Rd17-1 Naesb

NORTH AMERICAN ENERGY STANDARDS BOARD

801 Travis, Suite 1675 • Houston, Texas 77002 • Phone: (713) 356-0060 • Fax: (713) 356-0067
email: [email protected] • Web Site Address: www.naesb.org

March 27, 2017
Filed Electronically
The Honorable Kimberly D. Bose
Secretary
Federal Energy Regulatory Commission
888 First Street N.E., Room 1A
Washington, D.C. 20426
RE:

NAESB Status Report on the Reservation of WEQ-006 Manual Time Error Correction Business Practice
Standards (Docket Nos. RM05-5-000 and RD17-1-000)

Dear Ms. Bose:
The North American Energy Standards Board ("NAESB") voluntarily submits this report to the Federal Energy
Regulatory Commission ("FERC" or "Commission") regarding standards development by the NAESB Wholesale
Electric Quadrant (“WEQ”) corresponding to efforts by the North American Electric Reliability Corporation
(“NERC”) to retire Reliability Standards BAL-004-0 Time Error Correction, approved by the Commission via letter
order on January 18, 2017 in Docket No. RD17-1-000. The purpose of this report is to inform the Commission that
NAESB has reserved the complementary business practice standards, WEQ-006 Manual Time Error Correction.
The reservation of the standards will be reflected in the next publication of the NAESB WEQ Business Practice
Standards, Version 003.2, tentatively scheduled for release later this year. This filing is intended to be informational
only. NAESB will make a subsequent filing with the Commission following the publication of the NAESB WEQ
Business Practice Standards Version 003.2 that will reflect the reservation of the WEQ-006 Manual Time Error
Correction Business Practice Standards.
The cover letter and report are being filed electronically in Adobe Acrobat® Portable Document Format (.pdf), with
each enclosure bookmarked separately. The entire filing is also available on the NAESB web site (www.naesb.org).
Please feel free to call the office at (713) 356-0060 or refer to the NAESB website (www.naesb.org) should you
have any questions or need additional information regarding the standards development effort.

Respectfully submitted,

Rae McQuade
Ms. Rae McQuade
President & COO, North American Energy Standards Board
cc without enclosures:

Acting Chairman Cheryl LaFleur, Federal Energy Regulatory Commission
Commissioner Colette Honorable, Federal Energy Regulatory Commission
Mr. Michael Bardee, Director, Office of Electric Reliability, Federal Energy Regulatory
Commission
Mr. David Morenoff, General Counsel of the Commission, Federal Energy Regulatory
Commission

NORTH AMERICAN ENERGY STANDARDS BOARD

801 Travis, Suite 1675 • Houston, Texas 77002 • Phone: (713) 356-0060 • Fax: (713) 356-0067
email: [email protected] • Web Site Address: www.naesb.org

March 27, 2017
Page 2

Mr. Michael Goldenberg, Senior Attorney, Office of General Counsel, Federal Energy
Regulatory Commission
Ms. Jamie L. Simler, Director, Office of Energy Market Regulation, Federal Energy
Regulatory Commission
Mr. J. Arnold Quinn, Director, Office of Energy Policy and Innovation, Federal Energy
Regulatory Commission
Mr. Michael Desselle, Chairman and CEO, North American Energy Standards Board
Mr. Jonathan Booe, Executive Vice President & CAO, North American Energy Standards
Board
Mr. William P. Boswell, General Counsel, North American Energy Standards Board
Mr. Gerry W. Cauley, President and Chief Executive Officer, North American Electric
Reliability Corporation
Mr. Mark Lauby, Senior Vice President and Chief Reliability Officer, North American
Electric Reliability Corporation
Mr. Charles A. Berardesco, Senior Vice President, General Counsel, and Corporate
Secretary, North American Electric Reliability Corporation
Enclosures (all documents and links are available publically on the NAESB website – www.naesb.org)
Appendix A

Links to Meeting Minutes, Comments, Work Papers and Voting Records

Appendix B

List of Executive Committee Minutes and Available Transcripts

Appendix C

Membership Ratification

Appendix C

NAESB Process to Develop and Adopt Standards

Status Report of the North American Energy Standards Board
NAESB WEQ-006 Manual Time Error Correction Business Practice Standards
(Docket Nos. RM05-5-000 and RD17-1-000)
March 27, 2017
Page 1 of 2

UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
Standards for Business Practices
And Communication Protocols for Public Utilities
WEQ-006 Manual Time Error Correction

)
)
)
)

Docket No. RM05-5-000

Docket No. RD17-1-000

The North American Energy Standards Board ("NAESB") is voluntarily submitting this report to the
Federal Energy Regulatory Commission (“FERC” or “Commission”) to inform the Commission of recent standards
development efforts undertaken by the NAESB Wholesale Electric Quadrant (“WEQ”) related to WEQ-006 Manual
Time Error Correction Business Practice Standards. This standards development activity supports corresponding
efforts by the North American Electric Reliability Corporation (“NERC”) to retire Reliability Standard BAL-004
Time Error Correction, approved by the Commission via letter order on January 18, 2017 in Docket No. RD17-1000. 1 NAESB initiated standards development in response to a request submitted by NERC, which resulted in the
reservation of the WEQ-006 Manual Time Error Correction Business Practice Standards as well as corresponding
modifications to WEQ-000 Abbreviations, Acronyms, and Definition of Terms Business Practice Standards. These
changes will be reflected in the NAESB WEQ Business Practice Standards Version 003.2, tentatively scheduled for
publication later this year.

NAESB will make an informational filing with the Commission following the

publication of the new version of the NAESB WEQ Business Practice Standards. The purpose of this report is to
provide the Commission with information on as well as the outcome of the specific standards development effort
related to the reservation of WEQ-006 Manual Time Error Correction.
On February 2, 2016, NERC submitted Standard Request R16002 to NAESB. In the request, NERC noted
its intentions to retire Reliability Standard BAL-004 Time Error Correction and proposed NAESB consider similar
actions regarding the complimentary business practice standards, WEQ-006 Manual Time Error Correction. The
WEQ Business Practices Subcommittee (BPS) met and preliminarily reviewed the request on March 1, 2016. At
that meeting, the subcommittee decided to postpone development of a recommendation to support the request until
the NERC Board of Trustees took action regarding the proposed retirement of the Reliability Standard BAL-004
Time Error Correction, which subsequently occurred on November 2, 2016.
The WEQ BPS reconvened on the matter of Standards Request R16002 at its meeting on November 9,
2016. During this meeting, the WEQ BPS unanimously voted out a recommendation in support of the standards
request, proposing the reservation of WEQ-006 Manual Time Error Correction as well as corresponding
modifications to WEQ-000 Abbreviations, Acronyms, and Definition of Terms. During the formal comment period,
one set of comments was submitted by MISO proposing consistency changes. In response, the WEQ BPS submitted

1

Letter Order, Petition of the North American Electric Reliability Corporation for Approval of Retirement of
Currently-Effective Reliability Standard BAL-004-0, FERC Docket Nos. RD17-1-000 (January 18, 2017).

Status Report of the North American Energy Standards Board
NAESB WEQ-006 Manual Time Error Correction Business Practice Standards
(Docket Nos. RM05-5-000 and RD17-1-000)
March 27, 2017
Page 2 of 2
late formal comments proposing revisions to incorporate the modifications put forward by MISO as well as
additional changes for accuracy purposes. On February 21, 2017, the WEQ Executive Committee unanimously
adopted the recommendation as revised by the formal comments of the WEQ BPS. NAESB membership ratified the
proposed standard changes on March 24, 2017.
As noted above, FERC has approved NERC’s petition to retire Reliability Standard BAL-004 Time Error
Correction, including NERC’s proposed implementation plan. NAESB is committed to working with both the
Commission and NERC to ensure a seamless industry implementation of the retirement of Reliability Standard
BAL-004 Time Error Correction Reliability Standard and the reservation of the WEQ-006 Manual Time Error
Correction. As always, NAESB will be ready to support the Commission’s direction in any manner deemed
appropriate.
For over a decade, NAESB and NERC have enjoyed a close working relationship. The organizations
regularly engage on cross-over matters impacting both commercial and reliability wholesale electric market
interests. Regarding time error correction, NAESB and NERC held discussions for well over a year, starting in 2015
prior to NERC’s submittal of the standards request. This effort is yet another example that demonstrates NAESB’s
and NERC’s ability to successfully coordinate commercial and reliability standards to better serve the wholesale
electric industry.

