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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 REGIONAL RELIABILITY STANDARD FAC-501-WECC-2
Sandy Mooy
Associate General Counsel
Ruben Arredondo
Senior Legal Counsel
Western Electricity Coordinating Council
155 North 400 West, Suite 200
Salt Lake City, UT 84103
(801) 582-0353
[email protected]
[email protected]
Shamai Elstein
Senior Counsel
Lauren Perotti
Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
[email protected]
[email protected]
Counsel for the Western Electricity
Coordinating Council
Counsel for the North American Electric
Reliability Corporation
March 16, 2018
TABLE OF CONTENTS
I.
EXECUTIVE SUMMARY .................................................................................................... 3
II.
NOTICES AND COMMUNICATIONS ................................................................................ 4
III. BACKGROUND .................................................................................................................... 4
A.
Regulatory Framework ..................................................................................................... 5
B.
WECC Regional Reliability Standards Development Process ........................................ 6
C.
Approval of FAC-501-WECC-1 ...................................................................................... 7
D.
Development of the Proposed Regional Reliability Standard.......................................... 7
IV. JUSTIFICATION FOR APPROVAL..................................................................................... 8
V.
A.
WECC Transfer Path Table.............................................................................................. 8
B.
Other Clarifications .......................................................................................................... 9
C.
Enforceability of Proposed Regional Reliability Standard FAC-501-WECC-2 ............ 10
EFFECTIVE DATE .............................................................................................................. 11
VI. CONCLUSION ..................................................................................................................... 12
Exhibit A
Proposed Regional Reliability Standard FAC-501-WECC-2 – Transmission
Maintenance
Exhibit B
Implementation Plan for Proposed Regional Reliability Standard FAC-501WECC-2
Exhibit C
Order No. 672 Criteria for Proposed Regional Reliability Standard FAC-501WECC-2
Exhibit D
Analysis of Violation Severity Levels
Exhibit E
Summary of Development History and Complete Record of Development
Exhibit F
Standard Drafting Team Roster for Project WECC-0120 Transmission
Maintenance Five-Year Review
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 REGIONAL RELIABILITY STANDARD FAC-501-WECC-2
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 Regional Reliability Standard FAC-501-WECC-2 –
Transmission Maintenance for Commission approval. Regional Reliability Standard FAC-501WECC-2 addresses transmission maintenance for specified transmission paths in the Western
Interconnection.
NERC and WECC request that the Commission approve proposed Regional Reliability
Standard FAC-501-WECC-2 (Exhibit A) as just, reasonable, not unduly discriminatory or
preferential, and in the public interest. 4 NERC and WECC also request approval of the associated
1
16 U.S.C. § 824o (2012).
18 C.F.R. § 39.5 (2017).
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) (“ERO
Certification Order”).
4
Unless otherwise designated, 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.
2
2
implementation plan (Exhibit B), and the associated Violation Severity Levels (“VSLs”) (Exhibit
D), as detailed in this petition.
As required by Section 39.5(a) 5 of the Commission’s regulations, this petition presents the
technical basis and purpose of the proposed Regional Reliability Standard, a summary of the
development proceedings (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 Regional
Reliability Standard FAC-501-WECC-2 was approved by the WECC Board of Directors on
December 6, 2017 and by the NERC Board of Trustees on February 8, 2018.
I.
EXECUTIVE SUMMARY
The purpose of FAC-501-WECC-2 is to ensure the Transmission Owner of a transmission
path identified in the table titled “Major WECC Transfer Paths in the Bulk Electric System”
(“WECC Transfer Path Table” or “Table”), including associated facilities, has a Transmission
Maintenance and Inspection Plan (“TMIP”) and performs and documents maintenance and
inspection activities in accordance with the TMIP. The proposed standard was developed
following a periodic review of the currently-effective version of the standard, FAC-501-WECC1, which became effective in 2011.
As a result of WECC’s periodic review, WECC revised the standard to clarify the
Transmission Owner’s obligations with respect to the development, implementation, and review
of TMIPs, and to directly incorporate the list of applicable transmission paths, thereby eliminating
incorporation by reference to any extrinsic document. Proposed Regional Reliability Standard
5
18 C.F.R. § 39.5(a) (2017).
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, FERC Stats. & Regs. ¶ 31,204, at P 262, 321-37, order on reh’g, Order No. 672-A,
FERC Stats. & Regs. ¶ 31,212 (2006).
6
3
FAC-501-WECC-2 continues to remain more stringent than continent-wide standards and
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 Regional
Reliability Standard FAC-501-WECC-2 and the associated elements. The following petition
presents the justification for approval and supporting documentation.
II.
NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the
following: 7
Sandy Mooy*
Associate General Counsel
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
[email protected]
[email protected]
[email protected]
III.
Shamai Elstein*
Senior Counsel
Lauren Perotti*
Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
[email protected]
[email protected]
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) the history of Project WECC0120 FAC-501-WECC-1 Transmission Maintenance, Five-Year Review.
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 (2017), to allow the inclusion
of more than two persons on the service list in this proceeding.
4
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
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.
8
9
10
11
12
13
16 U.S.C. § 824o (2012).
Id. § 824o(b)(1).
Id. § 824o(d)(5).
18 C.F.R. § 39.5(a) (2017).
16 U.S.C. § 824o(d)(2).
18 C.F.R. § 39.5(c)(1).
5
Similarly, the Commission approves Regional Reliability Standards proposed by Regional
Entities if the Regional Reliability Standard is just, reasonable, not unduly discriminatory or
preferential, and in the public interest. 14 In addition, Order No. 672 requires further criteria for
Regional Reliability Standards. A Regional difference from a continent-wide Reliability Standard
must either be: (1) more stringent than the continent-wide Reliability Standard, 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 Interconnectionwide basis with respect to a Regional Reliability Standard to be applicable within that
Interconnection. 16
B.
WECC Regional Reliability Standards Development Process
The proposed Regional Reliability Standard 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 certain of the 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 Regional Reliability Standard. Once the standard is approved by the WECC
14
Section 215(d)(2) of the FPA and 18 C.F.R. §39.5(a).
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).
16
Order No. 672 at P 344.
17
The currently-effective WECC RSDP was approved by the Commission on October 27, 2017 (see N. Am.
Elec. Reliability Corp., RR17-5-000 (Oct. 27, 2017) (unpublished letter order)) and is available at
http://www.nerc.com/FilingsOrders/us/Regional%20Delegation%20Agreements%20DL/WECC%20RSDP_201710
27.pdf.
15
6
Board of Directors, NERC posts the approved Regional Reliability Standard for an additional
comment period. Then the NERC Board of Trustees must adopt the Regional Reliability Standard
before the Regional Reliability Standard is submitted to the Commission for approval.
C.
Approval of FAC-501-WECC-1
The Commission approved currently-effective Regional standard FAC-501-WECC-1 in
Order No. 751, issued in 2011. FAC-501-WECC-1 was developed to replace Regional Reliability
Standard PRC-STD-005-1 to address FERC directives.
18
In approving the standard, the
Commission stated that it was more stringent than the then-effective NERC Reliability Standard
PRC-005-1 “by virtue of its requirement for a highly detailed maintenance and inspection plan for
all transmission and substation equipment components associated with transmission paths
identified in the WECC Transfer Path Table”. 19
D.
Development of the Proposed Regional Reliability Standard
As further described in Exhibit E hereto, proposed Regional Reliability Standard FAC501-WECC-2 was developed in accordance with the WECC RSDP, as part of a five-year review
of FAC-501-WECC-1. On October 11, 2017, the fifth draft of proposed Regional Reliability
Standard FAC-501-WECC-2 was approved by the WECC ballot body with 100 percent affirmative
vote. The WECC Board of Directors approved the standard on December 6, 2017. NERC posted
the standard for a 45-day comment period concluding on December 18, 2017. Commenters agreed
that WECC’s process was open, inclusive, balanced, transparent, and that due process was
followed, and there were no additional changes after this comment period. The NERC Board of
Trustees subsequently adopted the Regional standard on February 8, 2018.
18
Order Approving Regional Reliability Standards for the Western Interconnection and Directing
Modifications, 119 FERC ¶ 61,260, at P 98 (2007).
19
See Order No. 751, Version One Regional Reliability Standards for Facilities Design, Connections, and
Maintenance; Protection and Control; and Voltage and Reactive, 135 FERC ¶ 61,061 at P 33 (2011).
7
IV.
JUSTIFICATION FOR APPROVAL
The purpose of proposed Regional Reliability Standard FAC-501-WECC-2 is to ensure the
Transmission Owner of a transmission path identified in the WECC Transfer Path table has a TMIP
and performs and documents maintenance and inspection activities in accordance with the TMIP.
The provisions of the proposed Regional standard provide specific requirements for implementing
and maintaining comprehensive maintenance and inspection plans for transmission lines and
substation equipment. Proposed FAC-501-WECC-2 builds upon the currently-effective version of
the standard and improves it by clarifying the obligations of applicable Transmission Owners with
respect to TMIPs and their required content. The proposed regional standard remains more
stringent than its continent-wide counterparts in that it includes specific emphasis on the 40 major
paths of Attachment B not otherwise included elsewhere, applies a more stringent maintenance
protocol to those paths, and specifies a broader range of elements for maintenance than those
addressed in the continent-wide PRC Reliability Standards. The proposed changes are discussed
in more detail below.
A.
WECC Transfer Path Table
In proposed Regional Reliability Standard FAC-501-WECC-2, WECC has directly
incorporated the list of applicable transmission paths thereby eliminating incorporation by
reference to any extrinsic document. In currently-effective FAC-501-WECC-1, WECC removed
the Table from the standard, replacing it with a link to the table on the WECC website. 20 In
20
In Order No. 751, the Commission restated its concern from the Notice of Proposed Rulemaking that, due
to WECC removing the WECC Transfer Path Table from the standard and replacing it with a link to the table on the
WECC website, the applicability of the standard “could change without review and approval by NERC and the
Commission.” Order No. 751 at P 20. In response to WECC’s comments, the Commission directed WECC to file its
criterion for identifying and modifying major transmission paths listed in the tables on the WECC website before
they become effective with concurrent notification to the Commission, NERC and the industry. The Commission
stated, “We believe that this process balances the interests of WECC in developing timely revisions to the WECC
8
response to the Commission’s concerns, WECC agreed that no changes would be made to the
Table without using an open and transparent process and notifying the Commission accordingly.
In the intervening years, WECC has made no revisions to this Table, although WECC has had to
update the standard to reflect the new location of the Table on the WECC website. 21 To avoid
having to correct link locations in the future, the WECC drafting team and stakeholders agreed
that the WECC Transfer Path Table should be included in the standard. By removing the extrinsic
reference and incorporating the full content of the Table in the standard, the Commission’s
incorporation by reference concern from Order No. 751 is alleviated and any future changes to the
Table would require the full due process afforded by the WECC RSDP.
Other conforming changes include eliminating all links referencing this table and replacing
the term “Table” with the term “Attachment B”.
B.
Other Clarifications
The proposed Regional Reliability Standard FAC-501-WECC-2 includes several
clarifications that improve upon the existing standard. Requirement R1 is revised to add language
requiring each TMIP to contain, at a minimum, the items specified in Attachment A, Transmission
Maintenance and Inspection Plan Content. The term “System Operating Limit” is removed from
Requirement R1 to remain consistent with the revised System Operating Limit methodology
instituted by Peak Reliability effective April 1, 2017 which decouples the concepts of System
Transfer Path Table with the need for adequate transparency for transmission owners that are affected by changes to
the WECC Transfer Path Table.” Id. at P 24.
21
See Joint Informational Filing of the North American Electric Reliability Corporation and Western
Coordinating Council Regarding Correction of Links in WECC Regional Reliability Standards FAC-501-WECC-1
and PRC-004-WECC-2, in Docket No. RM15-13-000 (filed June 9, 2017).
9
Operating Limits and paths as they have traditionally been understood in the Western
Interconnection. 22
Requirement R1 now consists of two separate Requirements: the requirement to “have a
TMIP” (Requirement R1) and to “annually update it to reflect all changes” (Requirement R2).
Requirement R3 is revised to provide that each Transmission Owner shall adhere to its
TMIP (revised from “implement and follow” its TMIP).
Attachment A was revised clarifying the required contents of TMIPs and removing
“and/or” statements. The term “contamination control” was removed due to ambiguity. The
specific reference to “regulators” was determined to be an unnecessarily detailed subset of power
transformers and was also removed.
C.
Enforceability of Proposed Regional Reliability Standard FAC-501-WECC-2
The proposed regional Reliability Standard includes VRFs and VSLs. The VSLs provide
guidance on the way that NERC will enforce the requirements of the proposed regional 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 proposed regional Reliability Standard comport
with NERC and Commission guidelines related to their assignment. In proposed Reliability
Standard FAC-501-WECC-2, the VRFs remain unchanged from the related Requirements in
currently-effective FAC-501-WECC-1. The VSL section has been changed to match the current
NERC table format and the revised language of underlying Requirements. The VSLs for the
22
See Exhibit E, Posting 1 Response to Comments at 4-6 (responding to comments submitted by Bonneville
Power Administration). For additional information on the shift away from the path-centric model to the framework
established in the continent-wide TOP and IRO Reliability Standards, see generally Docket No. RD16-10-000
(retirement of TOP-007-WECC-1a).
10
proposed Regional Reliability Standard comport with NERC and Commission guidelines related
to their assignment.
The proposed Regional 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 nonpreferential manner and without prejudice to any party. 23
V.
EFFECTIVE DATE
NERC respectfully requests that the Commission approve the proposed implementation
plan, provided in Exhibit B hereto. Under the proposed implementation plan, proposed Reliability
Standard FAC-501-WECC-2 would become effective on the first day of the first calendar quarter
after Commission approval.
23
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.”).
11
VI.
CONCLUSION
For the reasons set forth above, NERC respectfully requests that the Commission approve:
•
the proposed Regional Reliability Standard FAC-501-WECC-2 in Exhibit A;
•
the other associated elements in the Reliability Standard in Exhibit A, including the
VRFs and VSLs in Exhibit D;
•
the proposed implementation plan, included in Exhibit B; and
•
the retirement of currently-effective Regional Reliability Standard FAC-501-WECC-1.
Respectfully submitted,
/s/ Lauren Perotti
Sandy Mooy
Associate General Counsel
Ruben Arredondo
Senior Legal Counsel
Western Electricity Coordinating Council
155 North 400 West, Suite 200
Salt Lake City, UT 84103
(801) 582-0353
[email protected]
[email protected]
Shamai Elstein
Senior Counsel
Lauren Perotti
Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
[email protected]
[email protected]
Counsel for the Western Electricity
Coordinating Council
Counsel for the North American Electric
Reliability Corporation
Date: March 16, 2018
12
Exhibit A
Proposed Regional Reliability Standard FAC-501-WECC-2 – Transmission Maintenance
Exhibit A
Proposed Regional Reliability Standard FAC-501-WECC-2 – Transmission Maintenance
Clean
FAC-501-WECC-2 – Transmission Maintenance
A. Introduction
1. Title:
Transmission Maintenance
2. Number:
FAC-501-WECC-2
3. Purpose:
To ensure the Transmission Owner of a transmission path identified in
Attachment B, Major WECC Transfer Paths in the Bulk Electric System,
including associated facilities has a Transmission Maintenance and
Inspection Plan (TMIP); and performs and documents maintenance and
inspection activities in accordance with the TMIP.
4. Applicability
4.1 Transmission Owners that maintain the transmission paths in Attachment B.
5. Effective Date: The first day of the first quarter following applicable regulatory approval.
B. Requirements and Measures
R1.
Each Transmission Owner shall have a TMIP that includes, at a minimum, each of
the items listed in Attachment A, Transmission Maintenance and Inspection Plan
Content. [Violation Risk Factor: Medium] [Time Horizon: Long-term Planning]
M1.
Each Transmission Owner will have evidence that it has a TMIP detailing each of the
items listed in Attachment A, as required in Requirement R1.
R2.
Each Transmission Owner shall annually update its TMIP to reflect all changes to its
TMIP. [Violation Risk Factor: Medium] [Time Horizon: Long-term Planning]
M2.
Each Transmission Owner will have evidence that it annually updated its TMIP, as
required in Requirement R2. When an annual update shows that no changes are
required to the TMIP, evidence may include but is not limited to, attestation that
the update was performed but showed that no changes were required.
R3.
Each Transmission Owner shall adhere to its TMIP. [Violation Risk Factor:
Medium] [Time Horizon: Operations Assessment]
M3.
Each Transmission Owner will have evidence that it adhered to its TMIP, as
required in Requirement R3. Evidence may include, but is not limited to:
1.1
The date(s) the patrol, inspection or maintenance was performed;
1.2
The transmission Facility or Element on which the maintenance was performed;
1.3
A description of the inspection results or maintenance performed.
Page 1 of 6
FAC-501-WECC-2 – Transmission Maintenance
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 Transmission Owners listed in section 4.1 shall keep data or
evidence of Requirements 1-3 for three calendar years, or since the last
audit, whichever is longer.
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 2 of 6
FAC-501-WECC-2 – Transmission Maintenance
Violation Severity Levels
R#
R1.
R2.
R3.
D.
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
The Transmission
Owner’s TMIP did
not include one
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
annually update
its TMIP (within
the 365 days
following the last
review), as
required by R2.
The Transmission
Owner’s TMIP did
not include two
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
update its TMIP
within the last
one year and 1
day (within the
366 days
following the last
review), as
required by R2.
The
Transmission
Owner failed to
adhere to:
1) two
transmission
line
maintenance
items; or, 2)
two station
maintenance
items; or 3) any
combination of
two items taken
from the above
list, for items
contained in its
TMIP, as
required in R3.
The Transmission
Owner’s TMIP did
not include three
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
update its TMIP
within the last
two years and 1
day (within the
731 days
following the last
review), as
required by R2.
The
Transmission
Owner failed to
adhere to:
1) three
transmission
line
maintenance
items; or, 2)
three station
maintenance
items; or 3) any
combination of
three items
taken from the
above list, for
items contained
in its TMIP, as
required in R3.
The Transmission
Owner’s TMIP did
not include four or
more of the items
listed in Attachment
A, as required in
Requirement R1.
The
Transmission
Owner failed to
adhere to: 1)
one
transmission
line
maintenance
item, or 2) one
station
maintenance
item, as
contained in its
TMIP, as
required in R3.
The Transmission
Owner did not update
its TMIP within the
last three years and 1
day (within the 1095
days following the
last review), as
required by R2.
The Transmission
Owner failed to
adhere to:
1) four or more
transmission line
maintenance items;
or, 2) four or more
station
maintenance items;
or, 3) any
combination of
four or more items
taken from the
above list, for items
contained in its
TMIP, as required
in R3.
Regional Variances
None.
Page 3 of 6
FAC-501-WECC-2 – Transmission Maintenance
E.
Associated Documents
None
Version History – Shows Approval History and Summary of Changes in the Action Field
Version
Date
Action
1
April 16, 2008
Permanent Replacement Standard for PRCSTD-005-1
1
October 29,
2008
NERC BOT conditional approval
1
April 21, 2011
FERC Approved in Order 751
2
July 1, 2017
Approved by the WECC Board of
Directors.
2
February 8,
2018
Approved by the NERC Board of Trustees.
Change
Tracking
1) Conformed to
newest NERC
template and
drafting
conventions, 2)
eliminated URLs,
3) clarified
Attachment A,
and Measure
M3.
Page 4 of 6
Attachment A
Transmission Maintenance and Inspection Plan Content
The TMIP shall include, at a minimum, each of the following details:
1.
Facilities
A list of Facilities (e.g., transmission lines, transformers, etc.) and Elements (e.g. circuit breaker, bus
section, etc.) that comprise each transmission path(s) identified in Attachment B, Major WECC
Transfer Paths in the Bulk Electric System.
2.
Maintenance Methodology
A description of the maintenance methodology used for the Facility, transmission line, or station
included in the TMIP.
The TMIP maintenance methodology may be any one of the following or any combination thereof,
but must include at least one of the following:
•
•
•
3.
Performance-based
Time-based
Condition based
Periodicity
A specification of the periodicity that the described maintenance will occur, or under what
circumstances it occurs.
4.
Transmission Line Maintenance
A description of each of the following for the transmission line(s) included in the TMIP:
a. Inspection requirements
b. Patrol requirements
c. Tower and wood pole structure management
5.
Station Maintenance
A description of each of the following for each station included in the TMIP:
a. Inspection requirements
b. Equipment maintenance for each of the following:
1.
Circuit breakers
2.
Power transformers (including, but not limited to, phase-shifting
transformers)
3.
Reactive devices (including, but not limited to, shunt capacitors, series
capacitors, synchronous condensers, shunt reactors, and tertiary reactors)
Page 5 of 6
Attachment B
Major WECC Transfer Paths in the Bulk Electric System
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
PATH NAME*
Alberta – British Columbia
Northwest – British Columbia
West of Cascades – North
West of Cascades – South
West of Hatwai
Montana to Northwest
Idaho to Northwest
South of Los Banos or Midway- Los Banos
Idaho – Sierra
Borah West
Idaho – Montana
Bridger West
Path C
Southwest of Four Corners
PG&E – SPP
Northern – Southern California
Intmntn. Power Project DC Line
TOT 1A
TOT 2A
Pavant – Gonder 230 kV
Intermountain – Gonder 230 kV
TOT 2B
TOT 2C
TOT 3
TOT 5
SDGE – CFE
West of Colorado River (WOR)
Southern New Mexico (NM1)
Northern New Mexico (NM2)
East of the Colorado River (EOR)
Cholla – Pinnacle Peak
Southern Navajo
Brownlee East
Lugo – Victorville 500 kV
Pacific DC Intertie
COI
North of John Day cutplane
Alturas
Montana Southeast
SCIT**
COI/PDCI – North of John Day cutplane**
Path Number
1
3
4
5
6
8
14
15
16
17
18
19
20
22
24
26
27
30
31
32
34
35
36
39
45
46
47
48
49
50
51
55
61
65
66
73
76
80
* For an explanation of terms, path numbers, and definition for the paths refer
to WECC’s Path Rating Catalog.
** The SCIT and COI/PDCI-North of John Day Cutplane are paths that are operated in
accordance with nomograms identified in WECC’s Path Rating Catalog.
Page 6 of 6
Exhibit A
Proposed Regional Reliability Standard FAC-501-WECC-2 – Transmission Maintenance
Redline
WECC Standard FAC-501-WECC-12 – Transmission Maintenance
A. Introduction
1. Title:
Transmission Maintenance
2. Number:
FAC-501-WECC-12
3. Purpose:
To ensure the Transmission Owner of a transmission path identified in the
table titled “Attachment B, Major WECC Transfer Paths in the Bulk Electric
System”, including associated facilities has a Transmission Maintenance
and Inspection Plan (TMIP); and performs and documents maintenance
and inspection activities in accordance with the TMIP.
4. Applicability
4.1 Transmission Owners that maintain the transmission paths in the most current table
titled “Attachment B.Major WECC Transfer Paths in the Bulk Electric
System” provided at:
https://www.wecc.biz/Reliability/TableMajorPaths4-28-08.pdf.
5. Effective Date: July 1, 2011The first day of the first quarter following applicable
regulatory approval.
B. Requirements and Measures
R1.
Each Transmission OwnersOwner shall have a TMIP detailing their inspection and
maintenance requirements that apply to all transmission facilities necessary for System
Operating Limits associated withincludes, at a minimum, each of the transmission
paths identified in table titled “Major WECC Transfer Paths in the Bulk Electric
System.”items listed in Attachment A, Transmission Maintenance and Inspection
Plan Content. [Violation Risk Factor: Medium] [Time Horizon: Long-term
Planning]
R1.1.
Transmission OwnersM1. Each Transmission Owner will have evidence that it has a
TMIP detailing each of the items listed in Attachment A, as required in
Requirement R1.
R2.
Each Transmission Owner shall annually review their TMIP and update as
required.
its TMIP to reflect all changes to its TMIP. [Violation Risk Factor: Medium] [Time Horizon:
Long-term Planning]
Transmission Owners shall M2.
Each Transmission Owner will have evidence that it
annually updated its TMIP, as required in Requirement R2. When an annual
update shows that no changes are required to the TMIP, evidence may include
the maintenance categories in Attachment 1-FAC-501- WECC-1 when developing their
TMIP.but is not limited to, attestation that the update was performed but
showed that no changes were required.
RevURL11-7-14
Page 1 of 134
WECC Standard FAC-501-WECC-12 – Transmission Maintenance
R3.
Each Transmission Owner shall adhere to its TMIP. [Violation Risk Factor:
Medium] [Time Horizon: Operations Assessment]
R.1. M3.
Each Transmission Owners shall implement and follow their TMIP.
[Violation Risk Factor: Medium] [Time Horizon: Operations Assessment]
A. Measures
M1. Transmission Owners shall have a documented TMIP per R.1.
M1.1
Transmission Owners shall have evidence they have annually reviewed their TMIP
and updated as needed.
M2. Transmission Owners shallOwner will have evidence that their TMIP addresses the
required maintenance details of R.2.
M3. Transmission Owners shall have records that they implemented and followed their TMIPit
adhered to its TMIP, as required in R.3. The records shallRequirement R3.
Evidence may include, but is not limited to:
The person or crew responsible for performingdate(s) the workpatrol, inspection
or maintenance was performed;
1. The transmission Facility or inspection,
1.1
2. The date(s) the work or inspection was performed,
The transmission facilityElement on which the workmaintenance was
performed, and;
1.11.2
1.21.3
RevURL11-7-14
A description of the inspection results or maintenance performed.
Page 2 of 134
WECC Standard FAC-501-WECC-12 – Transmission Maintenance
RevURL11-7-14
Page 3 of 134
WECC Standard FAC-501-WECC-12 – Transmission Maintenance
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 Transmission Owners listed in section 4.1 shall keep data or
evidence of Requirements 1-3 for three calendar years, or since the last
audit, whichever is longer.
