Petition Retire Rel Standared TOP-007-WECC-1a

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 RETIREMENT OF
REGIONAL RELIABILITY STANDARD TOP-007-WECC-1a
Sandy Mooy
Associate General Counsel
Chris Albrecht
Legal Counsel
Western Electricity Coordinating Council
155 North 400 West, Suite 200
Salt Lake City, UT 84103
(801) 582-0353
[email protected]
[email protected]
Counsel for the Western Electricity
Coordinating Council

Charles A. Berardesco
Senior Vice President and General Counsel
Holly A. Hawkins
Associate General Counsel
Shamai Elstein
Senior Counsel
Gizelle Wray
Associate Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
[email protected]
[email protected]
[email protected]
[email protected]
Counsel for the North American Electric
Reliability Corporation
March 23, 2016

TABLE OF CONTENTS

I.

NOTICES AND COMMUNICATIONS ............................................................................ 2

II.

BACKGROUND ................................................................................................................ 2
A.

Regulatory Framework ....................................................................................................... 2

B.

Procedural History .............................................................................................................. 4

III.

JUSTIFICATION FOR APPROVAL................................................................................. 5

A. TOP-007-WECC-1a, Requirement R1 is Addressed by Continent Wide Reliability
Standards ..................................................................................................................................... 5
B. TOP-007-WECC-1a, Requirement R2 is Addressed by Continent Wide Reliability
Standards ..................................................................................................................................... 9
IV.

EFFECTIVE DATE .......................................................................................................... 13

V.

CONCLUSION ................................................................................................................. 14

EXHIBITS
Exhibit A

Implementation Plan

Exhibit B

Order No. 672 Criteria

Exhibit C

Summary of Retirement History and Complete Record of Retirement Development

ii

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 A N D WESTERN
ELECTRICITY COORDINATING COUNCIL FOR APPROVAL OF RETIREMENT OF
REGIONAL RELIABILITY STANDARD TOP-007-WECC-1a
The North American Electric Reliability Corporation (“NERC”)1 and the Western
Electricity Coordinating Council (“WECC”) respectfully request that the Federal Energy Regulatory
Commission (“FERC” or the “Commission”) approve, in accordance with Section 215(d)(1) of the
Federal Power Act (“FPA”) 2 and Section 39.5 of the Commission’s Regulations,3 the retirement
of WECC regional Reliability Standard TOP-007-WECC-1a – System Operating Limits.4 The
primary purpose of this regional Reliability Standard is to ensure that actual flows and associated
scheduled flows on major WECC transfer paths do not exceed System Operating Limits (“SOL”)
for more than 30 minutes. As discussed below, however, the issues addressed by regional
Reliability Standard TOP-007-WECC-1a are addressed by continent-wide Reliability Standards,
making the regional Reliability Standard redundant and unnecessary. The retirement of regional
Reliability Standard TOP-007-WECC-1a will thus have no adverse effect on reliability of the Bulk
1

NERC has been certified by the Commission as the electric reliability organization (“ERO”) in accordance
with Section 215 of the Federal Power Act. The Commission certified NERC as the ERO in its order issued July 20,
2006 in Docket No. RR06-1-000. North American Electric Reliability Corp., 116 FERC ¶ 61,062 (2006) (“ERO
Certification Order”).
2
16 U.S.C. § 824o (2012).
3
18 C.F.R. § 39.5 (2014).
4
Unless otherwise designated herein, all capitalized terms shall have the meaning set forth in the Glossary of
Terms Used in NERC Reliability Standards, available at http://www.nerc.com/files/Glossary_of_Terms.pdf.

1

Power System and is in the public interest.
The WECC Board of Directors approved the retirement of TOP-007-WECC-1a on
December 2, 2015. On February 11, 2016, the NERC Board of Trustees approved the retirement
of the regional Reliability Standard.
I.

NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the following: 5

Shamai Elstein*
Senior Counsel
Gizelle Wray*
Associate Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
[email protected]
[email protected]
II.

