1.1.3 Transient and steady state stability; and
6
Attachment R1
1.1.4 Inter-area oscillations[AW3].
[AW3] The standard has left the interpretation on what
constitutes monitoring oscillation or transient to the
regulatory groups. There should be some language that
allows the Reliability Coordinator to determine how it
should monitor oscillations and transients. This can be
done through the standard or the methodology
1.2
A method to determine Contingencies included in
the analysis and assessments.
1.3
A method to determine Remedial Action Schemes
included in the analysis and assessments.
1.4
A method to determine Forecast data included in
the analysis and assessments. [AW4]
[AW4] R1.5 addresses model validation for steady state
and dynamic oscillatory system response. This requirement
conflicts with Mod-33 which already address model
validation for Steady- State and Dynamic System Models
Suggested addition: 1.6
A resolution process specifying any change to the
methodology must be agreed to by all Reliability
Coordinators.
MX1. Each Reliability Coordinator shall provide evidence
of a jointly developed, implemented and coordinated
Interconnection-wide modeling and monitoring
methodology, as specified in RX1. Evidence may include,
but is not limited to, a dated and acknowledged copy of the
jointly developed, implemented and coordinated
Interconnection-wide modeling and monitoring
methodology, as specified in RX1[AW5]
[AW5] In Measure MX1 "joint correspondence between the
Reliability Coordinators addressing the content of RX1" is
vague and could be interpreted as any language in which
the methodology was discussed between RC's. MX1 could
state "Each RC shall have a dated methodology."
7
Attachment R1
Response
The DT adopted the following changes:
Applicability:
As used in this WECC Regional Variance, Reliability Coordinator is specific to those Reliability
Coordinators providing Reliability Coordinator service(s) to entities operating within the Western
Interconnection, regardless of where the Reliability Coordinator may be located. (Accepted
“operating”; emphasis added.)
Requirement and Measures
1) Implementation
SPP’s suggestion that “implementation” be added to the first requirement resulting in deletion of the
proposed second requirement was not adopted. To accept the change would create two
requirements in a single requirement. This approach conflicts with standards drafting conventions.
2) All
SPP suggests deleting the word “all” from the requirement to avoid the appearance of noncompliance if any one or more RCs does not jointly participate in the development of the
methodology. The DT adopted the suggestion to delete the word “all”.
3) Jointly
The DT did not adopt inclusion of the word “jointly” as to do so adds ambiguity and conflicts with
standards drafting conventions that discourage the use of adverbs. This convention is in place
because adverbs are interpreted from the standpoint of the reader and may lead to varying
interpretations of the same language. For example, in the sentence “The aircraft moved swiftly”,
what constitutes “swiftly” is entirely dependent on all the surrounding circumstances.
4) Prepositional Changes to the Predicate
Although SPP’s suggestions are sound, the DT opted to eliminate the tailing phrase of the
requirement to avoid confusion. As proposed in Posting 1, the phrase included multiple time
horizons during which the task would be completed. By adjusting the phrase, the confusion is
eliminated.
5) Proposed changes Posting 1, RX1, 1.1
SPP’s suggestions were largely adopted while incorporating additional changes suggested by NERC,
Peak and the drafting team. The new language (Posting 2, RX1, 1.2) is as follows:
8
Attachment R1
“1.2 A method to determine impacts of Elements of the Bulk Electric System (BES) and non-BES
facilities, from internal and external systems on its Reliability Coordinator’s Area, that considers the
impact to each of the following:”
6) Interpretation of 1.1.4
The construction of Posting 1, Requirement 1.1.4 was intentional. The DT agrees with SPP that, as
drafted, the requirement leaves open what constitutes monitoring of inter-area oscillations. This
allows the RC “to determine how it should monitor oscillations and transients” (SPP).
The body of the requirement calls for creation of a methodology; it does not call for detailing “how”
the methodology will be implemented. That should be left to the learned discretion of the RCs as
they develop the methodology.
7) Syntax change and addition of “included in the analysis and assessments”
This change was adopted in Posting 1, RX1. 1.2, 1.3 and 1.4.
8) Defined Term “Forecast” in Posting 1, RX1. 1.4
The capitalized use of Forecast in Posting 1 RX1. 1.4 was not used because it is not a defined term in
the NERC Glossary of Terms Used in Reliability Standards.
9) Proposed deletion of 1.5
The DT opted to retain Posting 1, RX1. 1.5 as it creates a mandate specific to the RC that is not
present in MOD-33.
10) Proposed Inclusion of 1.6
SPP suggests including a 1.6 to require a resolution process specifying that any change to the
methodology must be agreed to by all Reliability Coordinators. For the same reason the DT adopted
SPPs suggestion to delete “all” from the body of the requirement, mandating “all” in a proposed 1.6
is problematic.
10) Proposed Changes to the Measure
Although the DT did not adopt the specific changes offered by SPP, changes were made to the
Measure to reflect the newly drafted Requirement.
Commenter
Comment
NERC, Robert Cummins
The following comments are summarized from a redline
version of Posting 1 provided by Mr. Cummins. The
redline is available for review on the WECC-0135 Project
Page on the Submit and Review Comments accordion. The
9
Attachment R1
provided electronic portal for submitting comments was
not used.
1) Add the phrase “in the Interconnection” to RX1.
2) Include a new 1.1 to serve as a baseline.
Proposed language: A methodology for development and
maintenance of an Interconnection -wide model to act as
the common starting point for all Reliability Coordinators
in the Interconnection including frequency of updating that
model.
3) Add the following in (existing) Requirement 1.1.
“(…and non-BES elements)”.
4) With rapid changes in resource mix and location of those
resources, the critical contingencies and the oscillatory
behavior will often change. That change in criticality must
be constantly reviewed.
To clarify existing 1.2, Mr. Cummins suggested the
following changes:
“A method for determining Contingencies required for
inclusion in Operational Planning Analysis and Real-time
Assessment. (Existing 1.2 would add on 1.2.1 “Critical
Contingency determination must be reviewed annually.”
Response
1) Interconnection
Adding “in the Interconnection” was not adopted as it is addressed in the Applicability section.
2) Include a new Posting 1, RX1. 1.1 to serve as a base line.
After considering NERC’s suggestion the following changes were adopted:
RX1. 1.1.
A methodology for development, maintenance, and periodic review of an
Interconnection-wide reference model to serve as the baseline from which Reliability Coordinator’s
operational models are derived.
3) Posting 1, RX1. 1.2 – Elements
10
Attachment R1
The defined term Elements was added to read as follows: “…impacts of Elements of the Bulk Electric
System (BES)…”
4) Posting 1, RX1. 1.2 clarification
NERC suggests attaching the phrase “in the Operational Planning Analysis and the Real-time
assessment” for determining Contingencies. If the language is adopted, it creates a slippery slope
begging why the condition is applied solely to Contingencies and not, for example, to Remedial
Action Schemes. To avoid adopting an artificial distinction, the team opted not to adopt the
language.
5) Addition of Posting 1, RX1. 1.2.1
NERC’s suggestion adds ambiguity in that what constitutes “critical” will vary based on all the
surrounding circumstances.
Commenter
Peak
Comment
The following comments are summarized from a redline
version of Posting 1 provided by Peak. The redline is
available for review on the WECC-0135 Project Page on the
Submit and Review Comments accordion. The provided
electronic portal for submitting comments was not used.
Peak finds the double inclusion of “include” in RX1 and
“to include” in RX1.1 confusing. Peak’s concern is that the
second inclusion could be interpreted to mean that RCs are
required to include the actual Facility Ratings, thermal
limits, voltage limits, etc. in the Interconnection-wide
methodology.
Peak believes the intent was for the RC to consider those
elements when determining the impact of internal/external
systems. However, as drafted the language could be
interpreted differently.
Peak suggests the following corrective language:
1.1
A method to determine SOL and IROL exceedances
due to impacts (both Bulk Electric System (BES) and nonBES facilities) from internal and external systems on its
Reliability Coordinator’s Area (to both Bulk Electric
System (BES) and non-BES facilities), to include by taking
into account:
11
Attachment R1
Response
1) Changes to existing Posting 1, RX1 1.1
After considering Peak’s suggestion, eliminated the double use of “include” and adopted the
following change appearing as Posting 2, RX1. 1.2:
“1.2
A method to determine impacts of Elements of the Bulk Electric System (BES) and non-BES
facilities, from internal and external systems on its Reliability Coordinator’s Area, that considers the
impact to each of the following:”
Commenter
Comment
BC Hydro/Powerex
The following comments are submitted on behalf of BC
Hydro and Powerex.
The Drafting Team welcomes comments on all aspects of
the document.
BC Hydro and Powerex are supportive of this draft version
that enables the Reliability Coordinators (RC) offering
reliability coordination services in the WECC Region to
develop a common methodology for modelling and
monitoring the Western Interconnection. BC Hydro and
Powerex believe that the common methodology approach
strikes an appropriate balance between ensuring that RCs
model and monitor elements that could impact their RC
footprint without requiring each RC to model BES
elements that are insensitive to their RC footprint.
The primary reason BC Hydro and Powerex believe RCs
should have the right to cull insensitive elements from
their energy management system (EMS) model is that the
size of the model will adversely impact an RC's ability to
run critical on-line applications, such as real-time Transient
Stability Analysis (TSA): a 15,000-bus model will require
substantially more time to calculate real-time transient
stability limits than a 7,500-bus model would require. This
will be particularly important to RCs whose footprints are
sensitive and vulnerable to transient and voltage stability
issues as they will want to recalculate transient and voltage
stability limits multiple times an hour. Delays in running
12
Attachment R1
these numerically and computationally intensive processes
will naturally mean that fewer limits can be calculated in
the same amount of time, thereby potentially adversely
impacting the reliability of the power system.
Furthermore, BC Hydro and Powerex believe it is
imperative for RCs to have the option to cull insensitive
BES elements from their EMS models because this will:
a) Reduce the risk of data problems with elements that are
insensitive to the RC footprint causing convergence
problems that prevent advanced applications from being
run and thereby rendering the results of the applications
(e.g. limits and limit violations) unavailable for longer
periods of time;
b) Reduce the risk that problems with elements that are
insensitive to the RC footprint could cause spurious alarms
or consume troubleshooting resources;
c) Reduce risk that errors from insensitive parts of a full
WECC model could mask issues within the RC footprint;
and,
d) Avoid the additional maintenance and licensing costs
associated with an unnecessarily large EMS model.
In addition, BC Hydro and Powerex suggest re-wording of
the language of Requirement RX2 and associated Measure
MX2 as follows:
•In RX2, replace "as described" with "developed" for
consistency with the requirement RX1; and
•In MX2, replace "used" with "implemented" for
consistency with the requirement RX2.
Response
The drafting team appreciates BC Hydro’s/Powerex’ participation in the standards development
process.
In considering changes to Posting 1 RX2, the team opted for a combination of BC/Powerex’
suggestion and that of NERC. The team adopted the word “developed” to reflect Requirement RX1
13
Attachment R1
and complemented that with the word “uses”, as suggested by NERC to indicate that the reliability
task is ongoing and not merely used at some point in the past. The resultant wording is as follows:
RX2.
Each Reliability Coordinator shall use the methodology developed in RX1. ([Violation Risk
Factor: High] [Time Horizon: Operations Planning]) (Emphasis added)
MX2. Each RC will have evidence that it uses the methodology developed in RX1, as required in
RX2 above. (Emphasis added.)
Commenter
Comment
BPA
BPA did not respond to Posting 1 via the provided
electronic portal; however, BPA did provide a suggested
redline to WECC via email. The proposed redline can be
found on the WECC-0135 Project Page on the Submit and
Review Comments accordion. In summary, BPA
suggested:
1) A change in language and task from that of developing a
method to that of developing criteria;
2) Inclusion of “voltage”; and,
3) Change the body of proposed RX1 to as follows:
RX1.
Each Reliability Coordinator shall, in coordination
with all other Reliability Coordinators, develop common
Interconnection-wide modeling standards, that all
Reliability Coordinators will use for performing
Operational Planning Analysis and Real-time Assessments,
to include at a minimum:
Response
1) Posting 1, RX1 1.1 Criteria for Developing
After consideration of BPA’s suggestion, the team opted not to adopt the change from mandating
development of a “method” in favor of developing a “criteria.” Assuming the criteria were
developed, as proposed by BPA there is no mandate to use it. By retaining the “method” approach,
the RCs developing the method will, by default, be required to include the criteria contained in the
method. The methodology is a broader construct that will include the criteria. Limiting the
requirement to criteria alone could be overly constricting.
2) Voltage
14
Attachment R1
The drafting team did not include “voltage” because the requirement as drafted addresses stability
time frames as opposed to stability types.
3) Restructuring
The team found BPA’s proposed restructuring as a viable alternative to Posting 1; however, the team
further concluded that the restructuring added no significant clarity. As to inclusion of a mandate to
develop (more) “modeling standards” within an existing standard, the team concluded that the
proposal would introduce undue ambiguity to the requirement; therefore, the proposal was not
adopted.
15
Attachment A
Standard Authorization Request
W. Shannon Black
WECC Consultant, Standards Processes
This Standard Authorization Request (SAR) was received on June 8, 2018 and deemed complete the
same day. The SAR was approved by the WECC Standards Committee (WSC) on June 19, 2018.
The scope of the SAR was modified by the WSC on September 20, 2018. (See section on Modified
Scope.)
Introduction
This project is a request to add a Regional Variance (RV) to IRO-002-5, Reliability Coordination—
Monitoring and Analysis.
Requester Information
Provide your contact information and your alternate’s contact information:
Primary contact
•
First name:
W. Shannon
•
Last name:
Black
•
Email:
sblack@wecc.org
•
Phone:
(503) 307-5782
•
Organization name:
WECC
Alternate
•
First name:
Steven
•
Last name:
Rueckert
•
Email:
srueckert@wecc.org
•
Phone:
(801) 883-6878
Type of Request
Specify the type of request: (select one)
•
Request for Regional Variance
155 Nort h 400 West | Suit e 200 | Salt Lake Cit y, Ut ah 84103
www. we cc.org
Attachment A
Create, Modify, or Retire a Document Questions
Provide information for your request to create, modify, or retire the document.
Requested Action (select one)
•
Request for Regional Variance
Document Type (select one)
•
NERC Standard
Issue
Specify what industry problem this request is trying to resolve.
In IRO-002-5, Reliability Coordination—Monitoring and Analysis, requirement R5 states:
R5. Each Reliability Coordinator shall monitor Facilities, the status of Remedial Action
Schemes, and non-BES facilities identified as necessary by the Reliability Coordinator, within
its Reliability Coordinator Area and neighboring Reliability Coordinator Areas to identify any
System Operating Limit exceedances and to determine any Interconnection Reliability
Operating Limit exceedances within its Reliability Coordinator Area. [Violation Risk Factor:
High] [Time Horizon: Real-Time Operations]
Due to the unique physical characteristics of the Bulk Power System in the Western Interconnection,
events in one part of the Interconnection can have significant impacts in other parts of the system. It is
unknown how many Reliability Coordinators (RC) there will be in the Western Interconnection and
what the potential RC Area footprints will be. However, it is highly likely that events in one RC’s Area
will impact facilities in another RC’s Area.
This SAR seeks an Regional Variance to R5 requiring each RC within the Western Interconnection to:
1. Model the entire Interconnection as part of its monitoring and identification processes; and
2. Include specific types of Remedial Action Schemes (RAS) in its processes.
Consideration should be given to:
1. Requiring the use of a single, common model covering the Western Interconnection; and
2. Inclusion (or exclusion) of specific types of RASs, such as wide-area and local-area RASs, as
discussed in the WECC Remedial Action Scheme Design Guide, January 2017.
Proposed Remedy
Specify how this request will address the issue.
This SAR would add a WECC RV to ensure coordination and consistent review between multiple RCs
within the Western Interconnection.
2
Attachment A
Applicable Entities
Each function will be reviewed if affected.
•
Reliability Coordinators
Detailed Description
See 5 above.
Affected Reliability Principles
Which of the following reliability principles is MOST affected by this request? (select one)
•
Reliability Principle #7 – The reliability of the interconnected bulk power system shall be assessed,
monitored, and maintained on a wide-area basis.
Modified Scope
The following is an excerpt from the WSC meeting minutes on September 20, 2018.
Request for Standard Authorization Approval (SAR)—Scope Adjustment
On September 11, 2018, the WECC-0135 IRO-002-5, Reliability Coordination—Monitoring and
Analysis, Request for Regional Variance Drafting Team concluded that the scope of the existing SAR
required adjustment.
The drafting team raised concerns that requiring each Reliability Coordinator to model the entire
Interconnection may not be necessary to ensure or enhance reliability, and may diminish reliability. As
an alternative, the team sought authorization to broaden the scope of the SAR to allow, at minimum,
any one or a combination of the following: 1) no change, 2) allow each Reliability Coordinator
flexibility in how the Interconnection would be modeled, 3) require each Reliability Coordinator to use
an Interconnection-wide model, 4) consideration to draft a geographic-specific variance applicable only
to the United States, and/or, 5) that position best considered by the subject matter experts assigned.
The team has set September 21, 2018, as the deadline to reach consensus on a drafting approach.
On a motion from Mr. Gary Nolan, the WSC agreed to expand the scope of the WECC-0135 SAR as
requested.
Document Information
Specify the document title, document number, and affected section regarding the request.
See 5 above.
3
Attachment A
Reference Uploads
Please reference or upload any affected standards, regional business practices, criteria, policies, white
papers, technical reports, or other relevant documents. If this request is based on a conflict of law,
please include a copy of—or accessible reference to—the specific law or regulatory mandate in conflict.
NA
Provide additional comments (if needed).
NA
4
IRO-002-5 - Reliability Coordination - Monitoring and Analysis
A. Introduction
1.
Title:
Reliability Coordination – Monitoring and Analysis
2.
Number:
IRO-002-5
3.
Purpose: To provide System Operators with the capabilities necessary to monitor
and analyze data needed to perform their reliability functions.
4.
Applicability:
4.1. Functional Entities:
4.1.1. Reliability Coordinators
5.
Effective Date: See Implementation Plan
B. Requirements and Measures
R1.
Each Reliability Coordinator shall have data exchange capabilities with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
for it to perform its Operational Planning Analyses. [Violation Risk Factor: Medium]
[Time Horizon: Operations Planning]
M1. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, a document that lists its data exchange capabilities with
its Balancing Authorities and Transmission Operators, and with other entities it deems
necessary, for it to perform its Operational Planning Analyses.
R2.