2.1 Additional Compliance Information
No additional compliance information.
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.
RevURL11-7-14
Page 4 of 134
WECC Standard FAC-501-WECC-12 – Transmission Maintenance
Violation Severity Levels
2.1. Lower: There shall be a Lower Level of non-compliance if any of the following
conditions exist:
The TMIP does not include associated
R#
R1.
R2.
R3.
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
The Transmission
Owner’s TMIP did
not include one
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
annually update
its TMIP (within
the 365 days
following the last
review), as
required by R2.
The Transmission
Owner’s TMIP did
not include two
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
update its TMIP
within the last
one year and 1
day (within the
366 days
following the last
review), as
required by R2.
The
Transmission
Owner failed to
adhere to:
1) two
transmission
line
maintenance
items; or, 2)
two station
maintenance
items; or 3) any
combination of
two items taken
from the above
list, for items
contained in its
TMIP, as
The Transmission
Owner’s TMIP did
not include three
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
update its TMIP
within the last
two years and 1
day (within the
731 days
following the last
review), as
required by R2.
The
Transmission
Owner failed to
adhere to:
1) three
transmission
line
maintenance
items; or, 2)
three station
maintenance
items; or 3) any
combination of
three items
taken from the
above list, for
items contained
in its TMIP, as
The Transmission
Owner’s TMIP did
not include four or
more of the items
listed in Attachment
A, as required in
Requirement R1.
The
Transmission
Owner failed to
adhere to: 1)
one
transmission
line
maintenance
item, or 2) one
station
maintenance
item, as
contained in its
TMIP, as
required in R3.
RevURL11-7-14
The Transmission
Owner did not update
its TMIP within the
last three years and 1
day (within the 1095
days following the
last review), as
required by R2.
The Transmission
Owner failed to
adhere to:
1) four or more
transmission line
maintenance items;
or, 2) four or more
station
maintenance items;
or, 3) any
combination of
four or more items
taken from the
above list, for items
contained in its
TMIP, as required
in R3.
Page 5 of 134
WECC Standard FAC-501-WECC-12 – Transmission Maintenance
required in R3.
required in R3.
D.
Regional Variances
E.
Associated Documents
None.
None
2.1.1
Facilities for one of the Paths identified in Attachment 1 FAC-501-WECC-1 as
required by R.1 but Transmission Owners are performing maintenance and
inspection for the missing Facilities.
2.1.2
Transmission Owners did not review their TMIP annually as required by R.1.1.
2.1.3
The TMIP does not include one maintenance category identified in Attachment 1
FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing
maintenance and inspection for the missing maintenance categories.
2.1.4
Transmission Owners do not have maintenance and inspection records as required
by R.3 but have evidence that they are implementing and following their TMIP.
2.2. Moderate: There shall be a Moderate Level of non-compliance if any of the following
conditions exist:
2.2.1
The TMIP does not include associated Facilities for two of the Paths identified in
the most current Table titled “Major WECC Transfer Paths in the Bulk Electric
System” as required by R.1 and Transmission Owners are not performing
maintenance and inspection for the missing Facilities.
2.2.2
The TMIP does not include two maintenance categories identified in Attachment
1 FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing
maintenance and inspection for the missing maintenance categories.
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Page 6 of 134
WECC Standard FAC-501-WECC-12 – Transmission Maintenance
2.2.3
Transmission Owners are not performing maintenance and inspection for one
maintenance category identified in Attachment 1 FAC-501-WECC-1 as required
in R3.
2.3. High: There shall be a High Level of non-compliance if any of the following condition
exists:
2.3.1 The TMIP does not include associated Facilities for three of the Paths identified in
the most current Table titled “Major WECC Transfer Paths in the Bulk Electric
System” as required by R.1 and Transmission Owners are not performing
maintenance and inspection for the missing Facilities.
2.3.2 The TMIP does not include three maintenance categories identified in Attachment 1
FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing
maintenance and inspection for the missing maintenance categories.
2.3.3 Transmission Owners are not performing maintenance and inspection for two
maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required in
R3.
2.4. Severe: There shall be a Severe Level of non-compliance if any of the following condition
exists:
2.4.1 The TMIP does not include associated Facilities for more than three of the Paths
identified in the most current Table titled “Major WECC Transfer Paths in the Bulk
Electric System” as required by R.1 and Transmission Owners are not performing
maintenance and inspection for the missing Facilities.
2.4.2 The TMIP does not exist or does not include more than three maintenance
categories identified in Attachment 1 FAC-501-WECC-1 as required by R.2 but
Transmission Owners are performing maintenance and inspection for the missing
maintenance categories.
2.4.3 Transmission Owners are not performing maintenance and inspection for more than
two maintenance categories identified in Attachment 1 FAC-501-WECC-1 as
required in R3.
Version History – Shows Approval History and Summary of Changes in the Action Field
Version
Date
1
April 16, 2008
Permanent Replacement Standard for
PRC-STD-005-1
1
October 29,
2008
NERC BOT conditional approval
1
April 21, 2011
FERC Approved in Order 751
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Action
Change
Tracking
Page 7 of 134
WECC Standard FAC-501-WECC-2 – Transmission Maintenance
Attachment 1- TBDJuly 1,
Approved by the WECC Board of
FAC-5012017
Directors.TBD
WECC-1 2
2
February 8,
2018
Approved by the NERC Board of Trustees.
Page 8 of 6
1) Conformed to
newest NERC
template and
drafting
conventions, 2)
eliminated URLs,
3) clarified
Attachment A,
and Measure
M3.
Attachment A
Transmission Line and Station Maintenance Detailsand Inspection Plan Content
The maintenance practices in the TMIP may be performance-based, time-based, conditional based, or a
combination of all three. The TMIP shall include:, at a minimum, each of the following details:
1.
Facilities
A list of Facilities and associated (e.g., transmission lines, transformers, etc.) and Elements necessary
to maintain the SOL for the transfer paths (e.g. circuit breaker, bus section, etc.) that comprise each
transmission path(s) identified in the most current Table titled “Attachment B, Major WECC Transfer
Paths in the Bulk Electric System;”.
1. The scheduled interval for any time-based maintenance activities and/or a description supporting
condition or performance-based maintenance activities including a description of the condition
based trigger;
2.
Maintenance Methodology
A description of the maintenance methodology used for the Facility, transmission line, or station
included in the TMIP.
The TMIP maintenance methodology may be any one of the following or any combination thereof,
but must include at least one of the following:
•
•
•
3.
Performance-based
Time-based
Condition based
Periodicity
A specification of the periodicity that the described maintenance will occur, or under what
circumstances it occurs.
4.
Transmission Line Maintenance Details:
A description of each of the following for the transmission line(s) included in the TMIP:
a. Inspection requirements
b. Patrol/Inspection requirements
a. Contamination Control
c. Tower and wood pole structure management
5.
Station Maintenance Details:
b. Inspections
c. Contamination Control
A description of each of the following for each station included in the TMIP:
a. Inspection requirements
PagePage
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a.b. Equipment Maintenancemaintenance for each of the following:
1.
Circuit Breakersbreakers
•
2.
Power Transformers (including phase-shifting transformers)
•
Regulators
Reactive Devices (including, but not limited to, phase-shifting transformers)
3.
Reactive devices (including, but not limited to, shut capacitors, series
capacitors, synchronous condensers, shunt reactors, and tertiary reactors)
PagePage
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4 of 6
Attachment B
Major WECC Transfer Paths in the Bulk Electric SystemShunt Capacitors, Series
Capacitors, Synchronous Condensers, Shunt Reactors, and Tertiary Reactors)
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
PATH NAME*
Alberta – British Columbia
Northwest – British Columbia
West of Cascades – North
West of Cascades – South
West of Hatwai
Montana to Northwest
Idaho to Northwest
South of Los Banos or Midway- Los Banos
Idaho – Sierra
Borah West
Idaho – Montana
Bridger West
Path C
Southwest of Four Corners
PG&E – SPP
Northern – Southern California
Intmntn. Power Project DC Line
TOT 1A
TOT 2A
Pavant – Gonder 230 kV
Intermountain – Gonder 230 kV
TOT 2B
TOT 2C
TOT 3
TOT 5
SDGE – CFE
West of Colorado River (WOR)
Southern New Mexico (NM1)
Northern New Mexico (NM2)
East of the Colorado River (EOR)
Cholla – Pinnacle Peak
Southern Navajo
Brownlee East
Lugo – Victorville 500 kV
Pacific DC Intertie
COI
North of John Day cutplane
Alturas
Montana Southeast
SCIT**
COI/PDCI – North of John Day cutplane**
Path Number
1
3
4
5
6
8
14
15
16
17
18
19
20
22
24
26
27
30
31
32
34
35
36
39
45
46
47
48
49
50
51
55
61
65
66
73
76
80
* For an explanation of terms, path numbers, and definition for the paths refer
to WECC’s Path Rating Catalog.
** The SCIT and COI/PDCI-North of John Day Cutplane are paths that are operated in
accordance with nomograms identified in WECC’s Path Rating Catalog.
PagePage
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4 of 6
Exhibit B
Implementation Plan for Proposed Regional Reliability Standard FAC-501-WECC-2
Implementation Plan
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Standard Authorization Request
WECC-0120 SAR is located here. In this filing, it is provided as Attachment A.
Approvals Required
•
•
•
WECC Board of Directors
NERC Board of Trustees
FERC
December 6, 2017
February 8, 2018
Pending
Applicable Entities
4.
Applicability
4.1
Transmission Owners that maintain the transmission paths in Attachment B.
Conforming Changes to Other Standards
There are no conforming changes to other standards required to implement the proposed document.
Proposed Effective Date
The Effective Date is proposed to be the first day of the first quarter following applicable regulatory approval.
Justification
The WECC-0120, FAC-501-WECC-2, Transmission Maintenance Drafting Team (DT) reviewed NERC Standards,
both in effect and those standards that are approved by the NERC Board of Trustees, but pending regulatory
disposition. The DT concluded that the proposed substantive changes pose a minimal burden beyond current
reasonable and customary operations. As such, the implementation time should impose no undue burden.
Consideration of Early Compliance
The drafting team foresees no concerns with early compliance.
Required Retirements
The currently approved standard (FAC-501-WECC-1) should be retired immediately prior to the Effective Date of
this version, FAC-501-WECC-2. No other retirements or modifications are needed.
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Exhibit C
Order No. 672 Criteria for Proposed Regional Reliability Standard FAC-501-WECC-2
Order 672 Criteria
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
NERC is responsible for the activities governing “the development, approval, revision, reaffirmation,
and withdrawal of Reliability Standards, Interpretations, Violations Risk Factors (VRF), Violation
Severity Levels (VSL), definitions, Variances, and reference documents developed to support standards
for the Reliable Operation and planning of the North American Bulk Power Systems”. 1
In FERC Order No. 672, 2 the Federal Energy Regulatory Commission (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.” 3 The following discussion identifies
these factors, and explains how the proposed Regional Reliability Standard (RRS) meets or exceeds
these criteria. 4
1.
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.” 5
1
NERC Rules of Procedure, Standard Processes Manual, Version 3, Section 1.0, Introduction, Sub-section 1.2 Scope. June 26,
2013. For purposes of this filing, the term Reliability Standard is synonymous with Regional Reliability Standard (RRS).
2
FERC Order 672, P 320-338.
3
FERC Order 672, P320.
NERC Rules of Procedure, Definitions Used in Rules of Procedure, Appendix 2 to the Rules of Procedure, page 19, October
31, 2016. See also NERC Rules of Procedure, Section 300 Reliability Standards development, Sub-section 312.1 Regional
Reliability Standards, indicating that Regional Reliability Standards “shall in all cases be submitted to NERC for adoption and,
if adopted, made part of the NERC Reliability Standards and shall be enforceable in accordance with the delegation
agreement between NERC and the Regional Entity or other instrument granting authority over enforcement to the Regional
Entity.”
5
Order No. 672 at P 321.
4
WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114
Attachment K: Order 672 Criteria—WECC-0120 FAC-501-WECC-2 Transmission Maintenance
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 Reliability Standard
serves a 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.” 6
Of NERC’s eight NERC Reliability Principles, FAC-501-WECC-2 meets:
Reliability Principle 3
“Information necessary for the planning and operation of interconnected bulk power systems shall be
made available to those entities responsible for planning and operating the systems reliably.”
2.
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 [Electricity 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 project was developed in accordance with the WECC Reliability Standards Development
Procedures (Procedures), as approved by NERC/FERC, in effect at each point in the process. Among
other things, the Procedures require that drafting be conducted by a team 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
6
NERC Rules of Procedure, Standard Processes Manual, Version 3, Section 2.0, Elements of a Reliability Standard, Subsection 2.2: Reliability Principles. NERC Reliability Principles are currently located here.
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Attachment K: Order 672 Criteria—WECC-0120 FAC-501-WECC-2 Transmission Maintenance
The Federal Energy Regulatory Commission (FERC) found Version 1 of this standard to be technically
sound in FERC Order 751. 7
Because the proposed changes either fill in a logical void or clarify the existing document, no additional
technical justification is offered.
This project: 1) adds a requirement to follow the Transmission Maintenance Inspection Plan (TMIP) as
opposed to simply having a TMIP, 2) updates Attachment A TMIP Content, reducing ambiguity in the
attachment, 3) eliminates incorporation by reference of the “Major WECC Transfer Paths in the Bulk
Electric System” table in favor of full inclusion as Attachment B, and 4) updates the content and format
of the compliance sections to incorporate NERC styles, format, and standardized language.
3.
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 Reliability Standard is as follows:
Applicable Entities
4.
Applicability
4.1.
4.
Transmission Owners that maintain the transmission paths in Attachment B.
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.
The WECC-0120 FAC-501-WECC-2, Transmission Maintenance project is the result of a five-year review
required under the Procedures. The Standard Authorization Request identified no specific issues nor
did it suggest that any specific changes be made.
7
Order 751, 135 FERC ¶ 61,061, United States of America, Federal Energy Regulatory Commission, 18 CFR Part 40, Docket
No. RM09-9-000; Version One Regional Reliability Standards for Facilities Design, Connections, and Maintenance; Protection
and Control; and Voltage and Reactive, issued April 21, 2011
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Attachment K: Order 672 Criteria—WECC-0120 FAC-501-WECC-2 Transmission Maintenance
The project clearly states the tasks each applicable entity must complete, how performance of the
tasks will be measured, and compliance elements indicating how lack of performance will be
addressed.
Per the Procedures, the project was posted for comment five times.
In Posting 2, the drafting team opted not to change language of Requirement R1 because the proposed
changes added no additional clarity but would have the effect of expanding the Applicability section of
the standard without providing justification for the change.
In Posting 3, the drafting team addressed ambiguities by: 1) correcting the plural tense of some
phrases, 2) eliminating an and/or statement in Attachment A, and 3) adopting NERC’s formatting and
boilerplate language for compliance sections.
In Posting 4, the drafting team merged a continuum of language from various requirements to
eliminate any single requirement containing multiple required tasks.
In Posting 5, the language of Measure M3 was streamlined to eliminate ambiguity.
For more information on the specifics of these changes please review Attachments R1-R5 of this filing.
5.
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.
Table of Compliance Elements
FAC-501-WECC-2, Transmission Maintenance, Section C – Compliance has been updated to reflect the
current language used in new NERC Standards.
Violation Risk Factors (VRF) 8
No changes were made to the Violation Risk Factors.
Violation Severity Levels (VSL) 9
The drafting team used NERC’s Violation Severity Level Guidelines (VSL) to review and complete an upto-date VSL table where none previously existed. The drafting team used the Version 1 VSL narrative
to populate the Version 2 VSL table, interpolating where necessary to achieve the required compliance
8
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NERC Criteria for Violation Risk Factors
NERC Violation Severity Level Guidelines
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tiers, and correcting the narrative to ensure the VSL had an actual relationship to the task impacted
(eliminating apples-to-oranges narrative). See Response to Comments, Posting 4 for further detail
(Attachment R4).
6.
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.
NERC’s most recent Compliance section narrative was included.
Each Requirement has a corresponding Measure.
Each Requirement has been assigned a Violation Risk Factor.
Each Requirement has been assigned a tiered Violation Severity Level.10
7.
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 five postings, the cost issue was neither raised nor addressed.
The reliability goal of the project is to ensure that Transmission Owners maintaining specified paths
have a TMIP and use that plan. The project calls for a high-level TMIP without precluding additional
detail.
8.
Proposed Reliability Standards cannot be “lowest common denominator”.
“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
10
Where required performance cannot be broken down into compliance tiers, those requirements require assignment of a
“severe” VSL. NERC Violation Severity Level Guidelines, page 2.
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reliability. Although the Commission will give due weight to the technical expertise of the ERO, [the
Commission] will not hesitate to remand a proposed Reliability Standard if…convinced it is not
adequate to protect reliability.” Order No. 672 at P 329.
Version 2 largely maintains the tasks and burdens included in Version 1; albeit, with greater clarity and
adoption of updated drafting conventions.
9.
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 five postings at WECC the industry raised no cost concerns.
10.
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
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.”
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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.” 11
In accordance with FERC Orders 751, paragraph 11, Version One was found to be applicable solely
within the Western Interconnection, and more stringent than NERC Standards. 12 Version Two does not
change that finding.
11.
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
changes made in Version Two.
In the five postings at WECC, the industry raised no concerns regarding competition or restrictive use
of the grid.
12.
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.
Per the Procedures, an implementation plan was posted for comment during at least one of the five
postings for comment. See Attachment F – Implementation Plan.
Conforming Changes to Other Standards
There are no conforming changes to other standards required to implement the proposed document.
11
NERC Rules of Procedure, Section 312, Regional Reliability Standards.
FERC Order 751, 135 FERC ¶ 61,061, United States of America, Federal Energy Regulatory Commission, 18 CFR Part 40,
Docket No. RM09-9-000, Version One Regional Reliability Standards for Facilities Design, Connections, and Maintenance;
Protection and Control; and Voltage and Reactive, Issued April 21, 2011
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Proposed Effective Date
The Effective Date is proposed to be the first day of the first quarter following applicable regulatory
approval.
Justification
The WECC-0120, FAC-501-WECC-2, Transmission Maintenance Drafting Team (DT) reviewed NERC
Standards, both in effect and those standards that have been approved by the NERC Board of Trustees
but pending final regulatory disposition. The DT concluded that the proposed substantive changes
pose a minimal burden beyond current reasonable and customary operations. As such, the
implementation time should impose no undue burden.
Consideration of Early Compliance
The drafting team foresees no concerns with early compliance.
Required Retirements
The currently approved standard, FAC-501-WECC-1, should be retired immediately prior to the
Effective Date of this version, FAC-501-WECC-2. No other retirements or modifications are needed.
13.
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.
The WECC Procedures, as approved by WECC/NERC/FERC were used during each development step of
this project.
In accordance with the Procedures, all drafting team meetings were open to the public.
All drafting team meetings were announced via the WECC Standards Email List for the prescribed
period, prior to each meeting. Notice of each meeting 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 online internet
visual capability allowing all participants to see the document(s) as they were being developed.
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Further, this team held an open-mic Standards Briefing prior to balloting affording the industry an
additional opportunity to have any questions addressed.
The project was also posted for comment at NERC in accordance with NERC’s Rules of Procedures.
Comments and responses to comments are found in their original format on the WECC-0120 Project
Page on the Submit and Review project accordion.
14.
Proposed Reliability Standards must balance with other vital public interests.
“Finally, [the Commission understands] 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 concerns were raised or noted.
15.
Proposed Reliability Standards must consider any other relevant factors.
“In considering whether a proposed Reliability Standard is just and reasonable, we will consider the
following 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.
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Exhibit D
Analysis of Violation Risk Factors and Violation Severity Levels
VRF and VSL Justification
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Table of Compliance Elements
FAC-501-WECC-2, Transmission Maintenance, Section C – Compliance has been updated to reflect the
current language used in new NERC Standards.
Violation Risk Factors (VRF) 1
No changes were made to the Violation Risk Factors.
Violation Severity Levels (VSL) 2
The drafting team used NERC’s Violation Severity Level Guidelines (VSL) to review and complete an upto-date VSL table where none previously existed. The drafting team used the Version 1 VSL narrative
to populate the Version 2 VSL table, interpolating where necessary to achieve the required compliance
tiers, and correcting the narrative to ensure the VSL had an actual relationship to the task impacted
(eliminating apples-to-oranges narrative). See Response to Comments, Posting 4 for further detail.
1
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NERC Criteria for Violation Risk Factors
NERC Violation Severity Level Guidelines
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Summary of Development History and Complete Record of Development
Summary of Development History
Summary of Development History
The development record for proposed Regional Reliability Standard FAC-501-WECC-2
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 Electric Reliability Organization (“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 Development
Project WECC-0120 FAC-501-WECC-2 – Transmission Maintenance, Five-Year
Review was initiated on June 10, 2016 with receipt of a proposed Standards Authorization
Request (“SAR”). The WECC Standards Committee formally approved the SAR on June 15,
2016 and created a standard drafting team on September 6, 2016.
B. First Posting – Comment Period
On October 12, 2016, the standard drafting team agreed by majority vote to post
proposed Regional Reliability Standard FAC-501-WECC-2 for a 45-day public comment
1
Section 215(d)(2) of the Federal Power Act; 16 U.S.C. §824(d)(2) (2012).
The WECC Reliability Standards Development Procedures are available at
https://www.wecc.biz/Reliability/Reliability%20Standards%20Development%20Procedures%20%20FERC%20Approved%20Dec%2023%202014.pdf
2
1
period. 3 Proposed Regional Reliability Standard FAC-501-WECC-2 was posted for a 45-day
public comment period from October 14, 2016 through November 29, 2016. WECC received
comments from two companies representing five of the eight WECC Standards Voting
Segments. Based on the comments received, the standard drafting team determined to make
substantive changes to the proposed standard. Therefore, the proposed standard was posted for
an additional comment period. 4
C. Second Posting – Comment Period
Proposed Regional Reliability Standard FAC-501-WECC-2 was posted for another public
comment period for 30 days from January 30, 2017 to March 2, 2017. 5 WECC received comments
from three companies representing five of the eight WECC Standards Voting Segments. Based on
the comments received, the standard drafting team determined to make substantive changes to the
proposed standard. 6
D. Third Posting – Comment Period
Proposed Regional Reliability Standard FAC-501-WECC-2 was posted for another public
comment period for 30 days from March 17, 2017 to April 17, 2017. 7 WECC received comments
from three companies representing five of the eight WECC Standards Voting Sectors. Based on
3
Notice of FAC-501-WECC-2 Transmission Maintenance Five-Year Review Posting 1 is available at
https://www.wecc.biz/Administrative/WECC-0120%20Notice%20of%20Posting%20for%20Comment%20%20Posting%201%20-%20FAC-501-WECC-2%2045-Day%20Comment%20Period.pdf.
4
Project WECC-0120 FAC-501-WECC-1 Transmission Maintenance Five-Year Review Response to
Comments for Posting 1 is available at https://www.wecc.biz/Reliability/WECC-0120%20Posting%201%20FAC501-WECC-1%20Response%20to%20Comments%20-%20Draft%201%20to%20Tech%20Writer%2001-262017.docx.
5
Notice of FAC-501-WECC-2 Transmission Maintenance Five-Year Review Posting 2 is available at
https://www.wecc.biz/Reliability/WECC-0120%20Posting%202%20FAC-501-WECC1%20Response%20to%20Comments%20-%20To%20Tech%20Writer%203-14-2017.docx.
6
Project WECC-0120 FAC-501-WECC-1 Transmission Maintenance Five-Year Review FAC-501-WECC-2
Response to Comments for Posting 2 is available at https://www.wecc.biz/Reliability/WECC0120%20Posting%203%20FAC-501-WECC-1%20Response%20to%20Comments.docx.
7
Notice of FAC-501-WECC-2 Transmission Maintenance Five-Year Review Posting 3 is available at
https://www.wecc.biz/Administrative/WECC-0120%20Notice%20of%20Posting%20for%20Comment%20%20Posting%203%20-%20FAC-501-WECC-2%2030-Day%20Comment%20Period.pdf.
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the comments received, the standard drafting team determined to make substantive changes to the
proposed standard. 8
E. Fourth Draft – Comment Period
Proposed Regional Reliability Standard FAC-501-WECC-2 was posted for another public
comment period for 30 days from May 2, 2017 to June 2, 2017. 9 WECC received comments from
two companies representing five of the eight WECC Standards Voting Segments. Based on the
comments received, the standard drafting team determined to make substantive changes to the
proposed standard. 10
F. Fifth Draft – Comment Period
Proposed Regional Reliability Standard FAC-501-WECC-2 was posted for another public
comment period for 30 days from June 23, 2017 to July 24, 2017. 11 WECC received comments
from three companies representing five of the eight WECC Standards Voting Segments.
G. Final Standard for WECC Standards Committee
Because only non-substantive changes were made between the fifth and sixth postings, the
standard drafting team did not solicit public comments on the sixth posting of the standard. On
July 27, 2017, the standard drafting team agreed to send the standard to the WECC Standards
Committee with a request for ballot.
8
Project WECC-0120 FAC-501-WECC-1 Transmission Maintenance Five-Year Review Response to
Comments for Posting 3 is available at https://www.wecc.biz/Reliability/WECC-0120%20Posting%203%20FAC501-WECC-1%20Response%20to%20Comments.docx.
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Notice of FAC-501-WECC-2 Transmission Maintenance Five-Year Review Posting 4 is available at
https://www.wecc.biz/Administrative/WECC-0120%20Notice%20of%20Posting%20for%20Comment%20%20Posting%204%20-%20FAC-501-WECC-2%2030-Day%20Comment%20Period.pdf.
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Project WECC-0120 FAC-501-WECC-1 Transmission Maintenance Five-Year Review Response to
Comments for Posting 4 is available at https://www.wecc.biz/Reliability/WECC-0120%20Posting%204%20FAC501-WECC-1%20Response%20to%20Comments.docx.
