NERC Petition for PRC-004-WECC-2 Retirement (RD18-3-000)

NERC Petition for PRC-004-WECC-2 Retirement (RD18-3-000).pdf

FERC-725E, (RD18-1, RD18-2, RD18-3, and RD18-5) Mandatory Reliability Standards for the Western Electric Coordinating Council

NERC Petition for PRC-004-WECC-2 Retirement (RD18-3-000)

OMB: 1902-0246

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UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
North American Electric Reliability
Corporation

)
)

Docket No. _________

JOINT PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION AND
WESTERN ELECTRICITY COORDINATING COUNCIL FOR APPROVAL OF
RETIREMENT OF REGIONAL RELIABILITY STANDARD PRC-004-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, Utah 84103-1114
(801) 582-0353
[email protected]
[email protected]
Counsel for the Western Electricity
Coordinating Council

Shamai Elstein
Senior Counsel
Lauren A. Perotti
Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099– facsimile
[email protected]
[email protected]
Counsel for the North American Electric
Reliability Corporation

March 9, 2018

TABLE OF CONTENTS
NOTICES AND COMMUNICATIONS ................................................................................ 2
BACKGROUND .................................................................................................................... 2
A.

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

Procedural History............................................................................................................ 4
1.

Development and Approval of the WECC Regional Reliability Standard .................. 4

Summary of PRC-004-WECC-2 Retirement History .................................................. 5
JUSTIFICATION FOR RETIREMENT ............................................................................. 6

A.
Continent-Wide Reliability Standard FAC-003-4 Addresses the Vegetation
Management Causes that Originally Prompted the Development of the Regional Standard ..... 7
B.
The WECC Regional Standard is Redundant to Continent-wide Standards Relating to
Protection System and Remedial Action Scheme Performance and May be Retired with No
Adverse Impact on Reliability .................................................................................................... 8
1.
PRC-004-WECC-2 Requirement R1 is Redundant to Continent-wide Reliability
Standards ................................................................................................................................. 8
2.
PRC-004-WECC-2 Requirement R2 is Redundant to Continent-wide Reliability
Standards ............................................................................................................................... 10
3.
PRC-004-WECC-2 Requirement R3 is Administrative in Nature and May be Retired
with No Adverse Impact on Reliability ................................................................................ 12
EFFECTIVE DATE OF RETIREMENT .......................................................................... 13
CONCLUSION ..................................................................................................................... 14

Exhibit A

Technical Justification, Retirement of WECC Regional Reliability Standard PRC004-WECC-2 Protection System and Remedial Action Scheme Misoperation

Exhibit B

Implementation Plan

Exhibit C

Complete Record of Retirement Development

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
North American Electric Reliability
Corporation

)
)

Docket No. ________

JOINT PETITION OF THE
NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION AND
WESTERN ELECTRICITY COORDINATING COUNCIL FOR APPROVAL OF
RETIREMENT OF REGIONAL RELIABILITY STANDARD PRC-004-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 “Commission”) regulations, the North
American Electric Reliability Corporation (“NERC”) 3 and the Western Electricity Coordinating
Council (“WECC”) respectfully request that the Commission approve the retirement of WECC
Regional Reliability Standard PRC-004-WECC-2 - Protection System and Remedial Action
Scheme Misoperation.
The purpose of Regional Reliability Standard PRC-004-WECC-2 is to ensure that all
transmission and generation Protection System 4 and Remedial Action Scheme misoperations on
applicable transmission paths and Remedial Action Schemes are analyzed and/or mitigated.
Since the initial development of this regional standard, other continent-wide Reliability
Standards have been developed that have made the requirements of this regional Reliability
Standard redundant and no longer necessary for reliability in the Western Interconnection.

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. Amer. Elec. Reliability Corp., 116 FERC ¶ 61,062 (2006).
4
Unless otherwise designated, capitalized terms shall have the meaning set forth in the Glossary of Terms
Used in NERC Reliability Standards, http://www.nerc.com/files/Glossary_of_Terms.pdf.
2

Therefore, the retirement of the regional standard will have no adverse effect on reliability and is
in the public interest.
NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the following: 5
Shamai Elstein*
Senior Counsel
Lauren A. Perotti*
Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
[email protected]
[email protected]

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, Utah 84103-1114
(801) 582-0353
[email protected]
[email protected]
[email protected]

BACKGROUND
A.

Regulatory Framework

By enacting the Energy Policy Act of 2005, 6 Congress entrusted the Commission with
the duties of approving and enforcing rules to ensure the reliability of the Bulk-Power System
(“BPS”), 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) 7
of the FPA states that all users, owners, and operators of the BPS in the United States will be
subject to Commission-approved Reliability Standards. Section 215(d)(5) 8 of the FPA authorizes
the Commission to order the ERO to submit a new or modified Reliability Standard. Section
5

Persons to be included on the Commission’s service list are identified by an asterisk. NERC respectfully
requests a waiver of Rule 203 of the Commission’s regulations, 18 C.F.R. § 385.203, to allow the inclusion of more
than two persons on the service list in this proceeding.
6
16 U.S.C. § 824o.
7
Id. § 824o(b)(1).
8
Id. § 824o(d)(5).

39.5(a) 9 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, each modification to a Reliability Standard that the ERO
proposes should be made effective, and each Reliability Standard that the ERO proposes for
retirement.
The Commission is vested with the regulatory responsibility to approve Reliability
Standards that protect the reliability of the BPS and to ensure that Reliability Standards are just,
reasonable, not unduly discriminatory or preferential, and in the public interest. Pursuant to
Section 215(d)(2) of the FPA 10 and Section 39.5(c) 11 of the Commission’s regulations, the
Commission will give due weight to the technical expertise of the ERO with respect to the
content of a Reliability Standard.
Similarly, the Commission approves a Regional Reliability Standard proposed by a
Regional Entity if the Regional Reliability Standard is just, reasonable, not unduly
discriminatory or preferential, and in the public interest. 12 Order No. 672 provides additional
criteria that a Regional Reliability Standard must satisfy. Specifically, a regional difference from
a continent-wide Reliability Standard must either be: (1) more stringent than the continent-wide
Reliability Standard (which includes a regional standard that addresses matters that the
continent-wide Reliability Standard does not), or (2) necessitated by a physical difference in the
BPS. 13 The Commission must give due weight to the technical expertise of a Regional Entity,

18 C.F.R. § 39.5(a).
16 U.S.C. § 824o(d)(2).
11
18 C.F.R. § 39.5(c)(1).
12
16 U.S.C. § 824o(d)(2) and 18 C.F.R. § 39.5(a).
13
Order No. 672, Rules Concerning Certification of the Electric Reliability Organization; and Procedures for
the Establishment, Approval, and Enforcement of Electric Reliability Standards, FERC Stats. & Regs. ¶ 31,204, at P
291 (“Order No. 672”), order on reh’g, Order No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006).
10

like WECC, that is organized on an Interconnection-wide basis with respect to a Regional
Reliability Standard applicable within that Interconnection. 14
WECC Reliability Standards are intended to apply only to registered entities in the
Western Interconnection. WECC develops Regional Reliability Standards in accordance with its
Reliability Standards Development Procedures (“RSDP”). 15 Proposed WECC Regional
Reliability Standards are subject to approval by NERC, as the ERO, and FERC before becoming
mandatory and enforceable under Section 215 of the FPA.
B.

Procedural History

This section provides a discussion of the development and approval of WECC Regional
Reliability Standard PRC-004-WECC-2, as well as an overview of the standard development
process for the proposed retirement of the regional standard.
1.

Development and Approval of the WECC Regional Reliability Standard

On June 8, 2007, the Commission approved WECC Regional Reliability Standards
WECC-PRC-STD-001-1 (Certification of Protective Relay Applications and Settings) and
WECC-PRC-STD-003-1 (Protective Relay and Remedial Action Scheme Misoperation) as
mandatory and enforceable Reliability Standards for registered entities within the Western
Interconnection. 16 Regional standard WECC-PRC-STD-001-1 required applicable Transmission
Operators and Transmission Owners to certify that all protective relay applications for BPS
transmission paths in the Western Interconnection are appropriate, that all relay operations have

Order No. 672 at P 344.
The currently-effective WECC RSDP was approved by the Commission on October 27, 2017 (see N. Am.
Elec. Reliability Corp., Docket No. RR17-5-000 (Oct. 27, 2017) (unpublished letter order)) and is available at
http://www.nerc.com/FilingsOrders/us/Regional%20Delegation%20Agreements%20DL/WECC%20RSDP_201710
27.pdf.
16
Order Approving Regional Reliability Standards for the Western Interconnection and Directing
Modifications, 119 FERC ¶ 61,260 (2007).
15

been analyzed for correctness, and that appropriate corrective action has been taken. Regional
standard WECC-PRC-STD-003-1 required owners of protective relays and Remedial Action
Schemes for specified paths to analyze and prepare mitigation steps in response to known or
probable relay misoperations. WECC developed the predecessors to these standards following
two July 1996 system disturbances.
In Order No. 751, issued in 2011, the Commission approved WECC Regional Reliability
Standard PRC-004-WECC-1 (Protection System and Remedial Action Scheme Misoperation) to
replace the two WECC PRC standards. 17 In 2015, the Commission approved the currentlyeffective standard, PRC-004-WECC-2. 18 This version of the standard was developed as part of
NERC’s efforts to incorporate a new definition of Remedial Action Scheme and eliminate use of
the term Special Protection System.
2.

Summary of PRC-004-WECC-2 Retirement History

In October 2016, a regional Standard Authorization Request (“SAR”) was submitted to
perform a five-year review of WECC Regional Reliability Standard PRC-004-WECC-2 in
accordance with the periodic review requirements of the WECC RSDP. The SAR was approved
by the WECC Standards Committee on December 6, 2016.
WECC initiated Project WECC-0126 to review the regional standard. The standard
drafting team for this project recommended that it be retired for the reasons explained in the
following section and in Exhibit A. In accordance with the WECC RSDP, the proposed
retirement of PRC-004-WECC-2 was posted for a 45-day comment period from April 6, 2017

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 (2011).
18
Order No. 818, Revisions to Emergency Operations Reliability Standards; Revisions to Undervoltage Load
Shedding Reliability Standards; Revisions to the Definition of “Remedial Action Scheme” and Related Reliability
Standards, 153 FERC ¶ 61,228 (2015).

through May 22, 2017. The WECC Standards Committee approved the request for ballot by the
WECC Ballot Pool on July 6, 2017. The ballot pool was open from July 11, 2017 through July
26, 2017, and the final ballot was held from August 9, 2017 through August 28, 2017. The
proposed retirement achieved an 89.1% quorum and 98.2% approval.
In accordance with Section 312 of NERC’s Rules of Procedure, NERC posted the
proposed retirement of PRC-004-WECC-2 for a 45-day comment period from November 3, 2017
through December 18, 2017. Commenters agreed that WECC’s process was open, inclusive,
balanced, transparent, and that due process was followed. The WECC Board of Directors
approved the retirement of PRC-004-WECC-2 on December 6, 2017. The NERC Board of
Trustees approved the retirement on February 8, 2018.
JUSTIFICATION FOR RETIREMENT
The purpose of Regional Reliability Standard PRC-004-WECC-2 is to ensure that all
transmission and generation Protection System and Remedial Action Scheme misoperations on
applicable transmission paths and Remedial Action Schemes are analyzed and/or mitigated. The
language that would later become the regional standard was originally developed in response to
two System disturbances occurring within the Western Interconnection in the summer of 1996.
These two disturbances, which both started with the same 345 kV line flashing to a tree, involved
misoperations on the same element within a single 24-hour period. 19 Following these
disturbances, WECC determined that if a misoperation could be analyzed and the equipment
promptly removed from service, then system operators could remedy the cause before an
iterative misoperation took place.

See NERC, 1996 System Disturbances: Review of Electric System Disturbances in North America, 31
(2002), http://www.nerc.com/pa/rrm/ea/System%20Disturbance%20Reports%20DL/1996SystemDisturbance.pdf.

In the intervening years, NERC developed continent-wide Reliability Standards which
address not only the precipitating cause of these two 1996 disturbances but also the reliability
goals of the regional standard relating to Protection Systems and Remedial Action Schemes.
While the WECC regional standard applies only to a limited subset of WECC Remedial Action
Schemes and Protective Systems, the continent-wide standards apply to Protection Systems and
Remedial Action Schemes more generally.
This section provides a requirement-by-requirement discussion of how the reliability
goals of the regional standard are addressed in the continent-wide Reliability Standards. Further
detail is provided in Table A of the Technical Justification document attached to this petition as
Exhibit A. In light of the strong protection these continent-wide standards provide for reliability,
the WECC regional standard is no longer necessary for reliability in the Western Interconnection
and should be retired.
A.

Continent-Wide Reliability Standard FAC-003-4 Addresses the Vegetation
Management Causes that Originally Prompted the Development of the
Regional Standard

Continent-wide Reliability Standard FAC-003-4 – Transmission Vegetation Management
addresses the vegetation management issues that initiated the 1996 disturbances which lead to
the development of the regional standard. 20 The FAC-003-4 standard is applicable to
Transmission Owners and Generator Owners that own certain transmission lines, including
overhead transmission lines operated at 200 kV or higher and lines operated at under 200 kV if
they have been identified as elements of a Major WECC Transfer Path. Reliability Standard

The purpose of the FAC-003-4 standard is “[t]o maintain a reliable electric transmission system by using a
defense-in-depth strategy to manage vegetation located on transmission rights of way (ROW) and minimize
encroachments from vegetation located adjacent to the ROW, thus preventing the risk of those vegetation- related
outages that could lead to Cascading.” This standard, as well as the other standards noted in this filing, are available
at http://www.nerc.net/standardsreports/standardssummary.aspx.

FAC-003-4 requires, among other things, that vegetation be managed to prevent the type of
encroachment encountered in 1996 (Requirements R1 and R2); that timely notification be made
to the control center of vegetation conditions that could cause a Fault at any moment
(Requirement R4); and that corrective action be taken to ensure that flashover distances will not
be violated due to work constraints (R5).
B.

The WECC Regional Standard is Redundant to Continent-wide Standards
Relating to Protection System and Remedial Action Scheme Performance
and May be Retired with No Adverse Impact on Reliability
1.

PRC-004-WECC-2 Requirement R1 is Redundant to Continent-wide
Reliability Standards

PRC-004-WECC-2 Requirement R1 requires an applicable entity’s System Operators to
review all tripping of transmission elements and Remedial Action Scheme operations to identify
apparent misoperations within 24 hours, and the entity’s system protection personnel to analyze
all operations of Protection Systems and Remedial Action Schemes within 20 business days for
correctness to determine whether a misoperation has occurred that may not have been identified
by the System Operators.
This regional Requirement is redundant to those contained in continent-wide NERC
Reliability Standards for Protection Systems and Remedial Action Schemes which contain
rigorous requirements for Protection System and Remedial Action Scheme analysis. With respect
to Protection Systems, Reliability Standard PRC-004-5(i) (Protection System Misoperation
Identification and Correction) requires applicable entities to identify and correct the causes of
misoperations of Protection Systems for Bulk Electric System Elements. Reliability Standard
PRC-001.1.1(ii) (System Protection Coordination) requires applicable entities to be familiar with
the purpose and limitations of the Protection Systems applied in its area and to take corrective
actions to resolve equipment failures involving system reliability as soon as possible. Under
8

Reliability Standard PRC-005-6 (Protection System, Automatic Reclosing, and Sudden Pressure
Relaying Maintenance), entities are required to establish a testing and maintenance program for
their Protection Systems and demonstrate efforts to correct Unresolved Maintenance Issues.
Monitoring and situational awareness are addressed in PRC-001-1.1(ii) and TOP-003-3
(Operational Reliability Data).
With respect to Remedial Action Schemes, currently-effective Reliability Standard PRC016-1 (Remedial Action Scheme Misoperations) requires entities owning Remedial Action
Schemes to analyze their operations, keep a record of all misoperations, take corrective action to
avoid future misoperations, and provide documentation of its activities to the Regional
Reliability Organization and NERC upon request. 21 Reliability Standard PRC-017-1 (Remedial
Action Scheme Maintenance and Testing) requires owners of Remedial Action Schemes to
implement a maintenance and testing program for their Remedial Action Schemes and to provide
certain documentation to the Regional Reliability Organization and NERC upon request.
Additionally, and as described in more detail in Exhibit A, the continent-wide TOP
standards require evaluation of system impacts for a given configuration at least every day so
long as the facility continues in service with a single Protection System or Remedial Action
Scheme and require entities to take further action if required by the circumstances. The
timeframes provided in these standards are more rigorous than the 20-business day review
requirement in PRC-004-WECC-2 Requirement R1.2.
Together, the continent-wide Reliability Standards described above provide greater detail
for Protection System and Remedial Action Scheme analysis than provided in Requirement R1

Remedial Action Scheme analysis is also addressed in Reliability Standard PRC-012-2, which will become
effective in 2021 and replace PRC-016-1.The Commission approved Reliability Standard PRC-012-2 in Order No.
837, issued September 20, 2017. Order No. 837, Remedial Action Schemes Reliability Standard, 160 FERC ¶ 61,071
(2017).

of the PRC-004-WECC-2 standard. This regional standard requirement, which is now redundant
to those contained in continent-wide Reliability Standards, may thus be retired with no adverse
impact on reliability in the Western Interconnection.
2.

PRC-004-WECC-2 Requirement R2 is Redundant to Continent-wide
Reliability Standards

PRC-004-WECC-2 Requirement R2 is divided into two parts, one assigning tasks in the
event of a Security-Based Misoperation 22 and the other assigning tasks in the event of a
Dependability-Based Misoperation. 23 The requirement to analyze each misoperation attaches
whenever the misoperation is discovered. If the Protection System misoperation is SecurityBased, the Protection System or Remedial Action Scheme shall be removed from service within
22 hours of the identification of the misoperation. Whether the Protection System requires repair,
removal, replacement, or modification is fact specific and subject to if/then statements in the
standard. If the Protection System or Remedial Action Scheme misoperation is DependabilityBased, the Protection System or Remedial Action Scheme can remain in service so long as repair
or replacement occurs within 20 days of the identification of the misoperation; otherwise, it must
be removed from service.
Like Requirement R1, the reliability-related substance of this Requirement is adequately
addressed in the continent-wide Reliability Standards. These standards provide a clear and
flexible approach to maintaining reliability, as opposed to the rigid if/then approach prescribed in

The WECC regional term Security-Based Misoperation is defined in the Glossary of Terms Used in NERC
Reliability Standards as follows: “A Misoperation caused by the incorrect operation of a Protection System or
[Remedial Action Scheme]. Security is a component of reliability and is the measure of a device’s certainty not to
operate falsely.”
23
The WECC regional term Dependability-Based Misoperation is defined in the Glossary of Terms Used in
NERC Reliability Standards as follows: “Is the absence of a Protection System or [Remedial Action Scheme]
operation when intended. Dependability is a component of reliability and is the measure of a device’s certainty to
operate when required.”

the WECC regional standard. Reliability Standard PRC-001-1.1(ii) Requirement R2 requires that
if a protective relay or equipment failure reduces system reliability, then corrective action is to be
taken as soon as possible. Likewise, Reliability Standard PRC-016-1 Requirement R2 requires
the Remedial Action Scheme owner to take corrective actions to avoid future misoperations.
Reliability Standard TOP-001-3 requires the Transmission Operator and Balancing Authority to
maintain the reliability of their respective areas by their own actions (or by issuing Operating
Instructions).
Through its analysis, WECC has determined that not only is the regional standard
redundant to continent-wide requirements, application of the regional standard could lessen
reliability in certain cases because it mandates a specific action without regard to outcome when
an alternate action may be better for reliability. Additionally, WECC’s analysis of the 22-hour
timeline in PRC-004-WECC-2 Requirement R2.1 has indicated that, because the obligation is
not triggered until after a misoperation is identified and such identification may take weeks to
occur, the requirement does not in fact provide a higher performance threshold than the
continent-wide Reliability Standards. Lastly, WECC has concluded that the standard does not
sufficiently define what are considered Protection Systems or Remedial Action Scheme actions
“that appear to be entirely reasonable and correct” and thus exempt from the actions specified in
Requirement R2 Parts 2.1 through 2.4. 24
In conclusion, WECC has determined that the continent-wide requirements address the
reliability goal of the regional standard and provide entities with the flexibility they need to take
the actions that best serve reliability in light of all of the relevant circumstances. Therefore, the
retirement of this regional standard Requirement is appropriate.

