In accordance with 5 CFR 1320, comment filed on proposed rule. Agency will address comments at the final rule stage.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
10/31/2013
36 Months From Approved
10/31/2013
472
0
472
8,305
0
8,305
0
0
0
The passage of the Electricity Modernization Act of 2005 (EPACT 2005)added to the CommissionÂs efforts by giving it the authority to strengthen the reliability of the interstate grid through the grant of new authority pursuant to section 215 of the Federal Power Act (FPA) which provides for a system of mandatory Reliability Standards developed by the Electric Reliability Organization (ERO), established by FERC, and enforced by the ERO and Regional Entities.
These regional Reliability Standards allow for the continuation of certain reliability practices that are in effect in the Western Interconnection. The Western Electricity Coordinating Council (WECC) is responsible for coordinating and promoting electric system reliability. In addition to promoting a reliable electric power system in the Western Interconnection, WECC supports efficient competitive power markets, assures open and non-discriminatory transmission access among members, provides a forum for resolving transmission access disputes, and provides an environment for coordinating the operating and planning activities of its members. The WECC region encompasses a vast area of nearly 1.8 million square miles. It is the largest and most diverse of the ten regional councils of the North American Electric Reliability Council (NERC). WECCÂs service territory extends from Canada to Mexico. It includes the provinces of Alberta and British Columbia, the northern portion of Baja California, Mexico, and all or portions of the 14 western states in between. Transmission lines span long distances connecting the Pacific Northwest with its abundant hydroelectric resources to the arid Southwest with its large coal-fired and nuclear resources. WECC and the nine other regional reliability councils were formed due to national concern regarding the reliability of the interconnected bulk power systems, the ability to operate these systems without widespread failures in electric service, and the need to foster the preservation of reliability through a formal organization. The Commission in accordance with section 215(d)(2) of the Federal Power Act (FPA)has approved the regional Reliability Standards.
In RM09-19-000(NOPR) FERC proposes to approve regional Reliability Standard IRO-006-WECC-1 (Qualified Transfer Path Unscheduled Flow Relief). The purpose of IRO-006-WECC-1 is to mitigate transmission overloads due to unscheduled flow on Qualified Transfer Paths. Under the Reliability Standard, reliability coordinators are responsible for initiating schedule curtailments and balancing authorities are responsible for implementing curtailments. FERC has concerns because of the dichotomies between the proposed regional Reliability Standard and the corresponding NERC standard and in particular (1)how will entities know whether to follow the national or regional Standard in a given situation; (2) how the webSAS tool will work with respect to national and regional Standard; (3) potential reliability impact of reliability coordinators' inability to request curtailments and (4)WECC's and NERC's reliance on regional Reliability Standard TOP-007-WECC-1 to ensure that entities manage power flows using steps one through three of the Mitigation Plan prior to requesting curtailments.
There is a program increase of 72 hours proposed in the NOPR in Docket RM09-19-000. This NOPR proposes to approve a new regional Reliability Standard, IRO-006-WECC-1, which will replace currently effective regional Reliability Standard IRO-STD-006-0 approved by the Commission on June 8, 2007. Rather than creating entirely new requirements, the proposed regional Reliability Standard instead modifies and improves the existing regional Reliability Standard governing qualified transfer path unscheduled flow relief. Thus, this proposed rulemaking imposes a minimal additional burden on the affected entities.
In modifying the regional Reliability Standard, WECC has eliminated the reference to the Mitigation Plan, included in both the NERC standard, IRO-006-4, and the currently effective WECC standard. The Mitigation Plan includes nine steps to address unscheduled flows; steps four and above requiring varying levels of curtailments of transactions. Requirement R1 of proposed IRO-006-WECC-1 provides that Â[u]pon receiving a request of Step 4 or greater  from the Transmission Operator of a Qualified Transfer Path, the Reliability Coordinator shall approve  or deny that request within five minutes, however, steps one through three are no longer referenced in IRO-006-WECC-1 or in the related regional Standard TOP-007-WECC-1.
On the other hand, NERC Reliability Standard IRO-006-4 continues to specifically reference the Mitigation Plan with regard to transmission loading relief in the Western Interconnection. However, the Mitigation Plan has not been updated to include the requirement that the reliability coordinator act on a request for relief within five minutes, an improvement contained in WECCÂs proposed IRO-006-WECC-1. Likewise, the Mitigation Plan continues to reference and require action by Âreceivers, while that term is removed from the proposed WECC regional Reliability Standard, in conformance with the CommissionÂs directive in the June 8, 2007 Order.
Because of these dichotomies between the proposed regional Reliability Standard and the corresponding NERC Standard, the Commission has several areas of concern regarding how the proposed regional Standard would work in practice to ensure Reliable Operation in the Western Interconnection. Specifically, the Commission is concerned with: (1) how entities will know whether to follow the national or regional Standard in a given situation; (2) WECCÂs and NERCÂs reliance on TOP-007-WECC-1 to ensure that entities manage power flows using steps one through three of the Mitigation Plan prior to requesting curtailments; (3) how the webSAS tool will work with respect to the national and regional Standard; and (4) the potential reliability impact of reliability coordinators inability to request curtailments.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
NERC_IRO-006-WECC-1_6_17_09.pdf
RM09-15-000 OMB Justification.doc
Madatory Reliability Standards for the Western Electricity Coordinating Council