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Notice of FAC-501-WECC-2 Transmission Maintenance Five-Year Review Posting 5 (modified June 22,
2017) is available at https://www.wecc.biz/Administrative/WECC0120%20Notice%20of%20Posting%20for%20Comment%20-%20Posting%205%20-%20FAC-501-WECC2%2030-Day%20Comment%20Period%20-%20Amended.pdf.
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H. Ballot Period and Results
On July 31, 2017, the WECC Standards Committee approved proposed Regional
Reliability Standard FAC-501-WECC-2 to be posted for ballot. The ballot pool opened on August
30, 2017 and closed on September 14, 2017. WECC held a Standards Briefing on September 19,
2017. Eighty-seven individuals joined the ballot pool. Seventy-one individuals cast votes, reaching
quorum at 81.6 percent. The standard obtained 55 affirmative votes, 12 which was 100 percent of
the weighted segment vote. As a result, the standard passed ballot on October 11, 2017. 13
I. WECC Board of Directors Approval
On December 6, 2017, the WECC Board of Directors approved proposed Regional
Reliability Standard FAC-501-WECC-2 and the retirement of currently-effective Regional
Reliability Standard FAC-501-WECC-1.
J. NERC Comment Period and Board of Trustees Adoption
NERC received the Regional Reliability Standard Submittal Request for FAC-501-WECC2 on September 6, 2017. NERC posted proposed Regional Reliability Standard FAC-501-WECC2 for a 45-day public comment period from November 3, 2017 to December 18, 2017. 14 The NERC
Board of Trustees adopted proposed Regional Reliability Standard FAC-501-WECC-2 on
February 8, 2018. 15
12
During the ballot period there were 16 abstentions and 16 individuals that did not cast a vote.
The FAC-501-WECC-2 ballot results are available at
https://www.wecc.biz/Reliability/20171011%20WECC-0120%20Final%20Voting%20Record.pdf.
14
The NERC web page for Regional Reliability Standards Under Development is available at
http://www.nerc.com/pa/Stand/Pages/RegionalReliabilityStandardsUnderDevelopment.aspx.
15
NERC, Board of Trustees Agenda Package, Agenda Item 6b (FAC-501-WECC-2 – Transmission
Maintenance), available at
http://www.nerc.com/gov/bot/Agenda%20highlights%20and%20Mintues%202013/Board_of_Trustees_Open_Agen
da_Package_February_8_2018.pdf.
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Complete Record of Development
Steven Rueckert
Director of Standards
(801) 883-6878
[email protected]
February 21, 2018
Mr. Mat Bunch
North American Electric Reliability Corporation (NERC)
Manager of Standards Development
3353 Peachtree Rd. NE, North Tower – Suite 600
Atlanta, GA 30326
Regarding: Notification of Completion
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Dear Mat,
In accordance with the WECC Reliability Standards Development Procedures, the WECC-0120 FAC-501WECC-2, Transmission Maintenance Drafting Team has completed its assigned project. The proposed
standard has been approved by the WECC Ballot Pool and the WECC Board of Directors.
WECC is seeking approval by the NERC Board of Trustees, with subsequent disposition by the Federal
Energy Regulatory Commission, to retire Version 1 of the standard and replace it with the proposed
Version 2.
Overview
This project: 1) adds a requirement to follow the Transmission Maintenance Inspection Plan (TMIP) as
opposed to simply having a TMIP, 2) updates Attachment A TMIP Content, reducing ambiguity in the
attachment, 3) eliminates incorporation by reference of the “Major WECC Transfer Paths in the Bulk
Electric System” table in favor of full inclusion as Attachment B, and 4) updates the content and format
of the compliance sections to incorporate NERC styles, format, and standardized language.
Thank you for your assistance.
Steven Rueckert
WECC Director of Standards
WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114
Attachment A: Supporting Documentation WECC-0120 FAC-501-WECC-2
2
For documentation support please contact Mr. W. Shannon Black, [email protected], (503) 307-5782.
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Regional Reliability Standard
SAR – Standard Authorization Request Attachment A (1)
Regional Reliability Standard(s) (Clean Existing) Attachment B (2)
Regional Reliability Standard(s) (redlined) Attachment C (3)
Regional Reliability Standard(s) (redlined) Attachment D (4)
Project Roadmap Attachment E (5)
Implementation Plan Attachment F (6)
Technical Justification Attachment G (7)
VRF & VSL Justification Attachment H (8)
Regional Reliability Standard Submittal Request Attachment I (9)
Order 672 Criteria Attachment J (10)
Drafting Team Roster with Biographies Attachment K (11)
Ballot Pool Members Attachment L (12)
Final Ballot Results Attachment M (13)
Minority Issues Attachment N (14)
WECC Standards Committee Roster Attachment O (15)
Responses to Comments – WECC Attachment P1 (16), P2 (17), P3 (18), P4 (19), P5 (20) and P6 (21)
Info (22)
FAC-501-WECC-2
Clean (23) |
Redline (24)
FAC-501-WECC-2
Transmission
Maintenance
Standard Under
Development
11/03/17 12/18/17
Submit Comments
Unofficial
Comment Form
(Word) (25)
Comments
Received (26)
Consideration of
Comments (27)
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Attachment A
Standard Authorization Request
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
This Standard Authorization Request (SAR) was received on June 10, 2016 and deemed complete the
same day. The SAR was vetted and approved during the June 15, 2016 WECC Standards Committee
meeting.
Introduction
In accordance with the Reliability Standards Development Procedures (Procedures), Regional Reliability
Standards (RRS) such as WECC’s Standard FAC-501-WECC-1, Transmission Maintenance (FAC) are to be
reviewed at least once every five years from the effective date of the most recent version of the RRS.
The FAC’s effective date was July 1, 2011 making it subject to review July 1, 2016.
Requester Information
1. Provide your contact information and your alternates contact information:
• Your First Name:
W. Shannon
• Your Last Name:
Black
• Your Email Address:
[email protected]
• Your Phone Number:
(503) 307-5782
• Organization Name:
WECC
• Alternate’s First Name:
Steven
• Alternate’s Last Name:
Rueckert
• Alternate’s Email Address: [email protected]
• Alternate’s Phone Number: NA
Type of Request
2. Specify the type of request: (select one)
• Request to Review and update as needed.
Create, Modify or Retire a Document Questions
Provide the requested information for your request to create, modify, or retire the document.
3. Requested Action: (select one)
• Other
i. Five-year review
WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114
Standard Authorization Request
2
4. Document Type: (select one)
• WECC Regional Reliability Standard (RRS)
5. Issue: Specify what industry problem this request is trying to resolve.
The FAC was created under the Procedures and requires review at least once every five years.
The RRS Effective Date is July 1, 2011 making it subject to review.
No specific issues have been identified.
No specific changes are known to be required.
6. Proposed Remedy: Specify how this request proposes to address the issue described.
The assigned drafting team (DT) is requested to review the documents and to take one of the
following courses of action (or an appropriate combination thereof) or each document:
Option 1:
No Change
Recommend that no changes should be made. If the DT recommends Option 1, the DT will
notify the WSC of its finding. The WSC will, in turn, communicate that decision via the
Standards Email List (SEL) and no further action will be required, per the Procedures at
Maintenance of RRS and Ops Documents.
Option 2:
Non-Substantive Changes
Recommend that only non-substantive changes should be made for clarity or conformity to
current drafting conventions. If the DT recommends Option 2, the DT will draft and provide
those changes to the WSC. Upon a WSC finding that the changes are non-substantive in nature,
the WSC shall request WECC Board of Director approval of the proposed changes, with
subsequent disposition to be handled in accordance with the NERC Standards Development
Manual or its successor, per the Procedures at Step 6 – Respond to Comments, NonSubstantive Changes.
Option 3:
Substantive Changes
Recommend that substantive changes should be made, in which case, the DT will draft and
develop those changes in accordance with the Procedures.
7. Functions: Each function will be reviewed if affected.
• 4.
Applicability
4.1 Transmission Owners that maintain the transmission paths in the most
current table titled “Major WECC Transfer Paths in the Bulk Electric System.”
(Table; as posted “Revised September 19, 2007.)
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8. Detailed Description:
See above.
Special Note regarding the Applicability Section and its Reference to the Table
If the Table is updated, the DT is charged to establish the criteria whereby paths are added or
subtracted from the Table.
In FERC Order 752, Docket No. RM09-14-000, FERC approved (WECC-0111) TOP-007-WECC-1a,
System Operating Limits (TOP) to replace TOP-STD-007-0 Operating Transfer Capability.
Because the Table is also incorporated by reference into the FAC, FERC expressed concern that
“the applicability of [those documents referencing the Table] could change without Commission
and industry notice and opportunity to respond” and instructed WECC to submit a compliance
filing to address FERC’s concern. P37.
The Commission accepted “WECC’s commitment to publicly post any revisions to the WECC
Transfer Path Table on the WECC website with concurrent notification to the Commission,
NERC, and industry. P43.
In FERC Order 751 and 752 Compliance Filing, Docket RM09-9-000 and RM-09-14-000, WECC
reported that it “is using an open, transparent, stakeholder process…to develop the criteria” for
modifying the Table. “After approval by the WECC Board of Directors, WECC will post the
criteria on its website and provide notice to FERC, NERC and the industry through a subsequent
Compliance Filing, unless otherwise directed by the Commission.” WECC has agreed not to
modify “the Tables in the interim, unless directed by the Commission.” (All references are in
Section III. WECC Transfer Path Table and WECC Remedial Action Schemes Table)
9. Affected Reliability Principles: Which of the following reliability principles is MOST affected by
this request? (select one)
• Reliability Principle — To ensure the applicable Transmission Owner includes specified
facilities in its Transmission Maintenance and Inspection Plans, and performs
maintenance and inspection accordingly.
Document Information
Specify the documents title, document number, and affected section regarding the request.
10. Document Title:
11. Document Title:
W
E S T E R N
E
FAC-501-WECC-1, Transmission Maintenance
Table – only if modified
L E C T R I C I T Y
C
O O R D I N A T I N G
C
O U N C I L
Standard Authorization Request
4
Reference Uploads
Please reference or upload any affected Standards, Regional Business Practices, Criterion, 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.
12. Provide additional comments (if needed)
W
E S T E R N
E
L E C T R I C I T Y
C
O O R D I N A T I N G
C
O U N C I L
WECC Standard FAC-501-WECC-1 – Transmission Maintenance
A. Introduction
1. Title:
Transmission Maintenance
2. Number:
FAC-501-WECC-1
3. Purpose:
To ensure the Transmission Owner of a transmission path identified in the table
titled “Major WECC Transfer Paths in the Bulk Electric System” including
associated facilities has a Transmission Maintenance and Inspection Plan (TMIP);
and performs and documents maintenance and inspection activities in accordance
with the TMIP.
4. Applicability
4.1 Transmission Owners that maintain the transmission paths in the most current table titled
“Major WECC Transfer Paths in the Bulk Electric System” provided at:
https://www.wecc.biz/Reliability/TableMajorPaths4-28-08.pdf.
5. Effective Date: July 1, 2011
B. Requirements
R.1. Transmission Owners shall have a TMIP detailing their inspection and maintenance
requirements that apply to all transmission facilities necessary for System Operating Limits
associated with each of the transmission paths identified in table titled “Major WECC
Transfer Paths in the Bulk Electric System.” [Violation Risk Factor: Medium] [Time
Horizon: Long-term Planning]
R1.1.
Transmission Owners shall annually review their TMIP and update as required.
[Violation Risk Factor: Medium] [Time Horizon: Long-term Planning]
R.2. Transmission Owners shall include the maintenance categories in Attachment 1-FAC-501WECC-1 when developing their TMIP. [Violation Risk Factor: Medium] [Time Horizon:
Operations Assessment]
R.3. Transmission Owners shall implement and follow their TMIP. [Violation Risk Factor:
Medium] [Time Horizon: Operations Assessment]
C. Measures
M1. Transmission Owners shall have a documented TMIP per R.1.
M1.1
Transmission Owners shall have evidence they have annually reviewed their TMIP
and updated as needed.
M2. Transmission Owners shall have evidence that their TMIP addresses the required
maintenance details of R.2.
M3. Transmission Owners shall have records that they implemented and followed their TMIP as
required in R.3. The records shall include:
1. The person or crew responsible for performing the work or inspection,
2. The date(s) the work or inspection was performed,
3. The transmission facility on which the work was performed, and
4. A description of the inspection or maintenance performed.
RevURL11-7-14
Page 1 of 4
WECC Standard FAC-501-WECC-1 – Transmission Maintenance
D. Compliance
1. Compliance Monitoring Process
1.1
Compliance Monitoring Responsibility
Compliance Enforcement Authority
1.2
Compliance Monitoring Period
The Compliance Enforcement Authority may use one or more of the following
methods to assess compliance:
-
Self-certification conducted annually
Spot check audits conducted anytime with 30 days notice given to prepare
Periodic audit as scheduled by the Compliance Enforcement Authority
Investigations
Other methods as provided for in the Compliance Monitoring Enforcement Program
The Reset Time Frame shall be one year.
1.3
Data Retention
The Transmission Owners shall keep evidence for Measure M1 through M3 for three
years plus the current year, or since the last audit, whichever is longer.
1.4 Additional Compliance Information
No additional compliance information.
2. Violation Severity Levels
2.1. Lower: There shall be a Lower Level of non-compliance if any of the following
conditions exist:
2.1.1
The TMIP does not include associated Facilities for one of the Paths identified in
Attachment 1 FAC-501-WECC-1 as required by R.1 but Transmission Owners
are performing maintenance and inspection for the missing Facilities.
2.1.2
Transmission Owners did not review their TMIP annually as required by R.1.1.
2.1.3
The TMIP does not include one maintenance category identified in Attachment 1
FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing
maintenance and inspection for the missing maintenance categories.
2.1.4
Transmission Owners do not have maintenance and inspection records as required
by R.3 but have evidence that they are implementing and following their TMIP.
2.2. Moderate: There shall be a Moderate Level of non-compliance if any of the following
conditions exist:
2.2.1
The TMIP does not include associated Facilities for two of the Paths identified in
the most current Table titled “Major WECC Transfer Paths in the Bulk Electric
System” as required by R.1 and Transmission Owners are not performing
maintenance and inspection for the missing Facilities.
2.2.2
The TMIP does not include two maintenance categories identified in Attachment
1 FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing
maintenance and inspection for the missing maintenance categories.
RevURL11-7-14
Page 2 of 4
WECC Standard FAC-501-WECC-1 – Transmission Maintenance
2.2.3
Transmission Owners are not performing maintenance and inspection for one
maintenance category identified in Attachment 1 FAC-501-WECC-1 as required
in R3.
2.3. High: There shall be a High Level of non-compliance if any of the following condition
exists:
2.3.1 The TMIP does not include associated Facilities for three of the Paths identified in
the most current Table titled “Major WECC Transfer Paths in the Bulk Electric
System” as required by R.1 and Transmission Owners are not performing
maintenance and inspection for the missing Facilities.
2.3.2 The TMIP does not include three maintenance categories identified in Attachment 1
FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing
maintenance and inspection for the missing maintenance categories.
2.3.3 Transmission Owners are not performing maintenance and inspection for two
maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required in
R3.
2.4. Severe: There shall be a Severe Level of non-compliance if any of the following condition
exists:
2.4.1 The TMIP does not include associated Facilities for more than three of the Paths
identified in the most current Table titled “Major WECC Transfer Paths in the Bulk
Electric System” as required by R.1 and Transmission Owners are not performing
maintenance and inspection for the missing Facilities.
2.4.2 The TMIP does not exist or does not include more than three maintenance
categories identified in Attachment 1 FAC-501-WECC-1 as required by R.2 but
Transmission Owners are performing maintenance and inspection for the missing
maintenance categories.
2.4.3 Transmission Owners are not performing maintenance and inspection for more than
two maintenance categories identified in Attachment 1 FAC-501-WECC-1 as
required in R3.
Version History – Shows Approval History and Summary of Changes in the Action Field
Version
1
1
Action
Permanent Replacement Standard for
PRC-STD-005-1
October 29, 2008 NERC BOT conditional approval
1
RevURL11-7-14
Date
April 16, 2008
April 21, 2011
FERC Approved in Order 751
Page 3 of 4
Change Tracking
WECC Standard FAC-501-WECC-1 – Transmission Maintenance
Attachment 1-FAC-501-WECC-1
Transmission Line and Station Maintenance Details
The maintenance practices in the TMIP may be performance-based, time-based, conditional based,
or a combination of all three. The TMIP shall include:
1. A list of Facilities and associated Elements necessary to maintain the SOL for the transfer paths
identified in the most current Table titled “Major WECC Transfer Paths in the Bulk Electric
System;”
2. The scheduled interval for any time-based maintenance activities and/or a description
supporting condition or performance-based maintenance activities including a description of the
condition based trigger;
3. Transmission Line Maintenance Details:
a. Patrol/Inspection
b. Contamination Control
c. Tower and wood pole structure management
4. Station Maintenance Details:
a. Inspections
b. Contamination Control
c. Equipment Maintenance for the following:
•
Circuit Breakers
•
Power Transformers (including phase-shifting transformers)
•
Regulators
•
Reactive Devices (including, but not limited to, Shunt Capacitors, Series
Capacitors, Synchronous Condensers, Shunt Reactors, and Tertiary Reactors)
Page 4 of 4
WECC Standard FAC-501-WECC-2 ─ Transmission Maintenance
A. Introduction
1.
Title:
2.
Number: FAC-501-WECC-2
3.
Purpose: To ensure the Transmission Owner of a transmission path identified in
Attachment B, Major WECC Transfer Paths in the Bulk Electric System,
including associated facilities has a Transmission Maintenance and
Inspection Plan (TMIP); and performs and documents maintenance and
inspection activities in accordance with the TMIP.
Transmission Maintenance
4. Applicability
4.1 Transmission Owners that maintain the transmission paths in Attachment B.
5.
Effective Date: The first day of the first quarter following applicable regulatory
approval.
B. Requirements and Measures
R1.
Each Transmission Owner shall have a TMIP that includes, at a minimum, each of
the items listed in Attachment A, Transmission Maintenance and Inspection Plan
Content. [Violation Risk Factor: Medium] [Time Horizon: Long-term Planning]
M1.
Each Transmission Owner will have evidence that it has a TMIP detailing each of the
items listed in Attachment A, as required in Requirement R1.
R2.
Each Transmission Owner shall annually update its TMIP to reflect all changes to its
TMIP. [Violation Risk Factor: Medium] [Time Horizon: Long-term Planning]
M2.
Each Transmission Owner will have evidence that it annually updated its TMIP, as
required in Requirement R2. When an annual update shows that no changes are
required to the TMIP, evidence may include but is not limited to, attestation that
the update was performed but showed that no changes were required.
R3.
Each Transmission Owner shall adhere to its TMIP. [Violation Risk Factor:
Medium] [Time Horizon: Operations Assessment]
M3.
Each Transmission Owner will have evidence that it adhered to its TMIP, as
required in Requirement R3. Evidence may include, but is not limited to:
1.1
The date(s) the patrol, inspection or maintenance was performed;
1.2
The transmission Facility or Element on which the maintenance was performed;
1.3
A description of the inspection results or maintenance performed.
Page 1 of 7
WECC Standard FAC-501-WECC-2 ─ Transmission Maintenance
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 Transmission Owners listed in section 4.1 shall keep data or
evidence of Requirements 1-3 for three calendar years, or since the last
audit, whichever is longer.
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 2 of 7
WECC Standard FAC-501-WECC-2 ─ Transmission Maintenance
Violation Severity Levels
R#
R1.
R2.
R3.
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
The Transmission
Owner’s TMIP did
not include one
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
annually update
its TMIP (within
the 365 days
following the last
review), as
required by R2.
The Transmission
Owner’s TMIP did
not include two
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
update its TMIP
within the last
one year and 1
day (within the
366 days
following the last
review), as
required by R2.
The
Transmission
Owner failed to
adhere to:
1) two
transmission
line
maintenance
items; or, 2)
two station
maintenance
items; or 3) any
combination of
two items taken
from the above
list, for items
contained in its
TMIP, as
required in R3.
The Transmission
Owner’s TMIP did
not include three
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
update its TMIP
within the last
two years and 1
day (within the
731 days
following the last
review), as
required by R2.
The
Transmission
Owner failed to
adhere to:
1) three
transmission
line
maintenance
items; or, 2)
three station
maintenance
items; or 3) any
combination of
three items
taken from the
above list, for
items contained
in its TMIP, as
required in R3.
The Transmission
Owner’s TMIP did
not include four or
more of the items
listed in Attachment
A, as required in
Requirement R1.
The
Transmission
Owner failed to
adhere to: 1)
one
transmission
line
maintenance
item, or 2) one
station
maintenance
item, as
contained in its
TMIP, as
required in R3.
Page 3 of 7
The Transmission
Owner did not update
its TMIP within the
last three years and 1
day (within the 1095
days following the
last review), as
required by R2.
The Transmission
Owner failed to
adhere to:
1) four or more
transmission line
maintenance items;
or, 2) four or more
station
maintenance items;
or, 3) any
combination of
four or more items
taken from the
above list, for items
contained in its
TMIP, as required
in R3.
WECC Standard FAC-501-WECC-2 ─ Transmission Maintenance
D. Regional Variances
None.
E. Associated Documents
None
Version History – Shows Approval History and Summary of Changes in the Action Field
Version
Date
Action
1
April 16, 2008
Permanent Replacement Standard for PRCSTD-005-1
1
October 29,
2008
NERC BOT conditional approval
1
April 21, 2011
FERC Approved in Order 751
2
TBD
TBD
Change
Tracking
1) Conformed to
newest NERC
template and
drafting
conventions, 2)
eliminated URLs,
3) clarified
Attachment A,
and Measure
3M.
Page 4 of 7
WECC Standard FAC-501-WECC-2 ─ Transmission Maintenance
Attachment A
Transmission Maintenance and Inspection Plan Content
The TMIP shall include, at a minimum, each of the following details:
1.
Facilities
A list of Facilities (e.g., transmission lines, transformers, etc.) and Elements (e.g., circuit breaker, bus
section, etc.) that comprise each transmission path(s) identified in Attachment B, Major WECC
Transfer Paths in the Bulk Electric System.
2.
Maintenance Methodology
A description of the maintenance methodology used for the Facility, transmission line, or station
included in the TMIP.
The TMIP maintenance methodology may be any one of the following or any combination thereof,
but must include at least one of the following:
•
•
•
3.
Performance-based
Time-based
Condition based
Periodicity
A specification of the periodicity that the described maintenance will occur, or under what
circumstances it occurs.
4.
Transmission Line Maintenance
A description of each of the following for the transmission line(s) included in the TMIP:
a. Inspection requirements
b. Patrol requirements
c. Tower and wood pole structure management
5.
Station Maintenance
A description of each of the following for each station included in the TMIP:
a. Inspection requirements
b. Equipment maintenance for each of the following:
1.
Circuit breakers
2.
Power transformers (including, but not limited to, phase-shifting
transformers)
3.
Reactive devices (including, but not limited to, shunt capacitors, series
capacitors, synchronous condensers, shunt reactors, and tertiary reactors)
Page 5 of 7
WECC Standard FAC-501-WECC-2 ─ Transmission Maintenance
Attachment B
Major WECC Transfer Paths in the Bulk Electric System
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
PATH NAME*
Alberta – British Columbia
Northwest – British Columbia
West of Cascades – North
West of Cascades – South
West of Hatwai
Montana to Northwest
Idaho to Northwest
South of Los Banos or Midway- Los Banos
Idaho – Sierra
Borah West
Idaho – Montana
Bridger West
Path C
Southwest of Four Corners
PG&E – SPP
Northern – Southern California
Intmntn. Power Project DC Line
TOT 1A
TOT 2A
Pavant – Gonder 230 kV
Intermountain – Gonder 230 kV
TOT 2B
TOT 2C
TOT 3
TOT 5
SDGE – CFE
West of Colorado River (WOR)
Southern New Mexico (NM1)
Northern New Mexico (NM2)
East of the Colorado River (EOR)
Cholla – Pinnacle Peak
Southern Navajo
Brownlee East
Lugo – Victorville 500 kV
Pacific DC Intertie
COI
North of John Day cutplane
Alturas
Montana Southeast
SCIT**
COI/PDCI – North of John Day cutplane**
Path Number
1
3
4
5
6
8
14
15
16
17
18
19
20
22
24
26
27
30
31
32
34
35
36
39
45
46
47
48
49
50
51
55
61
65
66
73
76
80
* For an explanation of terms, path numbers, and definition for the paths refer
to WECC’s Path Rating Catalog.
** The SCIT and COI/PDCI-North of John Day Cutplane are paths that are operated in
accordance with nomograms identified in WECC’s Path Rating Catalog.
Page 6 of 7
WECC Standard FAC-501-WECC-2 ─ Transmission Maintenance
THIS SECTION WILL NOT BE PART OF THE STANDARD BUT IS REQUIRED FOR NERC FILING.
Standards Authorization Request (SAR)
WECC-0120 FAC-501-WECC-2 Transmission Maintenance SAR
Approvals Required
•
•
•
•
WECC Ballot Pool
WECC Board of Directors
NERC Board of Trustees
FERC
Pending
Pending
Pending
Pending
Applicable Entities
Transmission Owners that maintain the transmission paths in the most current WECC Major Paths table
(Attachment B of the standard)
Conforming Changes to Other Standards
None are required.
Proposed Effective Date
The first day of the first quarter following regulatory approval
Justification
The WECC-0120, FAC-501-WECC-2, Transmission Maintenance Drafting Team (DT) has reviewed NERC
Standards, both in effect and those standards that are NERC Board of Trustees approved pending
regulatory filing. The DT concluded that the proposed substantive changes pose a minimal burden beyond
ordinary and current operations. As such, the short implementation time should impose no undue
burden.
Consideration of Early Compliance
The DT foresees no negative impacts to reliability in the event of early compliance.