Each Reliability Coordinator shall have data exchange capabilities, with redundant and
diversely routed data exchange infrastructure within the Reliability Coordinator's
primary Control Center, for the exchange of Real-time data with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
for performing its Real-time monitoring and Real-time Assessments. [Violation Risk
Factor: High] [Time Horizon: Same-Day Operations, Real-time Operations]
M2. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, system specifications, system diagrams, or other
documentation that lists its data exchange capabilities, including redundant and
diversely routed data exchange infrastructure within the Reliability Coordinator's
primary Control Center, for the exchange of Real-time data with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
as specified in the requirement.
R3.
Each Reliability Coordinator shall test its primary Control Center data exchange
capabilities specified in Requirement R2 for redundant functionality at least once
every 90 calendar days. If the test is unsuccessful, the Reliability Coordinator shall
Page 1 of 13
IRO-002-5 - Reliability Coordination - Monitoring and Analysis
initiate action within two hours to restore redundant functionality. [Violation Risk
Factor: Medium ] [Time Horizon: Operations Planning]
M3. Each Reliability Coordinator shall have, and provide upon request, evidence that it
tested its primary Control Center data exchange capabilities specified in Requirement
R2 for redundant functionality, or experienced an event that demonstrated the
redundant functionality; and if the test was unsuccessful, initiated action within two
hours to restore redundant functionality as specified in Requirement R3. Evidence
could include, but is not limited to: dated and time-stamped test records, operator
logs, voice recordings, or electronic communications.
R4.
Each Reliability Coordinator shall provide its System Operators with the authority to
approve planned outages and maintenance of its telecommunication, monitoring and
analysis capabilities. [Violation Risk Factor: High] [Time Horizon: Operations Planning,
Same-Day Operations, Real-time Operations]
M4. Each Reliability Coordinator shall have, and provide upon request evidence that could
include, but is not limited to, a documented procedure or equivalent evidence that
will be used to confirm that the Reliability Coordinator has provided its System
Operators with the authority to approve planned outages and maintenance of its
telecommunication, monitoring and analysis capabilities.
R5.
Each Reliability Coordinator shall monitor Facilities, the status of Remedial Action
Schemes, and non-BES facilities identified as necessary by the Reliability Coordinator,
within its Reliability Coordinator Area and neighboring Reliability Coordinator Areas to
identify any System Operating Limit exceedances and to determine any
Interconnection Reliability Operating Limit exceedances within its Reliability
Coordinator Area. [Violation Risk Factor: High] [Time Horizon: Real-Time Operations]
M5. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, Energy Management System description documents,
computer printouts, SCADA data collection, or other equivalent evidence that will be
used to confirm that it has monitored Facilities, the status of Remedial Action
Schemes, and non-BES facilities identified as necessary by the Reliability Coordinator,
within its Reliability Coordinator Area and neighboring Reliability Coordinator Areas to
identify any System Operating Limit exceedances and to determine any
Interconnection Reliability Operating Limit exceedances within its Reliability
Coordinator Area.
R6.
Each Reliability Coordinator shall have monitoring systems that provide information
utilized by the Reliability Coordinator’s operating personnel, giving particular
emphasis to alarm management and awareness systems, automated data transfers,
and synchronized information systems, over a redundant infrastructure. [Violation
Risk Factor: High] [Time Horizon: Real-time Operations]
Page 2 of 13
IRO-002-5 - Reliability Coordination - Monitoring and Analysis
M6. The Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, Energy Management System description documents,
computer printouts, SCADA data collection, or other equivalent evidence that will be
used to confirm that it has monitoring systems consistent with the requirement.
C. Compliance
1.
Compliance Monitoring Process
1.1. Compliance Enforcement Authority:
“Compliance Enforcement Authority” means NERC or the Regional Entity, or any
entity as otherwise designated by an Applicable Governmental Authority, in
their respective roles of monitoring and/or enforcing compliance with
mandatory and enforceable Reliability Standards in their respective
jurisdictions.
1.2. Evidence Retention:
The following evidence retention period(s) identify the period of time an entity
is required to retain specific evidence to demonstrate compliance. For instances
where the evidence retention period specified below is shorter than the time
since the last audit, the Compliance Enforcement Authority may ask an entity to
provide other evidence to show that it was compliant for the full-time period
since the last audit.
The applicable entity shall keep data or evidence to show compliance as
identified below unless directed by its Compliance Enforcement Authority to
retain specific evidence for a longer period of time as part of an investigation.
•
•
•
The Reliability Coordinator shall retain its current, in force document and
any documents in force for the current year and previous calendar year for
Requirements R1, R2, and R4 and Measures M1, M2, and M4.
The Reliability Coordinator shall retain evidence for Requirement R3 and
Measure M3 for the most recent 12 calendar months, with the exception of
operator logs and voice recordings which shall be retained for a minimum of
90 calendar days.
The Reliability Coordinator shall keep data or evidence for Requirements R5
and R6 and Measures M5 and M6 for the current calendar year and one
previous calendar year.
1.3. Compliance Monitoring and Enforcement Program
As defined in the NERC Rules of Procedure, “Compliance Monitoring and
Enforcement Program” refers to the identification of the processes that will be
used to evaluate data or information for the purpose of assessing performance
or outcomes with the associated Reliability Standard.
Page 3 of 13
IRO-002-5 - Reliability Coordination - Monitoring and Analysis
Violation Severity Levels
R#
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
R1.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with one applicable entity, or
5% or less of the applicable
entities, whichever is greater.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with two applicable entities, or
more than 5% or less than or
equal to 10% of the applicable
entities, whichever is greater.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with three applicable entities,
or more than 10% or less than
or equal to 15% of the
applicable entities, whichever is
greater.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with four or more applicable
entities or greater than 15% of
the applicable entities,
whichever is greater.
R2.
N/A
N/A
The Reliability Coordinator had
data exchange capabilities with
its Balancing Authorities and
Transmission Operators, and
with other entities it deems
necessary, for performing Realtime monitoring and Real-time
Assessments, but did not have
redundant and diversely routed
data exchange infrastructure
within the Reliability
Coordinator's primary Control
Center, as specified in the
requirement.
The Reliability Coordinator did
not have data exchange
capabilities with its Balancing
Authorities and Transmission
Operators, and with other
entities it deems necessary, for
performing Real-time
monitoring and Real-time
Assessments as specified in the
requirement.
R3.
The Reliability Coordinator
tested its primary Control
The Reliability Coordinator
tested its primary Control
The Reliability Coordinator
tested its primary Control
The Reliability Coordinator
tested its primary Control
Page 4 of 13
IRO-002-5 - Reliability Coordination - Monitoring and Analysis
R#
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 90 calendar days but less
than or equal to 120 calendar
days since the previous test;
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 120 calendar days but less
than or equal to 150 calendar
days since the previous test;
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 150 calendar days but less
than or equal to 180 calendar
days since the previous test;
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 180 calendar days since
the previous test;
OR
OR
OR
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in
more than 2 hours and less
than or equal to 4 hours.
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in
more than 4 hours and less
than or equal to 6 hours.
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in
more than 6 hours and less
than or equal to 8 hours.
OR
The Reliability Coordinator did
not test its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality;
OR
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
did not initiate action within 8
hours to restore the redundant
functionality.
Page 5 of 13
IRO-002-5 - Reliability Coordination - Monitoring and Analysis
R#
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
R4.
N/A
N/A
N/A
The Reliability Coordinator
failed to provide its System
Operator with the authority to
approve planned outages and
maintenance of its
telecommunication, monitoring
and analysis capabilities.
R5.
N/A
N/A
N/A
The Reliability Coordinator did
not monitor Facilities, the
status of Remedial Action
Schemes, and non-BES facilities
identified as necessary by the
Reliability Coordinator, within
its Reliability Coordinator Area
and neighboring Reliability
Coordinator Areas to identify
any System Operating Limit
exceedances and to determine
any Interconnection Reliability
Operating Limit exceedances
within its Reliability
Coordinator Area.
R6.
N/A
N/A
N/A
The Reliability Coordinator did
not have monitoring systems
that provide information
utilized by the Reliability
Coordinator’s operating
Page 6 of 13
IRO-002-5 - Reliability Coordination - Monitoring and Analysis
R#
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
personnel, giving particular
emphasis to alarm
management and awareness
systems, automated data
transfers, and synchronized
information systems, over a
redundant infrastructure.
Page 7 of 13
IRO-002-5 - Reliability Coordination - Monitoring and Analysis
D. Regional Variances
None.
E. Associated Documents
The Implementation Plan and other project documents can be found on the project page.
Page 8 of 13
IRO-002-5 - Reliability Coordination - Monitoring and Analysis
Version History
Version
Date
Action
0
April 1,
2005
0
August 8,
2005
1
November Adopted by Board of Trustees
1, 2006
Change Tracking
Effective Date
New
Removed “Proposed” from Effective
Date
Errata
Revised
1
April 4,
2007
Replaced Levels of Non-compliance
with the Feb 28, BOT approved
Violation Severity Levels (VSLs)
Corrected typographical errors in
BOT approved version of VSLs
Revised to add missing
measures and compliance
elements
2
October
17, 2008
Adopted by NERC Board of Trustees
Deleted R2, M3 and
associated compliance
elements as conforming
changes associated with
approval of IRO-010-1.
Revised as part of IROL
Project
2
March 17, Order issued by FERC approving IRO2011
002-2 (approval effective 5/23/11)
FERC approval
2
February
24, 2014
Updated VSLs based on June 24,
2013 approval.
VSLs revised
3
July 25,
2011
Revised under Project 2006-06
Revised
3
August 4,
2011
Approved by Board of Trustees
Retired R1-R8 under Project
2006-06.
4
November Approved by Board of Trustees
13, 2014
Revisions under Project
2014-03
4
November FERC approved IRO-002-4. Docket
19, 2015 No. RM15-16-000
FERC approval
5
February
9, 2017
Adopted by Board of Trustees
Revised
Page 9 of 13
IRO-002-5 - Reliability Coordination - Monitoring and Analysis
5
April 17,
2017
FERC letter Order approved IRO-0025. Docket No. RD17-4-000
Page 10 of 13
Supplemental Material
Guidelines and Technical Basis
None
Page 11 of 13
Supplemental Material
Rationale
During development of IRO-002-5, text boxes are embedded within the standard to explain the
rationale for various parts of the standard. Upon Board adoption of IRO-002-5, the text from
the rationale text boxes will be moved to this section.
Rationale text from the development of IRO-002-4 in Project 2014-03 follows. Additional
information can be found on the Project 2014-03 project page.
Changes made to the proposed definitions were made in order to respond to issues raised in
NOPR paragraphs 55, 73, and 74 dealing with analysis of SOLs in all time horizons, questions on
Protection Systems and Special Protection Systems in NOPR paragraph 78, and
recommendations on phase angles from the SW Outage Report (recommendation 27). The
intent of such changes is to ensure that Real-time Assessments contain sufficient details to
result in an appropriate level of situational awareness. Some examples include: 1) analyzing
phase angles which may result in the implementation of an Operating Plan to adjust generation
or curtail transactions so that a Transmission facility may be returned to service, or 2)
evaluating the impact of a modified Contingency resulting from the status change of a Special
Protection Scheme from enabled/in-service to disabled/out-of-service.
Rationale for Requirements:
The data exchange elements of Requirements R1 and R2 from approved IRO-002-2 have been
added back into proposed IRO-002-4 in order to ensure that there is no reliability gap. The
Project 2014-03 SDT found no proposed requirements in the current project that covered the
issue. Voice communication is covered in proposed COM-001-2 but data communications needs
to remain in IRO-002-4 as it is not covered in proposed COM-001-2. Staffing of communications
and facilities in corresponding requirements from IRO-002-2 is addressed in approved PER-0042, Requirement R1 and has been deleted from this draft.
Rationale for R2:
Requirement R2 from IRO-002-3 has been deleted because approved EOP-008-1, Requirement
R1, part 1.6.2 addresses redundancy and back-up concerns for outages of analysis tools. New
Requirement R4 (R6 in IRO-002-5) has been added to address NOPR paragraphs 96 and 97:
“…As we explain above, the reliability coordinator’s obligation to monitor SOLs is important to
reliability because a SOL can evolve into an IROL during deteriorating system conditions, and for
potential system conditions such as this, the reliability coordinator’s monitoring of SOLs provides
a necessary backup function to the transmission operator….”
Rationale for Requirements R1 and R2:
The proposed changes address directives for redundancy and diverse routing of data exchange
capabilities (FERC Order No. 817 Para 47).
Redundant and diversely routed data exchange capabilities consist of data exchange
infrastructure components (e.g., switches, routers, servers, power supplies, and network
cabling and communication paths between these components in the primary Control Center for
the exchange of system operating data) that will provide continued functionality despite failure
Page 12 of 13
Supplemental Material
or malfunction of an individual component within the Reliability Coordinator's (RC) primary
Control Center. Redundant and diversely routed data exchange capabilities preclude single
points of failure in primary Control Center data exchange infrastructure from halting the flow of
Real-time data. Requirement R2 does not require automatic or instantaneous fail-over of data
exchange capabilities. Redundancy and diverse routing may be achieved in various ways
depending on the arrangement of the infrastructure or hardware within the RC's primary
Control Center.
The reliability objective of redundancy is to provide for continued data exchange functionality
during outages, maintenance, or testing of data exchange infrastructure. For periods of planned
or unplanned outages of individual data exchange components, the proposed requirements do
not require additional redundant data exchange infrastructure components solely to provide
for redundancy.
Infrastructure that is not within the RC's primary Control Center is not addressed by the
proposed requirement.
Rationale for Requirement R3:
The revised requirement addresses directives for testing of data exchange capabilities used in
primary Control Centers (FERC Order No. 817 Para 51).
A test for redundant functionality demonstrates that data exchange capabilities will continue to
operate despite the malfunction or failure of an individual component (e.g., switches, routers,
servers, power supplies, and network cabling and communication paths between these
components in the primary Control Center for the exchange of system operating data). An
entity's testing practices should, over time, examine the various failure modes of its data
exchange capabilities. When an actual event successfully exercises the redundant functionality,
it can be considered a test for the purposes of the proposed requirement.
Rationale for R4 (R6 in IRO-002-5):
The requirement was added back from approved IRO-002-2 as the Project 2014-03 SDT found
no proposed requirements that covered the issues.
Page 13 of 13
Attachment C1
Clean Proposed as Posted
WECC-0135 IRO-002-5
RC - Monitoring and Analysis - RV
Overview
As the Western Interconnection moves to a multi-Reliability Coordinator (RC) environment, focused
coordination of those RCs will become critical. This filing is designed to ensure coordination between
each of those RCs by creating a WECC Regional Variance (RV) to IRO-002-5, Reliability Coordination –
Monitoring and Analysis (RCMA).
This filing does not change any part of the underlying standard. Only the proposed RV and the
associated compliance components will be offered for comment. Proposed changes to the existing body
of the standard will not be considered.
Once finalized, the proposed language will be renumbered per NERC’s numbering nomenclature for
RVs and inserted into the existing standard (RCMA). An example of a WECC RV can be seen in VAR001-4.1 — Voltage and Reactive Control Compliance, Section D Regional Variances.
The following language is offered for comment as the proposed RV, Posting 2.
Purpose
To develop a methodology that creates models for performing Operational Planning Analyses and
Real-time Assessments.
Proposed Regional Variance
Applicability
As used in this WECC Regional Variance, Reliability Coordinator is specific to those Reliability
Coordinators providing Reliability Coordinator service(s) to entities operating within the Western
Interconnection, regardless of where the Reliability Coordinator may be located.
Requirement and Measures
RX1.
Each Reliability Coordinator shall, in coordination with other Reliability Coordinators, develop
a common Interconnection-wide methodology to determine the modeling and monitoring of
BES and non-BES Elements that are internal and external to its Reliability Coordinator Area,
necessary for providing operational awareness of the impacts on Bulk Electric System Facilities
within its Reliability Coordinator Area, including at a minimum: ([Violation Risk Factor: High]
[Time Horizon: Operations Planning])
155 Nort h 400 West | Suit e 200 | Salt Lake Cit y, Ut ah 84103
www. we cc.org
Attachment C1
1.1.
A method for development, maintenance, and periodic review of a Western
Interconnection-wide reference model to serve as the baseline from which Reliability
Coordinator’s operational models are derived;
1.2
The impacts of Inter-area oscillations;
1.3
A method to determine Contingencies included in analyses and assessments;
1.4
A method to determine Remedial Action Schemes included in analyses and assessments;
1.5
A method to determine forecast data included in analyses and assessments; and
1.6
A method for the validation and periodic review of the Reliability Coordinator’s
operational model for steady state and dynamic/oscillatory system response.
MX1. Each Reliability Coordinator will have evidence that it developed a common Western
Interconnection-wide methodology, addressing modeling and monitoring, in coordination with
other Reliability Coordinators, that includes the features required in RX1.
RX2.
Each Reliability Coordinator shall use the methodology developed in RX1. ([Violation Risk
Factor: High] [Time Horizon: Operations Planning])
MX2. Each Reliability Coordinator will have evidence that it uses the methodology developed in RX1,
as required in RX2 above.
Compliance
A. Compliance
1.2 Evidence Retention:
•
The Reliability Coordinator shall keep data or evidence for Requirements R5, R6, and the
WECC Regional Variance, and Measures M5, M6, and the WECC Regional Variance for the
current calendar year and one previous calendar year.
Violation Severity Levels for the WECC Regional Variance
R#
RX1
Lower VSL
Moderate VSL
High VSL
Severe VSL
The Reliability Coordinator
did not develop the
methodology as required in
RX1.
2
Attachment C1
Violation Severity Levels for the WECC Regional Variance
R#
RX2
Lower VSL
Moderate VSL
High VSL
Severe VSL
The Reliability Coordinator
did not implement the
methodology as required in
RX2.
3
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
A. Introduction
1.
Title:
Reliability Coordination – Monitoring and Analysis
2.
Number:
IRO-002-6
3.
Purpose: To provide System Operators with the capabilities necessary to monitor
and analyze data needed to perform their reliability functions.
4.
Applicability:
4.1. Functional Entities:
4.1.1. Reliability Coordinators
5.
Effective Date: See Implementation Plan
B. Requirements and Measures
R1.
Each Reliability Coordinator shall have data exchange capabilities with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
for it to perform its Operational Planning Analyses. [Violation Risk Factor: Medium]
[Time Horizon: Operations Planning]
M1. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, a document that lists its data exchange capabilities with
its Balancing Authorities and Transmission Operators, and with other entities it deems
necessary, for it to perform its Operational Planning Analyses.
R2.