Sandy Mooy*
Associate General Counsel
Chris Albrecht*
Legal Counsel
Western Electricity Coordinating Council
155 North 400 West, Suite 200
Salt Lake City, UT 84103
(801) 582-0353
[email protected]
[email protected]

BACKGROUND

A. Regulatory Framework
By enacting the Energy Policy Act of 2005, 6 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 duty of certifying an ERO that would be charged with developing and enforcing
mandatory Reliability Standards, subject to Commission approval. Section 215(b)(1) of the FPA
states that all users, owners, and operators of the Bulk-Power System in the United States will be

5

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 (2014), to allow the inclusion of
more than two persons on the service list in this proceeding.
6
16 U.S.C. § 824o (2012).

2

subject to Commission-approved Reliability Standards. 7
Section 39.5(a) of the Commission’s regulations requires the ERO to file with the
Commission for its approval each Reliability Standard that the ERO proposes to become mandatory
and enforceable in the United States, each modification to a Reliability Standard that the ERO
proposes to be made effective, and each Reliability Standard that the ERO proposes for retirement.
The Commission has the regulatory responsibility to approve Reliability Standards that protect the
reliability of the Bulk Power System and to ensure that such standards are just, reasonable, not
unduly discriminatory or preferential, and in the public interest. Pursuant to Section 215(d)(2) of
the FPA and Section 39.5(c)(1) 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
and to the technical expertise of a Regional Entity, like WECC, that is organized on an
Interconnection-wide basis with respect to a regional Reliability Standard to be applicable within
that Interconnection. 8
A regional Reliability Standard proposed by a Regional Entity must meet the same standards
that NERC’s Reliability Standards must meet, i.e., the regional Reliability Standard must be shown
to be just, reasonable, not unduly discriminatory or preferential, and in the public interest.9 Order
No. 672 also requires additional criteria that a regional Reliability Standard must satisfy. A regional
difference from a continent-wide Reliability Standard must either be: (1) more stringent than the

7

See Section 215(b)(1)(“All users, owners and operators of the bulk-power system shall comply with
reliability standards that take effect under this section.”) (“Letter Order”).
8
18 C.F.R. § 39.5 (2014).
9
Section 215(d)(2) of the FPA and 18 C.F.R. §39.5(a).

3

continent-wide Reliability Standard (which includes a regional standard that addresses matters that
the continent-wide Reliability Standard does not), or (2) necessitated by a physical difference in the
Bulk Power System. 10
B. Procedural History
On December 17, 2014, consistent with WECC’s Reliability Standards Development
Process, WECC staff submitted a Standards Authorization Request (“SAR”) to retire TOP-007WECC-1a. The SAR stated that the entire reliability-related substance of TOP-007-WECC-1a is
redundant to NERC’s continent-wide Reliability Standards and is no longer needed to support
reliability in WECC. On January 8, 2015, the WECC Standards Committee approved the SAR and
assigned a drafting team to review the regional Reliability Standard in comparison with current
NERC Reliability Standards both in effect and those pending regulatory approval. 11
On March 27, the WECC drafting team completed the review and posted their justification
for retirement for a 45-day comment period. The drafting team received comments from three
entities representing five of the eight WECC Standards Voting Sectors. After considering the
comments, the drafting team modified its justification for retirement and posted it for a second 45day comment period on July 1, 2015. After considering the comments on the second posting, the
drafting team submitted the proposed retirement to the WECC Standards Committee for ballot.
On August 12, 2015, the WECC Standards Committee agreed with the Drafting Team’s
10

Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the
Establishment, Approval, and Enforcement of Electric Reliability Standards, Order No. 672, FERC Stats. & Regs. ¶
31,204, at P 291, order on reh’g, Order No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006).
11
The drafting team consisted of representatives from PEAK Reliability, Arizona Public Service, Smart Wires,
Inc., Tri-State Generation and Transmission Association, Colorado Springs Utility, Public Service Company of
Colorado (Xcel Energy), and Bonneville Power Administration.