See Exhibit A.

PRC-004-WECC-2 Requirement R3 is Administrative in Nature and May
be Retired with No Adverse Impact on Reliability

PRC-004-WECC-2 Requirement R3 requires applicable entities to submit misoperation
incident reports to WECC within 10 days of identifying a Protection System or Remedial Action
Scheme misoperation or completing repairs or replacement of the equipment that misoperated.
As the requirement requires only a report be presented, with no further guidance on the contents
of the report or additional analysis to be made, WECC has determined that the requirement is
administrative in nature and redundant to other standards, and its retirement would not negatively
impact the reliability of the BPS. As noted above, other NERC Reliability Standards address
analysis of Protection System and Remedial Action Scheme misoperations. To the extent the
data collection aspects of Requirement R3 remain necessary, they can be addressed through
requirements in other standards (such as PRC-016-1 Requirement R3 for Remedial Action
Schemes) or through a targeted request for data or information pursuant to Section 1600 of the
NERC Rules of Procedure. Therefore, WECC and NERC seek the retirement of Requirement R3
pursuant to paragraph 81 of the Commission’s 2012 order approving NERC’s Find, Fix, Track
and Report program. 25

In this order, the Commission stated:
The Commission is interested in obtaining views on whether [redundant or
unnecessary] requirements could be removed from the Reliability Standards with
little effect on reliability and an increase in efficiency of the ERO compliance
program. If NERC believes that specific Reliability Standards or specific
requirements within certain Standards should be revised or removed, we invite
NERC to make specific proposals to the Commission identifying the Standards or
requirements and setting forth in detail the technical basis for its belief. . . .
N. Am. Elec. Reliability Corp., 138 FERC ¶ 61,193, at P 81 (2012).

For these reasons, and as stated more fully in Exhibit A, NERC and WECC jointly
submit that the retirement of regional Reliability Standard PRC-004-WECC-2 would have no
adverse impact on reliability and that the Commission should approve its retirement.
EFFECTIVE DATE OF RETIREMENT
NERC and WECC respectfully request that the Commission approve the retirement of
WECC Regional Reliability Standard PRC-004-WECC-2 to be effective as of the date of
regulatory approval in accordance with the proposed implementation plan (Exhibit B). Following
the retirement of PRC-004-WECC-2, the two WECC defined terms that are now used only in the
PRC-004-WECC-2 standard, Security-Based Misoperation and Dependability-Based
Misoperation, would be considered retired as well.

CONCLUSION
For the reasons set forth above, NERC and WECC respectfully request that the
Commission approve the proposed retirement of Regional Reliability Standard PRC-004WECC-2, effective as proposed herein.

Respectfully submitted,
/s/ Lauren A. Perotti
Sandy Mooy
Associate General Counsel
Ruben Arredondo
Senior Legal Counsel
Western Electricity Coordinating Council
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114
(801) 582-0353
[email protected]
[email protected]
Counsel for the Western Electricity
Coordinating Council

Shamai Elstein
Senior Counsel
Lauren A. Perotti
Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099– facsimile
[email protected]
[email protected]
Counsel for the North American Electric
Reliability Corporation

March 9, 2018

Exhibit A
Technical Justification, Retirement of WECC Regional Reliability Standard PRC-004WECC-2 Protection System and Remedial Action Scheme Misoperation

Technical Justification
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Request to Retire

Cover Sheet
Technical Justification
Retirement of WECC Regional Reliability Standard
PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation

White Paper:
Retirement of WECC Regional Reliability Standard
PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Technical Justification
WECC Standards Committee
June 21, 2017
Developed as: WECC-0126

155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114

Attachment G
Technical Justification
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Request to Retire
Executive Summary
The WECC-0126 PRC-004-WECC-2 Protection System (PS) and Remedial Action Scheme (RAS)
Misoperation Drafting Team (DT) reviewed NERC Standards, both in effect and proposed for regulatory
approval. The DT also considered the development history of PRC-004-WECC-2 and its history of
performance.
The following are the DT’s findings, conclusions, and recommendations.

Findings and Conclusion
The DT concluded that retirement of the standard can be made without incurring a negative impact on
reliability because:
1. The reliability concern for which the standard was drafted is now specifically covered in
FAC-003-4 Transmission Vegetation Management (enforceable October 1, 2016);
2. The Applicability section is overly narrow and included in other existing NERC Standards;
3. Requirement R1 is covered in other NERC Standards;
4. Requirement R2 is covered in other NERC Standards, conflicts with existing NERC Standards,
and its application can lessen reliability as opposed to enhancing it;
5. Requirement R3 is entirely administrative in nature and should be retired under FERC P81
criteria;
6. The language of the standard does not meet the FERC Order 672 criteria in that it fails to assign
the reliability task directly to an entity included in the NERC Functional Model.

Recommendation
After completing its review, the DT recommends that the substance of PRC-004-WECC-2 should be
retired immediately and in its entirety because the reliability-related substance is addressed in
peripheral NERC Standards. The DT does not believe any further actions are necessary to implement
the proposed change.

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

WECC-0126 PRC-004-WECC-2 Request to Retire

Background
In 1996, two system disturbances occurred within the Western Interconnection, on the same elements
within a single 24-hour period, due to improper vegetation management. To prevent reoccurrence of
such a specific event, language was included in WECC’s Reliability Management System (RMS) requiring
that the relay or Remedial Action Scheme (RAS) that misoperated be removed from service or repaired
within 22 hours. 1 2 The language was premised on the position that if the misoperation was analyzed
and promptly removed from service, the system operators could remedy the cause before an iterative
misoperation took place.
By 2007, with the implementation of mandatory standards, WECC examined the RMS, identifying those
requirements it deemed essential for reliability that were not addressed by NERC Standards, and
translated those requirements into a language and format acceptable to the North America Electricity
Reliability Council (NERC) 3 and the Federal Energy Regulatory Commission (FERC). That translation
resulted in WECC Standard PRC-STD-003-1, Protective Relay and Remedial Action Scheme
Misoperation and PRC-STD-001-1, Certification of Protective Relay Applications and Settings. 4
As the mandatory scheme evolved, two things occurred. First, NERC/FERC identified drafting and
format concerns in those two PRC-STD standards and instructed WECC to redraft them accordingly.
The result was that the current PRC-004-WECC-1 (inactive March 31, 2017) was replaced by PRC-004WECC-2 (United States Enforcement Date April 1, 2017) to accommodate changes in the NERC Glossary

The Reliability Management System (RMS) (AKA: Western Electricity Coordinating Council, FERC Electric Tariff, First
Revised Volume No. 1, Original Sheet Number 1) was the precursor to the NERC Mandatory Standards within the Western
Interconnection. The Transfer Path Table and the Remedial Action Scheme table were originally developed as part of the
RMS. The 22-hour period was memorialized in the RMS, Section I. Protective Relay and Remedial Action Scheme
Misoperation, and Section 2. WSCC Criterion, Section a. For more detail, refer to Compliance Filing of WECC in Response to
Order Numbers 751 and 752 on Version One Regional Reliability Standards, RM09-09-000.
2

“WECC explains that these requirements were developed as a result of a 345 kV line relay misoperation in July 1996 when
virtually the same outage occurred the next day because the faulty equipment had not been isolated.” 119 FERC ¶ 61,260;
United States of America Federal Energy Regulatory Commission (FERC) North American Electric Reliability Corporation,
Docket No. RR07-11-000, Order Approving Regional Reliability Standards for the Western Interconnection and Directing
Modifications (Issued June 8, 2007), para. 85.
3

Currently known as the North American Electricity Reliability Corporation (emphasis added).

135 FERC ¶ 61,061; United States of America Federal Energy Regulatory Commission, 18 CFR Part 40, Docket No. RM09-9000; Order No. 751, Version One Regional Reliability Standards for Facilities Design, Connections, and Maintenance;
Protection and Control; and Voltage and Reactive (issued April 21, 2011), para. 34. FERC Order issued approving PRC-004WECC-1 (approval effective June 27, 2011).

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of Terms Used in NERC Reliability Standards (Glossary). 5 6 Second, the Facilities Design, Connection and
Maintenance (FAC) standards were introduced to address the specific type of vegetation management
concerns that caused the 1996 disturbances.
In the 20 years since the precipitating events, the remedy for those events shifted to the vegetation
management standard of the NERC FAC suite and the remaining language pertinent to Protection
Systems (PS), Special Protection Schemes (SPS), and Remedial Action Schemes (RAS) shifted to other
NERC PRC Standards. 7

Shifting Remediation
At the threshold, it should be noted that remediation of the 1996 seminal event has shifted to FAC003-4, Transmission Vegetation Management. Therefore, PRC-004-WECC-2 no longer addresses the
cause for which it was drafted.
In 1996, if the applicable entities had been complying with a 2016 version of FAC-003-4, Transmission
Vegetation Management (enforceable October 1, 2016) it is unlikely that the predecessors to PRC-004WECC-2 would have been written. Remediation for the primary causal event has shifted to FAC-003-4,
which is applicable to transmission facilities operated at 200-kV or higher, and below 200-kV if the
facility is identified as an element of a Major WECC Transfer Path. FAC-003-4 requires: 1) that
vegetation be managed to prevent the type of encroachment encountered in 1996 (R1 and R2); 2)
timely notification to the appropriate control center of vegetation conditions that could cause a
Flashover at any moment (R4); and 3) corrective action to ensure that Flashover distances will not be
violated due to work constraints. 8

In the Glossary of Terms Used in NERC Reliability Standards, Protection Systems are not the same as Special Protection
Systems (SPS). An SPS is synonymous with a RAS per that glossary.

Footnote 31 NERC RAS Petition at 1-2. NERC requested approval of the PRC-004-WECC-2 to incorporate the proposed
definition of Remedial Action Scheme and eliminate use of the term Special Protection System. 153 FERC ¶ 61,228; United
States of America Federal Energy Regulatory Commission, 18 CFR Part 40, Docket Nos. RM15-7-000, RM15-12-000, and
RM15-13-000, Order No. 818, Revisions to Emergency Operations Reliability Standards; Revisions to Undervoltage Load
Shedding Reliability Standards; Revisions to the Definition of “Remedial Action Scheme” and Related Reliability Standards,
(Issued November 19, 2015).
7

This project is part of WECC’s commitment to harmonize PRC-004-WECC-2 with NERC Standards addressing RAS and PS
per PRC-004-4(i), 5 Background, page 2.
8

FAC-003-4, Transmission Vegetation Management, Section 6. Background. See also: “Consideration of Actual Field
Conditions in Determination of Facility Ratings.”

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specific RAS and PS included in defined tables, other NERC Standards address the same analysis
without limiting the analysis to RAS and PS contained in the specified tables.
The Applicability of the PRC-004-WECC-2 reads as follows:

4. Applicability
4.1.

4.2.
4.3.

Transmission Owners of selected WECC major transmission path facilities and RAS listed
in tables titled “Major WECC Transfer Paths in the Bulk Electric System” provided at
[hyperlink] and “Major WECC Remedial Action Schemes (RAS)” provided at [hyperlink].
Generator Owners that own RAS listed in the Table titled “Major WECC Remedial Action
Schemes (RAS)” provided at [hyperlink].
Transmission Operators that operate major transmission path facilities and RAS listed in
Tables titled “Major WECC Transfer Paths in the Bulk Electric System” provided at
[hyperlink] and “Major WECC Remedial Action Schemes (RAS)” provided at [hyperlink].

Although the requirements of PRC-004-WECC-2 address both RAS and PS, other existing NERC
Standards address these two topics in separate standards.
PRC-016-1 Remedial Action Scheme Misoperations, Requirement R1 requires any Transmission Owner
(TO), Generator Owner (GO), and Distribution Provider (DP) owning a RAS to “. . .analyze its RAS
operations and maintain a record of all misoperations. . .” in accordance with the regional procedures.
Since all RAS must be examined under PRC-016-1, there is no reason to retain PRC-004-WECC-2 which
only applies to a specific and limited subset of WECC RAS. Review of all RAS under PRC-016-1 includes
the subset of RAS targeted in PRC-004-WECC-2. Therefore, the PRC-004-WECC-2 Applicability section is
a lesser included subset of PRC-016-1 (effective date April 1, 2017) making PRC-004-WECC-2
redundant.
In like fashion, PRC-004-4(i) Protection System Misoperation Identification and Correction, requires all
TOs, GOs, and DPs to review all PS operations on the Bulk Electric System (BES) to: 1) identify those
that are Misoperations of PS; 2) analyze Misoperations of PS; and 3) develop and implement Corrective
Action Plans (CAP) to address the cause(s) of Misoperation.9 Thus, the PRC-004-WECC-2 Applicability
section is a lesser included subset of PRC-004-4(i) making PRC-004-WECC-2 redundant.

PRC-004-4(i) Protection System Misoperation Identification and Correction, 5. Background, page 2.

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Rather than assigning the reliability task to the TO or GO, Requirement R1 assigns its task to “System
Operators and System Protection personnel of the Transmission Owners and Generator Owners.”
Requirement R1 does not directly assign a reliability task to any applicable entity listed in the NERC
Functional Model. As such, it falls short of the FERC Order 672 mandate that a Reliability Standard
impose a requirement only on a user, owner, or operator of facilities associated with the Bulk-Power
System (BES). 10 Presuming the requirement could be interpreted to apply to the TO and GO directly,
Requirement R1 imposes a duty to “analyze all Protection System and RAS operations.” 11 Because
these tasks are covered in other NERC Standards (see following analysis) there is no need to retain the
requirement nor try to sort out which NERC Functional Model entity the original draft intended.

Retirement of Requirement R1
The entirety of Requirement R1 should be retired because it is redundant to other NERC Standards.
The text of Requirement R1 is as follows:

B. Requirements
The requirements below only apply to the major transmission paths facilities and RAS listed in the
tables titled “Major WECC Transfer Paths in the Bulk Electric System” and “Major WECC Remedial
Action Schemes (RAS).”
R.1. System Operators and System Protection personnel of the Transmission Owners and
Generator Owners shall analyze all Protection System and RAS operations. [Violation Risk
Factor: Lower] [Time Horizon: Operations Assessment]
R1.1. System Operators shall review all tripping of transmission elements and RAS operations
to identify apparent Misoperations within 24 hours.
R1.2. System Protection personnel shall analyze all operations of Protection Systems and RAS
within 20 business days for correctness to characterize whether a Misoperation has
occurred that may not have been identified by System Operators.

Covered Elsewhere
Unlike PRC-004-WECC-2 that includes both PS and RAS, in the NERC Standards these two classifications
of devices are addressed in separate standards.
As for PS, existing NERC Standards include and go beyond a mandate for analysis. TOs and Generator
Operators (GOP) are required to be familiar with the purpose and limitations of their PS schemes and
10

The proposed Reliability Standard may impose a requirement on any user, owner, or operator of such facilities, but not
on other entities (Order 672 at P. 322).
In the Glossary of Terms Used in NERC Reliability Standards, Protection Systems are not the same as Special Protection
Systems (SPS). An SPS is synonymous with a RAS per that glossary; an SPS is not the same as a Protection System.
11

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take corrective actions as soon as possible – not just analyze the problem.12 Entities must maintain and
test their PS, and demonstrate efforts to correct identified Unresolved Maintenance Issues. 13
Monitoring and situational awareness are also required 14. Finally, TOs and GOs are required to correct
identified and unresolved maintenance Issues. 15 These combined NERC Standards meet and exceed
the reliability concerns of Requirement R1 regarding PS.
As for RAS, PRC-004-4 not only calls for analysis it also requires coordination with other entities,
notification of events and findings, and – most importantly – that corrective actions be planned and
implemented. Elsewhere, applicable entities that own a RAS are required to analyze RAS operation and
misoperation, take corrective actions to ensure misoperation does not reoccur, and to provide
documentation of its activities upon request from the Regional Reliability Organization (RRO). 16 PRC016-1 Remedial Action Scheme Misoperation calls for the inclusion of specific detail in its reports
exceeding the requirement of PRC-004-WECC-2. Further, PRC-017-1 Special Protection System
Maintenance and Testing requires both the TO and GO to have a system maintenance and testing
program (to include specific characteristics), and to provide supporting documentation to the RRO on
request. These combined NERC Standards meet and exceed the reliability concerns of PRC-004-WECC-2
Requirement R1 regarding RAS.
Finally, even in the absence of the continent-wide PRC suite, TOP standards would require essential
analysis and remedial action so long as a facility continues in service with a single PS or RAS. In many
cases, this occurs in less than the 20-day window prescribed in PRC-004-WECC-2 and focuses on results
as opposed to a perfunctory task. 17
The continent-wide TOP standards require time frames to take action that range from as quickly as
possible out to as much as day-ahead planning. So long as a facility continues in service with a single PS
12

PRC-001-1.1(ii) System Protection Coordination, Requirements R1 and R2.

PRC-005-6 – Protection System, Automatic Reclosing, and Sudden Pressure Relaying Maintenance.

PRC-001-1.1(ii) — System Protection Coordination; TOP-003-3, Operational Reliability Data, R1, part 1.2.

PRC-005-6 — Protection System, Automatic Reclosing, and Sudden Pressure Relaying Maintenance, Requirement R5.

PRC-016-1 — Remedial Action Scheme Misoperation; (United States Enforcement Date April 1, 2017).

TPL-001-4 — Transmission System Planning Performance Requirements focuses on system performance rather than the
method of achieving that performance.
TOP-002-2.1b — Normal Operations Planning, R6 focuses on a different aspect of system performance by analyzing the
system at a minimum of the next N-1 Contingency planning.

TOP-004-2 — Transmission Operations, requires that TOPs operate to maintain reliability following occurrence of their most
severe single contingency and (R3) for any multiple contingencies identified by their RC. These contingencies exclude any
facilities that are already out-of-service (either forced or planned).
TOP-006-3 — Monitoring System Conditions, R3 requires that the RC, TOP, and Balancing Authority “shall provide its
operating personnel with appropriate technical information concerning protective relays within” their areas of
responsibility.
TOP-008-1 — Response to Transmission Limit Violations, R2 requires the TOP “operate to prevent the likelihood that a
disturbance, action or inaction will result in an IROL or SOL violation …” which reinforces the TPL-004-2 R2 requirement.