Retirements
None
Page 7 of 7
WECC Standard FAC-501-WECC-12 ─ Transmission Maintenance
A. Introduction
1.
Title:
2.
Number: FAC-501-WECC-12
3.
Purpose: To ensure the Transmission Owner of a transmission path identified in the
table titled “Attachment B, Major WECC Transfer Paths in the Bulk Electric
System”, including associated facilities has a Transmission Maintenance and
Inspection Plan (TMIP); and performs and documents maintenance and
inspection activities in accordance with the TMIP.
Transmission Maintenance
4. Applicability
4.1 Transmission Owners that maintain the transmission paths in the most current table
titled “Attachment B.Major WECC Transfer Paths in the Bulk Electric
System” provided at:
https://www.wecc.biz/Reliability/TableMajorPaths4-28-08.pdf.
5.
Effective Date: July 1, 2011The first day of the first quarter following applicable
regulatory approval.
B. Requirements and Measures
R1.
Each Transmission OwnersOwner shall have a TMIP detailing their inspection and
maintenance requirements that apply to all transmission facilities necessary for System
Operating Limits associated withincludes, at a minimum, each of the transmission
paths identified in table titled “Major WECC Transfer Paths in the Bulk Electric
System.”items listed in Attachment A, Transmission Maintenance and Inspection
Plan Content. [Violation Risk Factor: Medium] [Time Horizon: Long-term
Planning]
R1.1.
Transmission OwnersM1. Each Transmission Owner will have evidence that it has a
TMIP detailing each of the items listed in Attachment A, as required in Requirement
R1.
R2.
Each Transmission Owner shall annually review their TMIP and update as
required.
its TMIP to reflect all changes to its TMIP. [Violation Risk Factor: Medium] [Time Horizon:
Long-term Planning]
Transmission Owners shall M2.
Each Transmission Owner will have evidence that it
annually updated its TMIP, as required in Requirement R2. When an annual
update shows that no changes are required to the TMIP, evidence may include the
maintenance categories in Attachment 1-FAC-501- WECC-1 when developing their
TMIP.but is not limited to, attestation that the update was performed but showed
that no changes were required.
RevURL11-7-14
Page 1 of 4
R3.
Each Transmission Owner shall adhere to its TMIP. [Violation Risk Factor:
Medium] [Time Horizon: Operations Assessment]
R.1. M3.
Each Transmission Owners shall implement and follow their TMIP.
[Violation Risk Factor: Medium] [Time Horizon: Operations Assessment]
A. Measures
M1. Transmission Owners shall have a documented TMIP per R.1.
M1.1
Transmission Owners shall have evidence they have annually reviewed their TMIP
and updated as needed.
M2. Transmission Owners shallOwner will have evidence that their TMIP addresses the
required maintenance details of R.2.
M3. Transmission Owners shall have records that they implemented and followed their TMIPit
adhered to its TMIP, as required in R.3. The records shallRequirement R3. Evidence
may include, but is not limited to:
The person or crew responsible for performingdate(s) the workpatrol, inspection
or maintenance was performed;
1. The transmission Facility or inspection,
1.1
2. The date(s) the work or inspection was performed,
The transmission facilityElement on which the workmaintenance was
performed, and;
1.11.2
1.21.3
A description of the inspection results or maintenance performed.
WECC Standard FAC-501-WECC-12 ─ Transmission Maintenance
RevURL11-7-14
Page 1 of 4
C. Compliance
1.
Compliance Monitoring Process
2.1
Compliance Monitoring Responsibility
Enforcement Authority: “Compliance Enforcement Authority
Compliance Monitoring Period” means NERC
The Compliance Enforcement Authority may use one or more of the following
methods to assessRegional Entity, or any entity as otherwise designated by an
Applicable Governmental Authority, in their respective roles of monitoring and/or
enforcing compliance:
- Self-certification conducted annually
1.1. Spot check audits conducted anytime with 30 days notice given to
preparemandatory 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 Periodic audit as scheduled by the Compliance Enforcement Authority
- Investigations
- Other methods as provided for in the Compliance Monitoring Enforcement Program
The Reset Time Frame shall be one year.
2.2
Data Retention
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 Transmission Owners listed in section 4.1 shall keep data or
evidence for Measure M1 through M3of Requirements 1-3 for three
calendar years plus the current year, or since the last audit, whichever is
longer.
2.3 Additional Compliance Information
No additional compliance information.
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.
WECC Standard FAC-501-WECC-12 ─ Transmission Maintenance
Violation Severity Levels
2.1. Lower: There shall be a Lower Level of non-compliance if any of the following
conditions exist:
The TMIP does not include associated
R#
Violation Severity Levels
Lower VSL
R1.
R2.
R3.
The Transmission
Owner’s TMIP did
not include one
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
annually update
its TMIP (within
the 365 days
following the last
review), as
required by R2.
The
Transmission
Owner failed to
adhere to: 1)
one
transmission
line
maintenance
item, or 2) one
station
maintenance
item, as
contained in its
TMIP, as
required in R3.
RevURL11-7-14
Moderate VSL
The Transmission
Owner’s TMIP did
not include two
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
update its TMIP
within the last
one year and 1
day (within the
366 days
following the last
review), as
required by R2.
The
Transmission
Owner failed to
adhere to:
1) two
transmission
line
maintenance
items; or, 2)
two station
maintenance
items; or 3) any
combination of
two items taken
from the above
list, for items
contained in its
TMIP, as
Page 13 of 4
High VSL
Severe VSL
The Transmission
Owner’s TMIP did
not include three
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
update its TMIP
within the last
two years and 1
day (within the
731 days
following the last
review), as
required by R2.
The
Transmission
Owner failed to
adhere to:
1) three
transmission
line
maintenance
items; or, 2)
three station
maintenance
items; or 3) any
combination of
three items
taken from the
above list, for
items contained
in its TMIP, as
The Transmission
Owner’s TMIP did
not include four or
more of the items
listed in Attachment
A, as required in
Requirement R1.
The Transmission
Owner did not update
its TMIP within the
last three years and 1
day (within the 1095
days following the
last review), as
required by R2.
The Transmission
Owner failed to
adhere to:
1) four or more
transmission line
maintenance items;
or, 2) four or more
station
maintenance items;
or, 3) any
combination of
four or more items
taken from the
above list, for items
contained in its
TMIP, as required
in R3.
required in R3.
required in R3.
D. Regional Variances
None.
E. Associated Documents
None
2.1.1
Facilities for one of the Paths identified in Attachment 1 FAC-501-WECC-1 as
required by R.1 but Transmission Owners are performing maintenance and
inspection for the missing Facilities.
2.1.2
Transmission Owners did not review their TMIP annually as required by R.1.1.
2.1.3
The TMIP does not include one maintenance category identified in Attachment 1
FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing
maintenance and inspection for the missing maintenance categories.
2.1.4
Transmission Owners do not have maintenance and inspection records as required
by R.3 but have evidence that they are implementing and following their TMIP.
2.2. Moderate: There shall be a Moderate Level of non-compliance if any of the following
conditions exist:
2.2.1
The TMIP does not include associated Facilities for two of the Paths identified in
the most current Table titled “Major WECC Transfer Paths in the Bulk Electric
System” as required by R.1 and Transmission Owners are not performing
maintenance and inspection for the missing Facilities.
2.2.2
The TMIP does not include two maintenance categories identified in Attachment 1
FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing
maintenance and inspection for the missing maintenance categories.
WECC Standard FAC-501-WECC-12 ─ Transmission Maintenance
2.2.3
Transmission Owners are not performing maintenance and inspection for one
maintenance category identified in Attachment 1 FAC-501-WECC-1 as required
in R3.
2.3. High: There shall be a High Level of non-compliance if any of the following condition
exists:
2.3.1 The TMIP does not include associated Facilities for three of the Paths identified in
the most current Table titled “Major WECC Transfer Paths in the Bulk Electric
System” as required by R.1 and Transmission Owners are not performing
maintenance and inspection for the missing Facilities.
2.3.2 The TMIP does not include three maintenance categories identified in Attachment 1
FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing
maintenance and inspection for the missing maintenance categories.
2.3.3 Transmission Owners are not performing maintenance and inspection for two
maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required in
R3.
2.4. Severe: There shall be a Severe Level of non-compliance if any of the following condition
exists:
2.4.1 The TMIP does not include associated Facilities for more than three of the Paths
identified in the most current Table titled “Major WECC Transfer Paths in the Bulk
Electric System” as required by R.1 and Transmission Owners are not performing
maintenance and inspection for the missing Facilities.
2.4.2 The TMIP does not exist or does not include more than three maintenance
categories identified in Attachment 1 FAC-501-WECC-1 as required by R.2 but
Transmission Owners are performing maintenance and inspection for the missing
maintenance categories.
2.4.3 Transmission Owners are not performing maintenance and inspection for more than
two maintenance categories identified in Attachment 1 FAC-501-WECC-1 as
required in R3.
Version History – Shows Approval History and Summary of Changes in the Action Field
Version
Date
1
April 16, 2008
Permanent Replacement Standard for
PRC-STD-005-1
1
October 29,
2008
NERC BOT conditional approval
1
April 21, 2011
FERC Approved in Order 751
RevURL11-7-14
Action
Page 1 of 4
Change
Tracking
WECC Standard FAC-501-WECC-2 ─ Transmission Maintenance
Attachment 1- TBD
TBD
FAC-501WECC-1 2
Page 1 of 13
1) Conformed to
newest NERC
template and
drafting
conventions, 2)
eliminated URLs,
3) clarified
Attachment A,
and Measure
3M.
WECC Standard FAC-501-WECC-2 ─ Transmission Maintenance
Attachment A
Transmission Line and Station Maintenance Detailsand Inspection Plan Content
The maintenance practices in the TMIP may be performance-based, time-based, conditional based, or a
combination of all three. The TMIP shall include:, at a minimum, each of the following details:
1.
Facilities
A list of Facilities and associated (e.g., transmission lines, transformers, etc.) and Elements necessary
to maintain the SOL for the transfer paths (e.g., circuit breaker, bus section, etc.) that comprise each
transmission path(s) identified in the most current Table titled “Attachment B, Major WECC Transfer
Paths in the Bulk Electric System;”.
1. The scheduled interval for any time-based maintenance activities and/or a description supporting
condition or performance-based maintenance activities including a description of the condition
based trigger;
2.
Maintenance Methodology
A description of the maintenance methodology used for the Facility, transmission line, or station
included in the TMIP.
The TMIP maintenance methodology may be any one of the following or any combination thereof,
but must include at least one of the following:
•
•
•
3.
Performance-based
Time-based
Condition based
Periodicity
A specification of the periodicity that the described maintenance will occur, or under what
circumstances it occurs.
4.
Transmission Line Maintenance Details:
A description of each of the following for the transmission line(s) included in the TMIP:
a. Inspection requirements
b. Patrol/Inspection requirements
a. Contamination Control
c. Tower and wood pole structure management
5.
Station Maintenance Details:
b. Inspections
c. Contamination Control
A description of each of the following for each station included in the TMIP:
a. Inspection requirements
Page 2 of
WECC Standard FAC-501-WECC-2 ─ Transmission Maintenance
a.b. Equipment Maintenancemaintenance for each of the following:
1.
Circuit Breakersbreakers
•
2.
Power Transformers (including phase-shifting transformers)
•
Regulators
Reactive Devices (including, but not limited to, phase-shifting transformers)
3.
Reactive devices (including, but not limited to, shunt capacitors, series
capacitors, synchronous condensers, shunt reactors, and tertiary reactors)
Page 3 of 13
WECC Standard FAC-501-WECC-2 ─ Transmission Maintenance
Attachment B
Major WECC Transfer Paths in the Bulk Electric SystemShunt Capacitors, Series
Capacitors, Synchronous Condensers, Shunt Reactors, and Tertiary Reactors)
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
PATH NAME*
Alberta – British Columbia
Northwest – British Columbia
West of Cascades – North
West of Cascades – South
West of Hatwai
Montana to Northwest
Idaho to Northwest
South of Los Banos or Midway- Los Banos
Idaho – Sierra
Borah West
Idaho – Montana
Bridger West
Path C
Southwest of Four Corners
PG&E – SPP
Northern – Southern California
Intmntn. Power Project DC Line
TOT 1A
TOT 2A
Pavant – Gonder 230 kV
Intermountain – Gonder 230 kV
TOT 2B
TOT 2C
TOT 3
TOT 5
SDGE – CFE
West of Colorado River (WOR)
Southern New Mexico (NM1)
Northern New Mexico (NM2)
East of the Colorado River (EOR)
Cholla – Pinnacle Peak
Southern Navajo
Brownlee East
Lugo – Victorville 500 kV
Pacific DC Intertie
COI
North of John Day cutplane
Alturas
Montana Southeast
SCIT**
COI/PDCI – North of John Day cutplane**
Path Number
1
3
4
5
6
8
14
15
16
17
18
19
20
22
24
26
27
30
31
32
34
35
36
39
45
46
47
48
49
50
51
55
61
65
66
73
76
80
* For an explanation of terms, path numbers, and definition for the paths refer
to WECC’s Path Rating Catalog.
** The SCIT and COI/PDCI-North of John Day Cutplane are paths that are operated in
accordance with nomograms identified in WECC’s Path Rating Catalog.
Page 4 of
WECC Standard FAC-501-WECC-2 ─ Transmission Maintenance
THIS SECTION WILL NOT BE PART OF THE STANDARD BUT IS REQUIRED FOR NERC FILING.
Standards Authorization Request (SAR)
WECC-0120 FAC-501-WECC-2 Transmission Maintenance SAR
Approvals Required
•
•
•
•
WECC Ballot Pool
WECC Board of Directors
NERC Board of Trustees
FERC
Pending
Pending
Pending
Pending
Applicable Entities
Transmission Owners that maintain the transmission paths in the most current WECC Major Paths table
(Attachment B of the standard)
Conforming Changes to Other Standards
None are required.
Proposed Effective Date
The first day of the first quarter following regulatory approval
Justification
The WECC-0120, FAC-501-WECC-2, Transmission Maintenance Drafting Team (DT) has reviewed NERC
Standards, both in effect and those standards that are NERC Board of Trustees approved pending
regulatory filing. The DT concluded that the proposed substantive changes pose a minimal burden beyond
ordinary and current operations. As such, the short implementation time should impose no undue
burden.
Consideration of Early Compliance
The DT foresees no negative impacts to reliability in the event of early compliance.
Retirements
None
Page 5 of 13
Attachment E
Project Roadmap
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Project Roadmap
Actions
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
SAR Filed
WSC approved the SAR
WSC assigned the drafting team
First DT meeting
Posting 1 Comments Open
Posting 1 Comments Closed (45-day)
DT Meets to answer Comments
DT Meets to answer Comments
Posting 2 Comments Open
Posting 2 Comments Closed
DT Meets to answer Comments
Posting 3 Comments Open
Posting 3 Comments Closed
DT Meets to answer Comments
DT Meets to answer Comments
Posting 4 Comments Open
Posting 4 Comments Closed
DT Meets to answer Comments
Posting 5 Comments Open
Posting 5 Comments Closed
DT Meets to answer Comments
WSC approves for Ballot
Notice of Ballot Pool Forming
Ballot Pool Open
Notice of Standards Briefing
Ballot Pool Closed
Standards Briefing
Ballot Open
Ballot Closed
Date
June 10, 2016
June 15, 2016
September 6, 2016
October 12, 2016
October 14, 2016
November 29, 2016
December 13, 2016
January 26, 2017
January 30, 2017
March 2, 2017
March 14, 2017
March 17, 2017
April 17, 2017
April 20, 2017
April 27, 2017
May 2, 2017
June 2, 2017
June 6, 2017
June 14, 2017
July 14, 2017
July 25, 2017
July 31, 2017
August 23, 2017
August 30, 2017
September 1, 2017
September 14, 2017
September 19, 2017
September 21, 2017
October 11, 2017
WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114
WECC-0120 FAC-501-WECC-2 — Transmission Maintenance
Page 2 of 2
30. NERC Posting for 45 days Opens
November 3, 2017
31. WSC approves forwarding document to the WECC Board of Directors
November 15, 2017
32. WECC Board of Directors Approved
December 6, 2017
33. NERC Posting for 45 days Closes
December 18, 2017
Anticipated Actions
Proposed Date
34. NERC Board of Trustees approval
Pending
35. FERC approval
Pending
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Attachment F
Implementation Plan
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Standard Authorization Request
WECC-0120 SAR is located here. In this filing, it is provided as Attachment A.
Approvals Required
•
•
•
WECC Board of Directors
NERC Board of Trustees
FERC
December 6, 2017
February 8, 2018
Pending
Applicable Entities
4.
Applicability
4.1
Transmission Owners that maintain the transmission paths in Attachment B.
Conforming Changes to Other Standards
There are no conforming changes to other standards required to implement the proposed document.
Proposed Effective Date
The Effective Date is proposed to be the first day of the first quarter following applicable regulatory approval.
Justification
The WECC-0120, FAC-501-WECC-2, Transmission Maintenance Drafting Team (DT) reviewed NERC Standards,
both in effect and those standards that are approved by the NERC Board of Trustees, but pending regulatory
disposition. The DT concluded that the proposed substantive changes pose a minimal burden beyond current
reasonable and customary operations. As such, the implementation time should impose no undue burden.
Consideration of Early Compliance
The drafting team foresees no concerns with early compliance.
Required Retirements
The currently approved standard (FAC-501-WECC-1) should be retired immediately prior to the Effective Date of
this version, FAC-501-WECC-2. No other retirements or modifications are needed.
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Attachment G
Technical Justification
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
The Federal Energy Regulatory Commission (FERC) found Version 1 of this standard to be technically
sound in FERC Order 751. 1
Because the proposed changes either fill in a logical void or clarify the existing document, no additional
technical justification is offered.
The WECC-0120 FAC-501-WECC-2, Transmission Maintenance project is the result of a five-year review
required under the WECC Reliability Standards Development Procedures (Procedures), Maintenance of
RRSs and CRTs. The Standard Authorization Request identified no specific issues nor recommended
any specific changes.
This project:
1. adds a requirement to follow the Transmission Maintenance Inspection Plan (TMIP) as opposed
to simply having a TMIP,
2. updates Attachment A TMIP Content, reducing ambiguity in the attachment,
3. eliminates incorporation by reference of the “Major WECC Transfer Paths in the Bulk Electric
System” table in favor of full inclusion as Attachment B, and
4. updates the content and format of the compliance sections to incorporate NERC styles, format,
and standardized language.
Order 751, 135 FERC ¶ 61,061, United States of America, Federal Energy Regulatory Commission, 18 CFR Part 40, Docket
No. RM09-9-000; Version One Regional Reliability Standards for Facilities Design, Connections, and Maintenance; Protection
and Control; and Voltage and Reactive: issued April 21, 2011.
1
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Attachment H
VRF and VSL Justification
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Table of Compliance Elements
FAC-501-WECC-2, Transmission Maintenance, Section C – Compliance has been updated to reflect the
current language used in new NERC Standards.
Violation Risk Factors (VRF) 1
No changes were made to the Violation Risk Factors.
Violation Severity Levels (VSL) 2
The drafting team used NERC’s Violation Severity Level Guidelines (VSL) to review and complete an upto-date VSL table where none previously existed. The drafting team used the Version 1 VSL narrative
to populate the Version 2 VSL table, interpolating where necessary to achieve the required compliance
tiers, and correcting the narrative to ensure the VSL had an actual relationship to the task impacted
(eliminating apples-to-oranges narrative). See Response to Comments, Posting 4 for further detail.
1
2
NERC Criteria for Violation Risk Factors
NERC Violation Severity Level Guidelines
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Regional Reliability Standard Submittal Request
Attachment I
Region:
Western Electricity Coordinating Council
Regional Standard Number:
FAC-501-WECC-2
Regional Standard Title:
Transmission Maintenance
Date Submitted:
February 21, 2018
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 Variance
Interpret an Existing Standard
Approval of a new standard
Revision of an existing standard
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)):
December 6, 2017, Board of Directors / Board Resolution
Resolved, that the Western Electricity Coordinating Council Board of Directors (Board), acting upon
the recommendation of the WECC Standards Committee at the meeting of the Board on December
6, 2017, hereby approves the following Regional Reliability Standards and Regional Criteria as
presented to the Board on December 6, 2017.
• BAL-004-WECC-3, Automatic Time Error Correction
1
Regional Reliability Std Submittal Request
• FAC-501-WECC-2, Transmission Maintenance
• INT-007-WECC-CRT-3, Processing of Emergency Requests for Interchange
• INT-016-WECC-CRT-3, Data Submittal
• PRC-001-WECC-CRT-2, Governor Droop Setting
[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 The WECC-0120 FAC-501-WECC-2, Transmission Maintenance project
basis and purpose (scope) is the result of a five-year review required under the WECC Reliability
Standards Development Procedures, addressing the maintenance of
of request:
Regional Reliability Standards. The Standard Authorization Request
identified no specific issues or changes to be made. Once reviewed,
the drafting team made the following changes to bring the document
up to current NERC drafting standards and formats.
This project: 1) adds a requirement to follow the Transmission
Maintenance Inspection Plan (TMIP) as opposed to simply having a
TMIP, 2) updates Attachment A TMIP Content, reducing ambiguity in
the attachment, 3) eliminates incorporation by reference of the
“Major WECC Transfer Paths in the Bulk Electric System” table in
favor of full inclusion as Attachment B, and 4) updates the content
and format of the compliance sections to incorporate NERC styles,
format, and standardized language.
Concise statement of the
justification of the
request:
See above.
2
Regional Reliability Std Submittal Request
Attachment J
Order 672 Criteria
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
NERC is responsible for the activities governing “the development, approval, revision, reaffirmation,
and withdrawal of Reliability Standards, Interpretations, Violations Risk Factors (VRF), Violation
Severity Levels (VSL), definitions, Variances, and reference documents developed to support standards
for the Reliable Operation and planning of the North American Bulk Power Systems”. 1
In FERC Order No. 672, 2 the Federal Energy Regulatory Commission (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.” 3 The following discussion identifies
these factors, and explains how the proposed Regional Reliability Standard (RRS) meets or exceeds
these criteria. 4
1.
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.” 5
1
NERC Rules of Procedure, Standard Processes Manual, Version 3, Section 1.0, Introduction, Sub-section 1.2 Scope. June 26,
2013. For purposes of this filing, the term Reliability Standard is synonymous with Regional Reliability Standard (RRS).
2
FERC Order 672, P 320-338.
3
FERC Order 672, P320.
NERC Rules of Procedure, Definitions Used in Rules of Procedure, Appendix 2 to the Rules of Procedure, page 19, October
31, 2016. See also NERC Rules of Procedure, Section 300 Reliability Standards development, Sub-section 312.1 Regional
Reliability Standards, indicating that Regional Reliability Standards “shall in all cases be submitted to NERC for adoption and,
if adopted, made part of the NERC Reliability Standards and shall be enforceable in accordance with the delegation
agreement between NERC and the Regional Entity or other instrument granting authority over enforcement to the Regional
Entity.”
5
Order No. 672 at P 321.
4
WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114
Attachment K: Order 672 Criteria—WECC-0120 FAC-501-WECC-2 Transmission Maintenance
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 Reliability Standard
serves a 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.” 6
Of NERC’s eight NERC Reliability Principles, FAC-501-WECC-2 meets:
Reliability Principle 3
“Information necessary for the planning and operation of interconnected bulk power systems shall be
made available to those entities responsible for planning and operating the systems reliably.”
2.
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 [Electricity 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 project was developed in accordance with the WECC Reliability Standards Development
Procedures (Procedures), as approved by NERC/FERC, in effect at each point in the process. Among
other things, the Procedures require that drafting be conducted by a team 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
6
NERC Rules of Procedure, Standard Processes Manual, Version 3, Section 2.0, Elements of a Reliability Standard, Subsection 2.2: Reliability Principles. NERC Reliability Principles are currently located here.
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Attachment K: Order 672 Criteria—WECC-0120 FAC-501-WECC-2 Transmission Maintenance
The Federal Energy Regulatory Commission (FERC) found Version 1 of this standard to be technically
sound in FERC Order 751. 7
Because the proposed changes either fill in a logical void or clarify the existing document, no additional
technical justification is offered.
This project: 1) adds a requirement to follow the Transmission Maintenance Inspection Plan (TMIP) as
opposed to simply having a TMIP, 2) updates Attachment A TMIP Content, reducing ambiguity in the
attachment, 3) eliminates incorporation by reference of the “Major WECC Transfer Paths in the Bulk
Electric System” table in favor of full inclusion as Attachment B, and 4) updates the content and format
of the compliance sections to incorporate NERC styles, format, and standardized language.
3.
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 Reliability Standard is as follows:
Applicable Entities
4.
Applicability
4.1.
4.
Transmission Owners that maintain the transmission paths in Attachment B.
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.
The WECC-0120 FAC-501-WECC-2, Transmission Maintenance project is the result of a five-year review
required under the Procedures. The Standard Authorization Request identified no specific issues nor
did it suggest that any specific changes be made.
7
Order 751, 135 FERC ¶ 61,061, United States of America, Federal Energy Regulatory Commission, 18 CFR Part 40, Docket
No. RM09-9-000; Version One Regional Reliability Standards for Facilities Design, Connections, and Maintenance; Protection
and Control; and Voltage and Reactive, issued April 21, 2011
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The project clearly states the tasks each applicable entity must complete, how performance of the
tasks will be measured, and compliance elements indicating how lack of performance will be
addressed.
Per the Procedures, the project was posted for comment five times.
In Posting 2, the drafting team opted not to change language of Requirement R1 because the proposed
changes added no additional clarity but would have the effect of expanding the Applicability section of
the standard without providing justification for the change.
In Posting 3, the drafting team addressed ambiguities by: 1) correcting the plural tense of some
phrases, 2) eliminating an and/or statement in Attachment A, and 3) adopting NERC’s formatting and
boilerplate language for compliance sections.