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proposal to retire TOP-007-WECC-1a and posted it for ballot. On August 13, 2015, NERC posted
the proposed retirement for a 45-day public comment period. On October 8, 2015, the WECC ballot
was unanimously approved with no comments.
On December 2, 2015, the WECC Board of Directors approved the retirement of TOP-007WECC-1a and submitted the proposal to the NERC Board of Trustees for approval. On February
11, 2016, the NERC Board of Trustees approved the retirement of TOP-007-WECC-1a.
III.

JUSTIFICATION FOR APPROVAL
As noted above, regional Reliability Standard TOP-007-WECC-1a, which consists of two

Requirements, is designed to ensure that actual flows and associated scheduled flows on major
WECC transfer paths do not exceed SOLs for more than 30 minutes. As explained below, however,
the reliability need to ensure that Transmission Operators in the Western Interconnection do not
exceed SOLs on major transfer paths and to take corrective action when necessary is adequately
addressed by continent-wide Reliability Standards.

Regional Reliability Standard TOP-007-

WECC-1a is thus redundant and unnecessary and may be retired without creating any reliability
issues in WECC.
The following is a detailed explanation of the manner in which the continent-wide
Reliability Standards address the reliability issues in TOP-007-WECC-1a.
A. TOP-007-WECC-1a, Requirement R1 is Addressed by Continent Wide Reliability
Standards
Requirement R1 of TOP-007-WECC-1a provides that when the actual power flow exceeds
an SOL for a Transmission path, the Transmission Operators must take immediate action to reduce
the power flow across the path such that at no time shall the power flow for the Transmission path
5

exceed the SOL for more than 30 minutes. The WECC drafting team determined, however, that a
separate, regional Reliability Standard for Transmission Operators in the Western Interconnection
is not necessary to address this reliability issue as it is adequately covered by continent-wide
Reliability Standards currently in effect as well as the continent-wide Reliability Standards
approved in Order No. 817 12 that will supersede the currently-effective standards on April 1, 2017.
Specifically, currently-effective Reliability Standards TOP-002-2.1b, TOP-004-2, and
TOP-008-1 collectively require Transmission Operators to: (1) plan not to exceed SOLs; (2) operate
within all SOLs; (3) act to prevent violations of SOLs; and (4) take immediate action if an SOL is
exceeded, as follows:
Plan to Meet SOLs: Similar to the requirement in TOP-007-WECC-1a, currently-effective
Reliability Standard TOP-002-2.1b, Requirement R10 provides that Transmission Operators shall
plan to meet all SOLs and Interconnection Reliability Operating Limits (“IROLs”). Further, TOP002-2.1b R1, R4, R5, and R11, require relevant entities to coordinate to help ensure no SOL will
be exceeded. Specifically, Transmission Operators are required to work with Balancing Authorities
to maintain plans to ensure reliable operations and the ability to meet scheduled system
configuration.
Operate within SOLs: Currently-effective Reliability Standard TOP-004-2, Requirements
R1, R2 and R3 provide that Transmission Operators shall operate within IROLs and SOLs so that
instability, uncontrolled separation, or cascading outages will not occur. Further, under TOP-004-

12

Transmission Operations Reliability Standards and Interconnection Reliability Operations and
Coordination Reliability Standards, 153 FERC ¶ 61,178 (2015) (“Order 817”).

6

2, if a Transmission Operator enters an unknown operating state (i.e. any state for which valid
operating limits have not been determined), it will be considered an emergency and the
Transmission Operator is required to restore operations to the reliable power system limits within
30 minutes. TOP-004-2, Requirement R6 also requires Transmission Operators, individually and
jointly with other Transmission Operators, to develop, maintain, and implement formal policies and
procedures to provide for transmission reliability. These policies and procedures must address the
execution and coordination of activities that impact inter- and intra-Regional reliability, including
monitoring and controlling voltage levels, real and reactive power flows, switching transmission
elements, planned outages of transmission elements, and responding to IROL and SOL violations.
These requirements thus provide a greater level of planning on behalf of the Transmission Operators
as compared to TOP-007-WECC-1a.
Act to Prevent and Mitigate SOL Exceedances: As with TOP-007-WECC-1a, the currentlyeffective continent-wide standards require Transmission Operators to take actions to mitigate SOL
and IROL violations.