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or RAS, the TOP is required by the TOP standards to evaluate the system impacts for that configuration
at least every day and to take further action if required by the actual circumstances. These TOP time
restrictions are much more rigorous than the WECC 20 business days. 18
Because the reliability content of PRC-004-WECC-2 Requirement R1 is covered in other existing NERC
Standards, Requirement R1 can be retired without incurring any negative impact on reliability.
Illusory Time Windows – 20 Business Days
In Requirement R1.2, the 20-day review period has its origins in compliance and not in reliability.
Therefore, it is not essential for reliability.
When the predecessors of PRC-004-WECC-2 were developed (circa 1995-2000), the WECC Relay Work
Group identified the duration of the window (20 business days) to measure performance, not as a time
window essential for reliability. 19 Meeting minutes from the WECC Relay Work Group establish the first
draft of what would later be called a Violation Severity Level (VSL) wherein the 20-business-day
window was included in a Level 3 and Level 4 VSL.
The definition of the window (20 business days) makes its regulatory debut in the RMS 20 where it is
used as a defined term. A Business Day is defined as “any day other than Saturday, Sunday, or a legal
public holiday as designated in section 6103, of title 5 US Code.” If the 20-business day window was
reliability in nature it would not be predicated on weekends and holidays. This conclusion is further
buttressed when considering that holidays for the United States, Canada, and Mexico do not always
align.
To the extent that any level of reliability currently attaches to the 20-day window, other NERC
Standards impute a shorter time window for remedial action thereby rendering the 20-day window
moot. As presented, the review of numerous other NERC Standards shows that operational review of
the system is required to take place much sooner than 20 days.21 Thus, the duration and definition of
the time window are irrelevant to reliability and can be retired without detriment to the system.

Retirement of Requirement R2
The entirety of Requirement R2 should be retired because it is redundant to other NERC Standards.

IRO-001.1 R3, requires action within 30 minutes. TOP-008 R2, as noted, primarily reinforces TOP-004 R2, basically saying
that the TOP is covered within the IRO timing requirement.

WECC Relay Work Group Meeting Minutes, July 20, 2000.

Reliability Management System, I. Protection Relay and Remedial Action Scheme Misoperation, Section 2.d.

TOP-002-2.1b Normal Operations Planning, Requirement R6 requires a minimum of N-1 Contingency planning to meet
unscheduled changes in system configuration and generation dispatch.

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The text of Requirement R2 is as follows:

B. Requirements
R.2.

Transmission Owners and Generator Owners shall perform the following actions for each
Misoperation of the Protection System or RAS. It is not intended that Requirements R2.1
through R2.4 apply to Protection System and/or RAS actions that appear to be entirely
reasonable and correct at the time of occurrence and associated system performance is fully
compliant with NERC Reliability Standards. If the Transmission Owner or Generator Owner later
finds the Protection System or RAS operation to be incorrect through System Protection
personnel analysis, the requirements of R2.1 through R2.4 become applicable at the time the
Transmission Owner or Generator Owner identifies the Misoperation:
R2.1. If the Protection System or RAS has a Security-Based Misoperation and two or more
Functionally Equivalent Protection Systems (FEPS) or Functionally Equivalent RAS
(FERAS) remain in service to ensure Bulk Electric System (BES) reliability, the
Transmission Owners or Generator Owners shall remove from service the Protection
System or RAS that misoperated within 22 hours following identification of the
Misoperation. Repair or replacement of the failed Protection System or RAS is at the
Transmission Owners’ and Generator Owners’ discretion. [Violation Risk Factor: High]
[Time Horizon: Same-day Operations]
R2.2. If the Protection System or RAS has a Security-Based Misoperation and only one FEPS or
FERAS remains in service to ensure BES reliability, the Transmission Owner or Generator
Owner shall perform the following. [Violation Risk Factor: High] [Time Horizon: Sameday Operations]
R2.2.1. Following identification of the Protection System or RAS Misoperation,
Transmission Owners and Generator Owners shall remove from service within 22
hours for repair or modification the Protection System or RAS that misoperated.
R2.2.2. The Transmission Owner or Generator Owner shall repair or replace any
Protection System or RAS that misoperated with a FEPS or FERAS within 20
business days of the date of removal. The Transmission Owner or Generator
Owner shall remove the Element from service or disable the RAS if repair or
replacement is not completed within 20 business days.
R2.3. If the Protection System or RAS has a Security-Based or Dependability-Based
Misoperation and a FEPS and FERAS is not in service to ensure BES reliability,
Transmission Owners or Generator Owners shall repair and place back in service within
22 hours the Protection System or RAS that misoperated. If this cannot be done, then
Transmission Owners and Generator Owners shall perform the following. [Violation Risk
Factor: High] [Time Horizon: Same-day Operations]

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R2.3.1. When a FEPS is not available, the Transmission Owners shall remove the
associated Element from service.
R2.3.2. When FERAS is not available, then
2.3.2.1. The Generator Owners shall adjust generation to a reliable operating
level, or
2.3.2.2. Transmission Operators shall adjust the SOL and operate the facilities
within established limits.
R2.4. If the Protection System or RAS has a Dependability-Based Misoperation but has one or
more FEPS or FERAS that operated correctly, the associated Element or transmission
path may remain in service without removing from service the Protection System or RAS
that failed, provided one of the following is performed.
R2.4.1. Transmission Owners or Generator Owners shall repair or replace any Protection
System or RAS that misoperated with FEPS and FERAS within 20 business days of
the date of the Misoperation identification, or
R2.4.2. Transmission Owners or Generator Owners shall remove from service the
associated Element or RAS. [Violation Risk Factor: Lower] [Time Horizon:
Operations Assessment]
Retirement of Requirement R2
Requirement R2 is divided into two parts, one assigning tasks in the event of Security-Based
Misoperation and the other assigning tasks in the event of Dependability-based Misoperation.22 The
requirement to analyze each Misoperation attaches whenever the Misoperation is discovered
(identified).
If a PS or RAS Misoperation is Security-based, the PS or RAS shall be removed from service within 22
hours of the identification of the Misoperation. Whether the PS or RAS requires repair, removal,
replacement or modification is fact specific and subject to specified if/then statements.
If the PS or RAS Misoperation is Dependability-based, but portions of the systems operate as designed,
the PS or RAS can remain in service so long as repair or replacement occurs within 20 days of the
identification of the Misoperation; otherwise, the PS or RAS must be removed from service.
Illusory Time Windows – 22 Hours
On the surface, the 22-hour remediation trigger of PRC-004-WECC-2, Requirement R2.2.1 is quite
attractive and perceptually creates a much higher performance threshold than its peripheral NERC

Security-based Misoperations and Dependability-based Misoperations are included in the WECC-specific section of the
Glossary of Terms Used in NERC Reliability Standards.

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Standards.23 But when examined, the remedial clock does not begin to run until the Misoperation is
identified. Restated, there is no remediation required until the operation is identified. The system
operator may identify an apparent Misoperation (R1) within the identified period (R2) and thereby
meet the original intent to remediate the cause. However, the reality is that the identification will not
likely be determined by the Real-time system operator thus negating the assumed purpose of the 22
hours. The higher likelihood is that the system operator may annotate an anomaly in the operations
log and pass the investigation on to protection engineers. After analysis and identification by the
protection engineer, only then would the tolling clock begin to run. So, it could be days or weeks
before the requirement to perform remediation attached. Even though the 22 hours appears to be a
higher standard, in practice it is illusory because it lacks a definitive start time.
Because the 22-hour window appears in the requirement, the current mandatory regulatory regime
presumes that the original drafters intended its inclusion for reliability purposes. However, a review of
development record shows that the 22-hour time window did not appear in the requirement until
drafted into the Reliability Management System (RMS) agreement. Meeting minutes from the
July 20, 2000 WECC Relay Work Group meeting indicate that the 22-hour period was originally
intended for inclusion in what would today be called a Measure. As such, the 22-hour window was not
originally drafted to meet a reliability need; rather, it makes the task measurable. The minutes indicate
that:
“During the Phase 2 evaluation period the relay misoperation requirement was found to be too
loosely defined to enable the assessment of compliance on a consistent basis among all
affected parties, per the requirement, the clock starts as soon as it is determined that a relay
misoperated or probably misoperated. Making this determination could take days or weeks. It
was concluded that compliance with the requirement as originally worded is not measurable on
an accurate or consistent basis. Consequently, the Relay Work Group in cooperation with the
WSCC staff developed revisions to the requirement that will enable a consistent and
accurate measure of performance to assess compliance the revised requirement is described in
detail below.” (Italic emphasis added.)
In fact, the intent of the reports is stated in the 1998 predecessor to the RMS in that:
“The transmission path operators for the paths listed in Table 2 are requested to submit data as
specified in detail within this section. For the purpose of maintaining historical records, and in
the event, some or all of the compliance data have to be reviewed to resolve questions that

Since a real-time assessment of system performance is being conducted at least once every 30 minutes by the
Transmission Operator, the value of a review within 22 hours is diluted and somewhat redundant. TOP-001-3, Transmission
Operations, R13.

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may arise in the future, the Path Operators are requested to save the data, as defined below,
for at least a one-year period.” 24 (Emphasis added.)
The language that found its way into the requirement section of the RMS was originally intended to
serve a compliance purpose – not reliability. To the extent the 22-hour period may have evolved to
address a reliability task, that task (vegetation management) is now covered in the FAC suite. As such,
the 22-hour time frame can be deleted from the standard without impacting reliability.
Requirement R2 Conflicts with other Standards / Lessens Reliability
PRC-004-WECC-2 Requirement R2 has a specified set of actions that must be taken once the
Misoperation is identified. Because the operator cannot deviate from the specific actions, all discretion
is removed. Therefore, R2 conflicts with other standards and lessens reliability.
Under the fact pattern identified in PRC-004-WECC-2 Requirement R2.1, the TO and GO “shall remove
from service” the PS or RAS that misoperated. The inflexible mandate leaves the TO/GO no operational
choice. By contrast, PRC-001-1.1(ii) System Protection Coordination, Requirement R2, part 2.1 and 2.2
require that “[if] a protective relay or equipment failure reduces system reliability” then corrective
action is to be taken as soon as possible.25 Likewise, PRC-016-1 Remedial Action Scheme
Misoperations, Requirement R2 allows the TO/GO owning a RAS to take “corrective actions to avoid
Misoperations.” Further, TOP-001-3 Transmission Operations, Requirement R1 requires the
Transmission Operator (TOP) to maintain the reliability of its Transmission Operator Area via its own
actions (emphasis added). The Balancing Authority (BA) has a similar mandate in Requirement R2 of
that document.
To illustrate how retention of PRC-004-WECC-2 Requirement R2 can lessen reliability, the following
actual fact pattern is offered.
Example
A fault occurred on an important path line and the relays at both terminals operated correctly to clear
it. Different makes of reclosing relays are used at the two terminals, which did not allow the recloser
reset time to be set the same at both terminals. The terminal that normally recloses first had a longer
reset delay of 20 cycles (Terminal A), and the terminal that normally recloses after the other terminal
24

WSCC Detailed Reporting Instructions, Reliability Management System, Evaluation Program Phase 2, Phase 2 Evaluation
Period Reporting Requirements, A. Transmission Path Operators Data Collection, see sections on Protective Relay
Application and Settings, and Remedial Action Schemes, and Protective Relay and Remedial Action Scheme Misoperation,
August 12, 1998.
25

Under NERC Project 2007-06.2 Phase 2 of System Protection Coordination, PRC-001-1.1(ii) is proposed for retirement.
Should that occur, system awareness and corrective actions shift to other applicable entities under numerous existing NERC
Standards. Please refer to that proceeding for a detailed analysis of which NERC Standards would cover the reliability tasks
of PRC-001-1(ii) in the event of retirement. Misoperations that have causes other than failure can be mitigated by taking
corrective action as soon as possible.

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had a shorter reset delay of 15 cycles (Terminal B). A very unusual circumstance occurred when a
second fault occurred on the line after the time that the recloser at Terminal B had reset (15 cycles),
but before the recloser at the Terminal A had reset (20 cycles). Terminal A tripped to lockout after the
second fault and did not reclose. Terminal B, which would normally reclose after Terminal A, tripped
for the second fault and then proceeded to reclose. Because this is a very long line, the switch-ontofault (SOTF) settings are set sensitively to provide instantaneous tripping for the entire length of the
line. When Terminal B reclosed, the SOTF elements tripped it open due to the line charging current. It
is important to recall that this terminal normally recloses after Terminal A, in which case the voltage on
the line would block the SOTF elements.
Because Terminal B tripped for no fault, it created a misoperation. Because both relays at Terminal B
behaved the same, they both misoperated. This would bring Requirement R2.3.1 into play, requiring
the line to be removed from service if the applicable entity could not repair or replace the relays within
22 hours. Given the large volume of operations that were occurring due to the poor weather, repairing
the problem within 22 hours was not easy. Taking the line out of service would have caused more
problems than it solved because it would have removed an important line during heavy transfer
conditions. With the poor weather that was occurring, other lines were also operating, and every
available line needed to be in service. This did not present a reliability concern since the relays were
only susceptible to Misoperation during a reclose during the very unlikely scenario of a second fault
occurring between 15 and 20 cycles after the first.
This practical example illustrates that PRC-004-WECC-2 Requirement R2 can force undesirable
consequences. Had consideration of all the surrounding circumstances been allowed, strict adherence
to PRC-004-WECC-2 Requirement R2 would not have been the best choice for reliability.
As seen in the example, PRC-004-WECC-2 mandates a specific action without regard to outcome. By
contrast, the alternate approach of PRC-001-1.1(ii) allows the TO/GO owning a RAS to take reasoned
action if the failure reduces reliability. Further, it allows that entity to consider all the surrounding
circumstances and act accordingly. Finally, if retained, PRC-004-WECC-2 could conflict with other
standards wherein applicable entities are provided flexibility to decide the most appropriate actions to
ensure reliability. As such, the alternate approach of PRC-001-1.1(ii) should be adopted over that of the
PRC-004-WECC-2.
Requirement R2 – Failure to Meet Order 672 Criteria
Pursuant to FERC Order 672, a 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. 26 PRC-004-WECC-2, Requirement R2 falls
short of that requirement and should deleted.

FERC Order No. 672 at P 325.

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Requirement R2.1 through R2.4 are not intended to apply to PS and/or RAS actions “that appear to be
entirely reasonable and correct” when “associated system performance is fully compliant with NERC
Reliability Standards.” What appears to be reasonable to one entity may not appear reasonable to the
next. In like fashion, what appears to be reasonable to one auditor may not be reasonable to the next.
What is reasonable is the sum of all the surrounding circumstances. These circumstances will vary each
time the standard is applied.
Because of the ever-changing fact patterns, neither the applicable entity nor the assigned auditor can
be soundly informed as to what action must be taken or what constitutes compliance until after a
violation may have occurred. The result is a lack of due process. Further, the language implies that
what is reasonable equates to what is the best course of action to ensure reliability. This is not always
the case. As seen above, one may act to remain perfectly in compliance but those actions may not be
in the best interest of reliability. Finally, the requirement requires the applicable entity to stand as a
proxy to the compliance auditor in that it requires the applicable entity to know whether an act is
“entirely reasonable and correct” without further guidance. This is the standards’ equivalent of
drafting a law requiring all vehicles to stop close to the limit line – without indicating what constitutes
close.
Although entities make every effort to remain in compliance, applicable entities are not auditors and
cannot make the definitive determination whether an act complies with a standard. As such, the
ambiguity of the wording robs the applicable entity of the notice required under due process. Thus,
Requirement R2 does not meet FERC’s Order 672 criteria and should be deleted.
Retirement of Requirement R3
The entirety of Requirement R3 should be retired because it is purely administrative in nature and
meets the “P81” criteria for retirement.
The text of Requirement R3 is as follows:
B. Requirements
R.3. Transmission Owners and Generation Owners shall submit Misoperation incident reports to
WECC within 10 business days for the following. [Violation Risk Factor: Lower] [Time Horizon:
Operations Assessment]
R3.1. Identification of a Misoperation of a Protection System and/or RAS,
R3.2. Completion of repairs or the replacement of Protection System and/or RAS that
misoperated.
Retirement of Requirement R3
The language of PRC-004-WECC-2 Requirement R3 can be retired without incurring any negative
impact to reliability because the Requirement is administrative in nature.

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The purpose of PRC-004-WECC-2 is “to ensure all transmission and generation Protection System and
Remedial Action Scheme (RAS) Misoperations on Transmission Paths and RAS defined in section 4 are
analyzed and/or mitigated.”
Retirement of R3 would be consistent with FERC’s order 27 approving NERC’s Compliance Enforcement
Initiative (CEI), including the Find, Fix, Track and Report (FFT) program. On March 15, 2012, FERC issued
an order 28 approving NERC’s Compliance Enforcement Implementation, including the FFT program.
Paragraph 81 (“P 81”) of the FFT Order reads:
The Commission notes that NERC’s FFT initiative is predicated on the view that many violations
of requirements currently included in Reliability Standards pose lesser risk to the Bulk-Power
System. If so, some current requirements likely provide little protection for Bulk-Power System
reliability or may be redundant. The Commission is interested in obtaining views on whether
such requirements could be removed from the Reliability Standards with little effect on
reliability and an increase in efficiency of the ERO compliance program. If NERC believes that
specific Reliability Standards or specific requirements within certain Standards should be
revised or removed, we invite NERC to make specific proposals to the Commission identifying
the Standards or requirements and setting forth in detail the technical basis for its belief. In
addition, or in the alternative, we invite NERC, the Regional Entities and other interested
entities to propose appropriate mechanisms to identify and remove from the Commission
approved Reliability Standards unnecessary or redundant requirements. We will not impose a
deadline on when these comments should be submitted, but ask that to the extent such
comments are submitted NERC, the Regional Entities, and interested entities coordinate to
submit their respective comments concurrently. 29
In keeping with the FFT approach, the WECC-0126 DT reviewed the standard to identify requirements
that could be removed from Reliability Standards without negatively impacting the reliability of the
Bulk-Power System. This project identified Requirement R3 as a candidate for retirement under that
criteria.
Requirement R3 P81 Justification
The language of R3 can be retired without incurring any negative impact to reliability because it is
purely administrative in nature. At its core, the requirement calls for the TO and GO to “submit
Misoperation incident reports to WECC” and to prove compliance by having “evidence that they
reported.”

North American Electric Reliability Corporation, 138 FERC ¶ 61,193 at P 81 (2012) (“FFT Order”).

FFT Order at P 81.

Joint Petition for Approval of Proposed Regional Reliability Standards, VAR-002-WECC-2 AND VAR-501-WECC-2, Section C.
Project 2013-02 Paragraph 81, page 6 (VAR Order).