In Posting 4, the drafting team merged a continuum of language from various requirements to
eliminate any single requirement containing multiple required tasks.
In Posting 5, the language of Measure M3 was streamlined to eliminate ambiguity.
For more information on the specifics of these changes please review Attachments R1-R5 of this filing.
5.
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.
Table of Compliance Elements
FAC-501-WECC-2, Transmission Maintenance, Section C – Compliance has been updated to reflect the
current language used in new NERC Standards.
Violation Risk Factors (VRF) 8
No changes were made to the Violation Risk Factors.
Violation Severity Levels (VSL) 9
The drafting team used NERC’s Violation Severity Level Guidelines (VSL) to review and complete an upto-date VSL table where none previously existed. The drafting team used the Version 1 VSL narrative
to populate the Version 2 VSL table, interpolating where necessary to achieve the required compliance
8
9
NERC Criteria for Violation Risk Factors
NERC Violation Severity Level Guidelines
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tiers, and correcting the narrative to ensure the VSL had an actual relationship to the task impacted
(eliminating apples-to-oranges narrative). See Response to Comments, Posting 4 for further detail
(Attachment R4).
6.
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.
NERC’s most recent Compliance section narrative was included.
Each Requirement has a corresponding Measure.
Each Requirement has been assigned a Violation Risk Factor.
Each Requirement has been assigned a tiered Violation Severity Level.10
7.
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 five postings, the cost issue was neither raised nor addressed.
The reliability goal of the project is to ensure that Transmission Owners maintaining specified paths
have a TMIP and use that plan. The project calls for a high-level TMIP without precluding additional
detail.
8.
Proposed Reliability Standards cannot be “lowest common denominator”.
“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
10
Where required performance cannot be broken down into compliance tiers, those requirements require assignment of a
“severe” VSL. NERC Violation Severity Level Guidelines, page 2.
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reliability. Although the Commission will give due weight to the technical expertise of the ERO, [the
Commission] will not hesitate to remand a proposed Reliability Standard if…convinced it is not
adequate to protect reliability.” Order No. 672 at P 329.
Version 2 largely maintains the tasks and burdens included in Version 1; albeit, with greater clarity and
adoption of updated drafting conventions.
9.
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 five postings at WECC the industry raised no cost concerns.
10.
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
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.”
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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.” 11
In accordance with FERC Orders 751, paragraph 11, Version One was found to be applicable solely
within the Western Interconnection, and more stringent than NERC Standards. 12 Version Two does not
change that finding.
11.
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
changes made in Version Two.
In the five postings at WECC, the industry raised no concerns regarding competition or restrictive use
of the grid.
12.
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.
Per the Procedures, an implementation plan was posted for comment during at least one of the five
postings for comment. See Attachment F – Implementation Plan.
Conforming Changes to Other Standards
There are no conforming changes to other standards required to implement the proposed document.
11
NERC Rules of Procedure, Section 312, Regional Reliability Standards.
FERC Order 751, 135 FERC ¶ 61,061, United States of America, Federal Energy Regulatory Commission, 18 CFR Part 40,
Docket No. RM09-9-000, Version One Regional Reliability Standards for Facilities Design, Connections, and Maintenance;
Protection and Control; and Voltage and Reactive, Issued April 21, 2011
12
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Proposed Effective Date
The Effective Date is proposed to be the first day of the first quarter following applicable regulatory
approval.
Justification
The WECC-0120, FAC-501-WECC-2, Transmission Maintenance Drafting Team (DT) reviewed NERC
Standards, both in effect and those standards that have been approved by the NERC Board of Trustees
but pending final regulatory disposition. The DT concluded that the proposed substantive changes
pose a minimal burden beyond current reasonable and customary operations. As such, the
implementation time should impose no undue burden.
Consideration of Early Compliance
The drafting team foresees no concerns with early compliance.
Required Retirements
The currently approved standard, FAC-501-WECC-1, should be retired immediately prior to the
Effective Date of this version, FAC-501-WECC-2. No other retirements or modifications are needed.
13.
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.
The WECC Procedures, as approved by WECC/NERC/FERC were used during each development step of
this project.
In accordance with the Procedures, all drafting team meetings were open to the public.
All drafting team meetings were announced via the WECC Standards Email List for the prescribed
period, prior to each meeting. Notice of each meeting 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 online internet
visual capability allowing all participants to see the document(s) as they were being developed.
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Further, this team held an open-mic Standards Briefing prior to balloting affording the industry an
additional opportunity to have any questions addressed.
The project was also posted for comment at NERC in accordance with NERC’s Rules of Procedures.
Comments and responses to comments are found in their original format on the WECC-0120 Project
Page on the Submit and Review project accordion.
14.
Proposed Reliability Standards must balance with other vital public interests.
“Finally, [the Commission understands] 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 concerns were raised or noted.
15.
Proposed Reliability Standards must consider any other relevant factors.
“In considering whether a proposed Reliability Standard is just and reasonable, we will consider the
following 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.
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Attachment K
Drafting Team Roster
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Five-Year Review
Below please find a biographical snapshot for the members of the WECC-0120 FAC-501-WECC-2,
Transmission Maintenance Drafting Team.
Jeff Watkins
NV Energy
Chair
Mr. Watkins has four years working as a Substation Field Engineer assisting with
commissioning of new substations, troubleshooting misoperations and assisting
the crews with maintenance tasks including analyzing maintenance results
including DGA, breaker motion analysis and power factor testing.
Additionally, Mr. Watkins has seven years working as a System Protection
Engineer creating settings for new installations and trouble-shooting
misoperations. He served as a subject-matter expert for PRC-005-X, and
developed/implemented a new maintenance program for protection systems to
comply with PRC-005-2.
Mr. Watkins also has one year of experience working in the Compliance
Department as a Compliance Engineer. A majority of his time is spent working
with the various departments interpreting standards and supplying technical help
when needed. He also performs technical assessments on certain standards (such
as PRC-023 and TPL-001-4) to help ensure that the standards are correct from a
technical standpoint.
Cristi Sawtell
Ms. Sawtell began her career in the electrical industry at Bonneville Power as a
Transmission Lineman performing maintenance and construction activities. In
2010, she joined the Work Planning and Evaluation Group overseeing yearly
maintenance and construction work plans for the Transmission Field
Organization. For the last two and a half years Ms. Sawtell has been working as
the Transmission Field Compliance Specialist, focused on the maintenance
organizations compliance program related to PRC-005 and FAC-501 standards.
Diana Torres
Ms. Torres has worked in the public utility industry for 29 years, with the last 10
years in the reliability compliance office performing compliance assessments of
Operations and Planning standards, and developing and training internal
compliance programs (which included background of NERC/WECC compliance,
WECC CMEP, WECC audit training and internal controls). Ms. Torres coordinated
and helped lead four WECC audits working directly with audit leads.
Imperial
Irrigation
District
For the last four years, Ms. Torres has worked with subject-matter experts to
conduct compliance assessments of the FAC-501 Standard, Transmission
Maintenance and Inspection Program evidence and procedures. She regularly
attends WECC outreach events, such as open webinars, compliance workshops
and human performance conferences.
WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114
Attachment J
Drafting Team Roster
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Five-Year Review
Kathee Downey
PacifiCorp
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Ms. Downey has been involved in WECC committees for several years, on drafting
teams, and leading drafting teams. Specifically, those relating to Interchange
Scheduling and Accounting Subcommittee (ISAS) and Federal Energy Regulatory
Commission (FERC) Order 764. Currently she is serving as PacifiCorp's
representative on the Operating Committee and ISAS.
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Attachment L
Ballot Pool Members
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Ballot Pool
Title
Company
Sector
WECC-0120
Arizona Public
Service
Company
Distribution
WECC-0120
Arizona Public
Service
Company
Marketers and
Brokers
WECC-0120
Arizona Public
Service
Company
Vote
Comments
Created By
Yes
Michelle
Amarantos
Yes
Linda
Henrickson
Generation
Yes
Nicholas
Kirby
WECC-0120
Arizona Public
Service
Company
System
Coordination
Yes
Vivian Vo
WECC-0120
Arizona Public
Service
Company
Transmission
Yes
Gary Nolan
WECC-0120
Avista
Corporation
Generation
Yes
Glen
Farmer
WECC-0120
Avista
Corporation
Marketers and
Brokers
Yes
Scott
Kinney
WECC-0120
Balancing
Authority of
Northern
California
System
Coordination
Position is neutral - The
changes to the “-2”
Standard would be
somewhat insignificant to
our TMIP or current
inspection and
Abstain maintenance practices.
Joe
Tarantino
WECC-0120
Bonneville
Power
Administration
Distribution
Yes
Rebecca
Berdahl
WECC-0120
Bonneville
Power
Administration
Marketers and
Brokers
Yes
Andrew
Meyers
WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114
Ballot Pool Members: WECC-0120 FAC-501-WECC-2, Transmission Maintenance
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Title
Company
WECC-0120
Bonneville
Power
Administration
Transmission
WECC-0120
Bonneville
Power
Administration
System
Coordination
WECC-0120
British
Columbia
Hydro & Power
Authority
WECC-0120
British
Columbia
Hydro & Power
Authority
Transmission
WECC-0120
British
Columbia
Hydro & Power
Authority
Distribution
Hootan
Jarollahi
WECC-0120
British
Columbia
Hydro & Power
Authority
Generation
Helen
Hamilton
Harding
WECC-0120
California
Independent
System
Operator
System
Coordination
Yes
Richard
Vine
WECC-0120
California
Independent
System
Operator
Transmission
Yes
Richard
Vine
WECC-0120
Gridforce
Energy
Management,
LLC
System
Coordination
WECC-0120
Idaho Power
Company
System
Coordination
WECC-0120
Idaho Power
Company
E S T E R N
E
Sector
Vote
2
System
Coordination
Created By
Yes
Kammy
RogersHolliday
Yes
Francis
Halpin
Yes
BC Hydro requests the
drafting team provide
clarification on "results"
and what the intent is.
Patricia
Robertson
Yes
BC Hydro requests the
drafting team provide
clarification on "results"
and what the intent is.
Patricia
Robertson
David
Blackshear
Generation
L E C T R I C I T Y
Comments
C
Yes
Laura
Nelson
Yes
Laura
Nelson
O O R D I N A T I N G
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Title
Company
Sector
Vote
WECC-0120
Idaho Power
Company
Distribution
Yes
Laura
Nelson
WECC-0120
Idaho Power
Company
Transmission
Yes
Laura
Nelson
WECC-0120
Los Angeles
Department of
Water and
Power
System
Coordination
Yes
Pjoy Chua
WECC-0120
Los Angeles
Department of
Water and
Power
Generation
Yes
Pjoy Chua
WECC-0120
Los Angeles
Department of
Water and
Power
Distribution
Yes
Pjoy Chua
WECC-0120
Los Angeles
Department of
Water and
Power
Transmission
Yes
Pjoy Chua
WECC-0120
Los Angeles
Department of
Water and
Power
Marketers and
Brokers
Yes
Pjoy Chua
WECC-0120
Northern
California
Power Agency
Generation
Abstain None
Marty
Hostler
WECC-0120
Northern
California
Power Agency
Generation
Abstain None
Marty
Hostler
WECC-0120
Northern
California
Power Agency
Marketers and
Brokers
Standard applies to TO
only and NCPA is
Abstain registered as a GO/GOP.
WECC-0120
NV Energy
Transmission
Yes
WECC-0120
NV Energy
Generation
Yes
Dennis
Sismaet
Kevin
Salsbury
Kevin
Salsbury
WECC-0120
NV Energy
System
Coordination
Yes
Kevin
Salsbury
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O O R D I N A T I N G
Created By
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Ballot Pool Members: WECC-0120 FAC-501-WECC-2, Transmission Maintenance
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Title
Company
Sector
Vote
WECC-0120
NV Energy
Distribution
Yes
WECC-0120
Platte River
Power
Authority
Marketers and
Brokers
WECC-0120
Platte River
Power
Authority
Generation
WECC-0120
Platte River
Power
Authority
Transmission
WECC-0120
Platte River
Power
Authority
System
Coordination
WECC-0120
Powerex, Inc.
Marketers and
Brokers
WECC-0120
Public Service
Company of
Colorado (Xcel
Energy)
System
Coordination
Yes
Robert
Staton
WECC-0120
Public Service
Company of
Colorado (Xcel
Energy)
Generation
Yes
Robert
Staton
WECC-0120
Public Service
Company of
Colorado (Xcel
Energy)
Transmission
Yes
Robert
Staton
WECC-0120
Public Utility
District No. 1
of Snohomish
County
Generation
Yes
Franklin Lu
WECC-0120
Public Utility
District No. 1
of Snohomish
County
Distribution
Yes
Franklin Lu
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Comments
Created By
Kevin
Salsbury
PRPA does not operator
or maintain equipment on
Paths included in
Abstain Attachment A
PRPA does not operate or
maintain equipment on
Paths included in
Abstain Attachment A
PRPA does not operate or
maintain equipment on
Paths included in
Abstain Attachment A
Sabrina
Martz
Tyson
Archie
Jeff Landis
Matthew
Thompson
Gordon
DobsonMack
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Ballot Pool Members: WECC-0120 FAC-501-WECC-2, Transmission Maintenance
Title
Company
Sector
Vote
WECC-0120
Public Utility
District No. 1
of Snohomish
County
Transmission
Yes
Franklin Lu
Comments
Created By
Marketers and
Brokers
Yes
Franklin Lu
System
Coordination
Yes
LeRoy
Patterson
Generation
Yes
LeRoy
Patterson
Distribution
Yes
LeRoy
Patterson
Transmission
Yes
LeRoy
Patterson
Marketers and
Brokers
Yes
LeRoy
Patterson
WECC-0120
Public Utility
District No. 1
of Snohomish
County
Public Utility
District No. 2
of Grant
County
Public Utility
District No. 2
of Grant
County
Public Utility
District No. 2
of Grant
County
Public Utility
District No. 2
of Grant
County
Public Utility
District No. 2
of Grant
County
WECC-0120
Puget Sound
Energy, Inc.
Marketers and
Brokers
Lynda
Kupfer
WECC-0120
Puget Sound
Energy, Inc.
System
Coordination
Theresa
Rakowsky
WECC-0120
Puget Sound
Energy, Inc.
Distribution
Theresa
Rakowsky
WECC-0120
Puget Sound
Energy, Inc.
Transmission
Theresa
Rakowsky
WECC-0120
Puget Sound
Energy, Inc.
Generation
Eleanor
Ewry
WECC-0120
WECC-0120
WECC-0120
WECC-0120
WECC-0120
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Title
Company
Sector
WECC-0120
Sacramento
Municipal
Utility District
System
Coordination
Comments
Position is neutral - The
changes to the “-2”
Standard would be
somewhat insignificant to
our TMIP or current
inspection and
Abstain maintenance practices.
WECC-0120
Sacramento
Municipal
Utility District
Generation
Abstain See Above Comment
Joe
Tarantino
WECC-0120
Sacramento
Municipal
Utility District
Distribution
Abstain See Above Comment
Joe
Tarantino
WECC-0120
Sacramento
Municipal
Utility District
Transmission
Abstain See Above Comment
Joe
Tarantino
WECC-0120
Sacramento
Municipal
Utility District
Marketers and
Brokers
Abstain See Above Comment.
Joe
Tarantino
WECC-0120
Salt River
Project
Marketers and
Brokers
Bobby
Olsen
WECC-0120
Salt River
Project
Generation
Yes
Kevin
Nielsen
WECC-0120
Salt River
Project
Distribution
Yes
Rudy
Navarro
WECC-0120
San Diego Gas
& Electric
System
Coordination
Yes
Bridget
Silvia
WECC-0120
San Diego Gas
& Electric
Generation
Yes
Jerome
Gobby
WECC-0120
San Diego Gas
& Electric
Distribution
Yes
ANNIE RUIZ
WECC-0120
San Diego Gas
& Electric
Transmission
Yes
Martine
Blair
WECC-0120
Seattle City
Light
Transmission
Yes
Hao Li
E S T E R N
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L E C T R I C I T Y
Vote
C
O O R D I N A T I N G
C
Created By
Joe
Tarantino
O U N C I L
Ballot Pool Members: WECC-0120 FAC-501-WECC-2, Transmission Maintenance
Title
Company
Sector
WECC-0120
Seattle City
Light
Marketers and
Brokers
Charles
Freeman
WECC-0120
Southern
California
Edison
Company
System
Coordination
Yes
Romel
Aquino
WECC-0120
Southern
California
Edison
Company
Distribution
Yes
Steven
Mavis
WECC-0120
Southern
California
Edison
Company
Transmission
Yes
Steven
Mavis
WECC-0120
Southern
California
Edison
Company
Generation
Yes
Thomas
Rafferty
WECC-0120
Tacoma Power
System
Coordination
Not applicable to our
Abstain company
Twila Hofer
Generation
Standard not applicable to
Abstain company
Karen
Hedlund
Joseph
Wilson
Chad
Edinger
WECC-0120
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Tacoma Power
Vote
7
Comments
Created By
WECC-0120
Tacoma Power
Transmission
Standard not applicable to
Abstain company
WECC-0120
Tacoma Power
Distribution
Standard not applicable to
Abstain entity.
WECC-0120
Tacoma Power
Marketers and
Brokers
WECC-0120
Tri-State
Generation &
Transmission Reliability
System
Coordination
WECC-0120
Tri-State
Generation &
Transmission Reliability
E S T E R N
E
Todd Lloyd
Transmission
L E C T R I C I T Y
C
Yes
Tracy
Sliman
Yes
Tracy
Sliman
O O R D I N A T I N G
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Title
Company
Sector
WECC-0120
Tri-State
Generation &
Transmission Reliability
Distribution
Janelle Gill
WECC-0120
Tri-State
Generation &
Transmission Reliability
Generation
Mark Stein
WECC-0120
Western Area
Power
Administration
System
Coordination
Yes
Patrick
Harwood
WECC-0120
Western Area
Power
Administration
Transmission
Yes
Patrick
Harwood
WECC-0120
Western Area
Power
Administration
- Rocky
Mountain
Region
E S T E R N
E
Vote
8
Comments
Created By
James
Hirning
Transmission
L E C T R I C I T Y
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Attachment M
Final Ballot Results
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Ballot Name:
FAC-501-WECC-2 Transmission Maintenance
This project: 1) adds a requirement to follow the Transmission Maintenance
Inspection Plan (TMIP) as opposed to simply having a TMIP, 2) updates
Attachment A TMIP Content, reducing ambiguity in the attachment, 3)
eliminates incorporation by reference of the “Major WECC Transfer Paths in the
Bulk Electric System” table in favor of full inclusion as Attachment B, and 4)
updates the content and format of the compliance sections to incorporate NERC
styles, format, and standardized language.
Ballot Pool Open:
Ballot Pool Closed:
Ballot Opened:
Ballot Closed:
Total Ballot Pool:
Total Votes:
Quorum:
Weighted Votes:
Ballot Results:
Voting Sectors
Distribution
08/30/2017
09/14/2017
09/21/2017
10/11/2017
87
71
81.6 %
100.0 %
This project was approved by the WECC-0120 Ballot Pool.
Total
in
Ballot
Pool
Total
Votes
Weighted
Votes
NonSector
Yes
Segment
No
for
Abstain Weight Votes
Vote
Votes Abstain Quorum
Didn't
Vote
15
10
1
10
100.0%
0
2
12
3
0
0
0
0
0.0%
0
0
0
0
Generation
19
11
1
11
100.0%
0
5
16
3
Marketers and
Brokers
14
6
0.6
6
60.0%
0
3
9
5
0
0
0
0
0.0%
0
0
0
0
0
0
0
0
0.0%
0
0
0
0
19
13
1
13
100.0%
0
3
16
3
20
15
1
15
100.0%
0
3
18
2
End User
Representative
Other NonRegistered
State and
Provincial
Representatives
System
Coordination
Transmission
1
Attachment N
Minority Issues
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Following a ballot period from September 21, through October 11, 2017, the WECC Ballot Pool
approved WECC-0120 FAC-501-WECC-2, Transmission Maintenance.
Development Phase Comments – Minority View
Comment response forms and comments received during the development phase of this
project are included as Attachments R1 through R5.
WECC has posted this project for comment on five separate occasions. The drafting team reviewed and
considered all comments received. The following minority opinions were expressed by the industry
during the development phase, but were not accepted by the drafting team.
Posting 1
The 200-kV threshold proposed was not adopted noting that the Path Operator Task Force specifically
included six identified criteria for its approved methodology; however, there was no mention of a
200-kV threshold.
Out of an abundance of caution, during Posting 2 the drafting team agreed to ask the industry for
additional guidance on the proposed threshold.
Posting 2
The drafting team agreed with commenters that a 200-kV applicability threshold created an easily
manageable bright line for compliance. However, the suggested change to the applicability threshold
was declined because the alternatives examined would arbitrarily include additional facilities to which
the more stringent requirements need not apply.
Posting 3
The drafting team declined the invitation to alter the content of the Major WECC Transfer Paths in the
Bulk Electric System (Table). To do so required a much broader skillset than available on the drafting
team.
The drafting team instructed commenters that if changes to the table were needed, a separate
Standard Authorization Request should be filed for that specific purpose. To produce a work product
WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114
WECC-0120 FAC-501-WECC-2 Transmission Maintenance
2
that would comport with FERC’s instructions, it is likely that the WECC Path Rating Catalogue would
have to be revamped using the WECC Reliability Standards Development Procedures. 1
Any changes to the table that might result from such a project would require changing the impacted
information in each standard in which the table resides.
Posting 4
The drafting team considered each of the proposed non-substantive changes to Requirements R2, R3,
Attachment A – Title, Attachment A – Body, and the insertion of the more granular phrase
“Maintenance Categories.” Although the drafting team did not adopt these specific changes, other
changes were incorporated targeting greater clarity. (See Attachment R4, Response to Comment for
Posting 4.)
Posting 5
There were no minority concerns.
1
Please refer to the WECC-0120 Standard Authorization Request for background on FERC’s instructions regarding any
changes to the Table.
W
E S T E R N
E
L E C T R I C I T Y
C
O O R D I N A T I N G
C
O U N C I L
Attachment O
WECC Standards Committee Roster
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
The following individuals were assigned to the WECC Standards Committee as of September 1, 2017.
Sector
1. Transmission
2. Generation
3. Marketers and Brokers
4. Distribution
5. System Coordination
6. End User Representative
7. State and Provincial
8. Other Non-Registered Entities
9. Board of Directors
Name
Dana Cabbell
Gary Nolan
Tanner Brier
Warren Rust
Joseph Tarantino
Caitlin Liotiris
Vacant
Crystal Musselman
Joe McArthur
Organization
Southern California Edison Company
Arizona Public Service Company
Bonneville Power Administration
Colorado Springs Utilities
Sacramento Muni. Utility District
Utah Assoc. of Energy Users
Vacant
Proven Compliance Solutions
Non-Affiliate Director/WSC Chair
WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
SALT LAKE CITY, UTAH 84103-1114
Attachment P1
FAC-501-WECC-2
Transmission Maintenance
Response to Comments / Posting 1
October 14 through November 29, 2016
Posting 1
The WECC-0120 FAC-501-WECC-2, Transmission Maintenance Five-year Review Drafting Team (DT)
thanks everyone who submitted comments on the proposed document.
Posting
This document was posted for a 45-day public comment period from October 14, 2016 through
November 29, 2016.
On October 13, 2016, WECC distributed notice of the posting via the Standards Email List.
The DT asked stakeholders to provide feedback on the proposed document through a standardized
electronic template. WECC received comments from two entities as shown in the following table.
Location of Comments
All comments received on the document can be viewed in their original format on the WECC-0120
project page under the “Submit and Review Comments” accordion.
Changes in Response to Comment
The drafting team considered the suggested language and agreed to post the following change in
Posting 2:
"R1. Each Transmission Owner shall have a TMIP detailing its inspection and maintenance
requirements that apply to all transmission facilities comprising each transmission path identified in the
Table.” (emphasis added)
To conform the language to drafting conventions, in the Purpose statement the following phrase
would be added to streamline references that followed:
“Major WECC Transfer Paths in the Bulk Electric System” (Table).” (emphasis added)
Minority View
The 200-kV threshold proposed was not adopted noting that the Path Operator Task Force specifically
included six identified criteria for its approved methodology; however, there was no mention of a
200-kV threshold.
Comment Report Form for WECC-0120
Out of an abundance of caution, for Posting 2 the drafting team agreed to ask the industry for
additional guidance on the proposed threshold.
Effective Date and Implementation Plan
The Reliability Standards Development Procedures (Procedures) require that an implementation plan
be posted with at least one posting of the project. The Effective Date is proposed as the first day of the
first quarter following applicable regulatory approval.
Action Plan
The project will be posted for an iterative 30-day posting period to include the proposed changes and
the following additional questions:
1) Commenters have suggested that Requirement R1 should contain a threshold statement of 200
kV and above. Do you agree that Requirement R1 should state that it specifically applies at 200
kV and above? Yes/No
2) Please explain why you made the choice selected in Question 1.
3) Are there sufficient existing NERC Standards to cover the reliability-related substance of FAC501-WECC-1 in the event the entire document was retired? Yes/no.
4) If you answered yes to the above question, please list the specific NERC Standards and
Requirements that render FAC-501-WECC-1 redundant and practical for retirement.
5) The drafting team welcomes comments on all aspects of the document.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC
Consultant. In addition, the WECC Reliability Standards Appeals Process can be found in the Reliability
Standards Development Procedures.
Commenter
1 Kristie Cocco
Organization
Arizona Public Service Company
2
Bonneville Power Administration (SalientCRGT)
Justin Mosiman
Comment Report Form for WECC-0120
Index to Questions, Comments, and Responses
Question
The Drafting Team welcomes comments on all aspects of the document.
Comment Report Form for WECC-0120
1. Response Summary
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment
Arizona Public Service Company
Response
AZPS approves the changes as proposed.
The drafting team appreciates AZPS’s continued involvement in the standards development
process.