Status Report of the North American Energy Standards Board
NAESB WEQ-006 Manual Time Error Correction Business Practice Standards
(Docket Nos. RM05-5-000 and RD17-1-000)
March 27, 2017
Appendices

Appendices:
A. Links to Meeting Minutes, Comments, Work Papers and Voting Records
B. List of Executive Committee Minutes and Available Transcripts
C. Membership Ratification
D. NAESB Process to Develop and Adopt Standards

Status Report of the North American Energy Standards Board
NAESB WEQ-006 Manual Time Error Correction Business Practice Standards
(Docket Nos. RM05-5-000 and RD17-1-000)
March 27, 2017
Appendix A: Links to Meeting Minutes, Comments, Work Papers and Voting Records

Appendix A: Links to Meeting Minutes, Comments, Work Papers and Voting Records
Date

Link to Meeting Minutes and Voting Records

Links to Comments and Work Papers

March 1, 2016

NAESB WEQ Business Practice Subcommittee Conference Call
w/Web Conferencing:
Meeting Minutes: https://www.naesb.org/pdf4/weq_bps030116fm.docx
Attachment:
Joint BPS and OASIS Action Item List Revised March 1, 2016:
https://www.naesb.org/pdf4/weq_bps030116a1.xlsx

Work papers:
Joint BPS and OASIS Action Item List Revised February 2, 2016:
https://www.naesb.org/pdf4/weq_bps030116w1.xlsx
Action Item 11 Work Paper Revised February 2, 2016:
https://www.naesb.org/pdf4/weq_bps030116w2.docx
2.a.ii.2 Work Paper Revised February 2, 2016:
https://www.naesb.org/pdf4/weq_bps030116w3.docx
Request R16002: https://www.naesb.org/pdf4/weq_bps030116w4.doc
February 16, 2016 NERC ORS PFV Reliability Metrics Task Group Draft:
https://www.naesb.org/pdf4/weq_bps030116w5.pdf
NCEMC response to NAESB WEQ Annual Plan Item 5c – February 29, 2016:
https://www.naesb.org/member_login_check.asp?doc=weq_bps030116w6.docx

Appendix A, Page 1 of 2

Status Report of the North American Energy Standards Board
NAESB WEQ-006 Manual Time Error Correction Business Practice Standards
(Docket Nos. RM05-5-000 and RD17-1-000)
March 27, 2017
Appendix A: NAESB Process to Develop and Adopt Standards

Appendix A: Links to Meeting Minutes, Comments, Work Papers and Voting Records
Date

Link to Meeting Minutes and Voting Records

Links to Comments and Work Papers

November 9, 2016

NAESB WEQ Business Practice Standards Subcommittee Conference
Call w/Web Conferencing:
Meeting Minutes: https://www.naesb.org/pdf4/weq_bps110916fm.docx
Attachments:
R16002-WEQ 2016 AP Item 1.d Recommendation:
https://www.naesb.org/pdf4/weq_bps110916a1.docx
R16002-WEQ 2016 AP Item 1.d Recommendation Attachment:
https://www.naesb.org/member_login_check.asp?doc=weq_bps1109
16a2.docx

Work papers:
Draft R16002-2016 AP Item 1.d Recommendation November 7, 2016:
https://www.naesb.org/pdf4/weq_bps110916w1.docx
R16002: https://www.naesb.org/pdf4/weq_bps110916w2.doc
Draft 16002-2016 AP Item 1.d Recommendation Attachment November 7, 2016:
https://www.naesb.org/member_login_check.asp?doc=weq_bps110916w3.docx
Original WEQ-006 Definitions:
https://www.naesb.org/member_login_check.asp?doc=weq_bps110916w4.docx
Comments:
Recommendation to support WEQ 2016 Annual Plan Item 1.d / R16002 – Develop, modify or
delete business practices standards to support NERC activities related to NERC Time Error
Correction (BAL-004-0): https://www.naesb.org/pdf4/weq_2016_ap1d_r16002_rec.docx
Recommendation Attachment:
https://www.naesb.org/member_login_check.asp?doc=weq_2016_ap1d_r16002_rec_attach1.d
ocx
Request for Formal Comments – due December 9, 2016:
https://www.naesb.org/pdf4/weq_110916_reqcom.doc
Comments Submitted by K. Spontak, MISO:
https://www.naesb.org/pdf4/weq_110916_miso.docx
WEQ BPS Late Formal Comments – Attachment:
https://www.naesb.org/member_login_check.asp?doc=weq_110916_weq_bps_late_attac
hment.docx