Each Reliability Coordinator shall have data exchange capabilities, with redundant and
diversely routed data exchange infrastructure within the Reliability Coordinator's
primary Control Center, for the exchange of Real-time data with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
for performing its Real-time monitoring and Real-time Assessments. [Violation Risk
Factor: High] [Time Horizon: Same-Day Operations, Real-time Operations]
M2. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, system specifications, system diagrams, or other
documentation that lists its data exchange capabilities, including redundant and
diversely routed data exchange infrastructure within the Reliability Coordinator's
primary Control Center, for the exchange of Real-time data with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
as specified in the requirement.
R3.
Each Reliability Coordinator shall test its primary Control Center data exchange
capabilities specified in Requirement R2 for redundant functionality at least once
every 90 calendar days. If the test is unsuccessful, the Reliability Coordinator shall
initiate action within two hours to restore redundant functionality. [Violation Risk
Factor: Medium ] [Time Horizon: Operations Planning]
Page 1 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
M3. Each Reliability Coordinator shall have, and provide upon request, evidence that it
tested its primary Control Center data exchange capabilities specified in Requirement
R2 for redundant functionality, or experienced an event that demonstrated the
redundant functionality; and if the test was unsuccessful, initiated action within two
hours to restore redundant functionality as specified in Requirement R3. Evidence
could include, but is not limited to: dated and time-stamped test records, operator
logs, voice recordings, or electronic communications.
R4.
Each Reliability Coordinator shall provide its System Operators with the authority to
approve planned outages and maintenance of its telecommunication, monitoring and
analysis capabilities. [Violation Risk Factor: High] [Time Horizon: Operations Planning,
Same-Day Operations, Real-time Operations]
M4. Each Reliability Coordinator shall have, and provide upon request evidence that could
include, but is not limited to, a documented procedure or equivalent evidence that
will be used to confirm that the Reliability Coordinator has provided its System
Operators with the authority to approve planned outages and maintenance of its
telecommunication, monitoring and analysis capabilities.
R5.
Each Reliability Coordinator shall monitor Facilities, the status of Remedial Action
Schemes, and non-BES facilities identified as necessary by the Reliability Coordinator,
within its Reliability Coordinator Area and neighboring Reliability Coordinator Areas to
identify any System Operating Limit exceedances and to determine any
Interconnection Reliability Operating Limit exceedances within its Reliability
Coordinator Area. [Violation Risk Factor: High] [Time Horizon: Real-Time Operations]
M5. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, Energy Management System description documents,
computer printouts, SCADA data collection, or other equivalent evidence that will be
used to confirm that it has monitored Facilities, the status of Remedial Action
Schemes, and non-BES facilities identified as necessary by the Reliability Coordinator,
within its Reliability Coordinator Area and neighboring Reliability Coordinator Areas to
identify any System Operating Limit exceedances and to determine any
Interconnection Reliability Operating Limit exceedances within its Reliability
Coordinator Area.
R6.
Each Reliability Coordinator shall have monitoring systems that provide information
utilized by the Reliability Coordinator’s operating personnel, giving particular
emphasis to alarm management and awareness systems, automated data transfers,
and synchronized information systems, over a redundant infrastructure. [Violation
Risk Factor: High] [Time Horizon: Real-time Operations]
M6. The Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, Energy Management System description documents,
computer printouts, SCADA data collection, or other equivalent evidence that will be
used to confirm that it has monitoring systems consistent with the requirement.
Page 2 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
C. Compliance
1.
Compliance Monitoring Process
1.1. Compliance Enforcement Authority:
“Compliance Enforcement Authority” means NERC or the Regional Entity, or any
entity as otherwise designated by an Applicable Governmental Authority, in
their respective roles of monitoring and/or enforcing compliance with
mandatory and enforceable Reliability Standards in their respective
jurisdictions.
1.2. Evidence Retention:
The following evidence retention period(s) identify the period of time an entity
is required to retain specific evidence to demonstrate compliance. For instances
where the evidence retention period specified below is shorter than the time
since the last audit, the Compliance Enforcement Authority may ask an entity to
provide other evidence to show that it was compliant for the full-time period
since the last audit.
The applicable entity shall keep data or evidence to show compliance as
identified below unless directed by its Compliance Enforcement Authority to
retain specific evidence for a longer period of time as part of an investigation.
•
•
•
The Reliability Coordinator shall retain its current, in force document and
any documents in force for the current year and previous calendar year for
Requirements R1, R2, and R4 and Measures M1, M2, and M4.
The Reliability Coordinator shall retain evidence for Requirement R3 and
Measure M3 for the most recent 12 calendar months, with the exception of
operator logs and voice recordings which shall be retained for a minimum of
90 calendar days.
The Reliability Coordinator shall keep data or evidence for Requirements R5
and R6 and Measures M5 and M6 for the current calendar year and one
previous calendar year.
1.3. Compliance Monitoring and Enforcement Program
As defined in the NERC Rules of Procedure, “Compliance Monitoring and
Enforcement Program” refers to the identification of the processes that will be
used to evaluate data or information for the purpose of assessing performance
or outcomes with the associated Reliability Standard.
Page 3 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
Violation Severity Levels
R#
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
R1.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with one applicable entity, or
5% or less of the applicable
entities, whichever is greater.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with two applicable entities, or
more than 5% or less than or
equal to 10% of the applicable
entities, whichever is greater.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with three applicable entities,
or more than 10% or less than
or equal to 15% of the
applicable entities, whichever is
greater.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with four or more applicable
entities or greater than 15% of
the applicable entities,
whichever is greater.
R2.
N/A
N/A
The Reliability Coordinator had
data exchange capabilities with
its Balancing Authorities and
Transmission Operators, and
with other entities it deems
necessary, for performing Realtime monitoring and Real-time
Assessments, but did not have
redundant and diversely routed
data exchange infrastructure
within the Reliability
Coordinator's primary Control
Center, as specified in the
requirement.
The Reliability Coordinator did
not have data exchange
capabilities with its Balancing
Authorities and Transmission
Operators, and with other
entities it deems necessary, for
performing Real-time
monitoring and Real-time
Assessments as specified in the
requirement.
R3.
The Reliability Coordinator
tested its primary Control
Center data exchange
The Reliability Coordinator
tested its primary Control
Center data exchange
The Reliability Coordinator
tested its primary Control
Center data exchange
The Reliability Coordinator
tested its primary Control
Center data exchange
Page 4 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
R#
R4.
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 90 calendar days but less
than or equal to 120 calendar
days since the previous test;
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 120 calendar days but less
than or equal to 150 calendar
days since the previous test;
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 150 calendar days but less
than or equal to 180 calendar
days since the previous test;
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 180 calendar days since
the previous test;
OR
OR
OR
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in
more than 2 hours and less
than or equal to 4 hours.
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in
more than 4 hours and less
than or equal to 6 hours.
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in
more than 6 hours and less
than or equal to 8 hours.
N/A
N/A
N/A
OR
The Reliability Coordinator did
not test its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality;
OR
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
did not initiate action within 8
hours to restore the redundant
functionality.
The Reliability Coordinator
failed to provide its System
Operator with the authority to
approve planned outages and
Page 5 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
R#
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
maintenance of its
telecommunication, monitoring
and analysis capabilities.
R5.
N/A
N/A
N/A
The Reliability Coordinator did
not monitor Facilities, the
status of Remedial Action
Schemes, and non-BES facilities
identified as necessary by the
Reliability Coordinator, within
its Reliability Coordinator Area
and neighboring Reliability
Coordinator Areas to identify
any System Operating Limit
exceedances and to determine
any Interconnection Reliability
Operating Limit exceedances
within its Reliability
Coordinator Area.
R6.
N/A
N/A
N/A
The Reliability Coordinator did
not have monitoring systems
that provide information
utilized by the Reliability
Coordinator’s operating
personnel, giving particular
emphasis to alarm
management and awareness
systems, automated data
transfers, and synchronized
Page 6 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
R#
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
information systems, over a
redundant infrastructure.
Page 7 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
D. Regional Variance
A. Regional Variance for the Western Electricity Coordinating Council Region
The following Interconnection-wide variance shall be applicable in the Western Electricity
Coordinating Council (WECC) region.
Purpose
To develop a methodology that creates models for performing Operational Planning
Analyses and Real-time Assessments.
Applicability
As used in this WECC Regional Variance, Reliability Coordinator is specific to those Reliability
Coordinators providing Reliability Coordinator service(s) to entities operating within the
Western Interconnection, regardless of where the Reliability Coordinator may be located.
Requirements and Measures
D.A.7.
Each Reliability Coordinator shall, in coordination with other Reliability
Coordinators, develop a common Interconnection-wide methodology to
determine the modeling and monitoring of BES and non-BES Elements that are
internal and external to its Reliability Coordinator Area, necessary for providing
operational awareness of the impacts on Bulk Electric System Facilities within its
Reliability Coordinator Area, including at a minimum: ([Violation Risk Factor:
High] [Time Horizon: Operations Planning])
D.A.7.1.
A method for development, maintenance, and periodic review of
a Western Interconnection-wide reference model to serve as the
baseline from which Reliability Coordinator’s operational models
are derived;
D.A.7.2
The impacts of Inter-area oscillations;
D.A.7.3
A method to determine Contingencies included in analyses and
assessments;
D.A.7.4
A method to determine Remedial Action Schemes included in
analyses and assessments;
D.A.7.5
A method to determine forecast data included in analyses and
assessments; and
D.A.7.6
A method for the validation and periodic review of the Reliability
Coordinator’s operational model for steady state and
dynamic/oscillatory system response.
M.D.A.7. Each Reliability Coordinator will have evidence that it developed a common
Western Interconnection-wide methodology, addressing modeling and
Page 8 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
monitoring, in coordination with other Reliability Coordinators, that includes the
features required in D.A.7.
D.A.8.
Each Reliability Coordinator shall use the methodology developed in D.A.7.
([Violation Risk Factor: High] [Time Horizon: Operations Planning])
M.D.A.8. Each Reliability Coordinator will have evidence that it uses the methodology
developed in D.A.7., as required in D.A.8. above.
Compliance
Evidence Retention:
•
The Reliability Coordinator shall keep data or evidence for Requirements R5, R6, and
the WECC Regional Variance, and Measures M5, M6, and the WECC Regional
Variance for the current calendar year and one previous calendar year.
Violation Severity Levels for the WECC Regional Variance
R#
Lower VSL
Moderate VSL
High VSL
Severe VSL
D.A.7.
The Reliability Coordinator
did not develop the
methodology as required in
D.A.7.
D.A.8.
The Reliability Coordinator
did not implement the
methodology as required in
D.A.8.
E. Associated Documents
The Implementation Plan and other project documents can be found on the project page.
Page 9 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
Version History
Version
Date
Action
0
April 1,
2005
0
August 8,
2005
1
November Adopted by Board of Trustees
1, 2006
Change Tracking
Effective Date
New
Removed “Proposed” from Effective
Date
Errata
Revised
1
April 4,
2007
Replaced Levels of Non-compliance
with the Feb 28, BOT approved
Violation Severity Levels (VSLs)
Corrected typographical errors in
BOT approved version of VSLs
Revised to add missing
measures and compliance
elements
2
October
17, 2008
Adopted by NERC Board of Trustees
Deleted R2, M3 and
associated compliance
elements as conforming
changes associated with
approval of IRO-010-1.
Revised as part of IROL
Project
2
March 17, Order issued by FERC approving IRO2011
002-2 (approval effective 5/23/11)
FERC approval
2
February
24, 2014
Updated VSLs based on June 24,
2013 approval.
VSLs revised
3
July 25,
2011
Revised under Project 2006-06
Revised
3
August 4,
2011
Approved by Board of Trustees
Retired R1-R8 under Project
2006-06.
4
November Approved by Board of Trustees
13, 2014
Revisions under Project
2014-03
4
November FERC approved IRO-002-4. Docket
19, 2015 No. RM15-16-000
FERC approval
5
February
9, 2017
Adopted by Board of Trustees
5
April 17,
2017
FERC letter Order approved IRO-0025. Docket No. RD17-4-000
Revised
Page 10 of 13
IRO-002-6 - Reliability Coordination - Monitoring and Analysis
6
WECC Regional Variance
Page 11 of 13
Supplemental Material
Rationale
During development of IRO-002-5, text boxes are embedded within the standard to explain the
rationale for various parts of the standard. Upon Board adoption of IRO-002-5, the text from
the rationale text boxes will be moved to this section.
Rationale text from the development of IRO-002-4 in Project 2014-03 follows. Additional
information can be found on the Project 2014-03 project page.
Changes made to the proposed definitions were made in order to respond to issues raised in
NOPR paragraphs 55, 73, and 74 dealing with analysis of SOLs in all time horizons, questions on
Protection Systems and Special Protection Systems in NOPR paragraph 78, and
recommendations on phase angles from the SW Outage Report (recommendation 27). The
intent of such changes is to ensure that Real-time Assessments contain sufficient details to
result in an appropriate level of situational awareness. Some examples include: 1) analyzing
phase angles which may result in the implementation of an Operating Plan to adjust generation
or curtail transactions so that a Transmission facility may be returned to service, or 2)
evaluating the impact of a modified Contingency resulting from the status change of a Special
Protection Scheme from enabled/in-service to disabled/out-of-service.
Rationale for Requirements:
The data exchange elements of Requirements R1 and R2 from approved IRO-002-2 have been
added back into proposed IRO-002-4 in order to ensure that there is no reliability gap. The
Project 2014-03 SDT found no proposed requirements in the current project that covered the
issue. Voice communication is covered in proposed COM-001-2 but data communications needs
to remain in IRO-002-4 as it is not covered in proposed COM-001-2. Staffing of communications
and facilities in corresponding requirements from IRO-002-2 is addressed in approved PER-0042, Requirement R1 and has been deleted from this draft.
Rationale for R2:
Requirement R2 from IRO-002-3 has been deleted because approved EOP-008-1, Requirement
R1, part 1.6.2 addresses redundancy and back-up concerns for outages of analysis tools. New
Requirement R4 (R6 in IRO-002-5) has been added to address NOPR paragraphs 96 and 97:
“…As we explain above, the reliability coordinator’s obligation to monitor SOLs is important to
reliability because a SOL can evolve into an IROL during deteriorating system conditions, and for
potential system conditions such as this, the reliability coordinator’s monitoring of SOLs provides
a necessary backup function to the transmission operator….”
Rationale for Requirements R1 and R2:
The proposed changes address directives for redundancy and diverse routing of data exchange
capabilities (FERC Order No. 817 Para 47).
Redundant and diversely routed data exchange capabilities consist of data exchange
infrastructure components (e.g., switches, routers, servers, power supplies, and network
cabling and communication paths between these components in the primary Control Center for
the exchange of system operating data) that will provide continued functionality despite failure
Page 12 of 13
Supplemental Material
or malfunction of an individual component within the Reliability Coordinator's (RC) primary
Control Center. Redundant and diversely routed data exchange capabilities preclude single
points of failure in primary Control Center data exchange infrastructure from halting the flow of
Real-time data. Requirement R2 does not require automatic or instantaneous fail-over of data
exchange capabilities. Redundancy and diverse routing may be achieved in various ways
depending on the arrangement of the infrastructure or hardware within the RC's primary
Control Center.
The reliability objective of redundancy is to provide for continued data exchange functionality
during outages, maintenance, or testing of data exchange infrastructure. For periods of planned
or unplanned outages of individual data exchange components, the proposed requirements do
not require additional redundant data exchange infrastructure components solely to provide
for redundancy.
Infrastructure that is not within the RC's primary Control Center is not addressed by the
proposed requirement.
Rationale for Requirement R3:
The revised requirement addresses directives for testing of data exchange capabilities used in
primary Control Centers (FERC Order No. 817 Para 51).
A test for redundant functionality demonstrates that data exchange capabilities will continue to
operate despite the malfunction or failure of an individual component (e.g., switches, routers,
servers, power supplies, and network cabling and communication paths between these
components in the primary Control Center for the exchange of system operating data). An
entity's testing practices should, over time, examine the various failure modes of its data
exchange capabilities. When an actual event successfully exercises the redundant functionality,
it can be considered a test for the purposes of the proposed requirement.
Rationale for R4 (R6 in IRO-002-5):
The requirement was added back from approved IRO-002-2 as the Project 2014-03 SDT found
no proposed requirements that covered the issues.
Page 13 of 13
IRO-002-56 - Reliability Coordination - Monitoring and Analysis
A. Introduction
1.
Title:
Reliability Coordination – Monitoring and Analysis
2.
Number:
IRO-002-56
3.
Purpose: To provide System Operators with the capabilities necessary to monitor
and analyze data needed to perform their reliability functions.
4.
Applicability:
4.1. Functional Entities:
4.1.1. Reliability Coordinators
5.
Effective Date: See Implementation Plan
B. Requirements and Measures
R1.
Each Reliability Coordinator shall have data exchange capabilities with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
for it to perform its Operational Planning Analyses. [Violation Risk Factor: Medium]
[Time Horizon: Operations Planning]
M1. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, a document that lists its data exchange capabilities with
its Balancing Authorities and Transmission Operators, and with other entities it deems
necessary, for it to perform its Operational Planning Analyses.
R2.
Each Reliability Coordinator shall have data exchange capabilities, with redundant and
diversely routed data exchange infrastructure within the Reliability Coordinator's
primary Control Center, for the exchange of Real-time data with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
for performing its Real-time monitoring and Real-time Assessments. [Violation Risk
Factor: High] [Time Horizon: Same-Day Operations, Real-time Operations]
M2. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, system specifications, system diagrams, or other
documentation that lists its data exchange capabilities, including redundant and
diversely routed data exchange infrastructure within the Reliability Coordinator's
primary Control Center, for the exchange of Real-time data with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
as specified in the requirement.
R3.
Each Reliability Coordinator shall test its primary Control Center data exchange
capabilities specified in Requirement R2 for redundant functionality at least once
every 90 calendar days. If the test is unsuccessful, the Reliability Coordinator shall
initiate action within two hours to restore redundant functionality. [Violation Risk
Factor: Medium ] [Time Horizon: Operations Planning]
Page 1 of 14
IRO-002-56 - Reliability Coordination - Monitoring and Analysis
M3. Each Reliability Coordinator shall have, and provide upon request, evidence that it
tested its primary Control Center data exchange capabilities specified in Requirement
R2 for redundant functionality, or experienced an event that demonstrated the
redundant functionality; and if the test was unsuccessful, initiated action within two
hours to restore redundant functionality as specified in Requirement R3. Evidence
could include, but is not limited to: dated and time-stamped test records, operator
logs, voice recordings, or electronic communications.