Reliability Standard TOP-008-1 states that a Transmission Operator

experiencing or contributing to an IROL or SOL violation shall take immediate steps to relieve the
condition, which may include shedding firm load.

Further, Requirement R2 provides that

Transmission Operators shall operate to prevent the likelihood that a disturbance, action, or inaction
will result in an IROL or SOL violation. Also, in instances where there is a difference in derived
operating limits, the Transmission Operator must always operate the Bulk Power System to the
most limiting parameter. Lastly, TOP-008-1, Requirement R3 provides that the Transmission
Operator disconnect the affected facility if the overload on a transmission facility or abnormal

7

voltage or reactive condition persists and equipment is endangered.
Commission-approved Reliability Standards TOP-001-3 and TOP-002-4, which supersede
the currently-effective standard discussed above on April 1, 2017, will continue to cover these
issues and support the retirement of the regional Reliability Standard. Reliability Standard TOP001-3 is designed to prevent instability, uncontrolled separation, or cascading outages that adversely
impact the reliability of the Interconnection, in part, by ensuring that Transmission Operators
operate within all SOLs and take prompt action to prevent or mitigate SOL exceedances. TOP001-3 provides Transmission Operators with the authority to take action, or direct the actions of
others, to maintain reliability during Real-time operations. The standard includes Real-time
monitoring and Real-time assessment requirements to preserve reliability and ensure that applicable
entities identify and address all SOL exceedances.
Specifically, TOP-001-3, Requirement R1 requires Transmission Operators to maintain the
reliability of its Transmission Operator Area via its own actions or by issuing Operating Instructions
with same-day or Real-time operations time horizons.

TOP-001-3, Requirement R10 also

specifically requires a Transmission Operator to determine if there are any SOL exceedances (1)
within its Transmission Operator Area by monitoring facilities and the status of Special Protection
Systems and (2) outside its Transmission Operator Area by obtaining and utilizing status, voltages,
and flow data for facilities and the status of Special Protection Systems. Additionally, TOP-001-3,
Requirement R13 requires Transmission Operators to ensure that a Real-time Assessment is
performed at least once every 30 minutes and Requirement R14 requires each Transmission
Operator to initiate its Operating Plan to mitigate an SOL exceedance identified as part of its Real-

8

time monitoring or Real-time assessment. Finally, TOP-001-3, Requirement R18 provides that
Transmission Operators must operate to the most limiting parameter in instances where there is a
difference in SOLs. Collectively, the Requirements in TOP-001-3 address, in a similar manner as
TOP-007-WECC-1a, the reliability need to ensure that Transmission Operators prevent
exceedances of SOLs and take immediate actions if power flows exceed an SOL.
Additionally, the purpose of Commission-approved Reliability Standard TOP-002-4 is to
help ensure that Transmission Operators and Balancing Authorities have plans for operating within
specified limits.

Similar to currently-effective TOP-004-2 and TOP-002-2.1b, TOP-002-4

addresses next-day planning and provides for the necessary notifications and coordination between
various functional entities. TOP-002-4, Requirement R1 requires each Transmission Operator to
have an Operational Planning Analysis that will allow it to assess whether its planned operations
for the next day within its Transmission Operator Area will exceed any of its SOLs. TOP-002-4,
Requirement R2 requires each Transmission Operator to have operating plans for next-day
operations to address potential SOL exceedances identified as a result of its Operational Planning
Analysis. Finally, TOP-002-4, Requirement R3 requires each Transmission Operator to notify
entities identified in the Operating Plan required by Requirement R2 as to the their role in those
plans. This standard will thus further ensure that Transmission Operators have plans to avoid
operating with power flows exceeding SOLs.
B. TOP-007-WECC-1a, Requirement R2 is Addressed by Continent Wide Reliability
Standards
Requirement R2 of TOP-007-WECC-1a requires a Transmission Operator to prevent the
Net Scheduled Interchange (“NSI”) from exceeding an SOL when the Transmission Operator
9