Appendix A, Page 2 of 2

Status Report of the North American Energy Standards Board
NAESB WEQ-006 Manual Time Error Correction Business Practice Standards
(Docket Nos. RM05-5-000 and RD17-1-000)
March 27, 2017
Appendix B: List of Executive Committee Minutes and Available Transcripts

Appendix B: List of WEQ Executive Committee Minutes and Available Transcripts
Date

Link to Meeting Minutes

Work Papers

February 21, 2017

NAESB WEQ Executive Committee Meeting, Richmond, VA (Held at
the Dominion)
Meeting Minutes: https://www.naesb.org/pdf4/weq_ec022117dm.docx
Attachment:
WEQ 2017 Annual Plan as approved by the WEQ EC (Redline):
https://www.naesb.org/pdf4/weq_ec022117a1.docx

WEQ EC Meeting Materials Assembled:
https://www.naesb.org/member_login_check.asp?doc=weq_ecbk022117.pdf
Supplemental Material:
Revised WEQ 2017 Annual Plan - Redline:
https://www.naesb.org/pdf4/weq_ec022117w1.docx
WEQ SRS Update Presentation:
https://www.naesb.org/pdf4/weq_ec022117w2.pptx

Transcripts from the meeting can be ordered from:
Jill Vaughan, CSR
1803 Rustic Oak Ln
Seabrook, Texas 77586
Phone: 281-853-6807

Appendix B, Page 1 of 1

Status Report of the North American Energy Standards Board
NAESB WEQ-006 Manual Time Error Correction Business Practice Standards
(Docket Nos. RM05-5-000 and RD17-1-000)
March 27, 2017
Appendix C: Member Ratification

Appendix C: Member Ratification
Date of Ballot

Links to Member Ratification Ballot and Results

Links to Recommendations Ratified

February 22, 2017

NAESB WEQ Member Ratification Ballot – due March 24, 2017:
https://www.naesb.org/member_login_check.asp?doc=weq_rat022217b
allot.doc
Ballot Results: https://www.naesb.org/pdf4/rat_weq032417tally.xls
Final Action WEQ 2016 Annual Plan Item 1.d/R16002: Develop,
modify or delete business practices standards to support NERC
activities related to NERC Time Error Correction (BAL-004-0), ratified
March 24, 2017:
https://www.naesb.org/member_login_check.asp?doc=fa_weq_2016_a
p1d_r16002.docx
Attachment:
https://www.naesb.org/member_login_check.asp?doc=fa_weq_20
16_ap1d_r16002_attachment.docx

Recommendation WEQ 2016 Annual Plan Item 1.d/R16002: Develop, modify or delete
business practices standards to support NERC activities related to NERC Time Error
Correction (BAL-004-0) as approved by the WEQ Executive Committee on February 21,
2017:
https://www.naesb.org/member_login_check.asp?doc=weq_rat022217_weq_2016_ap1d_r160
02_rec.docx
Attachment (Redline):
https://www.naesb.org/member_login_check.asp?doc=weq_rat022217_weq_2016_ap1d_
r16002_rec_attachment_redline.docx
Attachment (Clean):
https://www.naesb.org/member_login_check.asp?doc=weq_rat022217_weq_2016_ap1d_
r16002_rec_attachment_clean.docx

Appendix C, Page 1 of 1

Status Report of the North American Energy Standards Board
NAESB WEQ-006 Manual Time Error Correction Business Practice Standards
(Docket Nos. RM05-5-000 and RD17-1-000)
March 27, 2017
Appendix D: NAESB Process to Develop and Adopt Standards