R4.
Each Reliability Coordinator shall provide its System Operators with the authority to
approve planned outages and maintenance of its telecommunication, monitoring and
analysis capabilities. [Violation Risk Factor: High] [Time Horizon: Operations Planning,
Same-Day Operations, Real-time Operations]
M4. Each Reliability Coordinator shall have, and provide upon request evidence that could
include, but is not limited to, a documented procedure or equivalent evidence that
will be used to confirm that the Reliability Coordinator has provided its System
Operators with the authority to approve planned outages and maintenance of its
telecommunication, monitoring and analysis capabilities.
R5.
Each Reliability Coordinator shall monitor Facilities, the status of Remedial Action
Schemes, and non-BES facilities identified as necessary by the Reliability Coordinator,
within its Reliability Coordinator Area and neighboring Reliability Coordinator Areas to
identify any System Operating Limit exceedances and to determine any
Interconnection Reliability Operating Limit exceedances within its Reliability
Coordinator Area. [Violation Risk Factor: High] [Time Horizon: Real-Time Operations]
M5. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, Energy Management System description documents,
computer printouts, SCADA data collection, or other equivalent evidence that will be
used to confirm that it has monitored Facilities, the status of Remedial Action
Schemes, and non-BES facilities identified as necessary by the Reliability Coordinator,
within its Reliability Coordinator Area and neighboring Reliability Coordinator Areas to
identify any System Operating Limit exceedances and to determine any
Interconnection Reliability Operating Limit exceedances within its Reliability
Coordinator Area.
R6.
Each Reliability Coordinator shall have monitoring systems that provide information
utilized by the Reliability Coordinator’s operating personnel, giving particular
emphasis to alarm management and awareness systems, automated data transfers,
and synchronized information systems, over a redundant infrastructure. [Violation
Risk Factor: High] [Time Horizon: Real-time Operations]
M6. The Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, Energy Management System description documents,
computer printouts, SCADA data collection, or other equivalent evidence that will be
used to confirm that it has monitoring systems consistent with the requirement.
Page 2 of 14
IRO-002-56 - Reliability Coordination - Monitoring and Analysis
C. Compliance
1.
Compliance Monitoring Process
1.1. Compliance Enforcement Authority:
“Compliance Enforcement Authority” means NERC or the Regional Entity, or any
entity as otherwise designated by an Applicable Governmental Authority, in
their respective roles of monitoring and/or enforcing compliance with
mandatory and enforceable Reliability Standards in their respective
jurisdictions.
1.2. Evidence Retention:
The following evidence retention period(s) identify the period of time an entity
is required to retain specific evidence to demonstrate compliance. For instances
where the evidence retention period specified below is shorter than the time
since the last audit, the Compliance Enforcement Authority may ask an entity to
provide other evidence to show that it was compliant for the full-time period
since the last audit.
The applicable entity shall keep data or evidence to show compliance as
identified below unless directed by its Compliance Enforcement Authority to
retain specific evidence for a longer period of time as part of an investigation.
•
•
•
The Reliability Coordinator shall retain its current, in force document and
any documents in force for the current year and previous calendar year for
Requirements R1, R2, and R4 and Measures M1, M2, and M4.
The Reliability Coordinator shall retain evidence for Requirement R3 and
Measure M3 for the most recent 12 calendar months, with the exception of
operator logs and voice recordings which shall be retained for a minimum of
90 calendar days.
The Reliability Coordinator shall keep data or evidence for Requirements R5
and R6 and Measures M5 and M6 for the current calendar year and one
previous calendar year.
1.3. Compliance Monitoring and Enforcement Program
As defined in the NERC Rules of Procedure, “Compliance Monitoring and
Enforcement Program” refers to the identification of the processes that will be
used to evaluate data or information for the purpose of assessing performance
or outcomes with the associated Reliability Standard.
Page 3 of 14
IRO-002-56 - Reliability Coordination - Monitoring and Analysis
Violation Severity Levels
R#
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
R1.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with one applicable entity, or
5% or less of the applicable
entities, whichever is greater.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with two applicable entities, or
more than 5% or less than or
equal to 10% of the applicable
entities, whichever is greater.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with three applicable entities,
or more than 10% or less than
or equal to 15% of the
applicable entities, whichever is
greater.
The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with four or more applicable
entities or greater than 15% of
the applicable entities,
whichever is greater.
R2.
N/A
N/A
The Reliability Coordinator had
data exchange capabilities with
its Balancing Authorities and
Transmission Operators, and
with other entities it deems
necessary, for performing Realtime monitoring and Real-time
Assessments, but did not have
redundant and diversely routed
data exchange infrastructure
within the Reliability
Coordinator's primary Control
Center, as specified in the
requirement.
The Reliability Coordinator did
not have data exchange
capabilities with its Balancing
Authorities and Transmission
Operators, and with other
entities it deems necessary, for
performing Real-time
monitoring and Real-time
Assessments as specified in the
requirement.
R3.
The Reliability Coordinator
tested its primary Control
Center data exchange
The Reliability Coordinator
tested its primary Control
Center data exchange
The Reliability Coordinator
tested its primary Control
Center data exchange
The Reliability Coordinator
tested its primary Control
Center data exchange
Page 4 of 14
IRO-002-56 - Reliability Coordination - Monitoring and Analysis
R#
R4.
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 90 calendar days but less
than or equal to 120 calendar
days since the previous test;
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 120 calendar days but less
than or equal to 150 calendar
days since the previous test;
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 150 calendar days but less
than or equal to 180 calendar
days since the previous test;
capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 180 calendar days since
the previous test;
OR
OR
OR
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in
more than 2 hours and less
than or equal to 4 hours.
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in
more than 4 hours and less
than or equal to 6 hours.
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in
more than 6 hours and less
than or equal to 8 hours.
N/A
N/A
N/A
OR
The Reliability Coordinator did
not test its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality;
OR
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
did not initiate action within 8
hours to restore the redundant
functionality.
The Reliability Coordinator
failed to provide its System
Operator with the authority to
approve planned outages and
Page 5 of 14
IRO-002-56 - Reliability Coordination - Monitoring and Analysis
R#
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
maintenance of its
telecommunication, monitoring
and analysis capabilities.
R5.
N/A
N/A
N/A
The Reliability Coordinator did
not monitor Facilities, the
status of Remedial Action
Schemes, and non-BES facilities
identified as necessary by the
Reliability Coordinator, within
its Reliability Coordinator Area
and neighboring Reliability
Coordinator Areas to identify
any System Operating Limit
exceedances and to determine
any Interconnection Reliability
Operating Limit exceedances
within its Reliability
Coordinator Area.
R6.
N/A
N/A
N/A
The Reliability Coordinator did
not have monitoring systems
that provide information
utilized by the Reliability
Coordinator’s operating
personnel, giving particular
emphasis to alarm
management and awareness
systems, automated data
transfers, and synchronized
Page 6 of 14
IRO-002-56 - Reliability Coordination - Monitoring and Analysis
R#
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
information systems, over a
redundant infrastructure.
Page 7 of 14
IRO-002-56 - Reliability Coordination - Monitoring and Analysis
D. Regional VariancesVariance
None.
A. Regional Variance for the Western Electricity Coordinating Council Region
The following Interconnection-wide variance shall be applicable in the Western Electricity
Coordinating Council (WECC) region.
Purpose
To develop a methodology that creates models for performing Operational Planning
Analyses and Real-time Assessments.
Applicability
As used in this WECC Regional Variance, Reliability Coordinator is specific to those Reliability
Coordinators providing Reliability Coordinator service(s) to entities operating within the
Western Interconnection, regardless of where the Reliability Coordinator may be located.
Requirements and Measures
D.A.7.
Each Reliability Coordinator shall, in coordination with other Reliability
Coordinators, develop a common Interconnection-wide methodology to
determine the modeling and monitoring of BES and non-BES Elements that are
internal and external to its Reliability Coordinator Area, necessary for providing
operational awareness of the impacts on Bulk Electric System Facilities within its
Reliability Coordinator Area, including at a minimum: ([Violation Risk Factor:
High] [Time Horizon: Operations Planning])
D.A.7.1.
A method for development, maintenance, and periodic review of
a Western Interconnection-wide reference model to serve as the
baseline from which Reliability Coordinator’s operational models
are derived;
D.A.7.2
The impacts of Inter-area oscillations;
D.A.7.3
A method to determine Contingencies included in analyses and
assessments;
D.A.7.4
A method to determine Remedial Action Schemes included in
analyses and assessments;
D.A.7.5
A method to determine forecast data included in analyses and
assessments; and
D.A.7.6
A method for the validation and periodic review of the Reliability
Coordinator’s operational model for steady state and
dynamic/oscillatory system response.
M.D.A.7. Each Reliability Coordinator will have evidence that it developed a common
Western Interconnection-wide methodology, addressing modeling and
Page 8 of 14
IRO-002-56 - Reliability Coordination - Monitoring and Analysis
monitoring, in coordination with other Reliability Coordinators, that includes the
features required in D.A.7.
D.A.8.
Each Reliability Coordinator shall use the methodology developed in D.A.7.
([Violation Risk Factor: High] [Time Horizon: Operations Planning])
M.D.A.8. Each Reliability Coordinator will have evidence that it uses the methodology
developed in D.A.7., as required in D.A.8. above.
Compliance
Evidence Retention:
•
The Reliability Coordinator shall keep data or evidence for Requirements R5, R6, and
the WECC Regional Variance, and Measures M5, M6, and the WECC Regional
Variance for the current calendar year and one previous calendar year.
Violation Severity Levels for the WECC Regional Variance
R#
Lower VSL
Moderate VSL
High VSL
Severe VSL
D.A.7.
The Reliability Coordinator
did not develop the
methodology as required in
D.A.7.
D.A.8.
The Reliability Coordinator
did not implement the
methodology as required in
D.A.8.
E. Associated Documents
The Implementation Plan and other project documents can be found on the project page.
Page 9 of 14
IRO-002-56 - Reliability Coordination - Monitoring and Analysis
Version History
Version
Date
Action
0
April 1,
2005
0
August 8,
2005
1
November Adopted by Board of Trustees
1, 2006
Change Tracking
Effective Date
New
Removed “Proposed” from Effective
Date
Errata
Revised
1
April 4,
2007
Replaced Levels of Non-compliance
with the Feb 28, BOT approved
Violation Severity Levels (VSLs)
Corrected typographical errors in
BOT approved version of VSLs
Revised to add missing
measures and compliance
elements
2
October
17, 2008
Adopted by NERC Board of Trustees
Deleted R2, M3 and
associated compliance
elements as conforming
changes associated with
approval of IRO-010-1.
Revised as part of IROL
Project
2
March 17, Order issued by FERC approving IRO2011
002-2 (approval effective 5/23/11)
FERC approval
2
February
24, 2014
Updated VSLs based on June 24,
2013 approval.
VSLs revised
3
July 25,
2011
Revised under Project 2006-06
Revised
3
August 4,
2011
Approved by Board of Trustees
Retired R1-R8 under Project
2006-06.
4
November Approved by Board of Trustees
13, 2014
Revisions under Project
2014-03
4
November FERC approved IRO-002-4. Docket
19, 2015 No. RM15-16-000
FERC approval
5
February
9, 2017
Adopted by Board of Trustees
5
April 17,
2017
FERC letter Order approved IRO-0025. Docket No. RD17-4-000
Revised
Page 10 of 14
IRO-002-56 - Reliability Coordination - Monitoring and Analysis
Guidelines and Technical Basis
None
Page 11 of 14
IRO-002-56 - Reliability Coordination - Monitoring and Analysis
6
WECC Regional Variance
Page 12 of 14
Supplemental Material
Rationale
During development of IRO-002-5, text boxes are embedded within the standard to explain the
rationale for various parts of the standard. Upon Board adoption of IRO-002-5, the text from
the rationale text boxes will be moved to this section.
Rationale text from the development of IRO-002-4 in Project 2014-03 follows. Additional
information can be found on the Project 2014-03 project page.
Changes made to the proposed definitions were made in order to respond to issues raised in
NOPR paragraphs 55, 73, and 74 dealing with analysis of SOLs in all time horizons, questions on
Protection Systems and Special Protection Systems in NOPR paragraph 78, and
recommendations on phase angles from the SW Outage Report (recommendation 27). The
intent of such changes is to ensure that Real-time Assessments contain sufficient details to
result in an appropriate level of situational awareness. Some examples include: 1) analyzing
phase angles which may result in the implementation of an Operating Plan to adjust generation
or curtail transactions so that a Transmission facility may be returned to service, or 2)
evaluating the impact of a modified Contingency resulting from the status change of a Special
Protection Scheme from enabled/in-service to disabled/out-of-service.
Rationale for Requirements:
The data exchange elements of Requirements R1 and R2 from approved IRO-002-2 have been
added back into proposed IRO-002-4 in order to ensure that there is no reliability gap. The
Project 2014-03 SDT found no proposed requirements in the current project that covered the
issue. Voice communication is covered in proposed COM-001-2 but data communications needs
to remain in IRO-002-4 as it is not covered in proposed COM-001-2. Staffing of communications
and facilities in corresponding requirements from IRO-002-2 is addressed in approved PER-0042, Requirement R1 and has been deleted from this draft.
Rationale for R2:
Requirement R2 from IRO-002-3 has been deleted because approved EOP-008-1, Requirement
R1, part 1.6.2 addresses redundancy and back-up concerns for outages of analysis tools. New
Requirement R4 (R6 in IRO-002-5) has been added to address NOPR paragraphs 96 and 97:
“…As we explain above, the reliability coordinator’s obligation to monitor SOLs is important to
reliability because a SOL can evolve into an IROL during deteriorating system conditions, and for
potential system conditions such as this, the reliability coordinator’s monitoring of SOLs provides
a necessary backup function to the transmission operator….”
Rationale for Requirements R1 and R2:
The proposed changes address directives for redundancy and diverse routing of data exchange
capabilities (FERC Order No. 817 Para 47).
Redundant and diversely routed data exchange capabilities consist of data exchange
infrastructure components (e.g., switches, routers, servers, power supplies, and network
cabling and communication paths between these components in the primary Control Center for
the exchange of system operating data) that will provide continued functionality despite failure
Page 13 of 14
Supplemental Material
or malfunction of an individual component within the Reliability Coordinator's (RC) primary
Control Center. Redundant and diversely routed data exchange capabilities preclude single
points of failure in primary Control Center data exchange infrastructure from halting the flow of
Real-time data. Requirement R2 does not require automatic or instantaneous fail-over of data
exchange capabilities. Redundancy and diverse routing may be achieved in various ways
depending on the arrangement of the infrastructure or hardware within the RC's primary
Control Center.
The reliability objective of redundancy is to provide for continued data exchange functionality
during outages, maintenance, or testing of data exchange infrastructure. For periods of planned
or unplanned outages of individual data exchange components, the proposed requirements do
not require additional redundant data exchange infrastructure components solely to provide
for redundancy.
Infrastructure that is not within the RC's primary Control Center is not addressed by the
proposed requirement.
Rationale for Requirement R3:
The revised requirement addresses directives for testing of data exchange capabilities used in
primary Control Centers (FERC Order No. 817 Para 51).
A test for redundant functionality demonstrates that data exchange capabilities will continue to
operate despite the malfunction or failure of an individual component (e.g., switches, routers,
servers, power supplies, and network cabling and communication paths between these
components in the primary Control Center for the exchange of system operating data). An
entity's testing practices should, over time, examine the various failure modes of its data
exchange capabilities. When an actual event successfully exercises the redundant functionality,
it can be considered a test for the purposes of the proposed requirement.
Rationale for R4 (R6 in IRO-002-5):
The requirement was added back from approved IRO-002-2 as the Project 2014-03 SDT found
no proposed requirements that covered the issues.
Page 14 of 14
Attachment E
Project Roadmap
WECC-0135 IRO-002-5
RC—Monitoring and Analysis—RV
Project Roadmap
Actions
Proposed Date
1.
Standard Authorization Request (SAR) Filed
June 8, 2018
2.
WECC Standards Committee (WSC) approved the SAR
June 19, 2018
3.
Drafting Team (DT) Solicitation
June 19, 2018
4.
DT Initial Roster Approved
July 19, 2018
5.
DT Meeting
August 28, 2018
6.
DT Meeting
September 11, 2018
7.
DT Meeting
September 14, 2019
8.
DT Meeting
September 18, 2018
9.
DT meeting
September 21, 2018
10.
DT meeting
September 28, 2018
11.
DT Meeting
October 5, 2018
12.
Posting 1 – Open
October 9, 2018
13.
DT Meeting
November 2, 2018
14.
Posting 2 – Closed
November 8, 2018
15.
DT Meeting
November 9, 2018
16.
DT Meeting
November 16, 2018
17.
Posting 2 – Open
November 19, 2018
18.
Posting 2 – Closed
December 19, 2018
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Attachment E
19.
DT Meeting
January 11, 2019
20.
WSC Approved for Ballot
January 17, 2019
21.
Ballot Pool – Open
January 22, 2019
22.
Ballot Pool – Closed
February 5, 2019
23.
Standards Briefing
February 6, 2019
24.
Ballot – Open
February 7, 2019
25.
Ballot - Closed
February 21, 2019
26.
WSC approves forwarding to the WECC Board of Directors
(BOD) with a request for approval
BOD approves for NERC/FERC disposition
March 5, 2019
27.
Anticipated Actions
March 6, 2019
Proposed Date
28.
Filed at NERC
TBD
29.
NERC Board of Trustees Approves
TBD
30.
NERC files at FERC
TBD
31.
FERC Approves
TBD
2
Attachment F
Implementation Plan
WECC-0135 IRO-002-5
RC—Monitoring and Analysis—RV
Implementation Plan
Standards Authorization Request (SAR)
The original SAR is located here. The SAR with expanded scope is located here. Documentation
templates have been updated for final filing.
Approvals Required
•
WECC Board of Directors
March 6, 2019
•
NERC Board of Trustees
Pending
•
FERC
Pending
Applicability
As used in this WECC Regional Variance, Reliability Coordinator is specific to those Reliability
Coordinators providing Reliability Coordinator service(s) to entities operating within the Western
Interconnection, regardless of where the Reliability Coordinator may be located.
Conforming Changes to Other Standards
No conforming changes to other standards are required.
Proposed Effective Date
The proposed effective date for the WECC Regional Variance is “The first day of the first quarter after
regulatory approval, but no sooner than January 1, 2020.”
Justification
A January 1, 2020, effective date allows time for the winding-down of Peak Reliability, the start-up of
other Reliability Coordinators, and creates a window during which the Reliability Coordinators may
create the methodology required.