Bonneville Power Administration
SalientCRGT
NERC, in their "Operating Limit Definition and
Exceedance Clarification" document
reaffirmed their definition of a System
Operating Limit (SOL) to be a facility rating, a
voltage limit, or a stability limit. With the
exception of a stability limit, this definition of
SOL does not involve the concept of a "path"
as this term has historically been understood
in WECC. The Path Operator Implementation
Task Force (POITF) further expanded this
separation of "path" and SOL in a set of
recommendations that were approved by
WECC in March, 2016. These
recommendations are the basis of the revised
SOL Methodology that PeakRC has recently
drafted and which will go into effect on April
1, 2017.
Unless there is a stability limit, PeakRC will no
longer be associating SOLs with paths. All of
these actions on the part of NERC, WECC, and
PeakRC have broken the tight coupling
between the concept of SOL and the concept
of a "path" that has previously existed in
WECC. If the existing FAC-501 language is not
modified, Transmission Operators (TOPs)
would be forced to run a separate set of
studies using a methodology that may not be
consistent with the new standards and SOL
Comment Report Form for WECC-0120
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment
Response
methodology after April 1, 2017 simply to
identify facilities that could impact a path SOL
that is not even used in actual operations.
In order to maintain consistency and align
with the shift away from determining path
system operating limits in the operations time
horizon beginning April 1, 2017 and the
predominance of lines rated above 200kV
comprising the WECC Transfer Paths,
Bonneville Power Administration (BPA)
suggests modifying R1 to read:
"Each Transmission Owner shall have a TMIP
detailing its inspection and maintenance
requirements that apply to all transmission
facilities rated 200kV and above which
comprise each of the transmission paths
identified in the Table "Major WECC Transfer
Paths in the Bulk Electric System."
Requirement Change
The drafting team considered the suggested language and agreed to post the following change
for an additional 30-day comment period:
"R1. Each Transmission Owner shall have a TMIP detailing its inspection and maintenance
requirements that apply to all transmission facilities comprising each transmission path
identified in the Table.” (emphasis added)
Purpose Statement Change
To conform the language to drafting conventions, in the Purpose statement the following
phrase would be added to streamline references that followed:
“Major WECC Transfer Paths in the Bulk Electric System” (Table).” (emphasis added)
Comment Report Form for WECC-0120
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment
Response
Consideration of the 200-kV Threshold
The DT declined to adopt the suggested 200-kV threshold without further vetting. As such, a
specific question regarding the 200-kV threshold will be added to the next posting. That
decision is based on the following:
The January 1, 2016 definition of a System Operating Limit (SOL) states that the SOL
methodology includes, but is not limited to, those items mentioned by BPA.
The February 2, 2016, Path Operator Implementation Task Force, System Stressing
Methodology states:
For purposes of the Path Operator Implementation Task Force (POITF) and Peak
Reliability’s (Peak) SOL Methodology, the objective of stressing the system is to
determine whether instability risks practically exist for a particular transmission
interface or load area. Transfer analyses for purposes of determining TC or TTC are
outside the scope of the POITF and the RC’s SOL Methodology.
While the system should be stressed far enough to accomplish the intended objective,
the expectation of this methodology is to stress the system up to – and slightly beyond
– reasonable maximum stressed conditions. It is not the intent of this methodology for
TOPs to stress the system unrealistically or to stress the system to levels appreciably
beyond those that are practically or realistically achievable.
The paper goes on to provide six criteria that should be examined in the studies. None of the
criteria mention a 200-kV threshold.
The DT will ask the industry for further guidance regarding inclusion of the proposed 200-kV
threshold because:
•
•
the methodology may have been more deeply vetted during the POITF proceeding, and
the POITF did not mention the 200-kV threshold.
A question regarding the threshold will be included in Posting 2.
Consideration of Retirement
Finally, after considering comments during the January 26, 2017, DT call, the DT will also ask
the industry whether existing NERC Standards sufficiently cover the reliability concerns in the
event the FAC were to be retired.
Attachment P2
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Response to Comments / Posting 2
January 30 through March 2, 2017
Posting 2
The WECC-0120 FAC-501-WECC-2, Transmission Maintenance Five-year Review Drafting Team (DT)
thanks everyone who submitted comments on the proposed document.
Posting
This document was posted for a 30-day public comment period from January 30 through March 2,
2017.
On January 26, 2017, WECC distributed notice of the posting via the Standards Email List.
The DT asked stakeholders to provide feedback on the proposed document through a standardized
electronic template. WECC received comments from three entities as shown in the following table.
Location of Comments
All comments received on the document can be viewed in their original format on the WECC-0120
project page under the “Submit and Review Comments” accordion.
Changes in Response to Comments
All respondents concurred that the standard should not be retired.
The drafting team opted not to change the language of Requirement R1 because the proposed changes
added no additional clarity but would expand the applicability of the standard without providing
justification for the change.
A change was made to the Attachment so that the language of Item 1 would match the language of
Requirement R1.
Minority View
The drafting team agreed with commenters that a 200-kV applicability threshold created an easily
manageable bright line for compliance. However, the suggested change to the applicability threshold
was declined because the alternatives examined would arbitrarily include additional facilities to which
the more stringent requirements need not apply.
Comment Report Form for WECC-0120
Effective Date and Implementation Plan
The Reliability Standards Development Procedures (Procedures) require that an implementation plan
be posted with at least one posting of the project. The Effective Date is proposed as the first day of the
first quarter following applicable regulatory approval.
Action Plan
On March 14, 2017, the WECC-0120 FAC-501-WECC-2, Transmission Maintenance Five-year Review
Drafting Team (DT) agreed by majority vote to post Posting 3 of the project for a 30-day comment
period.
The posting period will open March 17, 2017 and close April 17, 2017. The drafting team will meet on
April 20, 2017 from 2:00 p.m. to 4:00 p.m. (MT) and on April 27, 2017 from 10:00 a.m. to 12:00 p.m.
(MT) to respond to comments received.
Comments can be submitted using the green survey buttons located on the Submit and Review
Comments accordion of the WECC-0120 project page.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC
Consultant. In addition, the WECC Reliability Standards Appeals Process can be found in the Reliability
Standards Development Procedures.
Comment Report Form for WECC-0120
WECC Standards Comment Table
Commenter
1 Aaron Cavanaugh
2 Ralph Tan
Organization
Bonneville Power Administration (BPA)
Not identified
3
Not identified
Laura Nelson
Index to Questions, Comments, and Responses
Question
The Drafting Team welcomes comments on all aspects of the document.
1) Commenters have suggested that Requirement R1 should contain a threshold statement of 200 kV
and above. Do you agree that Requirement R1 should state that it specifically applies at 200 kV
and above?
2) Please explain why you made the choice selected in Question 1.
3) Are there sufficient existing NERC Standards to cover the reliability-related substance of FAC-501WECC-1 in the event the entire document was retired?
4) If you answered yes to the above question, please list the specific NERC Standards and requirement
that render DAC-501-WECC-1 redundant and practical for retirement.
5) The drafting team welcomes comments on all aspects of the document.
Comment Report Form for WECC-0120
1. Response Summary
See summary in the preamble of this document.
Summary Consideration:
Commenters have suggested that Requirement R1 should contain a
threshold statement of 200 kV and above.
1) Do you agree that Requirement R1 should state that it
specifically applies to 200 kV and above?
2) Please explain why you made the choice selected in Question 1.
Commenter / Comment
Bonneville Power Administration (BPA)
Response
Yes.
BPA agrees with the new language as written.
Thank you. See response to Laura Nelson.
Ralph Tan
Yes.
Having a threshold voltage will provide a
clear requirement that is easy to remember and
abide by.
Thank you. See response to Laura Nelson.
Laura Nelson
Yes.
In R.1, it is unclear what the phrase "all
transmission facilities necessary for System
Operating Limits associated with each of the
transmission paths" means, especially as we
move into the post-TOP-007-WECC-1retirement paradigm (i.e., the phrase Path SOL
will be obsolete). I have always interpreted the
goal of R.1 as identifying all facilities necessary
for supporting the established WECC Path
Catalog Rating for each path in the Table. If this
is the spirit of R.1, I suggest replacing the
phrase "all transmission facilities necessary for
System Operating Limits associated with each
Comment Report Form for WECC-0120
See summary in the preamble of this document.
Summary Consideration:
Commenters have suggested that Requirement R1 should contain a
threshold statement of 200 kV and above.
1) Do you agree that Requirement R1 should state that it
specifically applies to 200 kV and above?
2) Please explain why you made the choice selected in Question 1.
Commenter / Comment
Response
of the transmission paths..." in R.1 with "all
transmission facilities necessary for supporting
the published path ratings in the WECC Path
Catalog associated with each of the
transmission paths...".
Basing the applicability of this Standard on the
"Major WECC Transfer Paths in the Bulk Electric
System" Table results in an arbitrary list of
facilities with regard to their importance in
terms of maintaining system reliability. This
Table hasn't been updated for almost a decade.
Using this Table as the basis results in the
inclusion of facilities that aren't very important
with regard to system reliability and excludes
facilities that are important. I suggest using a
different set of criteria for establishing
applicability, such as all transmission facilities >
200kV.
Change to applicability threshold
After considering its options, the drafting team opted not to change the language of
Requirement R1 because the proposed changes added no additional clarity but would expand
the applicability of the standard without providing justification for the change.
The drafting team appreciates the need to accurately identify the facilities to which the standard
should apply, taking note that the standard’s Attachment applies a more stringent scrutiny to the
applicable facilities than that contained in existing NERC Standards.
Comment Report Form for WECC-0120
See summary in the preamble of this document.
Summary Consideration:
Commenters have suggested that Requirement R1 should contain a
threshold statement of 200 kV and above.
1) Do you agree that Requirement R1 should state that it
specifically applies to 200 kV and above?
2) Please explain why you made the choice selected in Question 1.
Commenter / Comment
Response
The drafting team first considered changing R1, per Ms. Nelson’s request, to include “necessary
for supporting the published path ratings.” The drafting team concluded that determining what
was “necessary for supporting” the ratings was no more clear than the language included in
Posting 2. Determining what was necessary to support the ratings would be a technical
undertaking unto itself and would be outside of the scope of this project.
The drafting team next considered replacing the Table designation with that of the WECC Path
Rating Catalogue (Catalogue). The team noted that because the Catalogue is more frequently
updated and is currently more up-to-date than the Table, perhaps it would be the better source
to define the applicability. A comparison of the Table with the Catalogue shows that adopting
the Catalogue would increase the number of applicable paths from approximately 40 to 80. The
more stringent features of the standard’s Attachment would apply to nearly twice as many paths
when, in fact, the additional scrutiny is not needed on all of the additional facilities included in
the Catalogue.
In like fashion, the drafting team considered replacing the Table with the default applicability
levels of the Bulk Electric System. In many cases, that would lower the applicability threshold
down to 100 kV. Like the Catalogue and the commenter’s proposed 200-kV threshold, the
drafting team concluded that this approach would sweep in far more Facilities not in need of
additional scrutiny.
As such, no change was made to Requirement R1.
Comment Report Form for WECC-0120
See summary in the preamble of this document.
3) Are there sufficient existing NERC Standards to cover the
reliability-related substance of FAC-501-WECC-1 in the event the
Summary Consideration: entire document was retired?
4) If you answered yes to the above question, please list the specific
NERC Standards and requirement that render FAC-501-WECC-1
redundant and practical for retirement.
Commenter / Comment
Bonneville Power Administration (BPA)
Response
No.
BPA believes that after reviewing NERC
Standards the results did not produce a
standard that appeared toc over equipment
and maintenance of equipment in FAC-501.
N/A
Thank you.
Ralph Tan
No.
None.
Thank you.
Laura Nelson
Yes.
No further response.
Thank you.
Comment Report Form for WECC-0120
See summary in the preamble of this document.
Summary Consideration: 5) The drafting team welcomes comments on all aspects of the
document.
Commenter / Comment
Bonneville Power Administration (BPA)
Response
NA
The drafting team appreciates your continued and thoughtful involvement in the standards
development process.
Ralph Tan
None.
The drafting team appreciates your continued and thoughtful involvement in the standards
development process.
Laura Nelson
No response.
The drafting team appreciates your continued and thoughtful involvement in the standards
development process.
Attachment P3
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Response to Comments / Posting 3
March 17 through April 17, 2017
Posting 3
The WECC-0120 FAC-501-WECC-2, Transmission Maintenance Five-year Review Drafting Team (DT)
thanks everyone who submitted comments on the proposed document.
Posting
This document was posted for a 30-day public comment period from March 17 through April 17, 2017.
On March 14, 2017, WECC distributed notice of the posting via the Standards Email List.
The DT asked stakeholders to provide feedback on the proposed document through a standardized
electronic template. WECC received comments from three entities as shown in the following table.
Location of Comments
All comments received on the document can be viewed in their original format on the WECC-0120
project page under the “Submit and Review Comments” accordion.
Changes in Response to Comment
The drafting team agreed with Xcel regarding the functionality of the link to the Major WECC Transfer
Path (Table). Rather than retain the link, the actual Table has been embedded as Attachment B. This
eliminates the problem of dead links.
The drafting team agreed with Arizona Public Service (APS) and corrected the plurality concern in
Requirement R3.
The drafting team agreed with Farmington (FE) that the and/or statement in Attachment 1 (renamed
Attachment A in Posting 4) could cause confusion. The and/or was replaced with an “or” statement.
Posting 4 also adopts NERC’s newest standards template. VSLs have been changed from pure text to a
table. Fonts are adjusted. NERC’s boilerplate Compliance section has been adopted.
Included as an addendum is an Implementation Plan for comment. The Implementation Plan will not
remain in the standard but will be included as part of the final filing.
Comment Report Form for WECC-0120
Minority View
The drafting team declined the invitation to alter the content of the Major WECC Transfer Path in the
Bulk Electric System (Table). To do so requires a much broader skillset than currently available on the
drafting team.
If the commenters hold that changes are needed to the Table, it is suggested that a Standard
Authorization Request be filed for that specific purpose. To produce a work product that would
comport with FERC’s instructions (See WECC-0120 SAR), it is likely that the WECC Path Rating
Catalogue would have to be revamped using the WECC Reliability Standards Development Procedures
(Procedures).
Any changes to the Table that might result from such a project would require changing the impacted
information in each standard in which the Table resides.
Effective Date and Implementation Plan
The Procedures require that an implementation plan be posted with at least one posting of the project.
The Effective Date is proposed as the first day of the first quarter following applicable regulatory
approval.
Action Plan
On April 27, 2017, the WECC-0120 FAC-501-WECC-2, Transmission Maintenance Five-year Review
Drafting Team (DT) agreed by majority vote to post Posting 4 of the project for a 30-day comment
period.
The posting period will open May 2, 2017 and close June 2, 2017. The drafting team will meet on
June 6, 2017 from 10:00 a.m. to 12:00 p.m. (MT) and June 13, 2017 from 2:00 p.m. to 4:00 p.m. (MT) to
respond to comments received.
Comments can be submitted using the green survey buttons located on the Submit and Review
Comments accordion of the WECC-0120 project page.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC
Consultant. In addition, the WECC Reliability Standards Appeals Process can be found in the Reliability
Standards Development Procedures.
Comment Report Form for WECC-0120
WECC Standards Comment Table
Commenter
1 William Franklin
2 Kristie Cocco
Organization
Public Service Company of Colorado / Xcel Energy (Xcel)
Arizona Public Service Company (APS)
3
Farmington Electric Utility System (FE)
Linda Jacobson-Quinn
Index to Questions, Comments, and Responses
Question
The Drafting Team welcomes comments on all aspects of the document.
Comment Report Form for WECC-0120
1. Response Summary
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment
Xcel
Response
The applicable facilities list seems to become
more obscure.
The standard states " Transmission Owners that
maintain the transmission paths in the most
current Table provided by the Western
Electricity Coordinating Council."
To whom and how will WECC provide this
Table? Will it not be available as a general
document as well on the WECC site? Also, the
table itself does not list the affected
elements/facilities.
Additionally, further complications occur since
the elements that make up the Path can change
with each update of the Path Rating Catalog.
How will parties be notified of those changes?
Suggest having a good distribution and
notification process for changes to either of
these two documents.
Table Administration
The DT concurs with Xcel. Removal of the link could obscure implementation of the document.
On the other hand, retention of the link will continue to remain a concern each time the
software host changes its webpages or the document is relocated. This concern is compounded
when the affected document resides on both the NERC and WECC websites and changing one
does not automatically change the other.
To remedy the concern, the DT will embed the referenced table directly into the document as an
attachment and eliminate the link. This creates a document that is free-standing without
incorporation by reference. Thus, if future changes to the table are required those changes
would be implemented via a SAR that provides transparency and full due process.
This approach should align with FERC Order 752, Docket No. RM-09-14-000 wherein WECC has
agreed to use appropriate due process should it choose to change the content of the Table.
Comment Report Form for WECC-0120
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment
Response
With the Table embedded there is no chance that the content of the Table could be changed
without notice and due process.
Table Content
The DT recognizes that the content of the Table has short-comings. Although the Standard
Authorization Request (SAR) would allow the DT to alter the content, that alteration is voluntary
under the SAR. The DT concluded that a greater breadth of subject matter expertise would be
needed to change the content of the Table and that suggested changes might best be made
under a separate SAR targeting that specific task. As a precursor, the task might be undertaken
at the Standing Committee level and the resulting work product included in an iterative SAR that
would afford full due process beyond the committee level.
Per FERC Order 752, Docket No. RM-09-14-000, if any changes are made to the content of the
Table WECC is required to detail the criteria by which the changes were made, inform
NERC/FERC and post the changes on the WECC website. (See the WECC-0120 SAR for details.)
Restated, the DT could not simply update the Table. The methodology behind the update and its
applicability to each included Path would have to be detailed to NERC/FERC. That methodology
would have to work when considered in each standard in which the Table is referenced: e.g. FAC501-WECC, PRC-004-WECC (WECC-0126 will ballot the PRC for retirement), TOP-007 (retired
April 1, 2017), EOP-00-4-3, and FAC-003-4. The task is within the scope of this team but outside
of its expertise.
APS
AZPS offers the minor edit to remove the 's'
from the phrase "Transmission Owners" in R3.
Thank you. That change will be made.
FE
In addition, FEUS encourages the SDT to review
the item 2 of Attachment 1, "The scheduled
interval for any time-based maintenance
activities and/or a description supporting
condition or performance-based maintenance
activities including a description of the
condition based trigger." The and/or in criteria
has caused confusion when implementing the
requirement and audit approach. FEUS
Comment Report Form for WECC-0120
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment
Response
recommends if it is intended to be an 'and' the
standard be revised to be two separate
sentences. If it is an 'or' it should simply reflect
an 'or.'
Please refer to the above response provided to Xcel for additional information.
At the threshold, it appears FE is asking the DT to provide guidance on how to implement or
interpret the standard as currently approved. To do so would be outside of the scope of the SAR
but might be well placed in a Request for Interpretation. When a Request for Interpretation is
made the WECC Standards Committee endeavors to assign as many of the original drafting team
to the Interpretation team as is practical. The goal is to discern the intent from the original
drafters.
That said, the DT reviewed the Applicability section along with the approved Attachment 1 and
concluded the two are compatible and sufficiently clear to allow for compliance with the
standard. Attachment 1, requires the entity to identify the Facilities and Elements (both NERC
defined terms), schedule maintenance, and include specific descriptions of what is done and
when it is done. Since the applicable entity is the one identifying the Facilities and Elements,
what is included in the TMIP should be determined by the applicable entity.
To the extent the Path Rating Catalogue clouds the waters, the standard takes precedence.
As to the and/or statement, the DT eliminated the and/or statement and replaced it with “or.”
“The scheduled interval for any time-based maintenance activities, or a description supporting
condition or performance-based maintenance activities including a description of the condition
based trigger” (Emphasis added.)
Attachment P4
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Response to Comments / Posting 4
May 2 through June 2, 2017
Posting 4
The WECC-0120 FAC-501-WECC-2, Transmission Maintenance Five-year Review Drafting Team (DT)
thanks everyone who submitted comments on the proposed document.
Posting
This document was posted for a 30-day public comment period from May 2 through June 2, 2017.
On April 24, 2017, WECC distributed notice of the posting via the Standards Email List.
The DT asked stakeholders to provide feedback on the proposed document through a standardized
electronic template. WECC received comments from two entities as shown in the following table.
Location of Comments
All comments received on the document can be viewed in their original format on the WECC-0120
project page under the “Submit and Review Comments” accordion.
Changes in Response to Comment
In response to comments received in Posting 4 the drafting team made the following non-substantive
changes:
Table vs. Attachment B
The term “Table” was removed throughout in favor of “Attachment B.”
Changes in Response to Technical Review
To ensure the project meets current drafting conventions, the drafting team further reviewed the
project for consistency of content and application of Violation Severity Levels, and examined
restructuring the document for brevity and clarity.
The following concerns were identified with proposed remediation in Posting 5.
Requirements, Measures and Tables
•
The combination of Posting 4 Requirement R1 and Part R1.1 created a single Requirement
containing multiple requirements. The first was to “have a TMIP”, the second was to
“annually review it.” To remedy the concern the requirement of Part R1.1 was drafted as its
own freestanding Requirement.
Comment Report Form for WECC-0120
•
•
•
When Posting 4 Requirement R1 and Requirement R2 were read together, the result was a
requirement to have a TMIP “detailing its inspection and maintenance requirements” that
includes “the maintenance categories in Attachment A.” The drafting team concluded these
two Requirements could be merged by creating a Requirement requiring that each TMIP
contain the information specified in Attachment A, Transmission Line and Station
Maintenance Details.
Posting 4 Requirement R3, like Posting 4 Requirement R1 is a single Requirement with
multiple requirements therein. The first is to “implement” the TMIP and the second is to
“follow” the TMIP. This concern was remedied by requiring the Transmission Owner to
“adhere” to its TMIP. By default, an entity cannot adhere to a TMIP it has not implemented,
thus negating the first of the two requirements: to “implement.” Further concerns were
raised with the use of “implement” in that some of its common definitions include only
partial performance; thus, the term was replaced.
The substance of Attachment A was more finely parsed for readability.
Violation Severity Levels
•
•
Examination of the Violation Severity Table for Posting 4 Requirement R1 showed an
“apples-to-oranges” mixing of failed recordation ameliorated by maintenance performance.
Further, the VSL for Posting 4 Part R1.1 did not address any increasing severity in the event
review of the TMIP occurred multiple years after the annual review requirement. These
concerns were remedied by first adjusting the VSL to match the core of Posting 5
Requirement R1 – that the Transmission Owner have a TMIP that includes the elements of
Attachment A with the second concern addressed by creating a freestanding requirement to
review the TMIP. In the first instance, the VSL increases based on the number of items
omitted from the TMIP. In the latter, the VSL increases based on the time passed since the
last review.
Like Posting 4 Requirement R1, the VSL did not match the core of the underlying
Requirement. The Requirement called for implementation of the TMIP but the VSL was
based on record retention. This was remedied in Posting 5 Requirement R3 wherein the core
of the task is to adhere to the TMIP; the VSL increases as lack of adherence increases.
Minority View
The drafting team considered each of the proposed non-substantive changes to R2, R3, Attachment A –
Title, Attachment A – Body, and the insertion of the more granular phrase “Maintenance Categories.”
Although the DT did not adopt these specific changes other changes were incorporated targeting
greater clarity. (See above.)
Comment Report Form for WECC-0120
Effective Date and Implementation Plan
Implementation Plan
The Reliability Standards Development Procedures (Procedures) require that an implementation plan
be posted with at least one posting of the project. The Effective Date is proposed as the first day of the
first quarter following applicable regulatory approval. The Implementation Plan was posted with
Posting 4; no changes were made in Posting 5.
Action Plan
On June 6, 2017, the WECC-0120 FAC-501-WECC-2, Transmission Maintenance Five-year Review
Drafting Team (DT) agreed by majority vote to post Posting 5 of the project for a 30-day comment
period.
In response to comments received in Posting 4, no substantive changes were made; however, after a
review of the Violation Severity Level table some substantive changes are being proposed in Posting 5.
The posting period will open June 14, 2017 and close July 14, 2017. The drafting team will meet on July
25 and July 27, 2017 from 10:00 a.m. to 12:00 p.m. (MT), as needed, to discuss disposition of the
project.
Comments can be submitted using the green survey buttons located on the Submit and Review
Comments accordion of the WECC-0120 project page.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC
Consultant. In addition, the WECC Reliability Standards Appeals Process can be found in the Reliability
Standards Development Procedures.
Comment Report Form for WECC-0120
WECC Standards Comment Table
Commenter
Organization
1 William Franklin
Public Service Company of Colorado / PSCo
2 Michelle Amarantos
Arizona Public Service Company (APS)
On behalf of Todd Komaromy
Index to Questions, Comments, and Responses
Question
The Drafting Team welcomes comments on all aspects of the document.
Comment Report Form for WECC-0120
1. Response Summary
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment
PSCo
Response
PSCo appreciates the changes made to include
Attachment B to identify the Major WECC
Transfer Paths in the Bulk Electric System.
We noticed a few other areas in the standard
that still refer to "Table" and suggest those be
changed to "Attachment B": Applicability 4.1;
R1, Attachment A item 1
We thank the drafting team for its work on this
standard.
The DT sees the proposed change as non-substantive and accepts PSCo’s alternative drafting
approach. The term “Table” has been replaced with “Attachment B.”
APS
APS suggests the following edits:
R1.
Each Transmission Owner shall have a
TMIP detailing describing its inspection and
maintenance requirement practices that apply
to all transmission facilities comprising each
transmission path identified in the Table.