The NAESB Standards Development Process
NAESB is focused on proposing, considering, and adopting voluntary standards and model business practices
that will have a significant and lasting impact on all aspects of the natural gas and electricity marketplaces. As a
result of the standards NAESB adopts, it is expected that the industry will operate more efficiently and effectively,
benefiting both the industry and its customers. At the same time, it must be acknowledged that NAESB standards
may constitute a change in the way parties do business, with an accompanying effect on the use and allocation of
resources.
NAESB’s policy is to move at a deliberate pace, consistent with its annual plan(s), thus permitting those
affected by its standards, especially those standards adopted as regulations by the Federal Energy Regulatory
Commission (FERC) or other regulatory bodies, to assimilate them as part of their business practices. To this end,
NAESB will carefully consider whether proposed standards are both timely and necessary. In particular, it will try to
avoid adopting and implementing new standards, however beneficial, before the industry is able to reasonably make
use of them.
The standards development process is governed by the annual plan, and items can be included in the plan or
modified only with Board approval. The plan typically reflects requests from NAESB members, government
agencies, and other interested parties. In approving the annual plan, the Board considers the availability of resources,
including the NAESB budget and staff and the availability of industry volunteers. New requests received throughout
the year are either considered part of the existing annual plan or as new items that require Board approval.
The standards development process begins with an annual plan item or a triaged and approved request. Triage is
a process used by each quadrant of the Executive Committee (EC) to determine whether a request is within scope,
which quadrant(s) it applies to, which subcommittee(s) it should be referred to, and what priority it should be
assigned. Triage is carried out by EC members appointed by the EC chair. Triage recommendations are submitted to
the en banc EC and require EC approval, and may require Board approval if there are scope questions or if a
modification of the annual plan is required.
Once the triage process is completed, the subcommittees—more than one are normally involved in standards
recommendations—review the request, compare it to existing standards, and prepare recommendations that may
take the form of new or modified standards or interpretations. Participation in EC subcommittees is open to any
interested party regardless of membership status. All subcommittee participants may vote; voting is balanced by
segment and quadrant. All votes are public.
When the recommendation is complete, it is made available for a thirty-day industry comment period. The
recommendation and comments are then forwarded to the EC, which considers the recommendation, makes any
changes it deems necessary, and takes a vote. A recommendation must receive an affirmative vote of at least 67
percent from each applicable quadrant EC and 40 percent from each of the segments of the applicable quadrant(s).
After passage by the EC, the recommendation must be ratified by the NAESB members. An affirmative vote of
67 percent of the members of the applicable quadrant(s) is required for ratification. After ratification, standards and
modifications are considered final actions and will be published in the next version of NAESB standards.
All NAESB quadrants follow the same development process described herein. The process has been followed
by the WGQ since 1994 and has been used to develop more than five hundred standards that have been incorporated
by reference into federal regulations.

Appendix D, Page 1 of 4

Status Report of the North American Energy Standards Board
NAESB WEQ-006 Manual Time Error Correction Business Practice Standards
(Docket Nos. RM05-5-000 and RD17-1-000)
March 27, 2017
Appendix D: NAESB Process to Develop and Adopt Standards

North American Energy Standards Board
Standards Development Process Flow Chart

Request for Standard is forwarded to the NAESB
Office from any group. The request may include
fully developed recommended standards.

Board provides approved Annual
Plan to the EC

Triage Subcommittee considers request and
prepares a triage disposition

Executive Committee (EC) approves triage
disposition and specific Quadrant EC(s) to
which the work is assigned, directs its work
or directs work on the annual plan item.

EC Subcommittees consider request or
Annual Plan Item as directed by EC.

Recommendations including new or
modified standards are prepared by EC
Subcommittees

Industry comment on EC Subcommittee(s)
recommendations

Executive Committee for approval of
recommendation

Membership Ratification

Posting as Final Action, Publication of
Standards, Filings with FERC

Appendix D, Page 2 of 4

Status Report of the North American Energy Standards Board
NAESB WEQ-006 Manual Time Error Correction Business Practice Standards
(Docket Nos. RM05-5-000 and RD17-1-000)
March 27, 2017
Appendix D: NAESB Process to Develop and Adopt Standards