implements its Real-time schedules for the next hour. If the SOL decreases within 20 minutes
before the start of the hour, the Transmission Operator is required to adjust the NSI within 30
minutes to the new SOL value. The WECC drafting team determined that Requirement R2 should
be retired because: (1) Transmission Operators do not control NSI; and (2) coordination of Realtime schedules for the next-hour is covered in continent-wide Reliability Standards.
Transmission Operators Do Not Control Net Scheduled Interchange: The tasks assigned to
the Transmission Operator in TOP-007-WECC-1a, Requirement R2 do not align with the roles and
responsibilities described in the current version of the NERC Functional Model (“NERC FM”).13
The assignment of the Transmission Operator as the applicable entity to address NSI is now in
conflict with the NERC FM because the TOP does not control NSI. Of the 22 relationships with
other functional entities assigned to the Transmission Operator in the NERC FM, none address NSI
or scheduling. 14
Specifically, an Interchange Schedule cannot take place without an Interchange Transaction.
An Interchange Transaction is requested via a Request-for-Interchange, as required by the North
American Energy Standards Board (NAESB) Business Practice Standards. 15 The Request-forInterchange is implemented via an Interchange Transaction Tag or e-Tag, and communicated by
the Interchange Authority. Because the Transmission Operator is not part of the aforementioned

13

The Version 5 of the NERC FM was published in May 12, 2010. Reliability Functional Model Technical
Model Document, Version 5 (December 2009), available at:
http://www.nerc.com/pa/Stand/Functional%20Model%20Archive%201/FM_Technical_Document_V5_2009Dec1.pd
f.
14
NERC FM at p. 18. The NERC FM addresses how the relationships function between the Interchange
Coordinator, Balancing Authorities, and Transmission Service Providers in regards to Interchange Transactions.
15
North American Energy Standards Board conventions are not addressed in this filing.

10

chain, and whereas the Request-for-Interchange is generally submitted by the Purchasing-Selling
Entity, 16 and approved or denied by the Balancing Authority17 and Transmission Service
Provider, 18 it is not in the purview of the Transmission Operator to ensure the NSI does not exceed
an SOL, nor is that a reliability issue since several Reliability Standards exist that require the
Transmission Operator to operate within SOLs and to prevent and mitigate SOL exceedances, thus
preserving the reliability aspect of the Bulk Power System.
In approved NERC Reliability Standard, INT-006-4, NSI is addressed by the Balancing
Authority. The standard requires that responsible entities conduct a reliability assessment of each
Arranged Interchange before it is implemented. INT-006-4, Requirement R1 requires that each
Balancing Authority approve or deny each on time Arranged Interchange or emergency Arranged
Interchange. Requirement R1 describes those circumstances when a Balancing Authority “must”
deny an Arranged Interchange. The Balancing Authority has access to all of the information
required to perform the assigned task and is, thus, the appropriate applicable entity to carry out the
assigned task. By contrast, the Transmission Operator does not have access to each of these
informational elements and therefore should not perform the assigned task.
Further, INT-006-4 R3 specifically addresses changes to the Arranged Interchange for
reliability purposes. The requirement states that the Source Balancing Authority and the Sink
Balancing Authority receiving a Reliability Adjustment Arranged Interchange shall approve or
deny it prior to the expiration of the time period, and if the Balancing Authority denied the

16
17
18

See NAESB WEQ-004-1 and 004-2.
INT-006-4, Requirement R1.
INT-006-4, Requirement R2.

11

Reliability Adjustment Arranged Interchange, the Balancing Authority must communicate that fact
to its Reliability Coordinator no more than 10 minutes after denial.
Coordination of Real-Time Schedules for the Next-Hour is Addressed in Continent-wide
NERC Standards: Real-time schedules for the next-hour are addressed in currently-effective
Reliability Standards TOP-002-2.1b and TOP-004-2.