Consideration of Early Compliance
Earlier compliance should not be pursued. If an earlier effective date is imposed, the time window
could encompass the active operation of multiple Reliability Coordinators for which a coordinated
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Attachment F
handoff of responsibilities had not yet occurred. Further, as proposed, the effective date allows the
Reliability Coordinators time to create the required methodology. An earlier effective date may not
accommodate that need.
Required Retirements
No other retirements are required.
2
Attachment G
Violation Risk Factors
Violation Severity Levels
WECC-0135 IRO-002-5
RC—Monitoring and Analysis—RV
Violation Risk Factors
The Violation Risk Factors (VRF) for the proposed variance are as follows:
D.R1. ([Violation Risk Factor: High] [Time Horizon: Operations Planning])
D.R2. ([Violation Risk Factor: High] [Time Horizon: Operations Planning])
After reviewing the North American Electric Reliability Corporation (NERC) Violation Risk Factors
guidelines, the WECC-0135 Drafting Team set the VRF for both proposed requirements as “High.”
The “High” rating was set because failure to complete the assigned task could “directly cause or
contribute to bulk electric system instability, separation, or a cascading sequence of failures, or could
place the bulk electric system at an unacceptable risk of instability, separation, or cascading failures.” 1
Violation Severity Levels
The Violation Severity Levels (VSL) for the proposed variance are as follows:
D.R1. Severe
D.R2. Severe
The WECC-0135 DT set a “Severe” level because the assigned task is binary. It must either be
performed or not performed. Thus, a graded level of severity is not warranted.
Violation Severity Levels for the WECC Regional Variance
D.R #
D.R1.
Lower VSL
Moderate VSL
High VSL
Severe VSL
The Reliability Coordinator
did not develop the
methodology as required in
D.R1.
D.R2.
1
The Reliability Coordinator
did not implement the
https://www.nerc.com/pa/Stand/Resources/Documents/Violation_Risk_Factors.pdf
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Attachment G
Violation Severity Levels for the WECC Regional Variance
D.R #
Lower VSL
Moderate VSL
High VSL
Severe VSL
methodology as required in
D.R2.
2
Regional Reliability Standard Submittal
Request Attachment H
Region:
Western Electricity Coordinating Council
Regional Standard Number:
IRO-002-5
Regional Standard Title:
Date Submitted:
Reliability Coordination – Monitoring and Analysis – Request
for Regional Variance
April 30, 2019
Regional Contact Name:
Steven Rueckert
Regional Contact Title:
Director of Standards
Regional Contact Telephone
Number:
(801) 883-6878
Request (check all that apply):
Retirement of WECC Regional Reliability Standard
Interpret an Existing Standard
Approval of a new standard
Addition of WECC Regional Variance to IRO-002-5.
Withdrawal of an existing standard
Urgent Action
Has this action been approved by your Board of Directors:
Yes
No
(If no please indicate date standard action is expected along with the current status (e.g., third
comment period with anticipated board approval on mm/dd/year)):
March 6, 2019, Board of Directors Resolution:
Board Resolution
Item 2. Motion: Regional Variance to IRO-002-5
1
Regional Reliability Standard Submittal Request
Resolved, that the WECC Board of Directors, acting upon the recommendation of the WECC
Standards Committee (WSC) at the meeting of the Board on March 6, 2019, hereby approves
the WECC Regional Variance to NERC Reliability Standard IRO-002-5, Reliability
Coordination—Monitoring and Analysis, as presented and attached hereunto.
Result: Approved
[Note: The purpose of the remaining questions is to provide NERC with the information needed
to file the regional standard(s) with FERC. The information provided may to a large degree be
used verbatim. It is extremely important for the entity submitting this form to provide sufficient
detail that clearly delineates the scope and justification of the request.]
Concise statement of the
basis and purpose (scope)
of request:
Due to the unique physical characteristics of the Bulk Power System
in the Western Interconnection, events in one part of the
Interconnection can have significant impacts in other parts of the
system. As WECC moves into a new business environment
transitioning from a single Reliability Coordinator (RC) to multiple
RCs, coordinated monitoring and modeling of the Western
Interconnection will become crucial. The requested Regional
Variance ensures that coordination.
Concise statement of the
justification of the
request:
See above.
2
Regional Reliability Standard Submittal Request
Attachment I
Order 672 Criteria
WECC-0135 IRO-002-5
RC—Monitoring and Analysis—RV
Introduction
The North American Electric Reliability Corporation (NERC) is responsible for ensuring that the
Reliability Standards, Violation Risk Factors (VRF), Violation Severity Levels (VSL), definitions,
Variances, and Interpretations developed by drafting teams are developed in accordance with NERC
processes. These standards must also meet NERC’s benchmarks for Reliability Standards, as well as
criteria for governmental approval.
In Federal Energy Regulatory Commission (FERC) Order No. 672, 1 FERC identified criteria that it will
use to analyze proposed Reliability Standards for approval to ensure they are just, reasonable, not
unduly discriminatory or preferential, and in the public interest. The discussion below identifies these
factors, and explains how the proposed Reliability Standard meets or exceeds the criteria.
For purposes of this filing, the use of the term Reliability Standard is synonymous with Regional
Variance, unless otherwise specified.
Designed for a Specific Goal
Proposed Reliability Standards must be designed to achieve a specified reliability goal.
The proposed Reliability Standard must address a reliability concern that falls within the requirements
of Section 215 of the Federal Power Act. That is, it must provide for the reliable operation of BulkPower System facilities. It may not extend beyond reliable operation of such facilities or apply to other
facilities. Such facilities include all those necessary for operating an interconnected electric energy
transmission network, or any portion of that network, including control systems. The proposed
Reliability Standard may apply to any design of planned additions or modifications of such facilities
that is necessary to provide for reliable operation. It may also apply to Cybersecurity protection. Order
No. 672 at P 321.
Further, NERC Reliability Standards are based on certain reliability principles that define the
foundation of reliability for North American bulk power systems. Each Reliability Standard shall
enable or support one or more of the reliability principles, thereby ensuring that each standard serves a
1
FERC Order 672
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Attachment I
purpose in support of reliability of the North American bulk power systems. Each Reliability Standard
shall also be consistent with all of the reliability principles, thereby ensuring that no standard
undermines reliability through an unintended consequence. NERC Reliability Principles 2
The purpose of the proposed WECC Regional Variance is:
“To develop a methodology that creates models for performing Operational Planning Analyses and
Real-time Assessments.”
Of the eight NERC Reliability Principles, this standard addresses Reliability Principle 1, which states:
“Interconnected bulk power systems shall be planned and operated in a coordinated manner to
perform reliably under normal and abnormal conditions as defined in the NERC Standards.”
Technically Sound
Proposed Reliability Standards must contain a technically sound method to achieve the goal.
The proposed Reliability Standard must be designed to achieve a specified reliability goal and must
contain a technically sound means to achieve this goal. Although any person may propose a topic for a
Reliability Standard to the Electric Reliability Organization (ERO), in the ERO’s process, the specific
proposed Reliability Standard should be developed initially by persons within the electric power
industry and community with a high level of technical expertise and be based on sound technical and
engineering criteria. It should be based on actual data and lessons learned from past operating
incidents, where appropriate. The process for ERO approval of a proposed Reliability Standard should
be fair and open to all interested persons. Order No. 672 at P 324.
Standard Development
This proposed Reliability Standard was developed using the NERC and Western Electricity
Coordinating Council (WECC) Reliability Standards Development Procedures (Procedures) approved
by FERC and in effect at each point in the process. Among other things, these processes include
drafting of the standard by a drafting team composed of subject matter experts (SME); biographies of
those SMEs are provided with this filing.
These processes also include repeated public iterative comment/response cycles whereby comments are
received from the industry, and responses to those comments are provided by the drafting team.
Technically Sound
The proposed Regional Variance addresses the changing business climate wherein the Western
Interconnection (WI) is transitioning from a single Reliability Coordinator (RC) located within the
2
NERC Reliability Principles
2
Attachment I
footprint of the WI to an unspecified number of RCs potentially operating anywhere across the
continent. To address this change, the proposed Regional Variance has two requirements. Each RC
providing services in the WI shall coordinate with other RCs to (1) develop and (2) use “a common
Interconnection-wide methodology to determine the modeling and monitoring of BES and non-BES
Elements” necessary for providing operational awareness of the impacts on Bulk Electric System
Facilities.
In keeping with NERC’s goal to create performance-based standards, the proposed Regional Variance
does not state how the RCs are to develop the methodology, nor does it state the required content. 3
These attributes are vested in the RCs directly, as the RC SMEs have the technical knowledge to
address the myriad permutations of modeling and monitoring.
Applicability
Proposed Reliability Standards must be applicable to users, owners, and operators of the bulk
power system, and not others.
The proposed Reliability Standard may impose a requirement on any user, owner, or operator of such
facilities, but not on others. Order No. 672 at P 322.
The Applicability section of the proposed standard is as follows:
“As used in this WECC Regional Variance, Reliability Coordinator is specific to those Reliability
Coordinators providing Reliability Coordinator service(s) to entities operating within the Western
Interconnection, regardless of where the Reliability Coordinator may be located.”
Clear and Unambiguous
Proposed Reliability Standards must be clear and unambiguous as to what is required and who is
required to comply.
The proposed Reliability Standard should be clear and unambiguous regarding what is required and
who is required to comply. Users, owners, and operators of the Bulk-Power System must know what
they are required to do to maintain reliability. Order No. 672 at P 325.
Requirement D.R1 of the proposed Regional Variance requires the RC to develop a modeling and
monitoring methodology that identifies internal and external Elements “necessary for providing
operational awareness of the impacts of Bulk Electric System Facilities.” In Posting 2 of the project, the
“Performance-Based—defines a particular reliability objective or outcome to be achieved. In its simplest form, a
results-based requirement has four components: who, under what conditions (if any), shall perform what action,
to achieve what particular result or outcome?” Results Based Standards,
https://www.nerc.com/pa/Stand/Pages/ResultsBasedStandards.aspx.
3
3
Attachment I
drafting team grappled with the question as to what constitutes that which is “necessary” for inclusion.
The drafting team’s response to that concern is as follows:
Finally, the drafting team [DT] recognizes that what constitutes “necessary” in [D.R1] is not
specifically stated in the language of the [Regional Variance]. That was intentional. The DT was
faced with the impossible task of defining the complete universe of what is “necessary” for each
RC – present and future, known and unknown, and under all circumstances.
Since that which is necessary for one RC may not be the same as that which is necessary for
another RC; and, whereas that which is necessary for one RC may vary over time, the DT
concluded the best forum for that determination was during the coordinated development of
the methodology.
In reaching this conclusion, the DT was also concerned that if “necessary” was defined in full, the final
methodology would include more information than some RCs needed. The volume of data would slow
computer processing and create the potential for models to go unsolved due to minutia (data noise).
The solution was to require the RCs to coordinate their efforts and define what was necessary for each
RC in that inclusive setting. Finally, the DT recognized that because the Regional Variance is forwardlooking, the applicable RCs have not yet been identified. Rather than limit the reliability task to the
knowledge base of the assigned DT, the Regional Variance will allow the full knowledge base of
present and future RCs to be included in the development of the modeling and monitoring
methodology.
Understandable Consequence
Proposed Reliability Standards must include clear and understandable consequences and a range of
penalties (monetary and/or non-monetary) for a violation.
The possible consequences, including range of possible penalties, for violating a proposed Reliability
Standard should be clear and understandable by those who must comply. Order No. 672 at P 326.
Violation Risk Factors (VRF) and Violation Severity Levels (VSL) were assigned for each of the two
proposed requirements.
The VRFs for the proposed variance are as follows:
D.R1. ([Violation Risk Factor: High] [Time Horizon: Operations Planning])
D.R2. ([Violation Risk Factor: High] [Time Horizon: Operations Planning])
After reviewing the NERC Violation Risk Factors guidelines, the WECC-0135 Drafting Team set the
VRF for both proposed requirements as “High.”
4
Attachment I
The “High” rating was set because failure to complete the assigned task could “directly cause or
contribute to bulk electric system instability, separation, or a cascading sequence of failures, or could
place the bulk electric system at an unacceptable risk of instability, separation, or cascading failures.”
The VSLs for the proposed variance are as follows:
D.R1. Severe
D.R2. Severe
The WECC-0135 DT set a “Severe” level because the assigned tasks are binary. It either must be
performed or not; so, a graded level of severity is not warranted.
Measurability for Compliance
Proposed Reliability Standards must identify a clear and objective criterion or measure for
compliance, so that it can be enforced in a consistent and non-preferential manner.
There should be a clear criterion or measure of whether an entity is in compliance with a proposed
Reliability Standard. It should contain or be accompanied by an objective measure of compliance so
that it can be enforced and so that enforcement can be applied in a consistent and non-preferential
manner. Order No. 672 at P 327.
The measures for D.R1 and D.R2 are as follows:
D.M1. Each Reliability Coordinator will have evidence that it developed a common Western
Interconnection-wide methodology, addressing modeling and monitoring, in coordination with
other Reliability Coordinators, that includes the features required in D.R1.
D.M2. Each Reliability Coordinator will have evidence that it uses the methodology developed in
D.R1, as required in D.R2. above.
Effective and Efficient
Proposed Reliability Standards should achieve a reliability goal effectively and efficiently - but
does not necessarily have to reflect “best practices” without regard to implementation cost.
The proposed Reliability Standard does not necessarily have to reflect the optimal method, or “best
practice,” for achieving its reliability goal without regard to implementation cost or historical regional
infrastructure design. It should however achieve its reliability goal effectively and efficiently. Order
No. 672 at P 328.
During the two posting periods, no concerns were raised regarding implementation costs or historical
regional infrastructure.
5
Attachment I
The proposed Regional Variance reaches its goals effectively and efficiently by using existing business
practices. As of this filing, forums are already created and actively pursuing the tasks required in the
variance.
Lowest Common Denominator
Proposed Reliability Standards cannot be “lowest common denominator,” i.e., cannot reflect a
compromise that does not adequately protect bulk power system reliability.
The proposed Reliability Standard must not simply reflect a compromise in the ERO’s Reliability
Standard development process based on the least effective North American practice — the so-called
“lowest common denominator” — if such practice does not adequately protect Bulk-Power System
reliability. Although the Commission will give due weight to the technical expertise of the ERO, we
will not hesitate to remand a proposed Reliability Standard if we are convinced it is not adequate to
protect reliability. Order No. 672 at P 329.
The proposed Regional Variance addresses an area not currently codified in NERC Standards.
Costs
Proposed Reliability Standards may consider costs to implement for smaller entities but not at
consequence of less than excellence in operating system reliability.
A proposed Reliability Standard may take into account the size of the entity that must comply with the
Reliability Standard and the cost to those entities of implementing the proposed Reliability Standard.
However, the ERO should not propose a “lowest common denominator” Reliability Standard that
would achieve less than excellence in operating system reliability solely to protect against reasonable
expenses for supporting this vital national infrastructure. For example, a small owner or operator of the
Bulk-Power System must bear the cost of complying with each Reliability Standard that applies to it.
Order No. 672 at P 330.
During the development of the project, the industry raised no such concerns.
Continent-wide and Regional Variations
Proposed Reliability Standards must be designed to apply throughout North America to the
maximum extent achievable with a single reliability standard while not favoring one area or
approach.
A proposed Reliability Standard should be designed to apply throughout the interconnected North
American Bulk-Power System, to the maximum extent this is achievable with a single Reliability
Standard. The proposed Reliability Standard should not be based on a single geographic or regional
model but should take into account geographic variations in grid characteristics, terrain, weather, and
6
Attachment I
other such factors; it should also take into account regional variations in the organizational and
corporate structures of transmission owners and operators, variations in generation fuel type and
ownership patterns, and regional variations in market design if these affect the proposed Reliability
Standard. Order No. 672 at P 331.
In the Order 740 Remand at P4, the Commission states that:
“Reliability Standards that the ERO proposes to the Commission may include Reliability Standards that
are proposed to the ERO by a Regional Entity… When the ERO reviews a regional Reliability Standard
that would be applicable on an interconnection-wide basis and that has been proposed by a Regional
Entity organized on an interconnection-wide basis, the ERO must rebuttably presume that the regional
Reliability Standard is just, reasonable, not unduly discriminatory or preferential, and in the public
interest. In turn, the Commission must give “due weight” to the technical expertise of the ERO and of a
Regional Entity organized on an interconnection-wide basis.”
Further, regional entities may propose Regional Reliability Standards that set more stringent reliability
requirements than the NERC Reliability Standard or cover matters not covered by an existing NERC
Reliability Standard. NERC Rules of Procedure, Section 312, Regional Reliability Standards.
The proposed Regional Variance is applicable only in the Western Interconnection.
The proposed Regional Variance covers matters not covered in an existing NERC Reliability Standard
by requiring the development of an RC-coordinated methodology for Interconnection-wide system
modeling and monitoring.
No Undue Negative Effect
Proposed reliability standards should cause no undue negative effect on competition or restriction
of the grid.
As directed by section 215 of the FPA, the Commission itself will give special attention to the effect of a
proposed Reliability Standard on competition. The ERO should attempt to develop a proposed
Reliability Standard that has no undue negative effect on competition. Among other possible
considerations, a proposed Reliability Standard should not unreasonably restrict available transmission
capability on the Bulk-Power System beyond any restriction necessary for reliability and should not
limit use of the Bulk-Power System in an unduly preferential manner. It should not create an undue
advantage for one competitor over another. Order No. 672 at P 332.
The assigned drafting team does not foresee any negative impacts on competition resulting from the
proposed Regional Variance.
During the development phase of this project, the industry raised no concerns regarding competition or
restrictive use of the grid.
7
Attachment I
Implementation of New Requirements (Effective Date)
The implementation time for the proposed Reliability Standards must be reasonable.
In considering whether a proposed Reliability Standard is just and reasonable, the Commission will
consider also the timetable for implementation of the new requirements, including how the proposal
balances any urgency in the need to implement it against the reasonableness of the time allowed for
those who must comply to develop the necessary procedures, software, facilities, staffing or other
relevant capability. Order No. 672 at P 333.
In accordance with the WECC Reliability Standards Development Procedures, an implementation plan
for the proposed Regional Variance was included with Posting 1 of this project. The Implementation
Plan is included as Attachment F of this filing.
The proposed effective date for the WECC Regional Variance is “The first day of the first quarter after
regulatory approval, but no sooner than January 1, 2020.” A January 1, 2020 effective date allows time
for the winding down of Peak Reliability (serving as the primary Interconnection RC until December
31, 2019), other RCs to start up, and creates a window during which the RCs may create the
methodology required.