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In PRC-004-WECC-2, requiring documentation does not add to or detract from the reliability of the
grid; rather, having documentation is an element of verifying that a reliability task has been completed.
In application, the requirement looks backward to ensure paperwork was filled out. As drafted, it
neither requires identification of a Misoperation nor remediation of failing elements associated with a
Misoperation. It only requires that a report be made. The Measure advances reliability no further as it
too requires only that a report be presented. At its core, the Measure doesn’t even specify the content
of the report – only that a report be made. 30
Further, the implied reliability tasks of Requirement R3 are expressly addressed in peripheral NERC
Standards. The stated intent of the Requirement/Measure is to ensure that Misoperation of specific PS
and RAS are analyzed and mitigated. Although the standard under review addresses only specific PS
and specific RAS, these systems would be included in the broader and more general provisions of other
existing NERC Standards. (See Requirement R1 analysis.)
Finally, if the true intent of PRC-004-WECC-2 is to collect data, that data can be collected in accordance
with NERC’s Rules of Procedure via a Rule 1600 data request. In the alternative, specifically for RAS,
PRC-016-1 Requirement R3 requires both the TO and GO owning a RAS to “provide documentation of
the misoperations analyses and the correction action plans to” WECC on request. As such,
Requirement R3 is fully redundant and can be deleted.
Whereas Requirement R3 is administrative in nature, its implied and explicit reliability tasks are
covered in existing NERC Standards. The described data collection can occur in accordance with NERC
Rules of Procedure 1600; therefore, Requirement R3 can be retired without incurring any negative
impact on reliability.

If not retired, the language of each of the Measures should be redrafted to reflect “will have evidence” as opposed to the
requirement “shall have evidence.”

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Table A
NERC Standard / PRC-004-WECC-2 Cross-reference Table
The Purpose of PRC-004-WECC-2 is to serve as a “Regional Reliability Standard to ensure all
transmission and generation Protection System and Remedial Action Scheme (RAS) Misoperations on
Transmission Paths and RAS defined in section 4 are analyzed and/or mitigated”.
The requirements below only apply to the major transmission paths facilities and RAS listed in the
tables titled “Major WECC Transfer Paths in the Bulk Electric System” and “Major WECC Remedial
Action Schemes (RAS).”
The following table illustrates how each element of the PRC is either addressed elsewhere or simply
not needed for reliability.
Retirement of Regional Reliability Standard
PRC-004-WECC-1 Protection System and Remedial Action Scheme Misoperation
PRC-004-WECC-2
PRC-004-WECC-2
Description and Change Justification
Requirement in Approved Standard
Requirement covered elsewhere
Applicability
Applicability
(Narrow and exclusive)

(Broader and all-inclusive)

The Applicability section is narrowly
crafted to apply only to:

PRC-016-1 applies to TOs, GOs, and
Distribution Providers’ (DP) RAS
regardless of path.

1) Transmission Owners (TO) of
selected facilities with RAS
listed in a specific table;
2) Generator Owners (GO) with
RAS listed in a specific table;
and,

PRC-004-4 applies to TOs, GOs, and
DPs’ PS regardless of path.

3) Transmission Operators
operating facilities and RAS
listed in the specified table.
PRC-004-WECC-2

PRC-004-5(i)

Covers RAS plus PS

Covers PS.

R.1. System Operators and System
Protection personnel of the
Transmission Owners and Generator
Owners shall analyze all Protection
System and RAS operations.

PRC-004-5(I) Protection System
Misoperation Identification and
Correction.

E S T E R N

R1. requires the TO and GO to
identify the reasons for PS
operation and whether the

L E C T R I C I T Y

Whereas PRC-016-1 (RAS) and PRC004-4 (PS) do not carry the overly
exclusive exceptions of PRC-004WECC-2 (only major transmission
paths, facilities, and RAS listed in
specified tables), the Applicability
section of PRC-004-WECC-2 is fully
included in the aforementioned
standards. As such, all facilities
included in PRC-004-WECC-2 are
addressed elsewhere.

Whereas PRC-004-WECC-2 covers
analysis of both the RAS and the PS,
these two devices are now addressed
separately in NERC Standards PRC004-5(i), PRC-016-1, and PRC-012-2.
Each requires analysis like that

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[Violation Risk Factor: Lower] [Time
Horizon: Operations Assessment]

operation caused a Misoperation,
within 120 days. 31
See also PRC-001-1.1(ii),
Requirements R1 and R2; PRC-0056, Requirement R5.
PRC-016-1
Covers RAS
PRC-016-1 Special Protection
System Misoperations
R1. The TO and GO…shall
analyze…its RAS operations and
maintain a record of all
misoperations in accordance with
the Regional RAS review procedure
specified in PRC-012. R1. 32

prescribed in PRC-004-WECC-2.
Inclusion of the reliability elements of
PRC-004-WECC-2 in PRC-004-5(i) and
PRC-016-1 and PRC-012-2 render
PRC-004-WECC-2 redundant. As such,
the Requirement can be deleted.
The difference in time frames
between PRC-004-WECC-2 and the
other NERC Standards is addressed in
the preceding sections of this filing.

PRC-012-2, Remedial Action
Schemes 33
R5. Requires the TO and GO to
review its RAS within 120 days of
operation or failure. (The term
analyze is used in R5.2.) 34
PRC-004-WECC-2

PRC-012-2

R1.1 System Operators shall review
all tripping of transmission elements
and RAS operations to identify
apparent Misoperations within 24
hours.

R1.2. System Protection
personnel shall analyze all
operations of Protection Systems

Covering RAS
R5. Requires the TO and GO to
analyze each RAS operation, within
120 days, to determine: 1) 5.1.1,
what caused the operation, 2) 5.1.2
and 5.1.3, if the device worked
properly, and 3) 5.1.4., whether
there were any unintended
consequences.
PRC-004-5(i)
Covers PS

The language of PRC-004-WECC-2
fails to meet the FERC Order 672
criteria for clarity in that “apparent,”
“reasonable,” characterization” and
“correctness” are ambiguous.
Both PRC-012-2 and PRC-004-5(i)
require review after operation to
determine the cause and, in some
cases, even determine whether
unforeseen consequences resulted.

United States Enforcement Date is April 2, 2017.

Becomes Inactive on March 31, 2017.

PRC-012-2 has been filed with FERC and is pending regulatory disposition as of March 29, 2017.

NERC Board of Trustees approved May 5, 2016, pending at FERC. (FERC has proposed to approve the standard subject to
comments received on a Notice of Proposed Rulemaking (NOPR), comments closing April 10, 2017.)

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WECC-0126 PRC-004-WECC-2 Request to Retire
and RAS within 20 business days for
correctness to characterize whether
a Misoperation has occurred that
may not have been identified by
System Operators.

PRC-004-5(i), R1. Requires the TO
and GO owning a PS that operates,
to identify whether that PS caused
a Misoperation, within 120 days of
the event the threshold analysis,
the applicable entity is required to
determine: 1) R1.1, if the PS was
the cause of the Misoperation, 2)
R1.2, who owns the components,
and 3) R1.3 whether the operation
was automatic or manual.

Although the more specific analysis is
arguably included in the more
general PRC-004-WECC-2 analysis,
adoption of the superior PRC-012-2
and PRC-004-5(i) requirements add
clarity and conformity without
sacrificing reliability. As such, analysis
of both RAS and PS operation is
covered in greater detail outside of
PRC-004-WECC-2 making PRC-004WECC-2 redundant. Its retirement
would have no negative impact on
reliability because the tasks are
covered elsewhere.
See above analysis pertaining to 22hours, and 20 days for time window
differential.

2000-07-20-RWG-M
eeting.pdf
PRC-004-WECC-2

PRC-016-1

Covers PS and RAS

Covers PS

R.2. Transmission Owners and
Generator Owners shall perform the
following actions for each
Misoperation of the Protection
System or RAS.

PRC-016-1 — Remedial Action
Scheme Misoperations

PRC-012-2

E S T E R N

R2. Each TO, GO, and DP, owing a
RAS shall take corrective actions to
avoid future misoperations.

Whereas the reliability tasks of PRC004-WECC-2 Requirement R2 are
included in PRC-016-1 and PRC-0122, PRC-004-WECC-2 Requirement R2
is redundant and can be retired.

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Owner later finds the Protection
System or RAS operation to be
incorrect through System Protection
personnel analysis, the
requirements of R2.1 through R2.4
become applicable at the time the
Transmission Owner or Generator
Owner identifies the Misoperation:

R2.1. If the Protection System or
RAS has a Security-Based
Misoperation and two or more
Functionally Equivalent Protection
Systems (FEPS) or Functionally
Equivalent RAS (FERAS) remain in
service to ensure Bulk Electric
System (BES) reliability, the
Transmission Owners or Generator
Owners shall remove from service
the Protection System or RAS that
misoperated within 22 hours
following identification of the
Misoperation. Repair or
replacement of the failed Protection
System or RAS is at the Transmission
Owners’ and Generator Owners’
discretion. [Violation Risk Factor:
High] [Time Horizon: Same-day
Operations]

analyze and communicate RAS
performance.
PRC-012-2, Requirements R6 and
R7 further cover RAS
Requirement R6 requires the TO,
GO, and DP develop and submit a
Corrective Action Plan (CAP) to the
Reliability Coordinator within six
months of: 1) notification of a RAS
deficiency (see R4 and R5), or
identifying a deficiency while
performing a functional test (R8).
PRC-001-1.1(ii)

PRC-001-1.1(ii)

R2. Each Generator Operator and
Transmission Operator shall notify
reliability entities of relay or
equipment failures as follows:

R2 and R6 require the applicable
entities to be aware of PS/RAS and to
communicate with other affected
parties in the event of change or
operation of these devices. That
standard is broad enough to allow
the operators to determine the best
appropriate action based on all the
surrounding circumstances. Those
actions may or may not include the
specified tasks included in PRC-004WECC-2 Requirement R2. If the
specifics of that requirement are
retained, they limit the operator’s
discretion and could lead to a lessthan-favorable operational decision
simply to be compliant, thereby
defeating the reliability-related
intent.

R2.1. If a protective relay or
equipment failure reduces system
reliability, the Generator Operator
shall notify its Transmission
Operator and Host Balancing
Authority. The Generator Operator
shall take corrective action as soon
as possible.
R2.2. If a protective relay or
equipment failure reduces system
reliability, the Transmission
Operator shall notify its Reliability
Coordinator and affected
Transmission Operators and
Balancing Authorities. The
Transmission Operator shall take
corrective action as soon as
possible.
R6. Each Transmission Operator
and Balancing Authority shall
monitor the status of each Special
Protection System in their area,
and shall notify affected

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L E C T R I C I T Y

PRC-004-WECC-2 Requirement R2
requires that the device be taken
out-of-service under specified
circumstances. By contrast, TOP-0013, Requirement R1, requires the TO
to “act to maintain the reliability of
its Transmission Operator Area via its
own actions.” The TOP-001-3,

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Transmission Operators and
Balancing Authorities of each
change in status.
PRC-004-4(i)
R5. Each Transmission Owner,
Generator Owner, and Distribution
Provider that owns the Protection
System component(s) that caused
the Misoperation shall, within 60
calendar days of first identifying a
cause of the Misoperation:
• Develop a Corrective Action
Plan (CAP) for the identified
Protection System
component(s), and an
evaluation of the CAP’s
applicability to the entity’s
other Protection Systems
including other locations; or
• Explain in a declaration why
corrective actions are beyond
the entity’s control or would
not improve BES reliability, and
that no further corrective
actions will be taken.

Requirement R1 mandate to act with
discretion conflicts with the PRC-004WECC-2 Requirement R2 mandate to
perform specific tasks. The PRC-004WECC-2 Requirement R2 approach
has the potential to lead to reliability
concerns; by contrast, the approach
of PRC-001-1.1(ii) and TOP-001-3
provide the operator with discretion
more targeted for remedy of actual
circumstances and not implemented
merely for compliance purposes.
Additionally, the overly prescriptive
PRC-004-WECC-2 Requirement R2
approach may conflict with IRO-017-1
Requirement R1 wherein the
Reliability Coordinator (RC) is
required to “develop, implement,
and maintain an outage coordination
process.” If PRC-004-WECC-2
Requirement R2 is retained it
mandates a specific action that may
conflict with the broader authority
and outage coordination process
established by the RC.

PRC-016-1
R1. The Transmission Owner,
Generator Owner, and Distribution
Provider that owns an RAS shall
analyze its RAS operations and
maintain a record of all
misoperations in accordance with
the Regional RAS review procedure
specified in Reliability Standard
PRC-012-0_R1.
R2. The Transmission Owner,
Generator Owner, and Distribution
Provider that owns a RAS shall take
corrective actions to avoid future
misoperations.

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R2.2. If the Protection System or
RAS has a Security-Based
Misoperation and only one FEPS or
FERAS remains in service to ensure
BES reliability, the Transmission
Owner or Generator Owner shall
perform the following. [Violation
Risk Factor: High] [Time Horizon:
Same-day Operations]
R2.2.1. Following identification of
the Protection System or RAS
Misoperation, Transmission Owners
and Generator Owners shall remove
from service within 22 hours for
repair or modification the
Protection System or RAS that
misoperated.
R2.2.2. The Transmission Owner or
Generator Owner shall repair or
replace any Protection System or
RAS that misoperated with a FEPS or
FERAS within 20 business days of
the date of removal. The
Transmission Owner or Generator
Owner shall remove the Element
from service or disable the RAS if
repair or replacement is not
completed within 20 business days.
R2.3. If the Protection System or
RAS has a Security-Based or
Dependability-Based Misoperation
and a FEPS and FERAS is not in
service to ensure BES reliability,
Transmission Owners or Generator
Owners shall repair and place back
in service within 22 hours the
Protection System or RAS that
misoperated. If this cannot be done,
then Transmission Owners and
Generator Owners shall perform the
following. [Violation Risk Factor:

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High] [Time Horizon: Same-day
Operations]
R2.3.1. When a FEPS is not
available, the Transmission Owners
shall remove the associated Element
from service.
R2.3.2. When FERAS is not
available, then
2.3.2.1. The Generator Owners shall
adjust generation to a reliable
operating level, or
2.3.2.2. Transmission Operators
shall adjust the SOL and operate the
facilities within established limits.
R2.4. If the Protection System or
RAS has a Dependability-Based
Misoperation but has one or more
FEPS or FERAS that operated
correctly, the associated Element or
transmission path may remain in
service without removing from
service the Protection System or
RAS that failed, provided one of the
following is performed.
R2.4.1. Transmission Owners or
Generator Owners shall repair or
replace any Protection System or
RAS that misoperated with FEPS and
FERAS within 20 business days of
the date of the Misoperation
identification, or R2.4.2.
Transmission Owners or
Generator Owners shall remove
from service the associated Element
or RAS. [Violation Risk Factor:
Lower] [Time Horizon: Operations
Assessment]
R.3. Transmission Owners and
Generation Owners shall submit

E S T E R N

As of July 1, 2016, Protection
System Operations and

L E C T R I C I T Y

Retirement of PRC-004-WECC-2
Requirement R3 fits the retirement

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WECC-0126 PRC-004-WECC-2 Request to Retire
Misoperation incident reports to
WECC within 10 business days for
the following.
R3.1. Identification of a
Misoperation of a Protection System
and/or RAS,
R3.2. Completion of repairs or the
replacement of Protection System
and/or RAS that misoperated.

Misoperations are reported by TOs,
GOs, and DPs, via the Misoperation
Information Data Analysis System
at NERC (MIDAS) in PRC-004 -5(i)
and the accompanying 1600 Data
Request.
This renders PRC-004-WECC-2
administrative request redundant.

criteria established under FERC’s
“P81” criteria. See Retirement of
Requirement R3 analysis in the main
body of this filing.
The 10-day time window is a legacy
imported from the RMS, circa July
1999. A records search at WECC and
inquires via corporate memory did
not reveal why the original drafters
believed the 10 days were essential.
However, the 10-day reference was
found in the 1999 WSCC Reliability
Criteria Agreement (Section 5
Determining Compliance, 5.2 Data
Submission and Review) as part of
the document’s compliance section
giving rise to the conclusion that it
was required for accountability and
not reliability.
Considering the NERC 1600
requirement, the 10-days has proven
to no longer be essential.
Currently, Midas will send out
reminder notifications to entities that
have not yet submitted for a
specified quarter. They will also
provide confirmation notifications
upon submittal. Once the submittal is
reviewed by the regions or NERC, the
regions may send additional
notifications to the MIDAS contacts
as questions arise.
Currently, all WECC entities must
comply under that request, but they
have 60 days to do so while also
complying with the administrative
request under PRC-004-WECC-2.
Duplicative administrative reporting
is not needed.

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25
WECC will continue to be responsible
for facilitating and monitoring these
data submissions, and will continue
to share the content with the WECC
Relay Work Group (RWG) for further
analysis and recommendations.

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Exhibit B
Implementation Plan

Implementation Plan
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Request to Retire
Standard Authorization Request
WECC-0126 PRC-004-WECC-2 Request to Retire - Standard Authorization Request
Approvals Required
•
•
•

WECC Board of Directors ............. December 6, 2017
NERC Board of Trustees ................. February 8, 2018
FERC ............................................................. Pending

Applicable Entities
4. Applicability
4.1.

Transmission Owners of selected WECC major transmission path facilities and RAS
listed in tables titled “Major WECC Transfer Paths in the Bulk Electric System”
provided at https://www.wecc.biz/Reliability/TableMajorPaths4-28-08.pdf and “Major
WECC Remedial Action Schemes (RAS)” provided at
https://www.wecc.biz/Reliability/TableMajorRAS4-28-08.pdf.

4.2.

Generator Owners that own RAS listed in the Table titled “Major WECC Remedial
Action Schemes (RAS)” provided at https://wecc.biz/Reliability/TableMajorRAS4-2808.pdf.

4.3.

Transmission Operators that operate major transmission path facilities and RAS listed
in Tables titled “Major WECC Transfer Paths in the Bulk Electric System” provided at
https://www.wecc.biz/Reliability/TableMajorPaths4-28-08.pdf and “Major WECC
Remedial Action Schemes (RAS)” provided at
https://www.wecc.biz/Reliability/TableMajorRAS4-28-08.pdf.

Conforming Changes to Other Standards
The entire standard is proposed for retirement immediately and in its entirety on receipt of applicable
regulatory approval because the reliability-related substance is addressed in peripheral NERC
Standards. The WECC-0126 PRC-004-WECC-2, Protection System and Remedial Action Scheme
Misoperation Standard Drafting Team (DT) does not believe any further actions are necessary to
implement the proposed retirement.
Proposed Effective Date
Immediately upon receipt of applicable regulatory approval.

WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114

WECC-0126 PRC-004-WECC-2: Protection System and RAS Misoperation

Justification
The DT reviewed NERC Standards, both in effect and proposed for regulatory approval. The DT also
considered the development history of PRC-004-WECC-2 and its history of performance.
What follows are the findings and justification for full and immediate retirement of the document. A
detailed analysis of each of the following bullets is included with this filing.
1) The reliability concern for which the original standard was drafted is now specifically covered in
FAC-003-4 Transmission Vegetation Management (enforceable October 1, 2016).
2) The Applicability section is overly narrow and included in other existing NERC Standards.
3) Requirement R1 is covered in other NERC Standards.
4) Requirement R2 is covered in other NERC Standards, conflicts with existing NERC Standards,
and its application can lessen reliability as opposed to enhancing it.
5) Requirement R3 is entirely administrative in nature and should be retired under FERC P81
criteria.
6) The language of the standard does not meet the FERC Order 672 criteria in that it fails to assign
the reliability task directly to an entity included in the NERC Functional Model.
Considering the above findings, the DT is recommending full and immediate retirement of the standard
upon receipt of applicable regulatory approval.
Consideration of Early Compliance
The drafting team foresees no concerns with early compliance.
Required Retirements
The currently approved standard (PRC-004-WECC-2) should be retired completely and immediately
following applicable regulatory approval. No other retirements or modifications are needed.

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Exhibit C
Complete Record of Development

Steven Rueckert
155 North 400 West
Salt Lake City, Utah
84103
January 2, 2018
Subject:

Notification of Completion
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Request to Retire a Regional Reliability Standard

To:

Mat Bunch
Manager of Standards Development, Standards
North American Electric Reliability Corporation
3353 Peachtree Rd. NE, North Tower – Suite 600
Atlanta, GA 30326

Dear Mat,
In accordance with the Western Electricity Coordinating Council’s (WECC) Reliability Standards
Development Procedures, the WECC-0126 PRC-004-WECC-2, Protection System and Remedial Action
Scheme Misoperation Drafting Team has completed its assigned project. Proposed retirement of the
standard has been approved by the WECC Ballot Pool and the WECC Board of Directors.
The NERC Board of Trustees approved retirement of PRC-004-WECC-2 on February 8, 2018. WECC is
seeking disposition by the Federal Energy Regulatory Commission, to retire PRC-004-WECC-2
immediately on receipt of applicable regulatory approval. The reliability-related content of the
standard is covered in other NERC Standards.
Thank you for your assistance.
Sincerely,
Steven Rueckert
Director of Standards
Western Electricity Coordinating Council

WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114

Supporting Documentation
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Regional Reliability Standard
For documentation support please contact Mr. W. Shannon Black, [email protected], (503) 307-5782.
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Request to Retire a Regional Reliability Standard
SAR – Standard Authorization Request Attachment A (1)
Regional Reliability Standard(s) (Clean Existing) Attachment B (2)
Project Roadmap Attachment C (3)
Implementation Plan Attachment D (4)
Technical Justification Attachment E (5)
Regional Reliability Standard Submittal Request Attachment F (6)
Drafting Team Roster with Biographies Attachment G (7)
Ballot Pool Members Attachment H (8)
Final Ballot Results Attachment I (9)
Minority Issues Attachment J (10)
WECC Standards Committee Roster Attachment K (11)
Responses to Comments – WECC Attachment L1 (12) and L2 (12b)
Info (13)
PRC-004-WECC-2
(Retirement) (14)
Submit Comments
PRC-004-WECC-2
(Retirement)

Protection System
and Remedial
Action Scheme
Misoperation

Standard Under
Development

11/03/17 12/18/17

Technical Justification
for Retirement (15)
Unofficial Comment
Form (Word) (16)
Comments Received
(17)
Consideration of
Comments (18)

WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114

Attachment A
Standard Authorization Request
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Request to Retire

This Standard Authorization Request (SAR) was received on October 26, 2016, and deemed complete
the same day. The SAR was vetted and approved during the December 6, 2016 WECC Standards
Committee meeting.

Introduction
In accordance with the Reliability Standards Development Procedures (Procedures), WECC Regional
Reliability Standards (RRS), such as PRC-004-WECC-2, Protection System and Remedial Action Scheme
Misoperation, are to be reviewed at least once every five years.
Version 1 was approved in FERC Order 751 (issued April 21, 2011) with a United States Enforcement
Date of October 12, 2011. Version 2 was approved in FERC Order 818 (issued November 19, 2015) with
a United States Enforcement Date of April 1, 2017. Changes between Version 1 and Version 2 focus
mainly on incorporation of “the new Remedial Action Scheme definition and eliminate use of the term
Special Protection System, and the associated implementation plan.” FERC Order 818, p.23, footnote
31

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
• Alternates First Name:
Steven
• Alternates Last Name:
Rueckert
• Alternates Email Address:
[email protected]
• Alternates Phone Number: NA

WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114

Standard Authorization Request

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
4. Document Type: (select one)
• WECC Regional Reliability Standard (RRS)
5. Issue: Specify what industry problem this request is trying to resolve.
The RRS was created under the Procedures and requires review at least once every five years.
6. Proposed Remedy: Specify how this request proposes to address the issue described.
Overall Review
This SAR is designed to meet the five-year review requirement contained in the Procedures.
The assigned drafting team is requested to review the document and to recommend any one or
more of the following actions, as deemed appropriate:
•
•
•
•
•
•
•

Complete or partial retirement;
Correction of non-substantive drafting conventions and formats;
Full redraft, if deemed necessary;
Conformity and/or alignment with other regulatory documents;
Restructuring of the document;
Relocating portions of the document;
Any combination of the above.

Consider for Retirement
In completing the five-year review, the drafting team is requested to specifically review
Requirement R3 for possible retirement because, among other things, the requirement is
administrative in nature, may be redundant to WECC authority under the NERC Rules of

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Standard Authorization Request

Procedure, Section 1600 Data Request, and may provide no added reliability to the Bulk-Electric
System. 1
The drafting team should review PRC-004-4(i), Protection System Misoperation Identification
and Correction to ensure PRC-004-WECC-2 does not conflict with or create redundancy to that
document. (See Background section of the NERC PRC-004-4(i).)
The following is offered for drafting team guidance.
When a Regional Reliability Standard requirement meets one or more of the following three
criteria, it should be retired: 2
1) Retirement of the requirement creates no reliability gaps;
2) The requirement is generally administrative in nature; or,
3) The requirement is redundant, or is adverse to the reliability principles set forth by NERC.

1
Reliability Standard PRC-004-WECC-2 addresses the analysis of misoperations that occur on transmission and generation
protection systems and remedial action schemes in the Western Interconnection. Docket No. RM09-9-000. It replaced PRC004-WECC-1. (Predecessors include WECC PRC-STD-001-1, and WECC PRC-STD-003-1.) Changes made to the tables
included in the applicability section of the standard will require development and submittal of the underlying methodology.
18 CFR Part 40, RM-09-9-000, Order Number 751, p. 40 (Order 751). FERC has already deemed this regional standard more
stringent than the NERC equivalent. Order 751. para. 34-37.
2
NERC Paragraph 81 Technical White Paper, page 6, December 20, 2012

Criterion A: Reliability Gaps
Retirement of the requirement would create no reliability gaps.
Criterion B: Administrative
The requirement is generally administrative in nature in that is meets one or more of the following criteria: 1)
administrative; 2) data collection/data retention; 3) documentation; 4) reporting; 5) periodic updates; 6) commercial or
business practice; and 7) redundant).
Criterion C: Redundancy
The requirement is redundant in that it meets one or more of the following criteria: 1) the requirement part of a
Find/Fix/Track filing; 2) the requirement is being reviewed in an ongoing Standards Development Project; 3) the
requirement is a Violation Risk Factor (“VRF”) of the requirement; 4) the requirement is a Tier in the 2013 Actively
Monitored List (“AML”); 5) the requirement has a negative impact on NERC’s reliability principles; 6) the requirement has a
negative impact on the defense in-depth protection of the Bulk Electric System; or 7) the requirement has a negative
impact on the promotion of results or performance based Reliability Standards.
2
P81 Technical Paper, Section II. Executive Summary, Oct 23, 2012.

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Standard Authorization Request

Specifically, for a requirement to be proposed for retirement, it must satisfy both, number 1
and 2 above. Number 3 is considered as additional information to make a more informed
decision.
7. Functions: Each function will be reviewed if affected.
• Transmission Owners of selected WECC major transmission path facilities and Remedial
Action Schemes listed in the tables titled “Major WECC Transfer Path in the Bulk Electric
System” and “Major WECC Remedial Action Schemes (RAS)”.
• Generator Owners that own RASs listed in the table titled “Major WECC Remedial
Action Schemes (RAS)”.
• Transmission Operators that operate major transmission path facilities and RAS listed in
Tables title “Major WECC Transfer Paths in the Bulk Electric System” and “Major WECC
Remedial Action Schemes (RAS)".
8. Detailed Description:
See above.
9. Affected Reliability Principles: Which of the following reliability principles is MOST affected by
this request? (select one)
• Reliability Principle —Information necessary for the planning and operation of
interconnected bulk electric systems shall be made available to those entities responsible
for planning and operating the systems reliably.

Document Information
Specify the documents title, document number, and affected section regarding the request.
10. Document Title:

See above.

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.
11. Provide additional comments (if needed)
Standard PRC-012-2 Remedial Action Schemes, Gene Henneberg, NV Energy, Davis Erwin,
Pacific Gas and Electric Company

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WECC Standard PRC-004-WECC-2 — Protection System and Remedial Action Scheme Misoperation

A. Introduction
1. Title:

Protection System and Remedial Action Scheme Misoperation

2. Number:

PRC-004-WECC-2

3. Purpose:

Regional Reliability Standard to ensure all transmission and generation Protection
System and Remedial Action Scheme (RAS) Misoperations on Transmission Paths
and RAS defined in section 4 are analyzed and/or mitigated.

4. Applicability
4.1. Transmission Owners of selected WECC major transmission path facilities and RAS listed in
tables titled “Major WECC Transfer Paths in the Bulk Electric System” provided
at https://www.wecc.biz/Reliability/TableMajorPaths4-28-08.pdf and “Major WECC
Remedial Action Schemes (RAS)” provided at
https://www.wecc.biz/Reliability/TableMajorRAS4-28-08.pdf.
4.2. Generator Owners that own RAS listed in the Table titled “Major WECC Remedial Action
Schemes (RAS)” provided at https://wecc.biz/Reliability/TableMajorRAS4-28-08.pdf..
4.3. Transmission Operators that operate major transmission path facilities and RAS listed in
Tables titled “Major WECC Transfer Paths in the Bulk Electric System” provided at
https://www.wecc.biz/Reliability/TableMajorPaths4-28-08.pdf and “Major WECC Remedial
Action Schemes (RAS)” provided at https://www.wecc.biz/Reliability/TableMajorRAS4-2808.pdf.
5. Effective Date: See Implementation Plan for the Revised Definition of “Remedial Action
Scheme”
B. Requirements
The requirements below only apply to the major transmission paths facilities and RAS listed in the
tables titled “Major WECC Transfer Paths in the Bulk Electric System” and “Major WECC
Remedial Action Schemes (RAS).”
R.1. System Operators and System Protection personnel of the Transmission Owners and
Generator Owners shall analyze all Protection System and RAS operations. [Violation Risk
Factor: Lower] [Time Horizon: Operations Assessment]
R1.1.

System Operators shall review all tripping of transmission elements and RAS
operations to identify apparent Misoperations within 24 hours.

R1.2.

System Protection personnel shall analyze all operations of Protection Systems and
RAS within 20 business days for correctness to characterize whether a Misoperation
has occurred that may not have been identified by System Operators.

R.2. Transmission Owners and Generator Owners shall perform the following actions for each
Misoperation of the Protection System or RAS. It is not intended that Requirements R2.1
through R2.4 apply to Protection System and/or RAS actions that appear to be entirely
reasonable and correct at the time of occurrence and associated system performance is fully
compliant with NERC Reliability Standards. If the Transmission Owner or Generator Owner
later finds the Protection System or RAS operation to be incorrect through System Protection
personnel analysis, the requirements of R2.1 through R2.4 become applicable at the time the
Transmission Owner or Generator Owner identifies the Misoperation:
R2.1.

If the Protection System or RAS has a Security-Based Misoperation and two or more
Functionally Equivalent Protection Systems (FEPS) or Functionally Equivalent RAS
(FERAS) remain in service to ensure Bulk Electric System (BES) reliability, the
Transmission Owners or Generator Owners shall remove from service the Protection
1

WECC Standard PRC-004-WECC-2 — Protection System and Remedial Action Scheme Misoperation

System or RAS that misoperated within 22 hours following identification of the
Misoperation. Repair or replacement of the failed Protection System or RAS is at the
Transmission Owners’ and Generator Owners’ discretion. [Violation Risk Factor:
High] [Time Horizon: Same-day Operations]
R2.2.

If the Protection System or RAS has a Security-Based Misoperation and only one
FEPS or FERAS remains in service to ensure BES reliability, the Transmission
Owner or Generator Owner shall perform the following. [Violation Risk Factor:
High] [Time Horizon: Same-day Operations]
R2.2.1. Following identification of the Protection System or RAS Misoperation,
Transmission Owners and Generator Owners shall remove from service
within 22 hours for repair or modification the Protection System or RAS
that misoperated.
R2.2.2. The Transmission Owner or Generator Owner shall repair or replace any
Protection System or RAS that misoperated with a FEPS or FERAS within
20 business days of the date of removal. The Transmission Owner or
Generator Owner shall remove the Element from service or disable the
RAS if repair or replacement is not completed within 20 business days.

R2.3.

If the Protection System or RAS has a Security-Based or Dependability-Based
Misoperation and a FEPS and FERAS is not in service to ensure BES reliability,
Transmission Owners or Generator Owners shall repair and place back in service
within 22 hours the Protection System or RAS that misoperated. If this cannot be
done, then Transmission Owners and Generator Owners shall perform the following.
[Violation Risk Factor: High] [Time Horizon: Same-day Operations]
R2.3.1. When a FEPS is not available, the Transmission Owners shall remove the
associated Element from service.
R2.3.2. When FERAS is not available, then
2.3.2.1. The Generator Owners shall adjust generation to a reliable
operating level, or
2.3.2.2. Transmission Operators shall adjust the SOL and operate the
facilities within established limits.

R2.4.

If the Protection System or RAS has a Dependability-Based Misoperation but has
one or more FEPS or FERAS that operated correctly, the associated Element or
transmission path may remain in service without removing from service the
Protection System or RAS that failed, provided one of the following is performed.
R2.4.1. Transmission Owners or Generator Owners shall repair or replace any
Protection System or RAS that misoperated with FEPS and FERAS within
20 business days of the date of the Misoperation identification, or
R2.4.2. Transmission Owners or Generator Owners shall remove from service the
associated Element or RAS. [Violation Risk Factor: Lower] [Time
Horizon: Operations Assessment]

R.3. Transmission Owners and Generation Owners shall submit Misoperation incident reports to
WECC within 10 business days for the following. [Violation Risk Factor: Lower] [Time
Horizon: Operations Assessment]
R3.1.

Identification of a Misoperation of a Protection System and/or RAS,

R3.2.

Completion of repairs or the replacement of Protection System and/or RAS that
misoperated.
2

WECC Standard PRC-004-WECC-2 — Protection System and Remedial Action Scheme Misoperation

C. Measures
Each measure below applies directly to the requirement by number.
M1.

M2.

Transmission Owners and Generation Owners shall have evidence that they reported and
analyzed all Protection System and RAS operations.
M1.1

Transmission Owners and Generation Owners shall have evidence that System
Operating personnel reviewed all operations of Protection System and RAS
within 24 hours.

M1.2

Transmission Owners and Generation Owners shall have evidence that System
Protection personnel analyzed all operations of Protection System and RAS for
correctness within 20 business days.

Transmission Owners and Generation Owners shall have evidence for the following.
M2.1

Transmission Owners and Generation Owners shall have evidence that they
removed the Protection System or RAS that misoperated from service within 22
hours following identification of the Protection System or RAS Misoperation.

M2.2

Transmission Owners and Generation Owners shall have evidence that they
removed from service and repaired the Protection System or RAS that
misoperated per measurements M2.2.1 through M2.2.2.
M2.2.1 Transmission Owners and Generation Owners shall have evidence that
they removed the Protection System or RAS that misoperated from
service within 22 hours following identification of the Protection System
or RAS Misoperation.
M2.2.2 Transmission Owners and Generation Owners shall have evidence that
they repaired or replaced the Protection System or RAS that misoperated
within 20 business days or either removed the Element from service or
disabled the RAS.

M2.3

The Transmission Owners and Generation Owners shall have evidence that they
repaired the Protection System or RAS that misoperated within 22 hours
following identification of the Protection System or RAS Misoperation.
M2.3.1 The Transmission Owner shall have evidence that it removed the
associated Element from service.
M2.3.2 The Generator Owners and Transmission Operators shall have
documentation describing all actions taken that adjusted generation or
SOLs and operated facilities within established limits.

M2.4

Transmission Owners and Generation Owners shall have evidence that they
repaired or replaced the Protection System or RAS that misoperated including
documentation that describes the actions taken.
M2.4.1 Transmission Owners and Generation Owners shall have evidence that
they repaired or replaced the Protection System or RAS that misoperated
within 20 business days of the misoperation identification.
M2.4.2 Transmission Owners and Generation Owners shall have evidence that
they removed the associated Element or RAS from service.

M3.

Transmission Owners and Generation Owners shall have evidence that they reported the
following within 10 business days.
3

WECC Standard PRC-004-WECC-2 — Protection System and Remedial Action Scheme Misoperation

M3.1

Identification of all Protection System and RAS Misoperations and corrective
actions taken or planned.

M3.2

Completion of repair or replacement of Protection System and/or RAS that
misoperated.

D. Compliance
1. Compliance Monitoring Process
1.1

Compliance Monitoring Responsibility

1.2

Compliance Enforcement Authority
Compliance Monitoring Period
Compliance Enforcement Authority may use one or more of the following methods to
assess compliance:
- Misoperation Reports
- Reports submitted quarterly
- 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
1.2.1

1.3

The Performance-reset Period is one calendar month.

Data Retention
Reliability Coordinators, Transmission Owners, and Generation Owners shall keep
evidence for Measures M1 and M2 for five calendar years plus year to date.

1.4.

Additional Compliance Information
None.

WECC Standard PRC-004-WECC-2 — Protection System and Remedial Action Scheme Misoperation

2. Violation Severity Levels
R1
Lower

Moderate

High

Severe

System Operating personnel
of the Transmission Owner
or Generator Owner did not
review the Protection
System Operation or RAS
operation within 24 hours
but did review the
Protection System
Operation or RAS operation
within six business days.

System Operating personnel of
the Transmission Owner or
Generator Owner did not
review the Protection System
operation or RAS operation
within six business days.

System Protection personnel
of the Transmission Owner
and Generator Owner did
not analyze the Protection
System operation or RAS
operation within 20 business
days but did analyze the
Protection System operation
or RAS operation within 25
business days.

System Protection
personnel of the
Transmission Owner or
Generator Owner did not
analyze the Protection
System operation or RAS
operation within 25
business days.

Lower

Moderate

High

Severe

The Transmission Owner
and Generator Owner did
not remove from service,
repair, or implement other
compliance measures for the
Protection System or RAS
that misoperated as required
within 22 hours but did
perform the requirements
within 24 hours.

The Transmission Owner and
Generator Owner did not
remove from service, repair,
or implement other
compliance measures for the
Protection System or RAS that
misoperated as required in less
than 24 hours but did perform
the requirements within 28
hours.

The Transmission Owner
and Generator Owner did
not perform the removal
from service, repair, or
implement other compliance
measures for the Protection
System or RAS that
misoperated as required in
less than 28 hours but did
perform the requirements
within 32 hours.