TOP-002-2.1b requires that current

operations plans and procedures are being prepared for reliable operations, including response to
unplanned events. Under TOP-002-2.1b, Requirement R4, the Transmission Operator is required
to coordinate its current-day plans with the Reliability Coordinator. The current day plans must
include Real-time operations (present time as opposed to future time), so that normal
Interconnection operation can proceed in an orderly and consistent manner. Further, TOP-0022.1b, Requirement R10 requires the Transmission Operator to plan to meet all SOLs and also to
operate within SOLs when operating in Real-time, irrespective of scheduling practices. In addition,
TOP-004-2, Requirement R1 requires Transmission Operators to operate within IROLs and SOLs.
Finally, TOP-002-2.1b, Requirement R11 covers any situational awareness contained within TOP007-WECC-1a Requirement R2 because it requires the Transmission Operator to perform cyclical
studies to determine potential changing SOLs.
Additionally, the TOP Reliability Standards approved in Order No. 817 will continue to
address Real-time schedules. Reliability Standard, TOP-002-4, Requirement R1 requires the
Transmission Operator to have Operational Planning Analysis to determine whether planned
operations for next day will exceed SOLs and IROLs and

Requirement R2 requires the

Transmission Operator to develop Operating Plans that address potential SOL exceedances

12

identified in its Operational Planning Analysis.

In addition, Requirement R3 requires the

Transmission Operator to notify entities identified in the Operating Plans as to their role in those
plans. Further, Requirement R14 requires each Transmission Operator to initiate its Operating
Plans to mitigate exceedances identified as part of its Real-time monitoring or Real-time
Assessment. The Operating Plans are expected to include, among other things, company-specific
system restoration plans that detail an operating procedure for blackstart units, and operating
processes for communicating restoration progress with other entities.
IV.

EFFECTIVE DATE
As the currently-effective continent-wide Reliability Standards address the issues in TOP-

007-WECC-1a, the proposed implementation plan provides that the Commission approve the
proposed retirement of TOP-007-WECC-1a to be effective on the first day of the first quarter
following Commission approval. NERC and WECC respectfully request, however, that the
Commission approve the retirement to be effective on April 1, 2017 to align the retirement of
TOP-007-WECC-1a with the effective date for the modified TOP Reliability Standards approved
in Order No. 817. Additionally, Peak Reliability (the Reliability Coordinator in the Western
Interconnection) is scheduled to issue a revised SOL Methodology to support the retirement of
TOP-007-WECC-1a on October 1, 2016, with an effective date of April 1, 2017. Aligning these
effective dates will allow the Transmission Operators in the WECC Region to efficiently transition
to compliance with the continent-wide Reliability Standards without having to transition to two
sets of TOP standards in a short period of time (i.e., moving from the TOP-007-WECC-1a to the
currently-effective continent-wide Reliability Standards and then transitioning to the modified

13

TOP standards approved in Order No. 817).
V.

CONCLUSION
For the reasons set forth above, NERC respectfully requests that the Commission approve

the proposed retirement of the regional Reliability Standard TOP-007-WECC-1a, effective as
proposed herein.
Respectfully submitted,
/s/ Gizelle Wray
Sandy Mooy
Charles A. Berardesco
Associate General Counsel
Senior Vice President and General Counsel
Chris Albrecht
Shamai Elstein
Legal Counsel
Senior Counsel
Western Electricity Coordinating Council Gizelle Wray
155 North 400 West, Suite 200
Associate Counsel
Salt Lake City, UT 84103
North American Electric Reliability
(801) 582-0353
Corporation
[email protected]
1325 G Street, N.W., Suite 600
[email protected]
Washington, D.C. 20005
(202) 400-3000
Counsel for the Western Electricity
[email protected]
Coordinating Council
[email protected]
[email protected]
Counsel for the North American Electric
Reliability Corporation

Date: March 23, 2016

14