Flexibility
NAESB recognizes that flexibility is necessary as standards are developed to address regional concerns or to
incorporate variances to accommodate operational or structural differences. Several WEQ standards incorporate
regional or operational differences for both Version 0 and Version 1. There is a high threshold for incorporating
such variances in a standard; the subcommittee(s) in drafting the standard, the EC in approving the subcommittee
recommendation, and the membership in approving the standard must all agree that such variance is necessary.
Nonetheless, NAESB procedures are well suited to take into account operational and regional differences.
Transparency
All NAESB meetings are open for attendance and participation by any interested party, with the exception of
executive sessions of the Board or Managing Committee for purposes of discussing personnel, compensation or
legal issues. Meeting announcements and agendas are posted in advance to permit the widest possible participation.
Conference-calling capability is available for all meetings and web casting is available for most. Those intending to
attend a meeting in person or by telephone are asked to notify NAESB by a specific date to permit adequate meeting
planning.
Transcripts are made of all Board of Directors and EC meetings, and may be made of other meetings that are
expected to be controversial. Transcripts are maintained in the NAESB office and are provided to regulatory
agencies for their internal use. All other interested parties can purchase transcripts from the relevant transcription
service.
Coordination with NERC
For business practice standards development for the WEQ, if it is determined by NERC and NAESB Executive
Management that joint development is needed by NERC and NAESB, the NERC-NAESB Coordination Joint
Development Process is implemented. 1 This process requires that the appropriate NAESB Subcommittee and
NERC Standards drafting team work together to develop reliability standards and business practices.
The Joint Interface Committee of NAESB, NERC and the ISO-RTO Council (“JIC”) were dissolved as part of
the agreement to create the Independent Grid Operator segment of the WEQ. The joint development process
between NAESB and NERC is being used to ensure appropriate coordination. The ISOs and RTOs have strong
decision-making roles in both NERC and NAESB, and thus with the use of the joint development process, the JIC
was no longer necessary.
Copyright and Accessibility of Standards and Work Products
All published NAESB standards and work products are protected under United States Copyright laws, and
NAESB alone retains the rights to publication, reproduction, display and distribution of the its published works
consistent with the NAESB Copyright Policy. The NAESB standards and protected work products are accessible to
members at no cost as a benefit of their membership. Non-members can purchase the standards and work products
as a full version, or they can purchase individual final actions. Non-members can also access the standards at no
cost by requesting an evaluation copy. A materials order form from the NAESB web site for ordering standards or
for instructions on accessing standards for evaluation may be downloaded from the NAESB website homepage
(www.naesb.org).
The NAESB Copyright Policy and a list of entities with recorded valid access to the standards and work
products can be found through the following hyperlink: https://naesb.org/pdf2/copyright.pdf. Additionally, a list of
Federal Energy Regulatory Commission jurisdictional entities without record of valid access to the most recently
1

The NERC-NAESB Coordination Joint Development Process was submitted to the Commission on February 17, 2006 in
Attachment C of the Progress Report on NAESB Activities impacting Docket No. RM05-5-000, “Standards for Business
Practices and Communication Protocols for Public Utilities”: http://www.naesb.org/doc_view2.asp?doc=ferc021706.pdf.
Appendix D, Page 3 of 4

Status Report of the North American Energy Standards Board
NAESB WEQ-006 Manual Time Error Correction Business Practice Standards
(Docket Nos. RM05-5-000 and RD17-1-000)
March 27, 2017
Appendix D: NAESB Process to Develop and Adopt Standards
mandated NAESB WGQ 2 and WEQ 3 Business Practice Standards can be found through the following two
hyperlinks.
•
•

WGQ Entities: https://naesb.org/pdf4/wgq_jurisdictional_entities_without_recorded_access.pdf
WEQ Entities: https://naesb.org/pdf4/weq_jurisdictional_entities_without_recorded_access.pdf

2

Per 18 C.F.R. §284.12(a), the NAESB WGQ Business Practice Standards apply to an interstate pipeline that (1) transports gas
on behalf of any intrastate pipeline or any local distribution company in accordance with 18 C.F.R. §284.101 OR (2) transports
on behalf of others in accordance with 18 C.F.R. §284.221.
3
Per 18 C.F.R. §18.1(a), the NAESB WEQ Business Practice Standards apply to all public utilities that own, operate, or control
facilities used for the transmission of electric energy in interstate commerce or for the sale of electric energy at wholesale in
interstate commerce and any non-public utility that seeks voluntary compliance with jurisdictional transmission tariff reciprocity
conditions.
Appendix D, Page 4 of 4