Earlier compliance should not be pursued. If an earlier effective date is imposed, the time window
could encompass the active operation of multiple RCs for which a coordinated handoff of
responsibilities had not yet occurred. As proposed, the effective date allows the RCs a period to create
the required methodology. An earlier effective date may not accommodate that need. No other
retirements are required.
Fair and Open Process
The Reliability Standard development process must be open and fair.
Further, in considering whether a proposed Reliability Standard meets the legal standard of review, we
will entertain comments about whether the ERO implemented its Commission-approved Reliability
Standard development process for the development of the particular proposed Reliability Standard in a
proper manner, especially whether the process was open and fair. However, we caution that we will
not be sympathetic to arguments by interested parties that choose, for whatever reason, not to
participate in the ERO’s Reliability Standard development process if it is conducted in good faith in
accordance with the procedures approved by the Commission. Order No. 672 at P 334
WECC followed the WECC Reliability Standards Development Procedures (Procedures) approved by
FERC in effect at the time of each step in the process.
In accordance with the Procedures, all drafting team meetings are open to the public.
8
Attachment I
All drafting team meetings were announced via the WECC Standards Email List for the period
prescribed in the Procedures. Notice of the meetings was provided to NERC and posted on the WECC
Calendar along with meeting minutes.
All meetings were supported by a telephone conference bridge associated with an on-line internet
visual capability allowing all participants to see the document(s) as they were being developed.
Further, this team held an open-mic Standards Briefing prior to balloting affording the industry an
additional opportunity to have its questions addressed.
This project was posted twice for public comment at WECC.
Comments and the associated responses are currently posted on the WECC website, on the WECC-0135
project page, under the Submit and Review Comments accordion. 4 Response to Comments forms were
provided with this filing.
In addition to posting under the WECC Procedures, this project was also posted by NERC for 45-days
in accordance with NERC’s Rules of Procedure and NERC’s internal business practices.
Balanced with Other Vital Interests
Proposed Reliability Standards must balance with other vital public interests.
Finally, we understand that at times development of a proposed Reliability Standard may require that
a particular reliability goal must be balanced against other vital public interests, such as environmental,
social and other goals. We expect the ERO to explain any such balancing in its application for approval
of a proposed Reliability Standard. Order No. 672 at P 335.
WECC is not aware of any other vital public interests. No such balancing concerns were raised or
noted.
Consideration of Other Facts
Proposed Reliability Standards must consider any other relevant factors.
In considering whether a proposed Reliability Standard is just and reasonable, [FERC] will consider
[several] general factors, as well as other factors that are appropriate for the particular Reliability
Standard proposed. Order No. 672 at P 323.
WECC is not aware of any other general factors in need of consideration.
4
https://www.wecc.org/Standards/Pages/WECC-0135.aspx
9
Attachment J
Drafting Team Roster
WECC-0135 IRO-002-5
RC—Monitoring and Analysis—RV
Drafting Team Roster
Below please find a biographical snapshot for the members of the WECC-0135 IRO-002-5 Reliability
Coordination Monitoring and Analysis, Request for WECC Regional Variance Drafting Team. 1
Name
Biography
Djordje Atanackovic,
Mr. Djordje Atanackovic received his Ph.D. in electrical engineering from
BC Hydro
McGill University, Canada. In 2001, he joined British Columbia (BC) Hydro,
supporting real-time Energy Management System (EMS) network
applications. Before joining BC Hydro, Dr. Atanackovic was with Canadian
Aviation Electronics and Société national de Conseil-Lavalin, working on the
development of EMS and Distribution Management System advancednetwork applications. He is currently Engineering Division Manager of BC
Hydro's Real-time Systems department in Transmission and Distribution
System Operations. Dr. Atanackovic is a senior member of the Institute of
Electrical and Electronics Engineers (IEEE) and has authored 30 technical
papers in the field of power system operations, planning, and control.
Sean Erickson,
Mr. Erickson is a Senior Power Operations Specialist at the Western Area
Western Area Power
Power Administration. His qualifications include:
Administration
•
Two years of experience as a WECC Reliability Coordinator (2009–
2011);
•
Two years of experience as a WECC Reliability Coordination
Operations Engineer (2007–2009);
•
Four years of experience as an Operations Engineer (2011–2015);
•
Serving as the Transmission Alternate on the WECC Operating
Committee, as well as the WECC Ballot Body representative for both
WECC and NERC;
The following individuals were approved by the WECC Standards Committee (WSC) on July 19, 2018, via an
Action without a Meeting: Atanackovic, Howell, Miller, Malik. The following individuals were approved by the
WSC on August 7, 2018: Erickson, Shafeei, Subakti.
1
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Attachment J
•
Previous member of the WECC Performance Work Group during the
BAL-001 field trial evaluations;
•
Previous member of the Path Operator Task Force (POTF) (postSeptember 8, 2011, NERC/FERC findings and mitigation regarding
path operations) and the POTF Implementation Team for the
operational adoption of the POTF findings; and
Vic Howell, Peak
•
Contributor to retiring TOP-007-WECC-1a, System Operating Limits.
•
Currently serving as Manager of Modeling and Operations Support
Reliability (Peak)
Engineering at Peak Reliability.
•
Served as chair of WECC-0111 to retire TOP-007-WECC-1a.
•
Currently serving as chair of NERC Project 2015-09—Establish and
Communicate System Operating Limits.
•
Currently serving on NERC Methods for Establishing
Interconnection Reliability Operating Limits (IROL) Task Force
(MEITF).
•
Served on the WECC Path Operator Task Force. Served as vice chair
of WECC Path Operator Implementation Task Force (POITF).
•
Developed Peak's System Operating Limit (SOL) Methodology for
the Operations Horizon.
•
Very knowledgeable of Reliability Coordinator (RC) functions,
operations, and modeling; as well as NERC Reliability Standards and
standards-development processes.
Saal Malik, Peak
Reliability
Current Position: Director of Engineering, Peak Reliability
•
20 years overall industry experience
•
Nine years of experience with WECC-RC and now Peak in
Operations Planning and Real-time Operations
•
Experience with development/maintenance of following advanced
applications:
1. State Estimator,
2. Contingency Analysis,
3. Remedial Action Scheme (RAS) modeling and monitoring,
4. Voltage Stability,
5. Transient Stability, and
6. Synchro-phasor applications.
2
Attachment J
•
Extensive experience with operations coordination, training, NERC
compliance activities, SOL/IROL management, and systemmonitoring activities
•
Participated in the following drafting teams:
1. Team Chair: NERC Project 2009-02 “Real-time Monitoring and
Analysis Capabilities,”
2. Team Member: NERC Project 2016-01 “Modifications to TOP and
IRO Standards,” and
3. Team Member: NERC Compliance Guideline for Real-time
Assessments
Timothy Miller,
Tim Miller is SPP's Manager of Modeling and Data Integrity. In this role, he
Southwest Power
has responsibility for the modeling and support of the models used in SPP's
Pool (SPP)
real-time operations. His qualifications include:
•
Member of North American Electric Reliability Corporation (NERC)
Energy Management System (EMS) Working Group since 2016.
Active participant and presenter at Annual Situational Awareness
Conferences.
•
Member of North American Transmission Forum (NATF) EMS
Modeling Working Group and NATF Modeling Practices Working
Group since 2016.
•
13 years of experience building, validating, and using power system
models in various formats for both operational and long-term
planning use. Highly skilled in node-breaker modeling, maintenance,
validation, model management, and real-time support of EMS
advanced network applications.
•
Model building and maintenance experience includes SPP's efficient
model process that we use to consume models from neighboring
parties, including: Midcontinent Independent System Operator
(MISO), American Electric Power, and other SPP members and
neighbors.
•
Application support experience includes the development of SPP's
model validation processes, which have successfully satisfied NERC
Standard Requirements, Statement on Standards for Attestation
Engagements (SSAE) 16 audit standards, and internal business
controls for many years.
3
Attachment J
Phillip Shafeei,
Mr. Shafeei holds a Bachelor of Electrical Engineering and Master of
Colorado Springs
Engineering degree in Electric Power System Engineering from Rensselaer
Utility (CSU)
Polytechnic Institute, Troy, NY. From 2012 to the present, Mr. Shafeei
worked for the Colorado Springs Utility (CSU) as a Principle Power Systems
Engineer covering such issues as tariff rate design and development of
NERC Standards (MOD/TOP/FAC). Mr. Shafeei manages power system
studies, winter/summer seasons, Total Transfer Capability (TCC), outage
studies (approve-deny), weekly/next-day studies and model validations, and
the EMS model and studies. Mr. Shafeei attends the Peak RC and WECC
Board of Director meetings and was a member of the Peak RC alternative
funding.
From 2002 to 2012, he served at the New York Independent System Operator
(NYISO) as Senior Engineer addressing feasibility studies, system impact
studies, consultant interface, power flow analytics; and managed the NERC
Interchange Distribution Calendar (IDC) internal to NYISO, NYISO
representative in IDC, SDX, and Distribution Factor Working Group
(DFWG). Mr. Shafeei was the NYISO representative in the Northwest Power
and Conservation Council (NPCC) working groups, Control Performance
Working Group, and System Operational Tools Working Group. Mr. Shafeei
has 10 years of experience with industry training, data collection and
modeling, and interface with the North American Energy Standards Board.
Mr. Shafeei is experienced in distribution design, distribution management
systems, SCADA, power quality, distribution planning, and relay
coordination.
Dede Subakti,
Mr. Subakti is responsible for all operations engineering support and
California
services in California Independent System Operator (CAISO). This includes
Independent System
performing resource adequacy, seasonal operating studies, outage
Operator
coordination studies, day-ahead reliability analysis, real-time operations
engineering analysis, and developing operating procedures and tools, along
with other engineering needs, to support the system operations of the
CAISO Balancing Area and Transmission Grid.
Prior to joining the CAISO, Mr. Subakti was with Open Access Technology
International, Inc. (OATI), where he managed project development for
various transmission system applications including Inter-Control Center
Communication Protocol implementation, Open Access Same-Time
Information System automation, scheduling application, Total Transfer
4
Attachment J
Capability (TTC) and Available Transfer Capacity (ATC) calculation,
congestion management processes, and transmission settlement applications
for Transmission Service Providers in both the Western and Eastern
Interconnections.
Mr. Subakti spent much of his career as Manager of Regional Operations
Engineer for the Midwest ISO (MISO), where he managed the Real-time
Operations Engineers that support MISO’s control room operation.
Mr. Subakti is regularly involved in NERC and WECC efforts in both
Reliability Standards development and subcommittee’s efforts supporting
operations of the Interconnection. He was involved in the NERC MOD-A,
EOP Standard Drafting Team, the FAC Periodic Review Team, and the
associated standard drafting team.
Mr. Subakti is a licensed Professional Engineer with the State of Minnesota
and a certified NERC System Operator. He received his Master of Business
Administration from the Carlson School of Management at the University of
Minnesota and Master of Electrical Engineering with emphasis in power
systems from the Iowa State University where he also earned his Bachelor of
Science in electrical engineering.
5
Attachment K
Ballot Pool Members
WECC-0135 IRO-002-5
RC—Monitoring and Analysis—RV
Ballot Pool Members
Title
Company
Sector
Vote
Comments
Created By
WECC-0135
Western Area
Electricity
Yes
0
Timothy Vigil
Power
Brokers,
Administration
Aggregators, and
Yes
0
Kammy Rogers
Marketers
WECC-0135
Bonneville
Transmission
Power
Owners
Holliday
Administration
WECC-0135
Public Service
Transmission
Company of
Owners
Yes
0
Robert Staton
Yes
0
Robert Staton
Yes
0
Laurie Williams
Yes
0
Laurie Williams
Yes
0
Laurie Williams
Yes
0
Laurie Williams
Colorado (Xcel
Energy)
WECC-0135
Public Service
Load-Serving
Company of
Entities (LSE)
Colorado (Xcel
Energy)
WECC-0135
Public Service
Electric
Company of
Generators
New Mexico
WECC-0135
Public Service
Transmission
Company of
Owners
New Mexico
WECC-0135
Public Service
Load-Serving
Company of
Entities (LSE)
New Mexico
WECC-0135
Public Service
Electricity
Company of
Brokers,
New Mexico
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Attachment K
Aggregators, and
Marketers
WECC-0135
Avista
Electricity
Abstain
Using a common
Corporation
Brokers,
model instead of a
Aggregators, and
common
Marketers
methodology seems
Scott Kinney
for appropriate.
WECC-0135
British
Electric
Columbia
Generators
Yes
0
Adrian
Andreoiu
Hydro & Power
Authority
WECC-0135
British
Transmission
Columbia
Dependent
Hydro & Power
Utilities (TDU)
Yes
0
Adrian
Andreoiu
Authority
WECC-0135
British
Transmission
Columbia
Owners
Yes
0
Adrian
Andreoiu
Hydro & Power
Authority
WECC-0135
British
Load-Serving
Columbia
Entities (LSE)
Yes
0
Adrian
Andreoiu
Hydro & Power
Authority
WECC-0135
Powerex, Inc.
Electricity
Yes
0
Brokers,
Gordon Dobson
Mack
Aggregators, and
Marketers
WECC-0135
Sacramento
Electric
Municipal
Generators
Yes
0
Joe Tarantino
Yes
0
Joe Tarantino
Yes
0
Joe Tarantino
Utility District
WECC-0135
WECC-0135
Sacramento
Transmission
Municipal
Dependent
Utility District
Utilities (TDU)
Sacramento
Transmission
Municipal
Owners
Utility District
2
Attachment K
WECC-0135
Sacramento
Load-Serving
Municipal
Entities (LSE)
Yes
0
Joe Tarantino
Yes
0
Joe Tarantino
Yes
0
Joe Tarantino
Yes
0
Joe Tarantino
Yes
0
Richard Vine
Yes
0
Richard Vine
Yes
0
sean er
Yes
0
Rebecca
Utility District
WECC-0135
Sacramento
Electricity
Municipal
Brokers,
Utility District
Aggregators, and
Marketers
WECC-0135
Balancing
Transmission
Authority of
Owners
Northern
California
WECC-0135
WECC-0135
Balancing
Electricity
Authority of
Brokers,
Northern
Aggregators, and
California
Marketers
California
Regional
Independent
Transmission
System Operator
Organizations
(RTOs) and
Independent
System
Operators (ISO)
WECC-0135
California
Electricity
Independent
Brokers,
System Operator
Aggregators, and
Marketers
WECC-0135
Western Area
Transmission
Power
Owners
Administration
WECC-0135
Bonneville
Load-Serving
Power
Entities (LSE)
Berdahl
Administration
WECC-0135
Bonneville
Electricity
Power
Brokers,
Administration
Aggregators, and
Yes
0
Andrew
Meyers
Marketers
3
Attachment K
WECC-0135
Public Service
Electric
Company of
Generators
0
0
Gerry Huitt
0
0
Selene Willis
0
0
Romel Aquino
Colorado (Xcel
Energy)
WECC-0135
Southern
Electric
California
Generators
Edison
Company
WECC-0135
Southern
Load-Serving
California
Entities (LSE)
Edison
Company
4
Attachment L
Final Ballot Results
WECC-0135 IRO-002-5
RC—Monitoring—RV
Ballot Name:
WECC-0135 IRO-002-5, Reliability Coordination - Monitoring and Analysis,
Request for Regional Variance
Overview:
The project requires Reliability Coordinators (RC) serving the Western
Interconnection to : 1) develop a common, Interconnection-wide
methodology to determine the modeling and monitoring of elements
necessary for providing operational awareness, and 2) use the methodology.
Ballot Pool Open:
01/22/2019
Ballot Pool Closed:
02/05/2019
Ballot Opened:
02/07/2019
Ballot Closed:
02/21/2019
Total Ballot Pool:
29
Total Votes:
26
Quorum:
89.7%
Weighted Votes:
100%
Ballot Results:
Pass
Voting Sectors
Transmission Owners
Regional Transmission
Organizations (RTO) and
Independent System
Operators (ISO)
Load-Serving Entities (LSE)
Transmission Dependent
Utilities (TDU)
Electric Generators
Electricity Brokers,
Aggregators, and
Marketers
Large Electricity End Users
Small Electricity Users
Federal, State, Provincial
Regulatory, other Gov.
Entities
Regional Entities
Totals
Total in
Ballot
Pool
Votes
NonAbstain
Sector
Weight
Yes
Votes
Weighted
Segment
Vote
No
Votes
7
7
0.7
7
70.0%
1
6
1
5
0.1
0.5
1
5
2
5
2
3
0.2
0.3
8
0
0
7
0
0
0
0
29
In-Pool
Affiliates
Excluded
0
Abstain
Total
Votes for
Quorum
Did
Not
Vote
0
0
7
0
10.0%
50.0%
0
0
0
0
1
5
0
1
2
3
20.0%
30.0%
0
0
0
0
2
3
0
2
0.7
0
0
7
0
0
70.0%
0.0%
0.0%
0
0
0
1
0
0
8
0
0
0
0
0
0
0
0
0
0
0
0.0%
0.0%
0
0
0
0
0
0
0
0
25
2.5
25
100.0%
0
1
26
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Attachment M
Minority Issues
WECC-0135 IRO-002-5
RC—Monitoring and Analysis—RV
Minority Issues
Although this project passed with a 100 percent affirmative ballot, in Postings 1 and 2, minority issues
were raised and addressed.
Methodology vs. Model Mandate
At the start, the WECC-0135 Drafting Team (DT) was faced with the decision whether to mandate use
of a single named West-wide model or allow for the more practical use of a modeling and monitoring
methodology developed in an inclusive and coordinated environment. The DT chose the latter.
The DT chose the methodology approach because:
•
It is a better match for NERC’s direction that standards should be results-based as opposed to
mandating how the result should be reached (see NERC’s Results-Based Reliability Standard
Development Guidance).
•
Requiring use of a specified model may preclude use of a better model, causing a default to the
lowest common denominator (FERC Order 672, para. 329).
•
Requiring use of a specified model may diminish due process in that changes to the model
could occur outside the standards development process (FERC Order 672, para. 334).
•
If the WECC Regional Variance (RV) mandated use of a single model “or its successor,” until
the validity of “its successor” could be determined, compliance would be in question.
•
The methodology approach conforms with FERC direction in that it allows for the WECC RV to
consider “implementation cost [and] historical regional infrastructure design,” while
“effectively and efficiently” achieving the reliability objective (FERC Order 672, para. 328 and
330).