The Transmission Owner
and Generator Owner did
not perform the removal
from service, repair, or
implement other
compliance measures for
the Protection System or
RAS that misoperated as
required within 32 hours.

Lower

Moderate

High

Severe

The Transmission Operator
and Generator Owner did
not adjust generation to a
reliable operating level,
adjust the SOL and operate
the facilities within
established limits or
implement other compliance
measures for the Protection
System or RAS that
misoperated as required
within 22 hours but did
perform the requirements
within 24 hours.

The Transmission Operator
and Generator Owner did not
adjust generation to a reliable
operating level, adjust the
SOL and operate the facilities
within established limits or
implement other compliance
measures for the Protection
System or RAS that
misoperated as required in less
than 24 hours but did perform
the requirements within 28
hours.

The Transmission Operator
and Generator Owner did
not adjust generation to a
reliable operating level,
adjust the SOL and operate
the facilities within
established limits or
implement other compliance
measures for the Protection
System or RAS that
misoperated as required in
less than 28 hours but did
perform the requirements
within 32 hours.

The Transmission
Operator and Generator
Owner did not adjust
generation to a reliable
operating level, adjust the
SOL and operate the
facilities within
established limits or
implement other
compliance measures for
the Protection System or
RAS that misoperated as
required within 32 hours.

R2.1 and R2.2.1

R2.3

WECC Standard PRC-004-WECC-2 — Protection System and Remedial Action Scheme Misoperation

R2.2.2 and R2.4
Lower

Moderate

High

Severe

The Transmission Owner
and Generator Owner did
not perform the required
repairs, replacement, or
system operation
adjustments to comply with
the requirements within 20
business days but did
perform the required
activities within 25 business
days.

The Transmission Owner and
Generator Owner did not
perform the required repairs,
replacement, or system
operation adjustment to
comply with the requirements
within 25 business days but
did perform the required
activities within 28 business
days.

The Transmission Owner
and Generator Owner did
not perform the required
repairs, replacement, or
system operation adjustment
to comply with the
requirements within 28
business days but did
perform the required
activities within 30 business
days.

The Transmission Owner
and Generator Owner did
not perform the required
repairs, replacement, or
system operation
adjustments to comply
with the requirements
within 30 business days.

Lower

Moderate

High

Severe

The Transmission Owner
and Generator Owner did
not report the Misoperation
and corrective actions taken
or planned to comply with
the requirements within 10
business days but did
perform the required
activities within 15 business
days.

The Transmission Owner and
Generator Owner did not
report the Misoperation and
corrective actions taken or
planned to comply with the
requirements within 15
business days but did perform
the required activities within
20 business days.

The Transmission Owner
and Generator Owner did
not report the Misoperation
and corrective actions taken
or planned to comply with
the requirements within 20
business days but did
perform the required
activities within 25 business
days.

The Transmission Owner
and Generator Owner did
not report the
Misoperation and
corrective actions taken or
planned to comply with
the requirements within
25 business days.

Lower

Moderate

High

Severe

The Transmission Owner
and Generator Owner did
not report the completion of
repair or replacement of
Protection System and/or
RAS that misoperated to
comply with the
requirements within 10
business days of the
completion but did perform
the required activities within
15 business days.

The Transmission Owner and
Generator Owner did not
report the completion of repair
or replacement of Protection
System and/or RAS that
misoperated to comply with
the requirements within 15
business days of the
completion but did perform
the required activities within
20 business days.

The Transmission Owner
and Generator Owner did
not report the completion of
repair or replacement of
Protection System and/or
RAS that misoperated to
comply with the
requirements within 20
business days of the
completion but did perform
the required activities within
25 business days.

The Transmission Owner
and Generator Owner did
not report the completion
of repair or replacement
of Protection System
and/or RAS that
misoperated to comply
with the requirements
within 25 business days of
the completion.

R3.1

R3.2

WECC Standard PRC-004-WECC-2 — Protection System and Remedial Action Scheme Misoperation

Version History — Shows Approval History and Summary of Changes in the Action Field
Version
1

Date
April 16, 2008

April 21, 2011

2
2

Action
Permanent Replacement Standard for
PRC-STD-001-1 and PRC-STD-003-1

Change Tracking

FERC Order issued approving PRC004-WECC-1 (approval effective June
27, 2011)
November 13, 2014 Adopted by the NERC Board of
Trustees
November 19, 2015 FERC Order issued approving PRC004-WECC-2. Docket No. RM15-13000.
May 26, 2017

All links were updated in the
Applicability section of the standard
(4.1, 4.2 and 4.3)

Attachment C
Project Roadmap
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Request to Retire

Project Roadmap

Actions

Proposed Date

SAR Filed

October 26, 2016

DT Solicited

October 26, 2016

WSC approved the SAR and DT

December 6, 2016

First DT meeting

January 26, 2017

Posting 1 Comments Open

April 6, 2017

Posting 1 Comments Closed (45-day)

May 22, 2017

DT Meets to answer Comments

May 24, 2017

WSC approves for Ballot

July 6, 2017

Notice of Ballot Pool Forming

July 10, 2017

10. Ballot Pool Open

July 11, 2017

11. Notice of Standards Briefing

July 17, 2017

12. Ballot Pool – Closed

July 26, 2017

13. Standards Briefing

August 1, 2017

14. Ballot Open

August 9, 2017

15. Ballot Closes

August 28, 2017

16. NERC Posting for 45 days – Open

November 3, 2017

17. WECC Board of Directors approval

December 6, 2017

18. NERC Posting for 45 days – Closed

December 18, 2017

19. NERC Board of Trustees approval

February 8, 2017

WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114

WECC-0126 PRC-004-WECC-2: Protection System and RAS Misoperation
Anticipated Actions

2
Proposed Date

1. FERC approval

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Attachment D
Implementation Plan
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Request to Retire
Standard Authorization Request
WECC-0126 PRC-004-WECC-2 Request to Retire - Standard Authorization Request
Approvals Required
•
•
•

WECC Board of Directors ............. December 6, 2017
NERC Board of Trustees ................. February 8, 2018
FERC ............................................................. Pending

Applicable Entities
4. Applicability
4.1.

4.2.

Generator Owners that own RAS listed in the Table titled “Major WECC Remedial
Action Schemes (RAS)” provided at https://wecc.biz/Reliability/TableMajorRAS4-2808.pdf.

4.3.

WECC-0126 PRC-004-WECC-2: Protection System and RAS Misoperation

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O O R D I N A T I N G

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Attachment E
Technical Justification
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Request to Retire

Cover Sheet
Technical Justification
Retirement of WECC Regional Reliability Standard
PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation

155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114

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WECC-0126 PRC-004-WECC-2 Request to Retire

Currently known as the North American Electricity Reliability Corporation (emphasis added).

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WECC-0126 PRC-004-WECC-2 Request to Retire

In the Glossary of Terms Used in NERC Reliability Standards, Protection Systems are not the same as Special Protection
Systems (SPS). An SPS is synonymous with a RAS per that glossary.

This project is part of WECC’s commitment to harmonize PRC-004-WECC-2 with NERC Standards addressing RAS and PS
per PRC-004-4(i), 5 Background, page 2.
8

FAC-003-4, Transmission Vegetation Management, Section 6. Background. See also: “Consideration of Actual Field
Conditions in Determination of Facility Ratings.”

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WECC-0126 PRC-004-WECC-2 Request to Retire

4. Applicability
4.1.

4.2.
4.3.

PRC-004-4(i) Protection System Misoperation Identification and Correction, 5. Background, page 2.

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WECC-0126 PRC-004-WECC-2 Request to Retire

Retirement of Requirement R1
The entirety of Requirement R1 should be retired because it is redundant to other NERC Standards.
The text of Requirement R1 is as follows:

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WECC-0126 PRC-004-WECC-2 Request to Retire

PRC-001-1.1(ii) System Protection Coordination, Requirements R1 and R2.

PRC-005-6 – Protection System, Automatic Reclosing, and Sudden Pressure Relaying Maintenance.

PRC-001-1.1(ii) — System Protection Coordination; TOP-003-3, Operational Reliability Data, R1, part 1.2.

PRC-005-6 — Protection System, Automatic Reclosing, and Sudden Pressure Relaying Maintenance, Requirement R5.

PRC-016-1 — Remedial Action Scheme Misoperation; (United States Enforcement Date April 1, 2017).

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WECC-0126 PRC-004-WECC-2 Request to Retire

Retirement of Requirement R2
The entirety of Requirement R2 should be retired because it is redundant to other NERC Standards.

IRO-001.1 R3, requires action within 30 minutes. TOP-008 R2, as noted, primarily reinforces TOP-004 R2, basically saying
that the TOP is covered within the IRO timing requirement.

WECC Relay Work Group Meeting Minutes, July 20, 2000.

Reliability Management System, I. Protection Relay and Remedial Action Scheme Misoperation, Section 2.d.

TOP-002-2.1b Normal Operations Planning, Requirement R6 requires a minimum of N-1 Contingency planning to meet
unscheduled changes in system configuration and generation dispatch.

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WECC-0126 PRC-004-WECC-2 Request to Retire

The text of Requirement R2 is as follows:

B. Requirements
R.2.

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WECC-0126 PRC-004-WECC-2 Request to Retire

Security-based Misoperations and Dependability-based Misoperations are included in the WECC-specific section of the
Glossary of Terms Used in NERC Reliability Standards.

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L E C T R I C I T Y

O O R D I N A T I N G

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WECC-0126 PRC-004-WECC-2 Request to Retire

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L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

WECC-0126 PRC-004-WECC-2 Request to Retire

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WECC-0126 PRC-004-WECC-2 Request to Retire

FERC Order No. 672 at P 325.

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WECC-0126 PRC-004-WECC-2 Request to Retire

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WECC-0126 PRC-004-WECC-2 Request to Retire

North American Electric Reliability Corporation, 138 FERC ¶ 61,193 at P 81 (2012) (“FFT Order”).

FFT Order at P 81.

Joint Petition for Approval of Proposed Regional Reliability Standards, VAR-002-WECC-2 AND VAR-501-WECC-2, Section C.
Project 2013-02 Paragraph 81, page 6 (VAR Order).

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WECC-0126 PRC-004-WECC-2 Request to Retire

If not retired, the language of each of the Measures should be redrafted to reflect “will have evidence” as opposed to the
requirement “shall have evidence.”

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WECC-0126 PRC-004-WECC-2 Request to Retire

(Broader and all-inclusive)

The Applicability section is narrowly
crafted to apply only to:

PRC-016-1 applies to TOs, GOs, and
Distribution Providers’ (DP) RAS
regardless of path.

1) Transmission Owners (TO) of
selected facilities with RAS
listed in a specific table;
2) Generator Owners (GO) with
RAS listed in a specific table;
and,

PRC-004-4 applies to TOs, GOs, and
DPs’ PS regardless of path.

3) Transmission Operators
operating facilities and RAS
listed in the specified table.
PRC-004-WECC-2

PRC-004-5(i)

Covers RAS plus PS

Covers PS.

R.1. System Operators and System
Protection personnel of the
Transmission Owners and Generator
Owners shall analyze all Protection
System and RAS operations.

PRC-004-5(I) Protection System
Misoperation Identification and
Correction.

E S T E R N

R1. requires the TO and GO to
identify the reasons for PS
operation and whether the

L E C T R I C I T Y

O O R D I N A T I N G

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WECC-0126 PRC-004-WECC-2 Request to Retire
[Violation Risk Factor: Lower] [Time
Horizon: Operations Assessment]

PRC-012-2, Remedial Action
Schemes 33
R5. Requires the TO and GO to
review its RAS within 120 days of
operation or failure. (The term
analyze is used in R5.2.) 34
PRC-004-WECC-2

PRC-012-2

R1.1 System Operators shall review
all tripping of transmission elements
and RAS operations to identify
apparent Misoperations within 24
hours.

R1.2. System Protection
personnel shall analyze all
operations of Protection Systems

United States Enforcement Date is April 2, 2017.

Becomes Inactive on March 31, 2017.

PRC-012-2 has been filed with FERC and is pending regulatory disposition as of March 29, 2017.

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WECC-0126 PRC-004-WECC-2 Request to Retire
and RAS within 20 business days for
correctness to characterize whether
a Misoperation has occurred that
may not have been identified by
System Operators.

2000-07-20-RWG-M
eeting.pdf
PRC-004-WECC-2

PRC-016-1

Covers PS and RAS

Covers PS

R.2. Transmission Owners and
Generator Owners shall perform the
following actions for each
Misoperation of the Protection
System or RAS.

PRC-016-1 — Remedial Action
Scheme Misoperations

PRC-012-2

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R2. Each TO, GO, and DP, owing a
RAS shall take corrective actions to
avoid future misoperations.

Whereas the reliability tasks of PRC004-WECC-2 Requirement R2 are
included in PRC-016-1 and PRC-0122, PRC-004-WECC-2 Requirement R2
is redundant and can be retired.

L E C T R I C I T Y

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PRC-001-1.1(ii)

R2. Each Generator Operator and
Transmission Operator shall notify
reliability entities of relay or
equipment failures as follows:

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WECC-0126 PRC-004-WECC-2 Request to Retire

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O O R D I N A T I N G

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WECC-0126 PRC-004-WECC-2 Request to Retire

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O O R D I N A T I N G

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WECC-0126 PRC-004-WECC-2 Request to Retire

E S T E R N

As of July 1, 2016, Protection
System Operations and

L E C T R I C I T Y

Retirement of PRC-004-WECC-2
Requirement R3 fits the retirement

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WECC-0126 PRC-004-WECC-2 Request to Retire

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Regional Reliability Standard Submittal Request
Attachment F
Region:

Western Electricity Coordinating Council

Regional Standard Number:

PRC-004-WECC-2

Regional Standard Title:

Protection System and Remedial Action Scheme Misoperation

Date Submitted:

January 2, 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 Standard PRC-004-WECC-2
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 (WECC) Board of Directors (Board),
acting on the recommendation of the WECC Standards Committee at the meeting of the Board on
December 6, 2017, hereby retires Regional Reliability Standards –
• PRC-004-WECC-2, Protection System and Remedial Action Scheme Misoperation, and

1
Regional Reliability Std Submittal Request

•

VAR-002-WECC-2, Automatic Voltage Regulators

[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 See below.
basis and purpose (scope)
of request:

Concise statement of the
justification of the
request:

As proposed, PRC-004-WECC-2, Protection System and Remedial
Action Scheme Misoperation Procedures would be retired completely
and immediately on receipt of applicable regulatory approval.
Executive Summary
The WECC-0126 PRC-004-WECC-2 Standard Drafting Team (DT)
reviewed NERC Standards, both in effect and proposed for regulatory
approval. The DT also considered the development history of PRC004-WECC-2 and its history of performance.
The following are the findings, conclusion reached, and
recommendation of the DT.
Findings and Conclusion
The DT concluded that retirement of the standard can be made
without incurring a negative impact on reliability because:
1. The reliability concern for which the standard was drafted is
now specifically covered in FAC-003-4 Transmission
Vegetation Management (enforceable October 1, 2016).

2
Regional Reliability Std Submittal Request

2. The Applicability section is overly narrow and included in
other existing NERC Standards;
3. Requirement R1 is covered in other NERC Standards;
4. Requirement R2 is covered in other NERC Standards, conflicts
with existing NERC Standards, and its application can lessen
reliability as opposed to enhancing it;
5. Requirement R3 is entirely administrative in nature and
should be retired under FERC P81 criteria;
6. The language of the standard does not meet the FERC Order
672 criteria in that it fails to assign the reliability task directly
to an entity included in the NERC Functional Model.
Recommendation
After completing its review, the DT recommends that PRC-004-WECC2 be retired immediately and in its entirety, on receipt of applicable
regulatory approval, because the reliability-related content is
addressed in peripheral NERC Standards. The DT does not believe any
further actions are necessary to implement the proposed change.

3
Regional Reliability Std Submittal Request

Attachment G
Drafting Team Roster
WECC-0126 PRC-004-WECC-2
Request to Retire
Below are biographical snapshots for the members of the WECC-0126 PRC-004-WECC-3, Protection
Scheme and Remedial Action Scheme Misoperation Drafting Team.

WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114

Document Title

Name

Background

Bill Middaugh

Bill Middaugh has been working in the electric utility industry since 1982 with
about 26 years in system protection and eight years in transmission planning.
He Is currently the System Protection Manager at Tri-State Generation and
Transmission Association. As a transmission planning engineer, he performed
power flow studies in support of new generation interconnections, summer
and winter operating conditions, and future transmission requirements. He
also performed dynamic stability studies and developed tools to analyze
apparent impedances during power swings to evaluate relay performance. As a
protection engineer he developed Tri-State’s responses to NERC’s
Recommendation 8a which is to ensure that transmission facilities are not
unnecessarily interrupted during system disturbances when operator action
within the first 15-minutes could alleviate potentially damaging overloads or
prevent cascading outages. Additionally, regarding relay loadability, he
developed Tri-State’s documentation procedure for reliability standard PRC023.

Tri-State
Generation and
Transmission
Team Chair

He chaired the WECC Relay Work Group for about five years and coordinated
WECC member responses to NERC Recommendation 8a. He also chaired two
WECC regional drafting teams associated with misoperations; one a standard
and one a criterion. He chaired the NERC PRC-026 drafting team and is
currently the chair of Project 2007-06 – System Protection Coordination (PRC027-1), which is awaiting FERC approval. He was also a member of the team
developing NERC reliability standard PRC-004-3, “Protection System
Misoperation Identification and Correction.”
Mr. Middaugh received a Bachelor of Science degree in Electrical Engineering
from the University of Colorado at Boulder in 1982. He is a registered
Professional Engineer in the State of Colorado and a member of IEEE.

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Document Title

Name

Background

Mr. Gene
Henneberg

Mr. Gene Henneberg earned a Bachelor of Science from Walla Walla College
and Master of Science in Electrical Engineering from Washington State
University. He has more than 38 years of utility experience with NV Energy in
Transmission Planning, substation construction and operations, and System
Protection. Mr. Henneberg was the chair of the drafting team for NERC's PRC012-2, and for WECC's PRC-012—014-WECC-CRT-1 and -2, and a drafting team
member for WECC's PRC-004-WECC-1 He is a member of the WECC Relay
Work Group, chair of the WECC Remedial Action Scheme Reliability
Subcommittee, and is active in the IEEE Power System Relaying Committee. He
is a registered professional engineer in Nevada.

Nevada Energy

Randy Spacek
Avista Utilities

Mr. Spacek has 29 plus years of experience in transmission, distribution and
generation protection, operations, integration, technical training, and technical
writing.
Mr. Spacek is presently a System Protection Engineering Manager. As manager,
he is responsible for NERC compliance activities in the areas of Protection Relay
and Control (PRC), and facilitates the group's business, technical and support
efforts.
Mr. Spacek is also a Senior Electrical Engineer in the area of System Protection
and Integration having experience in the area of generation and transmission
relaying and substation integration. He has been involved in the development
of new transmission relay standards, relay applications and integration design,
and the development of Protection systems.
Mr. Spacek has a Bachelor of Science in Electrical Engineering from the
University of Idaho and is a registered Professional Engineer.