[Violation Risk Factor: Medium] [Time Horizon:
Long-term Planning]
The phrase "update as required" could benefit
from clarification. APS suggests a more
definitive revision such as "update when there
is a modification of or addition to any of the
topics required to be addressed in the TMIP as
set forth in Attachment 1." (R1.1) or:
R1.1. Each Transmission Owner shall annually
review its TMIP and update it as required to
reflect changes to its maintenance or inspection
practices or other applicable content. [Violation
Comment Report Form for WECC-0120
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment
Response
Risk Factor: Medium] [Time Horizon: Long-term
Planning]
R2.
Each Transmission Owner shall include
the required elements set forth maintenance
category topic in Attachment A of this
document when developing its TMIP. [Violation
Risk Factor: Medium] [Time Horizon:
Operations Assessment]
R3.
Each Transmission Owner shall
implement and follow its TMIP. [Violation Risk
Factor: Medium] [Time Horizon: Operations
Assessment]
APS believes "and follow" does not add clarity.
A revision to the title of Attachment A better
comports with the requirements.
Attachment A
Required Elements Of A Transmission Line and
Station Maintenance Implementation Plan
Detail
Additionally, Attachment A should be edited to
state and/or include:
A list of Facilities that comprise each
transmission path identifies in the Table and
the Elements associated with the listed
Facilities.
Inclusion of "maintenance categories" as
referred to in R1 and throughout.
The DT appreciates APS’s comments and made the following non-substantive/clarifying changes.
R1 and Part R1.1
Requirement R1 and Part R1.1 were parsed into two separate requirements for clarity.
Comment Report Form for WECC-0120
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment
Response
R2.
APS’s suggested change to R2 was not accepted. The DT did not concur that the proposed
language added any greater clarity; however, the DT did consider APS’s concerns in the project
redraft. (See Posting 5 Requirement R1.)
R3.
Although the team did not specifically adopt APS’ language it did consider the suggestion when
redrafting the project. (See Posting 5 Requirement R3.)
Specific to the use of the term “implement” the DT had concerns in the context of the
requirement in that some lesser common definitions of the term could be interpreted as only
starting a project without a mandate to finish it. Thus, the team tried to avoid using the term in
its redraft.
Attachment A - Title
APS’s suggested change to the Attachment A title was not accepted. The change as proposed
may have been appropriate if coupled with other APS-proposed changes; however, not all of
those changes were accepted. As the change adds no additional clarity it was not accepted.
Attachment A - Body
APS’s specific suggested change to the Attachment A body was not accepted; however, the body
of Attachment A was redrafted in pursuit of clarity.
Attachment P5
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Response to Comments / Posting 5
June 23 through July 24, 2017
Posting 5
The WECC-0120 FAC-501-WECC-2, Transmission Maintenance Five-year Review Drafting Team (DT)
thanks everyone who submitted comments on the proposed document.
Posting
This document was posted for a 30-day public comment period from June 23 through July 24, 2017.
On June 6, 2017, WECC distributed notice of the posting via the Standards Email List.
The DT asked stakeholders to provide feedback on the proposed document through a standardized
electronic template. WECC received comments from three entities as shown in the following table.
Location of Comments
All comments received on the document can be viewed in their original format on the WECC-0120
project page under the “Submit and Review Comments” accordion. 1
Changes in Response to Comment
In response to comments received in Posting 5 the drafting team made the following non-substantive
changes:
Measure M3 was changed as follows. The DT concluded this was clarification that did not add
substantive change to the document.
M3.
Each Transmission Owner will have evidence that it adhered to its TMIP, as required in
Requirement R3. Evidence may include, but is not limited to:
1.1
The date(s) the patrol, inspection or maintenance was performed;
1.2
The transmission Facility or Element on which the maintenance was performed;
1.3
A description of the inspection results or maintenance performed.
In response to a request for clarification of Attachment A the DT reorganized the entire attachment.
The DT concluded this was clarification that did not add substantive change to the document.
1
Comments received from Farmington Electric Utility System (FEUS) were augmented by emails received from FEUS after it
submitted its comments via the electronic portal. Comments as presented herein were approved by FEUS prior to the
July 25, 2017 meeting. FEUS joined the July 25, 2017 meeting to discuss the comments.
Comment Report Form for WECC-0120
Minority View
There were no minority concerns.
Effective Date and Implementation Plan
Implementation Plan
The Reliability Standards Development Procedures (Procedures) require that an implementation plan
be posted with at least one posting of the project. The Effective Date is proposed as the first day of the
first quarter following applicable regulatory approval. The Implementation Plan was posted with
Posting 4; no changes to the Implementation Plan were made.
Action Plan
On July 25, 2017, the WECC-0120 FAC-501-WECC-2, Transmission Maintenance Five-year Review
Drafting Team (DT) agreed to open a drafting team ballot to determine whether the project should be
forwarded to the WECC Standards Committee (WSC) with a request for ballot. The email ballot will
close at noon (Mountain) on July 27, 2017. If the ballot is approved the project will move forward to
the WSC. If the ballot fails, the team will reconvene at 2:00 p.m. on July 27, 2017.
No further postings are anticipated.
The WSC does not currently have a future meeting scheduled.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC
Consultant. In addition, the WECC Reliability Standards Appeals Process can be found in the Reliability
Standards Development Procedures.
Comment Report Form for WECC-0120
WECC Standards Comment Table
Commenter
1 William Franklin
2 Linda Jacobson-Quinn
Organization
Public Service Company of Colorado (PSCo)
Farmington Electric Utility System (FEUS)
3
Arizona Public Service Company (APS)
Todd Komaromy
Index to Questions, Comments, and Responses
Question
The Drafting Team welcomes comments on all aspects of the document.
Comment Report Form for WECC-0120
1. Response Summary
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment
PSCo
Response
PSCo appreciates the work of the drafting team
and has no further comments.
The drafting team appreciates PSCo’s continued involvement in the standards development
process.
FEUS
Changes to the Measure M3.
FEUS proposed the following changes to
Measure M3, Sub Parts 1.1 through 1.3:
Currently posted:
1.1
The date(s) the work or inspection was
performed;
1.2
The transmission facility on which the
work was performed;
1.3
A description of the inspection or
maintenance performed.
FEUS Proposed:
1.1
The date(s) the patrol, inspection or
maintenance was performed;
1.2
The transmission Facility or Element on
which the maintenance was performed;
1.3
A description of the inspection results or
maintenance performed.
Clarification on Attachment A “and/or”
Statement
FEUS would like clarification for the Revised
Attachment A. The introductory paragraph
states "The maintenance practices in the TMIP
may be performance-based, time-based,
conditional based, or any combination thereof."
Comment Report Form for WECC-0120
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment
Response
This would indicate having a TMIP with only one
of the practices would be compliant. However,
Section 3d and 4c indicate at performancebased and/or condition-based maintenance
must be included for transmission and station
maintenance.
FEUS recommends either revising the
introduction to clarify either the introduction or
section 2d and 4c to be consistent.
Changes to the Measure M3
M3.
Each Transmission Owner will have evidence that it adhered to its TMIP, as required in
Requirement R3. Evidence may include, but is not limited to:
1.4
The date(s) the patrol, inspection or maintenance was performed;
1.5
The transmission Facility or Element on which the maintenance was performed;
1.6
A description of the inspection results or maintenance performed.
Clarification to Attachment A
In response to FEUS the and/or statement was eliminated and the entire attachment reorganized
for clarity.
APS
For purposes of clarity, AZPS suggests modifying
Attachment A, item 1 as follows:
Currently Posted:
A list of Facilities and associated Elements that
apply to all transmission facilities comprising
each transmission path identified in Attachment
B, Major WECC Transfer Paths in the Bulk
Electric System.
Comment Report Form for WECC-0120
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment
Response
Suggested Change
A list of Facilities and the Elements associated
with those transmission Facilities that comprise
each transmission path(s) identified in
Attachment B, Major WECC Transfer Paths in
the Bulk Electric System.
The drafting team adopted the suggestion.
Attachment P6
WECC-0120 FAC-501-WECC-2
Transmission Maintenance Five-year Review
Response to Comments / NERC 45-day Posting
November 3 through December 18, 2017
Posting 1
The WECC-0120 FAC-501-WECC-2, Transmission Maintenance Five-year Review Drafting Team (DT)
thanks everyone who submitted comments on the proposed document.
Posting
This document was posted for a 45-day public comment period at the North American Electricity
Reliability Corporation (NERC) from November 3, through December 18, 2017.
On November 3, 2017, NERC distributed notice of the posting via the NERC Standards Announcements
email exploder.
NERC received comments from six entities as shown in the following table.
Location of Comments
All comments received on the project can be viewed in their original format on the WECC-0120 project
page under the “Submit and Review Comments” accordion. Additionally, the raw data provided to
WECC by NERC in support of this filing is appended to this response form.
Changes in Response to Comment
No changes were made to the project based on the comments received during this posting.
Minority View
There were no minority concerns.
Effective Date and Implementation Plan
The Reliability Standards Development Procedures (Procedures) require that an implementation plan
be posted with at least one posting of the project. The Effective Date is proposed as the first day of the
first quarter following applicable regulatory approval. The Implementation Plan was posted with
Posting 4; no changes to the Implementation Plan were made.
Comment Report Form for WECC-0120
Action Plan
As of January 10, 2018, this project is awaiting filing at NERC.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC
Consultant. In addition, the WECC Reliability Standards Appeals Process can be found in the Reliability
Standards Development Procedures.
Comment Report Form for WECC-0120
WECC Standards Comment Table
Commenter
1 Aaron Cavanaugh
2 John Tolo
Organization
Bonneville Power Administration (BPA)
Tucson Electric Power Company (TEP)
3
Laurie Williams
4
Sandra Shaffer
PNM Resources - Public Service Company of New
Mexico (PNM)
Berkshire Hathaway – PacifiCorp (PAC)
5
6
Glen Farmer
Michelle Amarantos
Avista
Arizona Public Service Company (APS)
Index to Questions, Comments, and Responses
Questions
1. Do you agree the development of the Regional Reliability Standard met the “Open” criteria as
outlined above? If “No,” please explain in the comment area below:
2. Do you agree the development of the Regional Reliability Standard met the “Inclusive” criteria as
outlined above? If “No,” please explain in the comment area below:
3. Do you agree the development of the Regional Reliability Standard met the “Balanced” criteria as
outlined above? If “No,” please explain in the comment area below:
4. Do you agree the development of the Regional Reliability Standard met the “Due Process” criteria as
outlined above? If “No,” please explain in the comment area below:
5. Do you agree the development of the Regional Reliability Standard met the “Transparent” criteria as
outlined above? If “No,” please explain in the comment area below:
Comment Report Form for WECC-0120
1. Response Summary
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment
Response
The WECC-0120 FAC-501-WECC-2, Transmission Maintenance Five-year Review Drafting Team
thanks all parties for their continued support and dedication to the standards development
process.
All respondents answered in the affirmative on all questions.
There were no minority opinions nor were there requests for modification.
No changes were made to the project.
Comment Report Form for WECC-0120
Raw data
provided by
NERC
Comment
Report
Project Name:
Regional Reliability Standard (WECC) | FAC-501-WECC-2
Comment Period Start
Date:
11/3/2017
Comment Period End
Date:
12/18/2017
Associated Ballots:
There were 6 sets of responses, including comments from approximately 6 different
people from approximately 6 companies representing 4 of the Industry Segments as
shown in the table on the following pages.
Bar
Comment Report Form for WECC-0120
Questions
1. Do you agree the development of the Regional Reliability Standard met the “Open”
criteria as outlined above? If “No”, please explain in the comment area below:
2. Do you agree the development of the Regional Reliability Standard met the “Inclusive”
criteria as outlined above? If “No”, please explain in the comment area below:
3. Do you agree the development of the Regional Reliability Standard met the “Balanced”
criteria as outlined above? If “No”, please explain in the comment area below:
4. Do you agree the development of the Regional Reliability Standard met the “Due
Process” criteria as outlined above? If “No”, please explain in the comment area below:
5. Do you agree the development of the Regional Reliability Standard met the
“Transparent” criteria as outlined above? If “No”, please explain in the comment area
below:
Comment Report Form for WECC-0120
Organization Name Segment(s) Region
Name
Group
Name
Group
Group
Group
Group
Member
Member
Member
Member
Name Organization Segment(s) Region
Comment Report Form for WECC-0120
1. Do you agree the development of the Regional Reliability Standard met the “Open”
criteria as outlined above? If “No”, please explain in the comment area below:
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Yes
Document Name
Comment
Likes
0
DisLikes
0
Response
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer
Document Name
Comment
Yes
Comment Report Form for WECC-0120
Likes
0
Dislikes
0
Response
Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
Response
0
Comment Report Form for WECC-0120
2. Do you agree the development of the Regional Reliability Standard met the “Inclusive”
criteria as outlined above? If “No”, please explain in the comment area below:
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer
Document Name
Comment
Yes
Comment Report Form for WECC-0120
Likes
0
Dislikes
0
Response
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
Response
0
Comment Report Form for WECC-0120
3. Do you agree the development of the Regional Reliability Standard met the
“Balanced” criteria as outlined above? If “No”, please explain in the comment area
below:
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer
Document Name
Comment
Yes
Comment Report Form for WECC-0120
Likes
0
Dislikes
0
Response
Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
Response
0
Comment Report Form for WECC-0120
4. Do you agree the development of the Regional Reliability Standard met the “Due
Process” criteria as outlined above? If “No”, please explain in the comment area below:
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer
Document Name
Comment
Yes
Comment Report Form for WECC-0120
Likes
0
Dislikes
0
Response
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
Response
0
Comment Report Form for WECC-0120
5. Do you agree the development of the Regional Reliability Standard met the
“Transparent” criteria as outlined above? If “No”, please explain in the comment area
below:
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer
Document Name
Comment
Yes
Comment Report Form for WECC-0120
Likes
0
Dislikes
0
Response
Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
Response
0
Regional Reliability
Standards Announcement
Western Electricity Coordinating Council
FAC-501-WECC-2, PRC-004-WECC-2, and VAR-002-WECC-2
Comment period open through December 18, 2017
Now Available
The Western Electricity Coordinating Council (WECC) has requested NERC to post the following proposed
Regional Reliability Standards for industry review and comment as permitted by the NERC Rules of
Procedure:
•
•
•
FAC-501-WECC-2 - Transmission Maintenance
PRC-004-WECC-2 - Protection System and Remedial Action Scheme Misoperation (Retirement)
VAR-002-WECC-2 - Automatic Voltage Regulators (Retirement)
Commenting
Use the Standards Balloting and Commenting System (SBS) to submit comments. If you experience any
difficulties using the electronic forms, contact Mat Bunch. The forms must be submitted by 8 p.m.
Eastern, Monday, December 18, 2017. Unofficial Word versions of the comment forms are 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. Although the technical aspects of this Regional Reliability
Standard have been vetted through WECC’s Regional Standards development process, the final approval
process for a Regional Reliability Standard requires NERC publicly to notice and request comment on the
criteria outlined in the unofficial comment forms.
Documents and information about this project are available on the WECC’s Standards Under
Development page.
For more information or assistance, contact Standards Developer, Mat Bunch (via email) or at (404) 4469785.
North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com
WECC Standard FAC-501-WECC-2 – Transmission Maintenance
A. Introduction
1. Title:
Transmission Maintenance
2. Number:
FAC-501-WECC-2
3. Purpose:
To ensure the Transmission Owner of a transmission path identified in
Attachment B, Major WECC Transfer Paths in the Bulk Electric System,
including associated facilities has a Transmission Maintenance and
Inspection Plan (TMIP); and performs and documents maintenance and
inspection activities in accordance with the TMIP.
4. Applicability
4.1 Transmission Owners that maintain the transmission paths in Attachment B.
5. Effective Date: The first day of the first quarter following applicable regulatory approval.
B. Requirements and Measures
R1.
Each Transmission Owner shall have a TMIP that includes, at a minimum, each of
the items listed in Attachment A, Transmission Maintenance and Inspection Plan
Content. [Violation Risk Factor: Medium] [Time Horizon: Long-term Planning]
M1.
Each Transmission Owner will have evidence that it has a TMIP detailing each of the
items listed in Attachment A, as required in Requirement R1.
R2.
Each Transmission Owner shall annually update its TMIP to reflect all changes to its
TMIP. [Violation Risk Factor: Medium] [Time Horizon: Long-term Planning]
M2.
Each Transmission Owner will have evidence that it annually updated its TMIP, as
required in Requirement R2. When an annual update shows that no changes are
required to the TMIP, evidence may include but is not limited to, attestation that
the update was performed but showed that no changes were required.
R3.
Each Transmission Owner shall adhere to its TMIP. [Violation Risk Factor:
Medium] [Time Horizon: Operations Assessment]
M3.
Each Transmission Owner will have evidence that it adhered to its TMIP, as
required in Requirement R3. Evidence may include, but is not limited to:
1.1
The date(s) the patrol, inspection or maintenance was performed;
1.2
The transmission Facility or Element on which the maintenance was performed;
1.3
A description of the inspection results or maintenance performed.
Page 1 of 6
WECC Standard FAC-501-WECC-2 – Transmission Maintenance
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 Transmission Owners listed in section 4.1 shall keep data or
evidence of Requirements 1-3 for three calendar years, or since the last
audit, whichever is longer.
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 2 of 6
WECC Standard FAC-501-WECC-2 – Transmission Maintenance
Violation Severity Levels
R#
R1.
R2.
R3.
Violation Severity Levels
Lower VSL
Moderate VSL
High VSL
Severe VSL
The Transmission
Owner’s TMIP did
not include one
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
annually update
its TMIP (within
the 365 days
following the last
review), as
required by R2.
The Transmission
Owner’s TMIP did
not include two
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
update its TMIP
within the last
one year and 1
day (within the
366 days
following the last
review), as
required by R2.
The
Transmission
Owner failed to
adhere to:
1) two
transmission
line
maintenance
items; or, 2)
two station
maintenance
items; or 3) any
combination of
two items taken
from the above
list, for items
contained in its
TMIP, as
required in R3.
The Transmission
Owner’s TMIP did
not include three
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
update its TMIP
within the last
two years and 1
day (within the
731 days
following the last
review), as
required by R2.
The
Transmission
Owner failed to
adhere to:
1) three
transmission
line
maintenance
items; or, 2)
three station
maintenance
items; or 3) any
combination of
three items
taken from the
above list, for
items contained
in its TMIP, as
required in R3.
The Transmission
Owner’s TMIP did
not include four or
more of the items
listed in Attachment
A, as required in
Requirement R1.
The
Transmission
Owner failed to
adhere to: 1)
one
transmission
line
maintenance
item, or 2) one
station
maintenance
item, as
contained in its
TMIP, as
required in R3.
Page 3 of 6
The Transmission
Owner did not update
its TMIP within the
last three years and 1
day (within the 1095
days following the
last review), as
required by R2.
The Transmission
Owner failed to
adhere to:
1) four or more
transmission line
maintenance items;
or, 2) four or more
station
maintenance items;
or, 3) any
combination of
four or more items
taken from the
above list, for items
contained in its
TMIP, as required
in R3.
WECC Standard FAC-501-WECC-2 – Transmission Maintenance
D.
Regional Variances
None.
E.
Associated Documents
None
Version History – Shows Approval History and Summary of Changes in the Action Field
Version
Date
Action
1
April 16, 2008
Permanent Replacement Standard for PRCSTD-005-1
1
October 29,
2008
NERC BOT conditional approval
1
April 21, 2011
FERC Approved in Order 751
2
TBD
TBD
Change
Tracking
1) Conformed to
newest NERC
template and
drafting
conventions, 2)
eliminated URLs,
3) clarified
Attachment A,
and Measure
3M.
Page 4 of 6
Attachment A
Transmission Maintenance and Inspection Plan Content
The TMIP shall include, at a minimum, each of the following details:
1.
Facilities
A list of Facilities (e.g., transmission lines, transformers, etc.) and Elements (e.g. circuit breaker, bus
section, etc.) that comprise each transmission path(s) identified in Attachment B, Major WECC
Transfer Paths in the Bulk Electric System.
2.
Maintenance Methodology
A description of the maintenance methodology used for the Facility, transmission line, or station
included in the TMIP.
The TMIP maintenance methodology may be any one of the following or any combination thereof,
but must include at least one of the following:
•
•
•
3.
Performance-based
Time-based
Condition based
Periodicity
A specification of the periodicity that the described maintenance will occur, or under what
circumstances it occurs.
4.
Transmission Line Maintenance
A description of each of the following for the transmission line(s) included in the TMIP:
a. Inspection requirements
b. Patrol requirements
c. Tower and wood pole structure management
5.
Station Maintenance
A description of each of the following for each station included in the TMIP:
a. Inspection requirements
b. Equipment maintenance for each of the following:
1.
Circuit breakers
2.
Power transformers (including, but not limited to, phase-shifting
transformers)
3.
Reactive devices (including, but not limited to, shunt capacitors, series
capacitors, synchronous condensers, shunt reactors, and tertiary reactors)
Page 5 of 6
Attachment B
Major WECC Transfer Paths in the Bulk Electric System
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
PATH NAME*
Alberta – British Columbia
Northwest – British Columbia
West of Cascades – North
West of Cascades – South
West of Hatwai
Montana to Northwest
Idaho to Northwest
South of Los Banos or Midway- Los Banos
Idaho – Sierra
Borah West
Idaho – Montana
Bridger West
Path C
Southwest of Four Corners
PG&E – SPP
Northern – Southern California
Intmntn. Power Project DC Line
TOT 1A
TOT 2A
Pavant – Gonder 230 kV
Intermountain – Gonder 230 kV
TOT 2B
TOT 2C
TOT 3
TOT 5
SDGE – CFE
West of Colorado River (WOR)
Southern New Mexico (NM1)
Northern New Mexico (NM2)
East of the Colorado River (EOR)
Cholla – Pinnacle Peak
Southern Navajo
Brownlee East
Lugo – Victorville 500 kV
Pacific DC Intertie
COI
North of John Day cutplane
Alturas
Montana Southeast
SCIT**
COI/PDCI – North of John Day cutplane**
Path Number
1
3
4
5
6
8
14
15
16
17
18
19
20
22
24
26
27
30
31
32
34
35
36
39
45
46
47
48
49
50
51
55
61
65
66
73
76
80
* For an explanation of terms, path numbers, and definition for the paths refer
to WECC’s Path Rating Catalog.
** The SCIT and COI/PDCI-North of John Day Cutplane are paths that are operated in
accordance with nomograms identified in WECC’s Path Rating Catalog.
Page 6 of 6
THIS SECTION WILL NOT BE PART OF THE STANDARD BUT IS REQUIRED FOR NERC FILING.
Standards Authorization Request (SAR)
WECC-0120 FAC-501-WECC-2 Transmission Maintenance SAR
Approvals Required
•
•
•
•
WECC Ballot Pool
WECC Board of Directors
NERC Board of Trustees
FERC
Pending
Pending
Pending
Pending
Applicable Entities
Transmission Owners that maintain the transmission paths in the most current WECC Major Paths table
(Attachment B of the standard)
Conforming Changes to Other Standards
None are required.
Proposed Effective Date
The first day of the first quarter following regulatory approval
Justification
The WECC-0120, FAC-501-WECC-2, Transmission Maintenance Drafting Team (DT) has reviewed NERC
Standards, both in effect and those standards that are NERC Board of Trustees approved pending
regulatory filing. The DT concluded that the proposed substantive changes pose a minimal burden beyond
ordinary and current operations. As such, the short implementation time should impose no undue
burden.
Consideration of Early Compliance
The DT foresees no negative impacts to reliability in the event of early compliance.
Retirements
None
Page 7 of 6
WECC Standard FAC-501-WECC-1 – Transmission Maintenance
A. Introduction
1. Title:
Transmission Maintenance
2. Number:
FAC-501-WECC-12
3. Purpose:
To ensure the Transmission Owner of a transmission path identified in the
table titled “Attachment B, Major WECC Transfer Paths in the Bulk Electric
System”, including associated facilities has a Transmission Maintenance
and Inspection Plan (TMIP); and performs and documents maintenance
and inspection activities in accordance with the TMIP.
4. Applicability
4.1 Transmission Owners that maintain the transmission paths in the most current table
titled “Attachment B.Major WECC Transfer Paths in the Bulk Electric
System” provided at:
https://www.wecc.biz/Reliability/TableMajorPaths4-28-08.pdf.
5. Effective Date: July 1, 2011The first day of the first quarter following applicable
regulatory approval.
B. Requirements and Measures
R1.
Each Transmission OwnersOwner shall have a TMIP detailing their inspection and
maintenance requirements that apply to all transmission facilities necessary for System
Operating Limits associated withincludes, at a minimum, each of the transmission
paths identified in table titled “Major WECC Transfer Paths in the Bulk Electric
System.”items listed in Attachment A, Transmission Maintenance and Inspection
Plan Content. [Violation Risk Factor: Medium] [Time Horizon: Long-term
Planning]
R1.1.
Transmission OwnersM1. Each Transmission Owner will have evidence that it has a
TMIP detailing each of the items listed in Attachment A, as required in
Requirement R1.
R2.
Each Transmission Owner shall annually review their TMIP and update as
required.
its TMIP to reflect all changes to its TMIP. [Violation Risk Factor: Medium] [Time Horizon:
Long-term Planning]
Transmission Owners shall M2.
Each Transmission Owner will have evidence that it
annually updated its TMIP, as required in Requirement R2. When an annual
update shows that no changes are required to the TMIP, evidence may include
the maintenance categories in Attachment 1-FAC-501- WECC-1 when developing their
TMIP.but is not limited to, attestation that the update was performed but
showed that no changes were required.
RevURL11-7-14
Page 1 of 4
WECC Standard FAC-501-WECC-1 – Transmission Maintenance
R3.
Each Transmission Owner shall adhere to its TMIP. [Violation Risk Factor:
Medium] [Time Horizon: Operations Assessment]
R.1. M3.
Each Transmission Owners shall implement and follow their TMIP.
[Violation Risk Factor: Medium] [Time Horizon: Operations Assessment]
A. Measures
M1. Transmission Owners shall have a documented TMIP per R.1.