The goal of the common methodology is to ensure that essential modelling details are maintained that
provide a Reliability Coordinator (RC) with a wide-area view while permitting unneeded data to be
culled. The benefits of ensuring that the RC models are no larger than necessary include: 1)
significantly enhanced performance of on-line applications such as Transient Stability Analysis, 2)
reduced risk that data problems with elements that are insensitive to the RC footprint will cause
convergence problems, 3) reduced risk that problems with elements that are insensitive to the RC
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Attachment M
footprint could cause false alarms or consume troubleshooting resources, and 4) reduced risk that
errors from insensitive parts of the Interconnection could mask issues within the RC footprint.
Miscellaneous Posting 1
In Posting 1, the DT did not adopt proposed changes:
•
That would further prescribe how the monitoring of oscillation should occur. The DT chose to
keep the methodology approach that meets the results-based concept.
•
That would delete Posting 1, D.R1, 1.5 because its inclusion creates a mandate specific to the RC
that is not present in MOD-33.
•
To adopt a dispute resolution clause requiring that all RCs agree.
•
To adopt inclusion of “voltage” because D.R1 addresses stability time frames as opposed to
stability types.
Miscellaneous Posting 2
In Posting 2, the DT did not adopt proposed changes:
•
To inclusively define the bounds of what is “necessary” in D.R1.
The Southwest Power Pool (SPP) raised concerns that inclusion of the word “necessary” in
Requirement D.R1 could cause confusion in the auditing process (not in execution of the requirement).
The term was kept after the team concluded its inclusion was neutral as to the Measure but added
valuable descriptive bounds to the reliability task. The team further concluded that, although use of the
word was not ideal, complete delineation of all features “necessary” for the monitoring and modeling
methodology was not practical to include in a Regional Variance.
In its response, the DT encouraged the industry to engage in the Reliability Standards Audit Worksheet
development process as described in the NERC Reliability Standard Audit Worksheet (RSAW) Review
and Revision Process (effective March 1, 2018). In all cases, the Regional Entity should rely on the
language in the Reliability Standard itself, not the language in the RSAW, to determine compliance
with the Reliability Standard. 1
Numerous structural and syntactic changes were not adopted.
https://www.nerc.com/pa/comp/Reliability%20Standard%20Audits%20Worksheets%20DL/NERC%20Reliability
%20Standard%20Audit%20Worksheet%20(RSAW)%20Review%20and%20Revision%20Process.pdf
1
2
Attachment N
WECC Standards Committee Roster
WECC-0135 IRO-002-5
RC—Monitoring and Analysis—RV
WECC Standards Committee Roster
The following individuals are those assigned to the WECC Standards Committee as of March 5, 2019.
Sunitha Kothapalli, Puget Sound Energy ........................................................................... SVS 1 Transmission
Robert Sullivan, California Independent System Operator.................................................... SVS 2 RTO/ISO 1
Dana Cabbell, Southern California Edison ........................................................................................ SVS 3 LSE 2
Marty Hostler, Northern California Power Agency ........................................................................ SVS 4 TDU 3
Gary Nolan, Arizona Public Service ........................................................................................ SVS 5 Generators
Joe Tarantino, Sacramento Municipal Utility District .......................... SVS 6 Broker/Aggregator/Marketers
Caitlin Liotiris, Utah Association of Energy Users .................................... SVS 7 Large Electricity End Users
Crystal Musselman, Proven Compliance Solutions .......................................... SVS 8 Small Electricity Users
Davy Zhuang, British Columbia Utilities Commission ..................................................... SVS 9 Gov. Entities
Steven Rueckert, WECC ................................................................................................ SVS 10 Regional Entities
James Avery, Chair.......................................................................................................... Non-Affiliated Director
Regional Transmission Organization/Independent System Operator
Load-Serving Entity
3 Transmission Dependent Utilities
1
2
155 Nort h 400 West | Suit e 200 | Salt Lake Cit y, Ut ah 84103
www. we cc.org
Consideration of Comments
Project Name:
WECC-0135 Regional Variance | IRO-002-5
Comment Period Start Date:
3/7/2019
Comment Period End Date:
4/22/2019
Associated Ballots:
There was one set of responses, including comments from approximately three different people from one company representing three of the
Industry Segments as shown in the table on the following pages.
All comments submitted can be reviewed in their original format on the project page.
If you feel that your comment has been overlooked, please let us know immediately. Our goal is to give every comment serious consideration
in this process. If you feel there has been an error or omission, you can contact the Senior Director of Standards and Education, Howard Gugel
(via email) or at (404) 446‐9693.
If you have any questions regarding the WECC Reliability Standards Development Procedures or this project, please contact WECC
Consultant, W. Shannon Black at (503) 307-5782.
Questions
1. Do you agree the proposed variance was developed in a fair and open process, using the associated Regional Reliability Standards
Development Procedure?
2. Does the proposed variance pose an adverse impact to reliability or commerce in a neighboring region or interconnection?
3. Does the proposed variance pose a serious and substantial threat to public health, safety, welfare, or national security?
4. Does the proposed variance pose a serious and substantial burden on competitive markets within the interconnection that is not
necessary for reliability?
5. Does the proposed variance meet at least one of the following criteria?
•
The proposed variance has more specific criteria for the same requirements covered in a continent-wide standard.
•
The proposed variance has requirements that are not included in the corresponding continent-wide reliability standard.
•
The proposed regional difference is necessitated by a physical difference in the bulk power system.
Consideration of Comments
Regional Reliability Standard | IRO-002-5 | May 2019
2
Organization
Name
Name
BC Hydro and Adrian
Power
Andreoiu
Authority
Segment(s)
1,3,5
Consideration of Comments
Regional Reliability Standard | IRO-002-5 | May 2019
Region
WECC
Group
Name
Group
Member
Name
BC Hydro Hootan
Jarollahi
Group
Member
Organization
Group
Member
Segment(s)
Group Member Region
BC Hydro and 3
Power
Authority
WECC
Helen
Hamilton
Harding
BC Hydro and 5
Power
Authority
WECC
Adrian
Andreoiu
BC Hydro and 1
Power
Authority
WECC
3
1. Do you agree the proposed variance was developed in a fair and open process, using the associated Regional Reliability Standards
Development Procedure?
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Consideration of Comments
Regional Reliability Standard | IRO-002-5 | May 2019
4
2. Does the proposed variance pose an adverse impact to reliability or commerce in a neighboring region or interconnection?
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer
No
Document Name
Comment
Likes
0
Dislikes
0
Response
Consideration of Comments
Regional Reliability Standard | IRO-002-5 | May 2019
5
3. Does the proposed variance pose a serious and substantial threat to public health, safety, welfare, or national security?
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer
No
Document Name
Comment
Likes
0
Dislikes
0
Response
Consideration of Comments
Regional Reliability Standard | IRO-002-5 | May 2019
6
4. Does the proposed variance pose a serious and substantial burden on competitive markets within the interconnection that is not
necessary for reliability?
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer
No
Document Name
Comment
Likes
0
Dislikes
0
Response
Consideration of Comments
Regional Reliability Standard | IRO-002-5 | May 2019
7
5. Does the proposed variance meet at least one of the following criteria?
•
The proposed variance has more specific criteria for the same requirements covered in a continent-wide standard.
•
The proposed variance has requirements that are not included in the corresponding continent-wide reliability standard.
•
The proposed regional difference is necessitated by a physical difference in the bulk power system.
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Consideration of Comments
Regional Reliability Standard | IRO-002-5 | May 2019
8
Attachment O2
Posting Two Response to Comments
WECC-0135 IRO-002-5
RC—Monitoring and Analysis—RV
Posting 2
The WECC-0135 IRO-002-5, Reliability Coordination—Monitoring and Analysis, Request for WECC
Regional Variance (RV) Drafting Team (DT) thanks everyone who submitted comments on the
proposed document.
Posting
This project was posted for public comment from November 28, 2018, through January 2, 2019.
WECC distributed the notice for the posting on November 28, 2018. 1 The DT asked stakeholders to
provide feedback on the proposed document through a standardized electronic template. One
comment was received on this posting.
Location of Comments
All comments received on the project can be viewed in their original format on the WECC-0135 project
page under the “Submit and Review Comments” accordion.
Method vs. Model Mandate
The proposed WECC RV addresses a condition in which multiple Reliability Coordinators (RC)
provide RC service(s) within the Western Interconnection, regardless of the RC’s geographic location.
Two primary approaches where considered for this project: 1) a requirement that all RCs use a single,
mandated model, and 2) a requirement that all affected RCs create a coordinated method to meet the
reliability goal. The DT chose the second approach. (For more detail, refer to WECC-0135 Posting 1,
Response to Comments, posted on the WECC-0135 project page at the “Submit and Review
Comments” accordion.)
Changes in Response to Comment
After consideration of Southwest Power Pool’s (SPP) comment, the DT chose to make no further
changes to the project.
Notice of Posting 2 was originally dispatched on November 19, 2018, with a closing date of December 19, 2018.
On November 28, 2018, notice was dispatched extending the closing date to January 2, 2019.
1
155 Nort h 400 West | Suit e 200 | Salt Lake Cit y, Ut ah 84103
www. we cc.org
WECC-0135 Response to Comments Posting 2
Minority View
The project requires RCs serving the Western Interconnection: 1) to develop a common,
Interconnection-wide method to determine the modeling and monitoring of elements “necessary” for
operational awareness, and 2) to use the method.
SPP raised concerns that inclusion of the word “necessary” in Requirement RX1 could cause confusion
in the auditing process (not in execution of the requirement). The term was retained after the team
concluded its inclusion was neutral as to the Measure, but added descriptive bounds to the reliability
task. Although use of the word was not ideal, naming all “necessary” features for the monitoring and
modeling method was not practical.
The drafting team also encouraged the industry to engage in the Reliability Standards Audit Worksheet
(RSAW) development process as described in the NERC RSAW Review and Revision Process (effective:
March 1, 2018). In all cases, the Regional Entity should rely on the language in the Reliability Standard
itself, and not on the language in the RSAW to determine compliance with the Reliability Standard. 2
Effective Date
The proposed effective date for the RV is “The first day of the first quarter after regulatory approval,
but no sooner than January 1, 2020.”
Action Plan
A January 1, 2020, effective date gives time for Peak Reliability to wind down, for other RCs to start up,
and creates a window during which the RCs may create the method required.
On January 11, 2019, the WECC-0135 IRO-002-5, Reliability Coordination—Monitoring and Analysis,
Request for WECC Regional Variance Drafting Team (DT) agreed by majority vote to forward the
project to the WECC Standards Committee (WSC) with a request for ballot. The WSC is targeted to
meet during the week of January 14, 2019.
If you have questions regarding the posting, please contact W. Shannon Black at (503) 307 5782.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC
Consultant, at (503) 307-5782. In addition, there is a WECC Reliability Standards appeals process.
Commenter
Organization
1
Southwest Power Pool (SPP)
Alan Wahlstrom
2
https://www.nerc.com/pa/comp/Reliability%20Standard%20Audits%20Worksheets%20DL/NERC%20Reliability%
20Standard%20Audit%20Worksheet%20(RSAW)%20Review%20and%20Revision%20Process.pdf
2
WECC-0135 Response to Comments Posting 2
Index to Questions, Comments, and Responses
Question
1. The Drafting Team welcomes comments on all aspects of the document.
3
WECC-0135 Response to Comments Posting 2
1. The Drafting Team welcomes comments on all aspects of the document.
Summary Consideration: See summary in the preamble of this document.
Commenter
Comment
Southwest Power Pool
In Requirement 1 the statement "necessary for providing
operational awareness of the impacts on BES Facilities
within its RC Area, including at a minimum", we believe
the word necessary could prove to be contradictory. What
the RC's deem as necessary and what the Regional Entity
deem as necessary could conflict. Our recommendation is
to strike the word necessary and rewrite the statement to
say, "to provide operational awareness of the impacts on
BES Facilities within its RC Area, including at a minimum".
The RC's will determine what is necessary in their
methodology.
Response
The DT appreciates SPP’s suggestion.
In RX1, it is the impacted RCs that develop the modeling and monitoring methodology that includes
a specified minimum content. Thereafter, RX2 requires the RC to implement the methodology.
Nowhere in the proposed Regional Variance (RV) is the Regional Entity (RE) required to act,
participate or opine; thus, any potential conflict between the RE and the RC is moot – as to the tasks
for performance under the RV.
That said, a good business practice would suggest that the RE should be consulted and/or included
in the development of the methodology due to the RE’s ability to access, distill, coordinate, and share
a breadth of information not always directly accessible by the RC. But, that is not required in the
proposed RV. The final determination of what is “necessary” falls to the RCs.
Alternatively, in its role as the enforcement entity, the RE may determine the nature of what
constitutes acceptable evidence of compliance. If this is SPP’s concern, SPP and each applicable RC is
encouraged to directly engage the enforcement activity to assist in drafting the associated Reliability
Standard Audit Worksheet.
Finally, the drafting team recognizes that what constitutes “necessary” in RX1 is not specifically
stated in the language of the RV. That was intentional. The DT was faced with the impossible task of
defining the complete universe of what is “necessary” for each RC – present and future, known and
unknown, and under all circumstances.
4
WECC-0135 Response to Comments Posting 2
Since that which is necessary for one RC may not be the same as that which is necessary for another
RC; and, whereas that which is necessary for one RC may vary over time, the DT concluded the best
forum for that determination was during the coordinated development of the methodology.
5
Consideration of Comments
Project Name:
WECC-0135 Regional Variance | IRO-002-5
Comment Period Start Date:
3/7/2019
Comment Period End Date:
4/22/2019
Associated Ballots:
There was one set of responses, including comments from approximately three different people from one company representing three of the
Industry Segments as shown in the table on the following pages.
All comments submitted can be reviewed in their original format on the project page.
If you feel that your comment has been overlooked, please let us know immediately. Our goal is to give every comment serious consideration
in this process. If you feel there has been an error or omission, you can contact the Senior Director of Standards and Education, Howard Gugel
(via email) or at (404) 446‐9693.
If you have any questions regarding the WECC Reliability Standards Development Procedures or this project, please contact WECC Consultant,
W. Shannon Black at (503) 307-5782.
Questions
1. Do you agree the proposed variance was developed in a fair and open process, using the associated Regional Reliability Standards
Development Procedure?
2. Does the proposed variance pose an adverse impact to reliability or commerce in a neighboring region or interconnection?
3. Does the proposed variance pose a serious and substantial threat to public health, safety, welfare, or national security?
4. Does the proposed variance pose a serious and substantial burden on competitive markets within the interconnection that is not
necessary for reliability?
5. Does the proposed variance meet at least one of the following criteria?
•
The proposed variance has more specific criteria for the same requirements covered in a continent-wide standard.
•
The proposed variance has requirements that are not included in the corresponding continent-wide reliability standard.
•
The proposed regional difference is necessitated by a physical difference in the bulk power system.
Consideration of Comments
Regional Reliability Standard | IRO-002-5 | May 2019
2
Organization
Name
Name
BC Hydro and Adrian
Power
Andreoiu
Authority
Segment(s)
1,3,5
Consideration of Comments
Regional Reliability Standard | IRO-002-5 | May 2019
Region
WECC
Group
Name
Group
Member
Name
BC Hydro Hootan
Jarollahi
Group
Member
Organization
Group
Member
Segment(s)
Group Member Region
BC Hydro and 3
Power
Authority
WECC
Helen
Hamilton
Harding
BC Hydro and 5
Power
Authority
WECC
Adrian
Andreoiu
BC Hydro and 1
Power
Authority
WECC
3
1. Do you agree the proposed variance was developed in a fair and open process, using the associated Regional Reliability Standards
Development Procedure?
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Consideration of Comments
Regional Reliability Standard | IRO-002-5 | May 2019
4
2. Does the proposed variance pose an adverse impact to reliability or commerce in a neighboring region or interconnection?
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer
No
Document Name
Comment
Likes
0
Dislikes
0
Response
Consideration of Comments
Regional Reliability Standard | IRO-002-5 | May 2019
5
3. Does the proposed variance pose a serious and substantial threat to public health, safety, welfare, or national security?
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer
No
Document Name
Comment
Likes
0
Dislikes
0
Response
Consideration of Comments
Regional Reliability Standard | IRO-002-5 | May 2019
6
4. Does the proposed variance pose a serious and substantial burden on competitive markets within the interconnection that is not
necessary for reliability?
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer
No
Document Name
Comment
Likes
0
Dislikes
0
Response
Consideration of Comments
Regional Reliability Standard | IRO-002-5 | May 2019
7
5. Does the proposed variance meet at least one of the following criteria?
•
The proposed variance has more specific criteria for the same requirements covered in a continent-wide standard.
•
The proposed variance has requirements that are not included in the corresponding continent-wide reliability standard.
•
The proposed regional difference is necessitated by a physical difference in the bulk power system.
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Consideration of Comments
Regional Reliability Standard | IRO-002-5 | May 2019
8
Regional Reliability
Standards Announcement
Western Electricity Coordinating Council
IRO-002-5 | WECC Variance
Comment Period Open through April 22, 2019
Now Available
The Western Electricity Coordinating Council (WECC) requested that NERC post the WECC Regional
Variance for IRO-002-5 - Reliability Coordination – Monitoring and Analysis for industry review and
comment in accordance with the NERC Rules of Procedure.
Background
As the Western Interconnection moves to a multi-Reliability Coordinator (RC) environment, focused
coordination of those RCs will become critical. WECC developed a proposed Regional Variance to NERC
Reliability Standard IRO-002-5 - Reliability Coordination - Monitoring and Analysis to ensure coordination
between each of those RCs.
The proposed Variance does not change any of the continent-wide Requirements. The WECC Board of
Directors adopted the proposed Variance on March 6, 2019.
Prior to NERC Board adoption, the proposed Variance will be inserted into proposed Reliability Standard
IRO-002-6, which is currently being balloted as part of the ongoing Project 2018-03 Standards Efficiency
Retirements project.
The standard was posted twice for comment by WECC, most recently from November 28, 2018 – January
2, 2019 and the comments received can be viewed here.
Commenting
Use the electronic form to submit comments. If you experience any difficulties in using the electronic
form, contact Nasheema Santos. The form must be submitted by 8 p.m. Eastern, Monday, April 22,
2019. An unofficial Word version of the comment form is posted on the Regional Reliability Standards
Under Development page.
Regional Reliability Standards Development Process
Section 300 of NERC’s Rules of Procedures of the Electric Reliability Organization governs the regional
reliability standards development process.
Documents and information about this project are available on the WECC’s Standards Under
Development page.
For more information or assistance, contact Senior Reliability Standards Analyst, Nasheema Santos (via
email) or at (404) 446-2564.