Stuart Steiner
Los Angeles
Department of
Water and
Power

E S T E R N

Mr. Steiner is a Subject Matter Expert for NERC Standards PRC-004 and PRC-005
with 31 years of experience in the System Protection group at the Los Angeles
Department of Water and Power.

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Document Title

Name

Background

Dean Bender

Mr. Dean Bender of the Bonneville Power Administration has 25 years of
protection system experience including setting relays and analyzing
misoperations. He currently serves as the vice-chair of the WECC Relay Work
Group. As Bonneville Power Administration's subject matter expert for PRC004-WECC since its inception, he has submitted 17 reports to WECC per the
requirements of this standard. Mr. Bender was a participant on original PRC
standard drafting team.

Bonneville
Power
Administration

Jonathan Meyer Mr. Meyer’s current position is Leader of System Protection Engineering at
Idaho Power Company. He has been a member of System Protection for 16
Idaho Power –
years, progressing from a Protection Engineer to the leadership role, setting the
System
philosophies for transmission protection at Idaho Power and taking
protection
responsibility for NERC/WECC compliance associated with Protection, Relaying,
and Control (PRC) Standards applicable to Transmission Owners (e.g. PRC-004,
PRC-005, PRC-23, etc.)
Mr. Meyer has created/reviewed the audit packages for the applicable
standards for three successful NERC/WECC audits and is regularly utilized as a
consultant with company on compliance related questions and interpretations
for other working groups, most recently for NERC FAC-008 for our Planning
Department. In addition, he was a member of the original drafting team for
PRC-004-WECC and is currently a member of the WECC Relay Work Group.
More recently, Mr. Meyer was a volunteer member of the NERC PRC-012-2
Remedial Action Schemes Drafting Team. Through his regular attendance and
participation, he was given the responsibilities of a full member (minus full
voting privilege). Mr. Meyer drafted Requirement 8 – functional testing,
created the draft rational and technical justification documents, responded to
industry comments, and presented on the NERC webinars for PRC-012.

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L E C T R I C I T Y

O O R D I N A T I N G

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Document Title

Name

Background

Rafael Pina

Mr. Pineda has over 25 years of experience in transmission protection,
substation engineering, and hydro generation engineering with the last 18
years in protection. He is a member of the WECC Relay Work Group since 2009
and is the PRC-004 Subject Matter Expert at PG&E.

Pacific Gas and
Electric

Mr. Pineda currently provides protection support for operations, maintenance,
and capital projects on PG&E’s 500kV transmission system and wide-area RAS
schemes.
Mr. Pineda earned a Bachelor of Science degree in Electrical Engineering from
California Polytechnic State University at San Luis Obispo in 1990. He is a
registered Professional Engineer in the State of California.
David Jensen
PacifiCorp

Mr. Jensen has 25 plus years of experience in transmission and distribution
planning, operations, and protection. He is currently a Senior Distribution and
Transmission Specialist in the PacifiCorp Protection and Control group and is
the current subject matter expert at PacifiCorp for PRC-004-WECC. He has
been involved with system protection investigations, procedures, compliance,
and reporting for more than 7 years.
Mr. Jensen has a Bachelor of Science degree in Electrical Engineering from the
University of Utah.

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O O R D I N A T I N G

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Attachment H
Ballot Pool Members
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Request to Retire
Ballot Pool
Title

Company

Sector

WECC-0126

AES
Corporation

Generation

WECC-0126

Arizona Public
Service
Company

System
Coordination

WECC-0126

Arizona Public
Service
Company

WECC-0126

Arizona Public
Service
Company

WECC-0126

Arizona Public
Service
Company

WECC-0126

Arizona Public
Service
Company

Vote

Comments

Created By
Leo Bernier

Yes

Vivian Vo

Marketers and
Brokers

Yes

Linda
Henrickson

Transmission

Yes

Gary Nolan

Yes

Kasey
Bohannon

Distribution

Yes

Michelle
Amarantos

WECC-0126

Avista
Corporation

Marketers and
Brokers

Yes

Scott Kinney

WECC-0126

Balancing
Authority of
Northern
California

System
Coordination

Yes

Joe Tarantino

WECC-0126

Black Hills
Corporation

Transmission

Eric Scherr

WECC-0126

Black Hills
Corporation

Distribution

Eric Scherr

Generation

WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114

Document Title

Title

Company

Sector

WECC-0126

Black Hills
Corporation

Generation

Eric Scherr

WECC-0126

Black Hills
Corporation

System
Coordination

Eric Scherr

WECC-0126

Bonneville
Power
Administration Transmission

WECC-0126

Bonneville
Power
Administration Distribution

WECC-0126

Bonneville
Power
Marketers and
Administration Brokers

WECC-0126

Bonneville
Power
System
Administration Coordination

WECC-0126

British
Columbia
Hydro &
Power
Authority

Distribution

WECC-0126

British
Columbia
Hydro &
Power
Authority

System
Coordination

WECC-0126

British
Columbia
Hydro &
Power
Authority

WECC-0126

California
Independent
System
Operator

E S T E R N

Vote

Comments

Created By

Yes

Kammy
RogersHolliday

Yes

Rebecca
Berdahl

Yes

Andrew
Meyers

Yes

Francis
Halpin

Abstain No Comments

Hootan
Jarollahi

Abstain No Comments

Patricia
Robertson

Transmission

Abstain No Comments

Patricia
Robertson

System
Coordination

Yes

Richard Vine

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Document Title

Title

Company

Sector

Vote

Comments

Created By

WECC-0126

California
Independent
System
Operator

Transmission

Yes

WECC-0126

Dominion
Resources
Services, Inc.

Generation

WECC-0126

El Paso Electric
Company
Transmission

Yes

Pablo Onate

WECC-0126

El Paso Electric System
Company
Coordination

Yes

Pablo Onate

Richard Vine

Sean Bodkin

Yes

EPE agrees with the
finding and conclusions of
the Drafting Team for the
retirement of this
standard.

Victor Garzon

WECC-0126

El Paso Electric
Company
Distribution

Yes

EPE agrees with the
finding and conclusions of
the Drafting Team for the
retirement of this
standard.

Victor Garzon

WECC-0126

Idaho Power
Company

System
Coordination

Yes

Laura Nelson

WECC-0126

Idaho Power
Company

Generation

Yes

Laura Nelson

WECC-0126

Idaho Power
Company

Distribution

Yes

Laura Nelson

WECC-0126

Idaho Power
Company

Transmission

Yes

Laura Nelson

WECC-0126

Nevada Power
Company

Transmission

Yes

Eric
Schwarzrock

WECC-0126

Northern
California
Power Agency

Marketers and
Brokers

Yes

Dennis
Sismaet

WECC-0126

El Paso Electric
Company
Generation

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Document Title

Title

Company

WECC-0126

Northern
California
Power Agency

Generation

WECC-0126

Open Access
Technology
International

End User
Representative Yes

Mark
Hackney

WECC-0126

Pacific Gas
and Electric
Company

Generation

Abstain none

Alex Chua

Yes

Sandra
Shaffer

Yes

Sandra
Shaffer

Yes

Sandra
Shaffer

Yes

Sandra
Shaffer

Yes

Sandra
Shaffer

Yes

Matthew
Thompson

WECC-0126
WECC-0126
WECC-0126

Sector

PacifiCorp
PacifiCorp

Generation
Distribution

Vote

Comments

Created By
Marty
Hostler

Yes

PacifiCorp

Transmission

PacifiCorp

Marketers and
Brokers

WECC-0126

PacifiCorp

System
Coordination

WECC-0126

Platte River
Power
Authority

System
Coordination

WECC-0126

Platte River
Power
Authority

Marketers and
Brokers

Yes

Sabrina
Martz

WECC-0126

Platte River
Power
Authority

Transmission

Yes

Jeff Landis

WECC-0126

Platte River
Power
Authority

Generation

Yes

Tyson Archie

WECC-0126

Public Service
Company of
New Mexico

System
Coordination

Yes

Laurie
Williams

WECC-0126

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Document Title

Title

Company

Sector

WECC-0126

Public Service
Company of
New Mexico

WECC-0126

Public Service
Company of
New Mexico

WECC-0126

Public Service
Company of
New Mexico

Transmission

WECC-0126

Public Service
Company of
New Mexico

Vote

Comments

Created By

Yes

Laurie
Williams

Yes

Laurie
Williams

Yes

Laurie
Williams

Marketers and
Brokers

Yes

Laurie
Williams

WECC-0126

Public Utility
District No. 1
of Clark
County

Transmission

Yes

Jack Stamper

WECC-0126

Public Utility
District No. 1
of Snohomish
County

Generation

Yes

Franklin Lu

WECC-0126

Public Utility
District No. 1
of Snohomish
County

Distribution

Yes

Franklin Lu

WECC-0126

Public Utility
District No. 1
of Snohomish
County

Transmission

Yes

Franklin Lu

WECC-0126

Public Utility
District No. 1
of Snohomish
County

Marketers and
Brokers

Yes

Franklin Lu

WECC-0126

Public Utility
District No. 2
of Grant
County

System
Coordination

Yes

LeRoy
Patterson

E S T E R N

Generation

Distribution

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Document Title

Title

Company

WECC-0126

Public Utility
District No. 2
of Grant
County

WECC-0126

Public Utility
District No. 2
of Grant
County

WECC-0126

Public Utility
District No. 2
of Grant
County

Transmission

WECC-0126

Public Utility
District No. 2
of Grant
County

Marketers and
Brokers

WECC-0126

Puget Sound
Energy, Inc.

WECC-0126

Puget Sound
Energy, Inc.

Distribution

WECC-0126

Puget Sound
Energy, Inc.

System
Coordination

WECC-0126

Puget Sound
Energy, Inc.

Marketers and
Brokers

Lynda Kupfer

WECC-0126

Puget Sound
Energy, Inc.

Generation

Eleanor Ewry

WECC-0126

Sacramento
Municipal
Utility District

System
Coordination

Yes

Joe Tarantino

WECC-0126

Sacramento
Municipal
Utility District

Generation

Yes

Joe Tarantino

WECC-0126

Sacramento
Municipal
Utility District

Distribution

Yes

Joe Tarantino

E S T E R N

Sector

Generation

Distribution

Transmission

L E C T R I C I T Y

Vote

Comments

Created By

Yes

LeRoy
Patterson

Yes

LeRoy
Patterson

Yes

LeRoy
Patterson

Yes

LeRoy
Patterson

Yes

Theresa
Rakowsky

Yes

Theresa
Rakowsky

Yes

Theresa
Rakowsky

O O R D I N A T I N G

O U N C I L

Document Title

Title

Company

Sector

Vote

WECC-0126

Sacramento
Municipal
Utility District

Transmission

Yes

Joe Tarantino

WECC-0126

Sacramento
Municipal
Utility District

Marketers and
Brokers

Yes

Joe Tarantino

WECC-0126

Salt River
Project

Generation

Yes

Kevin Nielsen

WECC-0126

Salt River
Project

Distribution

Yes

Rudy Navarro

WECC-0126

San Diego Gas
& Electric

Transmission

Yes

Martine Blair

WECC-0126

San Diego Gas
& Electric

Distribution

Yes

ANNIE RUIZ

WECC-0126

San Diego Gas
& Electric

Generation

Yes

Jerome
Gobby

WECC-0126

San Diego Gas
& Electric

System
Coordination

Yes

Bridget Silvia

WECC-0126

Seattle City
Light

Transmission

Yes

Hao Li

WECC-0126

Seattle City
Light

Distribution

Yes

Tuan Tran

WECC-0126

Seattle City
Light

System
Coordination

Yes

Pawel Krupa

WECC-0126

Seattle City
Light

Marketers and
Brokers

Yes

Charles
Freeman

WECC-0126

Seattle City
Light

Generation

Mike Haynes

WECC-0126

Southern
California
Edison
Company

Generation

Thomas
Rafferty

E S T E R N

L E C T R I C I T Y

Comments

Created By

Yes

O O R D I N A T I N G

O U N C I L

Document Title

Title

Company

Sector

Vote

Comments

Created By

WECC-0126

Southern
California
Edison
Company

Distribution

Yes

Steven Mavis

WECC-0126

Southern
California
Edison
Company

Transmission

Yes

Steven Mavis

WECC-0126

Southern
California
Edison
Company

System
Coordination

Yes

Romel
Aquino

WECC-0126

Tacoma Power Distribution

Yes

Chad Edinger

WECC-0126

System
Tacoma Power Coordination

Yes

Chad Edinger

Yes

Joseph
Wilson

WECC-0126

Tacoma Power Transmission

WECC-0126

Marketers and
Tacoma Power Brokers

WECC-0126

Tri-State
Generation &
Transmission Reliability

Distribution

Yes

Janelle Gill

WECC-0126

Tri-State
Generation &
Transmission Reliability

System
Coordination

Yes

Tracy Sliman

WECC-0126

Tri-State
Generation &
Transmission Reliability

Transmission

Yes

Tracy Sliman

WECC-0126

Tri-State
Generation &
Transmission Reliability

Generation

E S T E R N

L E C T R I C I T Y

Todd Lloyd

Mark Stein

O O R D I N A T I N G

O U N C I L

Document Title

Title

Company

Sector

Vote

WECC-0126

Tucson
Electric Power

System
Coordination

Yes

John Tolo

WECC-0126

Tucson
Electric Power

Generation

Yes

John Tolo

WECC-0126

Tucson
Electric Power

Distribution

Yes

John Tolo

WECC-0126

Tucson
Electric Power

Transmission

Yes

John Tolo

WECC-0126

Western Area
Power
System
Administration Coordination

Yes

Patrick
Harwood

WECC-0126

Western Area
Power
Administration Transmission

Yes

Patrick
Harwood

WECC-0126

Western Area
Power
Administration
- Rocky
Mountain
Region
Transmission

Yes

James
Hirning

WECC-0126

Western Area
Power
Administration
- Upper Great System
Plains Region
Coordination

WECC-0126

Western Area
Power
Administration
- Upper Great
Plains Region
Transmission

E S T E R N

L E C T R I C I T Y

Comments

Created By

NERC Standards should
suffice.

Lloyd Linke

NERC Standards should
suffice.

Lloyd Linke

O O R D I N A T I N G

O U N C I L

Attachment I
Final Ballot Results
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Request to Retire
Ballot Name:

WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
After completing a routine five-year review, the drafting team concluded that
the substance of PRC-004-WECC-2 should be retired immediately because the
reliability-related substance is addressed in peripheral NERC Standards.

Ballot Pool Open:
Ballot Pool Closed:
Ballot Opened:
Ballot Closed:
Total Ballot Pool:
Total Votes:
Quorum:
Weighted Votes:
Ballot Results:

07/11/2017
07/26/2017
08/09/2017
08/28/2017
101
90
89.1%
98.2%
Pass

Total
In
Ballot
Pool

Votes
NonAbstain

Sector
Weight

Yes
Votes

Weighted
Segment
Vote

No
Votes

Abstain

Total
Votes for
Quorum

100.0%

0.1

10.0%

Generation

100.0%

Marketers and
Brokers

100.0%

Other NonRegistered
WECC
Members and
Participating
Stakeholders

0.0%

Voting Sectors
Distribution
End User
Representative

Didn't
Vote

WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114

WECC-0126 PRC-004-WECC-2: Protection System and RAS Misoperation

Total
In
Ballot
Pool

Votes
NonAbstain

Sector
Weight

Yes
Votes

Weighted
Segment
Vote

No
Votes

Abstain

Total
Votes for
Quorum

0.0%

System
Coordination

95.0%

Transmission

95.7%

Voting Sectors
State and
Provincial
Representatives

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

Didn't
Vote

O U N C I L

Attachment J
Minority Issues
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Request to Retire
Following a ballot period from August 9 through August 28, 2017, the WECC Ballot Pool approved
retirement of WECC-0126 PRC-004-WECC-2, Protection System and Remedial Action Scheme
Misoperation.
The project was posted for comment on one occasion. The drafting team reviewed and considered all
comments received. No minority views were expressed from the posting.
A single negative vote was cast during balloting. That vote was supported with the following
statement: “NERC Standards should suffice.” Since the ballot proposed retirement of the standard, the
comment included with the negative vote seem to support retirement of the standard.
During the NERC 45-day posting there were no minority views expressed.

WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114

Attachment K
WECC Standards Committee Members
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Request to Retire
The following individuals are those assigned to the WECC Standards Committee as of September 1, 2017.
Sector

Name

Organization

1 Transmission

Dana Cabbell

Southern California Edison

2 Generation

Gary Nolan

Arizona Public Service Company

3 Marketers and Brokers

Tanner Brier

Bonneville Power Administration

4 Distribution

Warren Rust

Colorado Springs Utilities

5 System Coordination

Joseph Tarantino

Sacramento Muni. Utility District

6 End User Representative

Caitlin Liotiris

Utah Assoc. of Energy Users

7 State and Provincial

Vacant

8 Other Non-Registered Entities

Crystal Musselman

Proven Compliance Solutions

Board of Directors

Joe McArthur

Non-Affiliate Director / WSC Chair

WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114

Attachment L1
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Response to Comments / Posting 1
April 6 through May 22, 2017
Posting 1
The WECC-0126, PRC-004-WECC-2, Protection System and Remedial Action Scheme Misoperation
Drafting Team (DT) thanks everyone who submitted comments on the proposed document.

Posting
This project was posted for a 45-day public comment period from April 6 through May 22, 2017.
WECC distributed the notice for the posting on April 4, 2017. The DT asked stakeholders to provide
feedback on the proposed document through a standardized electronic template. WECC received four
comments on this posting.

Location of Comments
All comments received on the project can be viewed in their original format on the WECC-0126 project
page under the “Submit and Review Comments” accordion.

Changes in Response to Comment
In response to comments received, the WECC-0126 drafting team made no further substantive changes. All
respondents concurred with the DT that the document should be retired.

Minority View
There is no minority view.

Effective Date
The WECC-0126 drafting team is recommending immediate retirement of the Regional Reliability
Standard because the reliability-related substance is addressed in peripheral NERC Standards. The DT
does not believe any further actions are necessary to implement the proposed change.
The proposed Effective Date for the project is immediately on receipt of applicable regulatory
approval.

Justification
See above.

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Attachment L1
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Response to Comments / Posting 1
April 6 through May 22, 2017
Action Plan
On May 24, 2017, the WECC-0126 PRC-004-WECC-2 Protection System and Remedial Action Scheme
Misoperation Drafting Team agreed to forward the project to the WECC Standards Committee (WSC)
with a request for ballot.
No further postings are anticipated.

Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC
Consultant, at (503) 307-5782. In addition, there is a WECC Reliability Standards Appeals Process.

Commenter
1 Pjoy Chua

Organization
Los Angeles Department of Water and Power (LADWP)

2
3
4

Laura Nelson
Kenneth Silver
William Franklin

Idaho Power
Los Angeles Department of Water and Power (LADWP)
Public Service Company of Colorado (PSCO)

Michelle Amarantos

Arizona Public Service Company (APS)

WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114

Report Form for WECC-0126

Index to Questions, Comments, and Responses
Question
1. The Drafting Team welcomes comments on all aspects of the document.