M1.1
Transmission Owners shall have evidence they have annually reviewed their TMIP
and updated as needed.
M2. Transmission Owners shallOwner will have evidence that their TMIP addresses the
required maintenance details of R.2.
M3. Transmission Owners shall have records that they implemented and followed their TMIPit
adhered to its TMIP, as required in R.3. The records shallRequirement R3.
Evidence may include, but is not limited to:
The person or crew responsible for performingdate(s) the workpatrol, inspection
or maintenance was performed;
1. The transmission Facility or inspection,
1.1
2. The date(s) the work or inspection was performed,
The transmission facilityElement on which the workmaintenance was
performed, and;
1.11.2
1.21.3
RevURL11-7-14
A description of the inspection results or maintenance performed.
Page 12 of 4
WECC Standard FAC-501-WECC-1 – Transmission Maintenance
RevURL11-7-14
Page 13 of 4
WECC Standard FAC-501-WECC-1 – Transmission Maintenance
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 Transmission Owners listed in section 4.1 shall keep data or
evidence of Requirements 1-3 for three calendar years, or since the last
audit, whichever is longer.
2.1 Additional Compliance Information
No additional compliance information.
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.
RevURL11-7-14
Page 14 of 4
WECC Standard FAC-501-WECC-1 – Transmission Maintenance
Violation Severity Levels
2.1. Lower: There shall be a Lower Level of non-compliance if any of the following
conditions exist:
The TMIP does not include associated
R#
Violation Severity Levels
Lower VSL
R1.
R2.
R3.
The Transmission
Owner’s TMIP did
not include one
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
annually update
its TMIP (within
the 365 days
following the last
review), as
required by R2.
The
Transmission
Owner failed to
adhere to: 1)
one
transmission
line
maintenance
item, or 2) one
station
maintenance
item, as
contained in its
TMIP, as
required in R3.
RevURL11-7-14
Moderate VSL
The Transmission
Owner’s TMIP did
not include two
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
update its TMIP
within the last
one year and 1
day (within the
366 days
following the last
review), as
required by R2.
The
Transmission
Owner failed to
adhere to:
1) two
transmission
line
maintenance
items; or, 2)
two station
maintenance
items; or 3) any
combination of
two items taken
from the above
list, for items
contained in its
TMIP, as
Page 15 of 4
High VSL
Severe VSL
The Transmission
Owner’s TMIP did
not include three
of the items
listed in
Attachment A, as
required in
Requirement R1.
The Transmission
Owner did not
update its TMIP
within the last
two years and 1
day (within the
731 days
following the last
review), as
required by R2.
The
Transmission
Owner failed to
adhere to:
1) three
transmission
line
maintenance
items; or, 2)
three station
maintenance
items; or 3) any
combination of
three items
taken from the
above list, for
items contained
in its TMIP, as
The Transmission
Owner’s TMIP did
not include four or
more of the items
listed in Attachment
A, as required in
Requirement R1.
The Transmission
Owner did not update
its TMIP within the
last three years and 1
day (within the 1095
days following the
last review), as
required by R2.
The Transmission
Owner failed to
adhere to:
1) four or more
transmission line
maintenance items;
or, 2) four or more
station
maintenance items;
or, 3) any
combination of
four or more items
taken from the
above list, for items
contained in its
TMIP, as required
in R3.
WECC Standard FAC-501-WECC-1 – Transmission Maintenance
required in R3.
required in R3.
D.
Regional Variances
None.
E.
Associated Documents
None
2.1.1
Facilities for one of the Paths identified in Attachment 1 FAC-501-WECC-1 as
required by R.1 but Transmission Owners are performing maintenance and
inspection for the missing Facilities.
2.1.2
Transmission Owners did not review their TMIP annually as required by R.1.1.
2.1.3
The TMIP does not include one maintenance category identified in Attachment 1
FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing
maintenance and inspection for the missing maintenance categories.
2.1.4
Transmission Owners do not have maintenance and inspection records as required
by R.3 but have evidence that they are implementing and following their TMIP.
2.2. Moderate: There shall be a Moderate Level of non-compliance if any of the following
conditions exist:
2.2.1
The TMIP does not include associated Facilities for two of the Paths identified in
the most current Table titled “Major WECC Transfer Paths in the Bulk Electric
System” as required by R.1 and Transmission Owners are not performing
maintenance and inspection for the missing Facilities.
2.2.2
The TMIP does not include two maintenance categories identified in Attachment
1 FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing
maintenance and inspection for the missing maintenance categories.
RevURL11-7-14
Page 16 of 4
WECC Standard FAC-501-WECC-1 – Transmission Maintenance
2.2.3
Transmission Owners are not performing maintenance and inspection for one
maintenance category identified in Attachment 1 FAC-501-WECC-1 as required
in R3.
2.3. High: There shall be a High Level of non-compliance if any of the following condition
exists:
2.3.1 The TMIP does not include associated Facilities for three of the Paths identified in
the most current Table titled “Major WECC Transfer Paths in the Bulk Electric
System” as required by R.1 and Transmission Owners are not performing
maintenance and inspection for the missing Facilities.
2.3.2 The TMIP does not include three maintenance categories identified in Attachment 1
FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing
maintenance and inspection for the missing maintenance categories.
2.3.3 Transmission Owners are not performing maintenance and inspection for two
maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required in
R3.
2.4. Severe: There shall be a Severe Level of non-compliance if any of the following condition
exists:
2.4.1 The TMIP does not include associated Facilities for more than three of the Paths
identified in the most current Table titled “Major WECC Transfer Paths in the Bulk
Electric System” as required by R.1 and Transmission Owners are not performing
maintenance and inspection for the missing Facilities.
2.4.2 The TMIP does not exist or does not include more than three maintenance
categories identified in Attachment 1 FAC-501-WECC-1 as required by R.2 but
Transmission Owners are performing maintenance and inspection for the missing
maintenance categories.
2.4.3 Transmission Owners are not performing maintenance and inspection for more than
two maintenance categories identified in Attachment 1 FAC-501-WECC-1 as
required in R3.
Version History – Shows Approval History and Summary of Changes in the Action Field
Version
Date
1
April 16, 2008
Permanent Replacement Standard for
PRC-STD-005-1
1
October 29,
2008
NERC BOT conditional approval
1
April 21, 2011
FERC Approved in Order 751
RevURL11-7-14
Action
Page 17 of 4
Change
Tracking
WECC Standard FAC-501-WECC-2 – Transmission Maintenance
Attachment 1- TBD
TBD
FAC-501WECC-1 2
Page 8 of 6
1) Conformed to
newest NERC
template and
drafting
conventions, 2)
eliminated URLs,
3) clarified
Attachment A,
and Measure
3M.
Attachment A
Transmission Line and Station Maintenance Detailsand Inspection Plan Content
The maintenance practices in the TMIP may be performance-based, time-based, conditional based, or a
combination of all three. The TMIP shall include:, at a minimum, each of the following details:
1.
Facilities
A list of Facilities and associated (e.g., transmission lines, transformers, etc.) and Elements necessary
to maintain the SOL for the transfer paths (e.g. circuit breaker, bus section, etc.) that comprise each
transmission path(s) identified in the most current Table titled “Attachment B, Major WECC Transfer
Paths in the Bulk Electric System;”.
1. The scheduled interval for any time-based maintenance activities and/or a description supporting
condition or performance-based maintenance activities including a description of the condition
based trigger;
2.
Maintenance Methodology
A description of the maintenance methodology used for the Facility, transmission line, or station
included in the TMIP.
The TMIP maintenance methodology may be any one of the following or any combination thereof,
but must include at least one of the following:
•
•
•
3.
Performance-based
Time-based
Condition based
Periodicity
A specification of the periodicity that the described maintenance will occur, or under what
circumstances it occurs.
4.
Transmission Line Maintenance Details:
A description of each of the following for the transmission line(s) included in the TMIP:
a. Inspection requirements
b. Patrol/Inspection requirements
a. Contamination Control
c. Tower and wood pole structure management
5.
Station Maintenance Details:
b. Inspections
c. Contamination Control
A description of each of the following for each station included in the TMIP:
a. Inspection requirements
PagePage
4 of 94 of 6
a.b. Equipment Maintenancemaintenance for each of the following:
1.
Circuit Breakersbreakers
•
2.
•
Regulators
Power Transformers (including phase-shifting transformers)
Reactive Devices (including, but not limited to, phase-shifting transformers)
3.
Reactive devices (including, but not limited to, shut capacitors, series
capacitors, synchronous condensers, shunt reactors, and tertiary reactors)
PagePage
4 of10
4 of 6
Attachment B
Major WECC Transfer Paths in the Bulk Electric SystemShunt Capacitors, Series
Capacitors, Synchronous Condensers, Shunt Reactors, and Tertiary Reactors)
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
PATH NAME*
Alberta – British Columbia
Northwest – British Columbia
West of Cascades – North
West of Cascades – South
West of Hatwai
Montana to Northwest
Idaho to Northwest
South of Los Banos or Midway- Los Banos
Idaho – Sierra
Borah West
Idaho – Montana
Bridger West
Path C
Southwest of Four Corners
PG&E – SPP
Northern – Southern California
Intmntn. Power Project DC Line
TOT 1A
TOT 2A
Pavant – Gonder 230 kV
Intermountain – Gonder 230 kV
TOT 2B
TOT 2C
TOT 3
TOT 5
SDGE – CFE
West of Colorado River (WOR)
Southern New Mexico (NM1)
Northern New Mexico (NM2)
East of the Colorado River (EOR)
Cholla – Pinnacle Peak
Southern Navajo
Brownlee East
Lugo – Victorville 500 kV
Pacific DC Intertie
COI
North of John Day cutplane
Alturas
Montana Southeast
SCIT**
COI/PDCI – North of John Day cutplane**
Path Number
1
3
4
5
6
8
14
15
16
17
18
19
20
22
24
26
27
30
31
32
34
35
36
39
45
46
47
48
49
50
51
55
61
65
66
73
76
80
* For an explanation of terms, path numbers, and definition for the paths refer
to WECC’s Path Rating Catalog.
** The SCIT and COI/PDCI-North of John Day Cutplane are paths that are operated in
accordance with nomograms identified in WECC’s Path Rating Catalog.
PagePage
4 of11
4 of 6
THIS SECTION WILL NOT BE PART OF THE STANDARD BUT IS REQUIRED FOR NERC FILING.
Standards Authorization Request (SAR)
WECC-0120 FAC-501-WECC-2 Transmission Maintenance SAR
Approvals Required
•
•
•
•
WECC Ballot Pool
WECC Board of Directors
NERC Board of Trustees
FERC
Pending
Pending
Pending
Pending
Applicable Entities
Transmission Owners that maintain the transmission paths in the most current WECC Major Paths table
(Attachment B of the standard)
Conforming Changes to Other Standards
None are required.
Proposed Effective Date
The first day of the first quarter following regulatory approval
Justification
The WECC-0120, FAC-501-WECC-2, Transmission Maintenance Drafting Team (DT) has reviewed NERC
Standards, both in effect and those standards that are NERC Board of Trustees approved pending
regulatory filing. The DT concluded that the proposed substantive changes pose a minimal burden beyond
ordinary and current operations. As such, the short implementation time should impose no undue
burden.
Consideration of Early Compliance
The DT foresees no negative impacts to reliability in the event of early compliance.
Retirements
None
PagePage
4 of12
4 of 6
Unofficial Comment Form
Regional Reliability Standard
FAC-501-WECC-2
DO NOT use this form for submitting comments. Use the electronic form to submit comments on Regional
Reliability Standard FAC-501-WECC-2 – Transmission Maintenance. The electronic form must be
submitted by 8 p.m. Eastern, Monday, December 18, 2017.
Documents and information about this project are available on the WECC’s Standards Under
Development page. If you have questions, contact Standards Developer, Mat Bunch (via email) or at (404)
446-9785.
Background Information
In its five-year update, the WECC standard drafting team agreed to forward the project to the WECC Standards
Committee (WSC) with a request for ballot. The WSC approved making the following modifications to FAC-501WECC-1:
• Conform the existing document to the newest NERC template and drafting conventions;
• Eliminate URLs; and
• Clarify Attachment A and Measure 3M.
NERC Criteria for Developing or Modifying a Regional Reliability Standard
Regional Reliability Standard shall be: (1) a regional reliability standard that is more stringent than the
continent-wide reliability standard, including a regional standard that addresses matters that the
continent-wide reliability standard does not; or (2) a regional reliability standard that is necessitated by a
physical difference in the bulk power system. Regional reliability standards shall provide for as much
uniformity as possible with reliability standards across the interconnected bulk power system of the North
American continent. Regional reliability standards, when approved by FERC and applicable authorities in
Mexico and Canada, shall be made part of the body of NERC reliability standards and shall be enforced
upon all applicable bulk power system owners, operators, and users within the applicable area, regardless
of membership in the region.
The approval process for a regional reliability standard requires NERC to publicly notice and request
comment on the proposed standard. Comments shall be permitted only on the following criteria
(technical aspects of the standard are vetted through the regional standards development process):
Open — Regional reliability standards shall provide that any person or entity that is directly and
materially affected by the reliability of the bulk power system within the regional entity shall be
able to participate in the development and approval of reliability standards. There shall be no
undue financial barriers to participation. Participation shall not be conditional upon membership
in the regional entity, a regional entity or any organization, and shall not be unreasonably
restricted on the basis of technical qualifications or other such requirements.
Inclusive — Regional reliability standards shall provide that any person with a direct and material
interest has a right to participate by expressing an opinion and its basis, having that position
considered, and appealing through an established appeals process, if adversely affected.
Balanced — Regional reliability standards shall have a balance of interests and shall not be
dominated by any two-interest categories and no single-interest category shall be able to defeat a
matter.
Due Process — Regional reliability standards shall provide for reasonable notice and opportunity
for public comment. At a minimum, the standard shall include public notice of the intent to
develop a standard, a public comment period on the proposed standard, due consideration of
those public comments, and a ballot of interested stakeholders.
Transparent — All actions material to the development of regional reliability standards shall be
transparent. All standards development meetings shall be open and publicly noticed on the
regional entity’s Web site.
Review the revised the Regional Reliability Standard regional standard and answer the following
questions.
1. Do you agree the development of the Regional Reliability Standard met the “Open” criteria as
outlined above? If “No”, please explain in the comment area below:
Yes
No
Comments:
2. Do you agree the development of the Regional Reliability Standard met the “Inclusive” criteria as
outlined above? If “No”, please explain in the comment area below:
Yes
No
Comments:
3. Do you agree the development of the Regional Reliability Standard met the “Balanced” criteria as
outlined above? If “No”, please explain in the comment area below:
Yes
No
Comments:
4. Do you agree the development of the Regional Reliability Standard met the “Due Process” criteria
as outlined above? If “No”, please explain in the comment area below:
Unofficial Comment Form
Regional Reliability Standard FAC-501-WECC-2 | November 2017
2
Yes
No
Comments:
5. Do you agree the development of the Regional Reliability Standard met the “Transparent” criteria
as outlined above? If “No”, please explain in the comment area below:
Yes
No
Comments:
Unofficial Comment Form
Regional Reliability Standard FAC-501-WECC-2 | November 2017
3
Comment Report
Project Name:
Regional Reliability Standard (WECC) | FAC-501-WECC-2
Comment Period Start Date:
11/3/2017
Comment Period End Date:
12/18/2017
Associated Ballots:
There were 6 sets of responses, including comments from approximately 6 different people from approximately 6 companies
representing 4 of the Industry Segments as shown in the table on the following pages.
Questions
1. Do you agree the development of the Regional Reliability Standard met the “Open” criteria as outlined above? If “No”, please explain in the
comment area below:
2. Do you agree the development of the Regional Reliability Standard met the “Inclusive” criteria as outlined above? If “No”, please explain in
the comment area below:
3. Do you agree the development of the Regional Reliability Standard met the “Balanced” criteria as outlined above? If “No”, please explain
in the comment area below:
4. Do you agree the development of the Regional Reliability Standard met the “Due Process” criteria as outlined above? If “No”, please
explain in the comment area below:
5. Do you agree the development of the Regional Reliability Standard met the “Transparent” criteria as outlined above? If “No”, please
explain in the comment area below:
Organization
Name
Name
Segment(s)
Region
Group Name
Group Member
Name
Group
Member
Organization
Group
Member
Segment(s)
Group Member
Region
1. Do you agree the development of the Regional Reliability Standard met the “Open” criteria as outlined above? If “No”, please explain in the
comment area below:
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
Response
0
2. Do you agree the development of the Regional Reliability Standard met the “Inclusive” criteria as outlined above? If “No”, please explain in
the comment area below:
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
Response
0
3. Do you agree the development of the Regional Reliability Standard met the “Balanced” criteria as outlined above? If “No”, please explain
in the comment area below:
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
Response
0
4. Do you agree the development of the Regional Reliability Standard met the “Due Process” criteria as outlined above? If “No”, please
explain in the comment area below:
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
Response
0
5. Do you agree the development of the Regional Reliability Standard met the “Transparent” criteria as outlined above? If “No”, please
explain in the comment area below:
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
Response
0
Attachment R6
WECC-0120 FAC-501-WECC-2
Transmission Maintenance Five-year Review
Response to Comments / NERC 45-day Posting
November 3 through December 18, 2017
Posting 1
The WECC-0120 FAC-501-WECC-2, Transmission Maintenance Five-year Review Drafting Team (DT)
thanks everyone who submitted comments on the proposed document.
Posting
This document was posted for a 45-day public comment period at the North American Electricity
Reliability Corporation (NERC) from November 3 through December 18, 2017.
On November 3, 2017, NERC distributed notice of the posting via the NERC Standards Announcements
email exploder.
NERC received comments from six entities as shown in the following table.
Location of Comments
All comments received on the project can be viewed in their original format on the WECC-0120 project
page under the “Submit and Review Comments” accordion. Additionally, the raw data provided to
WECC by NERC in support of this filing is appended to this response form.
Changes in Response to Comment
No changes were made to the project based on the comments received during this posting.
Minority View
There were no minority concerns.
Effective Date and Implementation Plan
The Reliability Standards Development Procedures (Procedures) require that an implementation plan
be posted with at least one posting of the project. The Effective Date is proposed as the first day of the
first quarter following applicable regulatory approval. The Implementation Plan was posted with
Posting 4; no changes to the Implementation Plan were made.
Comment Report Form for WECC-0120
Action Plan
As of January 10, 2018, this project is awaiting filing at NERC.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC
Consultant. In addition, the WECC Reliability Standards Appeals Process can be found in the Reliability
Standards Development Procedures.
Comment Report Form for WECC-0120
WECC Standards Comment Table
Commenter
1 Aaron Cavanaugh
2 John Tolo
Organization
Bonneville Power Administration (BPA)
Tucson Electric Power Company (TEP)
3
Laurie Williams
4
Sandra Shaffer
PNM Resources - Public Service Company of New
Mexico (PNM)
Berkshire Hathaway – PacifiCorp (PAC)
5
6
Glen Farmer
Michelle Amarantos
Avista
Arizona Public Service Company (APS)
Index to Questions, Comments, and Responses
Questions
1. Do you agree the development of the Regional Reliability Standard met the “Open” criteria as
outlined above? If “No”, please explain in the comment area below:
2. Do you agree the development of the Regional Reliability Standard met the “Inclusive” criteria as
outlined above? If “No”, please explain in the comment area below:
3. Do you agree the development of the Regional Reliability Standard met the “Balanced” criteria as
outlined above? If “No”, please explain in the comment area below:
4. Do you agree the development of the Regional Reliability Standard met the “Due Process” criteria as
outlined above? If “No”, please explain in the comment area below:
5. Do you agree the development of the Regional Reliability Standard met the “Transparent” criteria as
outlined above? If “No”, please explain in the comment area below:
Comment Report Form for WECC-0120
1. Response Summary
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment
Response
The WECC-0120 FAC-501-WECC-2, Transmission Maintenance Five-year Review Drafting Team
thanks each party for their continued support and dedication to the standards development
process.
All respondents answered in the affirmative on all questions.
There were no minority opinions nor were there requests for modification.
No changes were made to the project.
Comment Report Form for WECC-0120
Raw data
provided by
NERC
Comment
Report
Project Name:
Regional Reliability Standard (WECC) | FAC-501-WECC-2
Comment Period Start
Date:
11/3/2017
Comment Period End
Date:
12/18/2017
Associated Ballots:
There were 6 sets of responses, including comments from approximately 6 different
people from approximately 6 companies representing 4 of the Industry Segments as
shown in the table on the following pages.
Bar
Comment Report Form for WECC-0120
Questions
1. Do you agree the development of the Regional Reliability Standard met the “Open”
criteria as outlined above? If “No”, please explain in the comment area below:
2. Do you agree the development of the Regional Reliability Standard met the “Inclusive”
criteria as outlined above? If “No”, please explain in the comment area below:
3. Do you agree the development of the Regional Reliability Standard met the “Balanced”
criteria as outlined above? If “No”, please explain in the comment area below:
4. Do you agree the development of the Regional Reliability Standard met the “Due
Process” criteria as outlined above? If “No”, please explain in the comment area below:
5. Do you agree the development of the Regional Reliability Standard met the
“Transparent” criteria as outlined above? If “No”, please explain in the comment area
below:
Comment Report Form for WECC-0120
Organization Name Segment(s) Region
Name
Group
Name
Group
Group
Group
Group
Member
Member
Member
Member
Name Organization Segment(s) Region
Comment Report Form for WECC-0120
1. Do you agree the development of the Regional Reliability Standard met the “Open”
criteria as outlined above? If “No”, please explain in the comment area below:
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer
Document Name
Comment
Yes
Comment Report Form for WECC-0120
Likes
0
Dislikes
0
Response
Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
Response
0
Comment Report Form for WECC-0120
2. Do you agree the development of the Regional Reliability Standard met the “Inclusive”
criteria as outlined above? If “No”, please explain in the comment area below:
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer
Document Name
Comment
Yes
Comment Report Form for WECC-0120
Likes
0
Dislikes
0
Response
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
Response
0
Comment Report Form for WECC-0120
3. Do you agree the development of the Regional Reliability Standard met the
“Balanced” criteria as outlined above? If “No”, please explain in the comment area
below:
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer
Document Name
Comment
Yes
Comment Report Form for WECC-0120
Likes
0
Dislikes
0
Response
Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
Response
0
Comment Report Form for WECC-0120
4. Do you agree the development of the Regional Reliability Standard met the “Due
Process” criteria as outlined above? If “No”, please explain in the comment area below:
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer
Document Name
Comment
Yes
Comment Report Form for WECC-0120
Likes
0
Dislikes
0
Response
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
Response
0
Comment Report Form for WECC-0120
5. Do you agree the development of the Regional Reliability Standard met the
“Transparent” criteria as outlined above? If “No”, please explain in the comment area
below:
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer
Document Name
Comment
Yes
Comment Report Form for WECC-0120
Likes
0
Dislikes
0
Response
Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
0
Response
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Yes
Document Name
Comment
Likes
0
Dislikes
Response
0
Exhibit F
Standard Drafting Team Roster for Project WECC-0120 Transmission Maintenance FiveYear Review
Drafting Team Roster
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Five-Year Review
Below please find a biographical snapshot for the members of the WECC-0120 FAC-501-WECC-2,
Transmission Maintenance Drafting Team.
Jeff Watkins
NV Energy
Chair
Mr. Watkins has four years working as a Substation Field Engineer assisting with
commissioning of new substations, troubleshooting misoperations and assisting
the crews with maintenance tasks including analyzing maintenance results
including DGA, breaker motion analysis and power factor testing.
Additionally, Mr. Watkins has seven years working as a System Protection
Engineer creating settings for new installations and trouble-shooting
misoperations. He served as a subject-matter expert for PRC-005-X, and
developed/implemented a new maintenance program for protection systems to
comply with PRC-005-2.
Mr. Watkins also has one year of experience working in the Compliance
Department as a Compliance Engineer. A majority of his time is spent working
with the various departments interpreting standards and supplying technical help
when needed. He also performs technical assessments on certain standards (such
as PRC-023 and TPL-001-4) to help ensure that the standards are correct from a
technical standpoint.
Cristi Sawtell
Ms. Sawtell began her career in the electrical industry at Bonneville Power as a
Transmission Lineman performing maintenance and construction activities. In
2010, she joined the Work Planning and Evaluation Group overseeing yearly
maintenance and construction work plans for the Transmission Field
Organization. For the last two and a half years Ms. Sawtell has been working as
the Transmission Field Compliance Specialist, focused on the maintenance
organizations compliance program related to PRC-005 and FAC-501 standards.
Diana Torres
Ms. Torres has worked in the public utility industry for 29 years, with the last 10
years in the reliability compliance office performing compliance assessments of
Operations and Planning standards, and developing and training internal
compliance programs (which included background of NERC/WECC compliance,
WECC CMEP, WECC audit training and internal controls). Ms. Torres coordinated
and helped lead four WECC audits working directly with audit leads.
Imperial
Irrigation
District
For the last four years, Ms. Torres has worked with subject-matter experts to
conduct compliance assessments of the FAC-501 Standard, Transmission
Maintenance and Inspection Program evidence and procedures. She regularly
attends WECC outreach events, such as open webinars, compliance workshops
and human performance conferences.
WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114
Attachment J
Drafting Team Roster
WECC-0120 FAC-501-WECC-2
Transmission Maintenance
Five-Year Review
Kathee Downey
PacifiCorp
W
E S T E R N
Ms. Downey has been involved in WECC committees for several years, on drafting
teams, and leading drafting teams. Specifically, those relating to Interchange
Scheduling and Accounting Subcommittee (ISAS) and Federal Energy Regulatory
Commission (FERC) Order 764. Currently she is serving as PacifiCorp's
representative on the Operating Committee and ISAS.
E
L E C T R I C I T Y
C
O O R D I N A T I N G
C
O U N C I L
| File Type | application/pdf |
| Author | NERC Legal (ST) |
| File Modified | 2018-03-16 |
| File Created | 2018-03-16 |