North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com
Standards Announcement
Revised Retirement Date of PRC-004-WECC-2 | December 2018
2
WECC-0135 IRO-002-5
Reliability Coordination—
Monitoring and Analysis
Regional Variance
Overview
As the Western Interconnection moves to a multi-Reliability Coordinator (RC) environment, focused
coordination of those RCs will become critical. This filing is designed to ensure coordination between
each of those RCs by creating a WECC Regional Variance (RV) to NERC Reliability Standard IRO-0025, Reliability Coordination—Monitoring and Analysis (RCMA).
This filing does not change any part of the underlying standard. Only the proposed RV and the
associated compliance components will be offered for comment. Proposed changes to the existing body
of the standard will not be considered.
Once finalized, the proposed language will be renumbered per NERC’s numbering nomenclature for
RVs and inserted into the existing standard. An example of a WECC RV can be seen in VAR-001-4.1—
Voltage and Reactive Control Compliance, Section D Regional Variances.
Purpose
To develop a methodology that creates models for performing Operational Planning Analyses and
Real-time Assessments.
Applicability
As used in this WECC Regional Variance, Reliability Coordinator is specific to those Reliability
Coordinators providing Reliability Coordinator service(s) to entities operating within the Western
Interconnection, regardless of where the Reliability Coordinator may be located.
Requirement and Measures
RX1.
Each Reliability Coordinator shall, in coordination with other Reliability Coordinators, develop
a common Interconnection-wide methodology to determine the modeling and monitoring of
BES and non-BES Elements that are internal and external to its Reliability Coordinator Area,
necessary for providing operational awareness of the impacts on Bulk Electric System Facilities
within its Reliability Coordinator Area, including at a minimum: ([Violation Risk Factor: High]
[Time Horizon: Operations Planning])
1.1.
A method for development, maintenance, and periodic review of a Western
Interconnection-wide reference model to serve as the baseline from which Reliability
Coordinator’s operational models are derived;
155 Nort h 400 West | Suit e 200 | Salt Lake Cit y, Ut ah 84103
www. we cc.org
WECC-0135 Posting 2 Clean
1.2
The impacts of Inter-area oscillations;
1.3
A method to determine Contingencies included in analyses and assessments;
1.4
A method to determine Remedial Action Schemes included in analyses and assessments;
1.5
A method to determine forecast data included in analyses and assessments; and
1.6
A method for the validation and periodic review of the Reliability Coordinator’s
operational model for steady state and dynamic/oscillatory system response.
MX1. Each Reliability Coordinator will have evidence that it developed a common Western
Interconnection-wide methodology, addressing modeling and monitoring, in coordination with
other Reliability Coordinators, that includes the features required in RX1.
RX2.
Each Reliability Coordinator shall use the methodology developed in RX1. ([Violation Risk
Factor: High] [Time Horizon: Operations Planning])
MX2. Each Reliability Coordinator will have evidence that it uses the methodology developed in RX1,
as required in RX2 above.
Compliance
A. Compliance
1.2 Evidence Retention:
•
The Reliability Coordinator shall keep data or evidence for Requirements R5, R6, and the
WECC Regional Variance, and Measures M5, M6, and the WECC Regional Variance for the
current calendar year and one previous calendar year.
Violation Severity Levels for the WECC Regional Variance
R#
RX1
Lower VSL
Moderate VSL
High VSL
Severe VSL
The Reliability
Coordinator did not
develop the methodology
as required in RX1.
RX2
The Reliability Coordinator
did not implement the
methodology as required
in RX2.
2
Comment Report
Project Name:
WECC Regional Variance | IRO-002-5
Comment Period Start Date:
3/7/2019
Comment Period End Date:
4/22/2019
Associated Ballots:
There were 1 sets of responses, including comments from approximately 4 different people from approximately 1 companies
representing 3 of the Industry Segments as shown in the table on the following pages.
Questions
1. Do you agree the proposed variance was developed in a fair and open process, using the associated Regional Reliability Standards
Development Procedure?
2. Does the proposed variance pose an adverse impact to reliability or commerce in a neighboring region or interconnection?
3. Does the proposed variance pose a serious and substantial threat to public health, safety, welfare, or national security?
4. Does the proposed variance pose a serious and substantial burden on competitive markets within the interconnection that is not
necessary for reliability?
5. Does the proposed variance meet at least one of the following criteria?
•
The proposed variance has more specific criteria for the same requirements covered in a continent-wide standard.
•
The proposed variance has requirements that are not included in the corresponding continent-wide reliability standard.
•
The proposed regional difference is necessitated by a physical difference in the bulk power system.
Organization
Name
Name
Segment(s)
BC Hydro and Adrian Andreoiu 1,3,5
Power
Authority
Region
WECC
Group Name Group Member
Name
Group
Group
Member
Member
Organization Segment(s)
Group Member
Region
BC Hydro
Hootan Jarollahi
BC Hydro and 3
Power
Authority
WECC
Helen Hamilton
Harding
BC Hydro and 5
Power
Authority
WECC
Adrian Andreoiu
BC Hydro and 1
Power
Authority
WECC
1. Do you agree the proposed variance was developed in a fair and open process, using the associated Regional Reliability Standards
Development Procedure?
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
Response
0
2. Does the proposed variance pose an adverse impact to reliability or commerce in a neighboring region or interconnection?
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer
No
Document Name
Comment
Likes
0
Dislikes
Response
0
3. Does the proposed variance pose a serious and substantial threat to public health, safety, welfare, or national security?
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer
No
Document Name
Comment
Likes
0
Dislikes
Response
0
4. Does the proposed variance pose a serious and substantial burden on competitive markets within the interconnection that is not
necessary for reliability?
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer
No
Document Name
Comment
Likes
0
Dislikes
Response
0
5. Does the proposed variance meet at least one of the following criteria?
•
The proposed variance has more specific criteria for the same requirements covered in a continent-wide standard.
•
The proposed variance has requirements that are not included in the corresponding continent-wide reliability standard.
•
The proposed regional difference is necessitated by a physical difference in the bulk power system.
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
Response
0
Unofficial Comment Form
WECC Regional Variance – IRO-002-5
DO NOT use this form for submitting comments. Use the electronic form to submit comments on Regional
Reliability Standard IRO-002-5 – Reliability Coordination – Monitoring and Analysis (WECC Variance).
Comments must be submitted by 8 p.m. Eastern, Monday, April 22, 2019.
The Regional Reliability Standards Under Development page contains documents and information about
this project. If you have questions, contact Nasheema Santos (via email).
Background Information
As the Western Interconnection moves to a multi-Reliability Coordinator (RC) environment, focused
coordination of those RCs will become critical. WECC developed a proposed Regional Variance to NERC
Reliability Standard IRO-002-5, Reliability Coordination—Monitoring and Analysis to ensure coordination
between each of those RCs.
The proposed Variance does not change any of the continent-wide Requirements. The WECC Board of
Directors adopted the proposed Variance on March 6, 2019.
Prior to NERC Board adoption, the Variance will be inserted into proposed Reliability Standard IRO-002-6,
which is currently being balloted as part of the ongoing Project 2018-03 Standards Efficiency Retirements
project.
The standard was posted twice for comment, most recently from November 19, 2018 – January 2, 2019
and the comments received can be viewed here.
Any variance from a NERC Reliability Standard Requirement that is proposed to apply to responsible
entities within a Regional Entity organized on an Interconnection-wide basis shall be considered an
Interconnection-wide Variance and shall be developed through that Regional Entity’s NERC-approved
regional Reliability Standards development procedure. While an Interconnection-wide Variance may be
developed through the associated Regional Entity standards development process, Regional Entities are
encouraged to work collaboratively with existing continent-wide drafting team to reduce potential
conflicts between the two efforts. An Interconnection-wide Variance from a NERC Reliability Standard
that is determined by NERC to be just, reasonable, and not unduly discriminatory or preferential, and in
the public interest, and consistent with other applicable standards of governmental authorities shall be
made part of the associated NERC Reliability Standard. NERC shall rebuttably presume that an
Interconnection-wide Variance from a NERC Reliability Standard that is developed, in accordance with a
standards development procedure approved by NERC, by a Regional Entity organized on an
Interconnection-wide basis, is just, reasonable, and not unduly discriminatory or preferential, and in the
public interest.
NERC is publicly noticing and requesting comment on the proposed WECC Variance. Comments shall be
permitted only on the following criteria (technical aspects of the Variance are vetted through the regional
standards development process):
Unfair or Closed Process – The Variance was not developed in a fair and open process that provided an
opportunity for all interested parties to participate. Although a NERC-approved regional reliability
standards development procedure shall be presumed to be fair and open, objections could be raised
regarding the implementation of the procedure.
Adverse Reliability or Commercial Impact on Other Interconnections – The Variance would have a
significant adverse impact on reliability or commerce in other interconnections.
Deficient Standard – The Variance fails to provide a level of reliability of the bulk power system such that
the Variance would be likely to cause a serious and substantial threat to public health, safety, welfare, or
national security.
Adverse Impact on Competitive Markets within the Interconnection – The Variance would create a
serious and substantial burden on competitive markets within the interconnection that is not necessary
for reliability.
Questions
1. Do you agree the proposed Variance was developed in a fair and open process, using the
associated Regional Reliability Standards Development Procedure?
Yes
No
Comments:
2. Does the proposed Variance pose an adverse impact to reliability or commerce in a neighboring
region or interconnection?
Yes
No
Comments:
3. Does the proposed Variance pose a serious and substantial threat to public health, safety,
welfare, or national security?
Yes
No
Comments:
Unofficial Comment Form
IRO-002-5 | March – April 2019
2
4. Does the proposed Variance pose a serious and substantial burden on competitive markets
within the interconnection that is not necessary for reliability?
Yes
No
Comments:
5. Does the proposed Variance meet at least one of the following criteria?
The proposed variance has more specific criteria for the same requirements covered in a
continent-wide standard.
The proposed variance has requirements that are not included in the corresponding
continent-wide reliability standard.
The proposed regional difference is necessitated by a physical difference in the bulk power
system.
Yes
No
Comments:
Unofficial Comment Form
IRO-002-5 | March – April 2019
3
Exhibit F
Standard Drafting Team Roster
Drafting Team Roster
WECC-0135 IRO-002-5
RC—Monitoring and Analysis—RV
Drafting Team Roster
Below please find a biographical snapshot for the members of the WECC-0135 IRO-002-5 Reliability
Coordination Monitoring and Analysis, Request for WECC Regional Variance Drafting Team. 1
Name
Biography
Djordje Atanackovic,
Mr. Djordje Atanackovic received his Ph.D. in electrical engineering from
BC Hydro
McGill University, Canada. In 2001, he joined British Columbia (BC) Hydro,
supporting real-time Energy Management System (EMS) network
applications. Before joining BC Hydro, Dr. Atanackovic was with Canadian
Aviation Electronics and Société national de Conseil-Lavalin, working on the
development of EMS and Distribution Management System advancednetwork applications. He is currently Engineering Division Manager of BC
Hydro's Real-time Systems department in Transmission and Distribution
System Operations. Dr. Atanackovic is a senior member of the Institute of
Electrical and Electronics Engineers (IEEE) and has authored 30 technical
papers in the field of power system operations, planning, and control.
Sean Erickson,
Mr. Erickson is a Senior Power Operations Specialist at the Western Area
Western Area Power
Power Administration. His qualifications include:
Administration
•
Two years of experience as a WECC Reliability Coordinator (2009–
2011);
•
Two years of experience as a WECC Reliability Coordination
Operations Engineer (2007–2009);
•
Four years of experience as an Operations Engineer (2011–2015);
•
Serving as the Transmission Alternate on the WECC Operating
Committee, as well as the WECC Ballot Body representative for both
WECC and NERC;
The following individuals were approved by the WECC Standards Committee (WSC) on July 19, 2018, via an
Action without a Meeting: Atanackovic, Howell, Miller, Malik. The following individuals were approved by the
WSC on August 7, 2018: Erickson, Shafeei, Subakti.
1
155 Nort h 400 West | Suit e 200 | Salt Lake Cit y, Ut ah 84103
www. we cc.org
•
Previous member of the WECC Performance Work Group during the
BAL-001 field trial evaluations;
•
Previous member of the Path Operator Task Force (POTF) (postSeptember 8, 2011, NERC/FERC findings and mitigation regarding
path operations) and the POTF Implementation Team for the
operational adoption of the POTF findings; and
Vic Howell, Peak
•
Contributor to retiring TOP-007-WECC-1a, System Operating Limits.
•
Currently serving as Manager of Modeling and Operations Support
Reliability (Peak)
Engineering at Peak Reliability.
•
Served as chair of WECC-0111 to retire TOP-007-WECC-1a.
•
Currently serving as chair of NERC Project 2015-09—Establish and
Communicate System Operating Limits.
•
Currently serving on NERC Methods for Establishing
Interconnection Reliability Operating Limits (IROL) Task Force
(MEITF).
•
Served on the WECC Path Operator Task Force. Served as vice chair
of WECC Path Operator Implementation Task Force (POITF).
•
Developed Peak's System Operating Limit (SOL) Methodology for
the Operations Horizon.
•
Very knowledgeable of Reliability Coordinator (RC) functions,
operations, and modeling; as well as NERC Reliability Standards and
standards-development processes.
Saal Malik, Peak
Reliability
Current Position: Director of Engineering, Peak Reliability
•
20 years overall industry experience
•
Nine years of experience with WECC-RC and now Peak in
Operations Planning and Real-time Operations
•
Experience with development/maintenance of following advanced
applications:
1. State Estimator,
2. Contingency Analysis,
3. Remedial Action Scheme (RAS) modeling and monitoring,
4. Voltage Stability,
5. Transient Stability, and
6. Synchro-phasor applications.
2
•
Extensive experience with operations coordination, training, NERC
compliance activities, SOL/IROL management, and systemmonitoring activities
•
Participated in the following drafting teams:
1. Team Chair: NERC Project 2009-02 “Real-time Monitoring and
Analysis Capabilities,”
2. Team Member: NERC Project 2016-01 “Modifications to TOP and
IRO Standards,” and
3. Team Member: NERC Compliance Guideline for Real-time
Assessments
Timothy Miller,
Tim Miller is SPP's Manager of Modeling and Data Integrity. In this role, he
Southwest Power
has responsibility for the modeling and support of the models used in SPP's
Pool (SPP)
real-time operations. His qualifications include:
•
Member of North American Electric Reliability Corporation (NERC)
Energy Management System (EMS) Working Group since 2016.
Active participant and presenter at Annual Situational Awareness
Conferences.
•
Member of North American Transmission Forum (NATF) EMS
Modeling Working Group and NATF Modeling Practices Working
Group since 2016.
•
13 years of experience building, validating, and using power system
models in various formats for both operational and long-term
planning use. Highly skilled in node-breaker modeling, maintenance,
validation, model management, and real-time support of EMS
advanced network applications.
•
Model building and maintenance experience includes SPP's efficient
model process that we use to consume models from neighboring
parties, including: Midcontinent Independent System Operator
(MISO), American Electric Power, and other SPP members and
neighbors.
•
Application support experience includes the development of SPP's
model validation processes, which have successfully satisfied NERC
Standard Requirements, Statement on Standards for Attestation
Engagements (SSAE) 16 audit standards, and internal business
controls for many years.
3
Phillip Shafeei,
Mr. Shafeei holds a Bachelor of Electrical Engineering and Master of
Colorado Springs
Engineering degree in Electric Power System Engineering from Rensselaer
Utility (CSU)
Polytechnic Institute, Troy, NY. From 2012 to the present, Mr. Shafeei
worked for the Colorado Springs Utility (CSU) as a Principle Power Systems
Engineer covering such issues as tariff rate design and development of
NERC Standards (MOD/TOP/FAC). Mr. Shafeei manages power system
studies, winter/summer seasons, Total Transfer Capability (TCC), outage
studies (approve-deny), weekly/next-day studies and model validations, and
the EMS model and studies. Mr. Shafeei attends the Peak RC and WECC
Board of Director meetings and was a member of the Peak RC alternative
funding.
From 2002 to 2012, he served at the New York Independent System Operator
(NYISO) as Senior Engineer addressing feasibility studies, system impact
studies, consultant interface, power flow analytics; and managed the NERC
Interchange Distribution Calendar (IDC) internal to NYISO, NYISO
representative in IDC, SDX, and Distribution Factor Working Group
(DFWG). Mr. Shafeei was the NYISO representative in the Northwest Power
and Conservation Council (NPCC) working groups, Control Performance
Working Group, and System Operational Tools Working Group. Mr. Shafeei
has 10 years of experience with industry training, data collection and
modeling, and interface with the North American Energy Standards Board.
Mr. Shafeei is experienced in distribution design, distribution management
systems, SCADA, power quality, distribution planning, and relay
coordination.
Dede Subakti,
Mr. Subakti is responsible for all operations engineering support and
California
services in California Independent System Operator (CAISO). This includes
Independent System
performing resource adequacy, seasonal operating studies, outage
Operator
coordination studies, day-ahead reliability analysis, real-time operations
engineering analysis, and developing operating procedures and tools, along
with other engineering needs, to support the system operations of the
CAISO Balancing Area and Transmission Grid.
Prior to joining the CAISO, Mr. Subakti was with Open Access Technology
International, Inc. (OATI), where he managed project development for
various transmission system applications including Inter-Control Center
Communication Protocol implementation, Open Access Same-Time
Information System automation, scheduling application, Total Transfer
4
Capability (TTC) and Available Transfer Capacity (ATC) calculation,
congestion management processes, and transmission settlement applications
for Transmission Service Providers in both the Western and Eastern
Interconnections.
Mr. Subakti spent much of his career as Manager of Regional Operations
Engineer for the Midwest ISO (MISO), where he managed the Real-time
Operations Engineers that support MISO’s control room operation.
Mr. Subakti is regularly involved in NERC and WECC efforts in both
Reliability Standards development and subcommittee’s efforts supporting
operations of the Interconnection. He was involved in the NERC MOD-A,
EOP Standard Drafting Team, the FAC Periodic Review Team, and the
associated standard drafting team.
Mr. Subakti is a licensed Professional Engineer with the State of Minnesota
and a certified NERC System Operator. He received his Master of Business
Administration from the Carlson School of Management at the University of
Minnesota and Master of Electrical Engineering with emphasis in power
systems from the Iowa State University where he also earned his Bachelor of
Science in electrical engineering.
5
| File Type | application/pdf |
| Author | Mark Olson |
| File Modified | 2019-05-30 |
| File Created | 2019-05-14 |