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Report Form for WECC-0126
1. The Drafting Team welcomes comments on all aspects of the document.
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment
LADWP ((1) Chua and (3) Silver)

Response
LADWP [agrees] the substance of PRC-004-WECC2 should be retired.

The DT appreciates LADWP’s continued involvement in the standards development process.
Idaho Power

Idaho Power agrees with the recommendation for
retirement of PRC-004-WECC-2.

The DT appreciates Idaho Power’s continued involvement in the standards development
process.
PSCo

PSCo supports retirement of the PRC-004-WECC-2
standard and supports the work of the drafting
team.

The DT appreciates PSCo’s continued involvement in the standards development process.
APS

APS supports the Drafting Team’s
recommendation to retire PRC-004-WECC-[2].

The DT appreciates APS’ continued involvement in the standards development process.

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Attachment L2
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
NERC Response to Comments / Posting 1
November 3 through December 18, 2017
Posting 1
The WECC-0126 PRC-004-WECC-2, Protection System and Remedial Action Scheme Misoperation (DT)
thanks everyone who submitted comments on the proposed project.
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 four 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-0126 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. After completing its review, the DT recommends
that the substance of PRC-004-WECC-2 should be retired immediately and in its entirety because the
reliability-related substance is addressed in peripheral NERC Standards. The DT does not believe any
further actions are necessary to implement the proposed changes.
Action Plan
As of January 10, 2018, this project is awaiting filing at NERC.
WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114

Comment Report Form for WECC-0126
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.

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Comment Report Form for WECC-0126
WECC Standards Comment Table
Commenter
1 Aaron Cavanaugh
2 John Tolo

Organization
Bonneville Power Administration (BPA)
Tucson Electric Power Company (TEP)

Laurie Williams

Glen Farmer

PNM Resources - Public Service Company of New
Mexico (PNM)
Avista

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:

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Comment Report Form for WECC-0126
1. Response Summary
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment

Response

The WECC-0126 PRC-004-WECC-2, Protection System and Remedial Action Scheme Misoperation
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.

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Comment Report Form for WECC-0126
bar

Raw Data

Raw Data
provided by
NERC
Comment
Report
Project Name:

Regional Reliability Standard (WECC) | PRC-004-WECC-2
Retirement

Comment Period
Start Date:

11/3/2017

Comment Period End 12/18/2017
Date:
Associated Ballots:

There were 4 sets of responses, including comments from approximately 4
different people from approximately 4 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:

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Comment Report Form for WECC-0126
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 Segment(s) Region Group Group
Group
Group
Group
Name
Name Member
Member
Member Member
Name Organization Segment(s) 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:
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Laurie Williams - PNM Resources - Public Service Company of New Mexico 1,3
Answer

E S T E R N

Yes

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Comment Report Form for WECC-0126
Document Name
Comment

Likes

Dislikes

Response

Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Comment Report Form for WECC-0126
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:
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Laurie Williams - PNM Resources - Public Service Company of New Mexico 1,3
Answer

Yes

Document Name
Comment

Likes

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Comment Report Form for WECC-0126
Dislikes

Response

John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

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:
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Laurie Williams - PNM Resources - Public Service Company of New Mexico 1,3
Answer

E S T E R N

Yes

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Comment Report Form for WECC-0126
Document Name
Comment

Likes

Dislikes

Response

Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Comment Report Form for WECC-0126
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:
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Laurie Williams - PNM Resources - Public Service Company of New Mexico 1,3
Answer

Yes

Document Name
Comment

Likes

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Comment Report Form for WECC-0126
Dislikes

Response

John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

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:
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Laurie Williams - PNM Resources - Public Service Company of New Mexico 1,3
Answer

E S T E R N

Yes

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Comment Report Form for WECC-0126
Document Name
Comment

Likes

Dislikes

Response

Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Comment Report Form for WECC-0126

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

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 PRC-004-WECC-2 — Protection System and Remedial Action Scheme Misoperation

A. Introduction
1. Title:

Protection System and Remedial Action Scheme Misoperation

2. Number:

PRC-004-WECC-2

3. Purpose:

4. Applicability
4.1. Transmission Owners of selected WECC major transmission path facilities and RAS listed in
tables titled “Major WECC Transfer Paths in the Bulk Electric System” provided at
https://www.wecc.biz/Reliability/TableMajorPaths4-28-08.pdf and “Major WECC Remedial
Action Schemes (RAS)” provided at https://www.wecc.biz/Reliability/TableMajorRAS4-2808.pdf.
4.2. Generator Owners that own RAS listed in the Table titled “Major WECC Remedial Action
Schemes (RAS)” provided at https://wecc.biz/Reliability/TableMajorRAS4-28-08.pdf..
4.3. Transmission Operators that operate major transmission path facilities and RAS listed in
Tables titled “Major WECC Transfer Paths in the Bulk Electric System” provided at
https://www.wecc.biz/Reliability/TableMajorPaths4-28-08.pdf and “Major WECC Remedial
Action Schemes (RAS)” provided at https://www.wecc.biz/Reliability/TableMajorRAS4-2808.pdf.
5. Effective Date: See Implementation Plan for the Revised Definition of “Remedial Action
Scheme”
B. Requirements
The requirements below only apply to the major transmission paths facilities and RAS listed in the
tables titled “Major WECC Transfer Paths in the Bulk Electric System” and “Major WECC
Remedial Action Schemes (RAS).”
R.1. System Operators and System Protection personnel of the Transmission Owners and
Generator Owners shall analyze all Protection System and RAS operations. [Violation Risk
Factor: Lower] [Time Horizon: Operations Assessment]
R1.1.

System Operators shall review all tripping of transmission elements and RAS
operations to identify apparent Misoperations within 24 hours.

R1.2.

WECC Standard PRC-004-WECC-2 — Protection System and Remedial Action Scheme Misoperation

R2.3.

R2.4.

Identification of a Misoperation of a Protection System and/or RAS,

R3.2.

Completion of repairs or the replacement of Protection System and/or RAS that
misoperated.
2

WECC Standard PRC-004-WECC-2 — Protection System and Remedial Action Scheme Misoperation

C. Measures
Each measure below applies directly to the requirement by number.
M1.

M2.

Transmission Owners and Generation Owners shall have evidence that they reported and
analyzed all Protection System and RAS operations.
M1.1

Transmission Owners and Generation Owners shall have evidence that System
Operating personnel reviewed all operations of Protection System and RAS
within 24 hours.

M1.2

Transmission Owners and Generation Owners shall have evidence that System
Protection personnel analyzed all operations of Protection System and RAS for
correctness within 20 business days.

Transmission Owners and Generation Owners shall have evidence for the following.
M2.1

M2.2

M2.3

M2.4

M3.

Transmission Owners and Generation Owners shall have evidence that they reported the
following within 10 business days.
3

WECC Standard PRC-004-WECC-2 — Protection System and Remedial Action Scheme Misoperation

M3.1

Identification of all Protection System and RAS Misoperations and corrective
actions taken or planned.

M3.2

Completion of repair or replacement of Protection System and/or RAS that
misoperated.

D. Compliance
1. Compliance Monitoring Process
1.1

Compliance Monitoring Responsibility

1.2

1.3

The Performance-reset Period is one calendar month.

Data Retention
Reliability Coordinators, Transmission Owners, and Generation Owners shall keep
evidence for Measures M1 and M2 for five calendar years plus year to date.

1.4.

Additional Compliance Information
None.

WECC Standard PRC-004-WECC-2 — Protection System and Remedial Action Scheme Misoperation

2. Violation Severity Levels
R1
Lower

Moderate

High

Severe

System Operating personnel of
the Transmission Owner or
Generator Owner did not
review the Protection System
operation or RAS operation
within six business days.

System Protection
personnel of the
Transmission Owner or
Generator Owner did not
analyze the Protection
System operation or RAS
operation within 25
business days.

Lower

Moderate

High

Severe

The Transmission Owner and
Generator Owner did not
remove from service, repair,
or implement other
compliance measures for the
Protection System or RAS that
misoperated as required in less
than 24 hours but did perform
the requirements within 28
hours.

The Transmission Owner
and Generator Owner did
not perform the removal
from service, repair, or
implement other
compliance measures for
the Protection System or
RAS that misoperated as
required within 32 hours.

Lower

Moderate

High

Severe

The Transmission Operator
and Generator Owner did not
adjust generation to a reliable
operating level, adjust the
SOL and operate the facilities
within established limits or
implement other compliance
measures for the Protection
System or RAS that
misoperated as required in less
than 24 hours but did perform
the requirements within 28
hours.

The Transmission Operator
and Generator Owner did
not adjust generation to a
reliable operating level,
adjust the SOL and operate
the facilities within
established limits or
implement other compliance
measures for the Protection
System or RAS that
misoperated as required in
less than 28 hours but did
perform the requirements
within 32 hours.

The Transmission
Operator and Generator
Owner did not adjust
generation to a reliable
operating level, adjust the
SOL and operate the
facilities within
established limits or
implement other
compliance measures for
the Protection System or
RAS that misoperated as
required within 32 hours.

R2.1 and R2.2.1

R2.3

WECC Standard PRC-004-WECC-2 — Protection System and Remedial Action Scheme Misoperation

R2.2.2 and R2.4
Lower

Moderate

High

Severe

The Transmission Owner
and Generator Owner did
not perform the required
repairs, replacement, or
system operation
adjustments to comply
with the requirements
within 30 business days.

Lower

Moderate

High

Severe

The Transmission Owner
and Generator Owner did
not report the
Misoperation and
corrective actions taken or
planned to comply with
the requirements within
25 business days.

Lower

Moderate

High

Severe

The Transmission Owner and
Generator Owner did not
report the completion of repair
or replacement of Protection
System and/or RAS that
misoperated to comply with
the requirements within 15
business days of the
completion but did perform
the required activities within
20 business days.

The Transmission Owner
and Generator Owner did
not report the completion of
repair or replacement of
Protection System and/or
RAS that misoperated to
comply with the
requirements within 20
business days of the
completion but did perform
the required activities within
25 business days.

The Transmission Owner
and Generator Owner did
not report the completion
of repair or replacement
of Protection System
and/or RAS that
misoperated to comply
with the requirements
within 25 business days of
the completion.

R3.1

R3.2

WECC Standard PRC-004-WECC-2 — Protection System and Remedial Action Scheme Misoperation

Version History — Shows Approval History and Summary of Changes in the Action Field
Version
1

Date
April 16, 2008

April 21, 2011

2
2

Action
Permanent Replacement Standard for
PRC-STD-001-1 and PRC-STD-003-1

Change Tracking

All links were updated in the
Applicability section of the standard
(4.1, 4.2 and 4.3)

Attachment F2
Technical Justification
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Request to Retire Regional Reliability Standard

Cover Sheet
Technical Justification
Retirement of WECC Regional Reliability Standard
PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation

155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114

Attachment F
Technical Justification
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
Request to Retire Regional Reliability Standard
Developed as: WECC-0126
Executive Summary
The WECC-0126 PRC-004-WECC-2 Standard Drafting Team (DT) reviewed NERC Standards, both in
effect and proposed for regulatory approval. The DT also considered the development history of PRC004-WECC-2 and its history of performance.
The following are the findings reached and conclusion, and the recommendation made by the DT.

Findings and Conclusion
The DT concluded that retirement of the standard can be made without incurring a negative impact on
reliability because:
1. The reliability concern for which the standard was drafted is now specifically covered in
FAC-003-4 Transmission Vegetation Management (enforceable October 1, 2016).
2. The Applicability section is overly narrow and included in other existing NERC Standards;
3. Requirement R1 is covered in other NERC Standards;
4. Requirement R2 is covered in other NERC Standards, conflicts with existing NERC Standards,
and its application can lessen reliability as opposed to enhancing it;
5. Requirement R3 is entirely administrative in nature and should be retired under FERC P81
criteria;
6. The language of the standard does not meet the FERC Order 672 criteria in that it fails to assign
the reliability task directly to an entity included in the NERC Functional Model.

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Background
In 1996, two system disturbances occurred within the Western Interconnection, on the same elements,
within a single 24-hour period, due to improper vegetation management. To prevent reoccurrence of
such a specific event, language was included in WECC’s Reliability Management System (RMS) requiring
that the relay or Remedial Action Scheme (RAS) that misoperated be removed from service or repaired
within 22 hours.1 2 The language was premised on the position that if the misoperation was analyzed
and promptly removed from service the system operators could remedy the cause before an iterative
misoperation took place.
By 2007, with the implementation of mandatory standards, WECC examined the RMS, identifying those
requirements it deemed essential for reliability, and translated those requirements into a language and
format acceptable to the North America Electricity Reliability Council (NERC) 3 and the Federal Energy
Regulatory Commission (FERC). That translation resulted in WECC Standard PRC-STD-003-1, Protective
Relay and Remedial Action Scheme Misoperation and PRC-STD-001-1, Certification of Protective Relay
Applications and Settings.4
As the mandatory scheme evolved, two things occurred. First, NERC/FERC identified drafting and
format concerns in those two standards and instructed WECC to redraft them accordingly. The result
was that the current PRC-004-WECC-1 (inactive March 31, 2017) was replaced by PRC-004-WECC-2
(United States Enforcement Date April 1, 2017) to accommodate changes in the NERC Glossary of
Terms Used in NERC Reliability Standards (Glossary).5 6 The second was the introduction of the

The Reliability Management System (AKA: Western Electricity Coordinating Council, FERC Electric Tariff, First Revised
Volume No. 1, Original Sheet Number 1) was the precursor to the NERC Mandatory Standards within the Western
Interconnection. The Transfer Path Table and the Remedial Action Scheme table were originally developed as part of the
RMS. The 22-hour period was memorialized in the RMS: I. Protective Relay and Remedial Action Scheme Misoperation; 2.
WSCC Criterion, Section a. For more detail refer to Compliance Filing of WECC in Response to Order Numbers 751 and 752
on Version One Regional Reliability Standards. RM09-09-000.
2

Currently known as the North American Electricity Reliability Corporation. (Emphasis added.)

135 FERC ¶ 61,061; United States of America Federal Energy Regulatory Commission, 18 CFR Part 40, Docket No. RM09-9000; Order No. 751, Version One Regional Reliability Standards for Facilities Design, Connections, and Maintenance;
Protection and Control; and Voltage and Reactive (Issued April 21, 2011), para. 34. FERC Order issued approving PRC-004WECC-1 (approval effective June 27, 2011).
5

In the Glossary of Terms Used in NERC Reliability Standards, Protection Systems are not the same as Special Protection
Systems (SPS). An SPS is synonymous with a RAS per that glossary.
6

FN31 NERC RAS Petition at 1-2. NERC requested approval of the following Reliability Standards to incorporate the
proposed definition of Remedial Action Scheme and eliminate use of the term Special Protection System: i.e., PRC-004WECC-2.

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Facilities Design, Connection and Maintenance (FAC) standards designed, among other things, to
address the specific type of vegetation management concerns that caused the 1996 disturbances.
In the 20 years since the precipitating events, the remedy for those events shifted to the vegetation
management standards of the NERC FAC suite and the remaining language pertinent to Protection
Systems (PS), Special Protection Schemes (SPS), and Remedial Action Schemes (RAS) shifted to other
NERC PRC Standards.7

Applicability – Scope
The narrow scope of the PRC-004-WECC-2 Applicability section should be retired in favor of the
broader Applicability section of other NERC Standards. Whereas PRC-004-WECC-2 only applies to
specific RAS and PS included in defined tables, other NERC Standards address the same analysis
without limiting the analysis to RAS and PS contained in the specified tables.

153 FERC ¶ 61,228; United States of America Federal Energy Regulatory Commission, 18 CFR Part 40, Docket Nos. RM15-7000, RM15-12-000, and RM15-13-000, Order No. 818, Revisions to Emergency Operations Reliability Standards; Revisions to
Undervoltage Load Shedding Reliability Standards; Revisions to the Definition of “Remedial Action Scheme” and Related
Reliability Standards, (Issued November 19, 2015)
7

This project is part of WECC’s commitment to harmonize PRC-004-WECC-2 with NERC Standards addressing RAS and PS
per PRC-004-4(i), 5 Background, page 2.
8

FAC-003-4, Transmission Vegetation Management, Section 6. Background. See also: “Consideration of Actual Field
Conditions in Determination of Facility Ratings”.

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The Applicability of the PRC-004-WECC-2 reads as follows:

4. Applicability
4.1.

4.2.
4.3.

Although the requirements of PRC-004-WECC-2 address both RAS and PS, the existing NERC Standards
address these two topics in separate standards.
PRC-016-1 Remedial Action Scheme Misoperations, Requirement R1 requires any Transmission Owner
(TO), Generator Owner (GO), and Distribution Provider (DP) owning a RAS to “. . .analyze its RAS
operations and maintain a record of all misoperations. . .” in accordance with the regional procedures.
Since all RAS must be examined under PRC-016-1, there is no reason to retain PRC-004-WECC-2 which
only applies to a specific and limited subset of WECC RAS. Review of all RAS under PRC-016-1 subsumes
the subset of RAS targeted in PRC-004-WECC-2. So, the specificity of the PRC-004-WECC-2 Applicability
section is a lesser included subset of PRC-016-1 (effective date April 1, 2017) making PRC-004-WECC-2
redundant.
In like fashion, PRC-004-4(i) Protection System Misoperation Identification and Correction, requires all
TOs, GOs, and DPs to review all PS operations on the BES to: 1) identify those that are Misoperations of
PS; 2) analyze Misoperations of PS; and 3) develop and implement Corrective Action Plans (CAP) to
address the cause(s) of Misoperation.9 Thus, the specificity of the PRC-004-WECC-2 Applicability
section is a lesser included subset of PRC-004-4(i) making PRC-004-WECC-2 redundant.

Applicability – Failure to Meet Order 672 Criteria
Although the Applicability section accurately identifies the correct NERC Functional Entities, the
Requirements do not assign tasks to those entities.
Rather than assigning the reliability task to the TO or GO, R1 assigns its task to “System Operators and
System Protection personnel of the Transmission Owners and Generator Owners.” R1 does not directly
assign a reliability task to any applicable entity listed in the NERC Functional Model. As such, it falls
9

PRC-004-4(i) Protection System Misoperation Identification and Correction, 5. Background, page 2.

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short of the FERC Order 672 mandate that a Reliability Standard impose a requirement only on a user,
owner, or operator of facilities associated with the Bulk-Power System (BES).10 Presuming the
requirement could be interpreted to apply to the TO and GO directly, R1 imposes a duty to “analyze all
Protection System and RAS operations.”11 Because these tasks are covered in other NERC Standards
(see following analysis) there is no need to retain the requirement nor try to sort out which NERC
Functional Model entity the original draft intended.

Retirement of Requirement R1
The entirety of Requirement R1 should be retired because it is redundant to other NERC Standards.
The text of Requirement R1 is as follows:

Covered Elsewhere
Unlike PRC-004-WECC-2 that sweeps in both PS and RAS, in the NERC Standards these two
classifications of devices are addressed in separate standards.
As for PS, existing NERC Standards include and go beyond a mandate for analysis. TOs and Generator
Operators (GOP) are required to be familiar with the purpose and limitations of their PS schemes and
take corrective actions as soon as possible – not just analyze the problem.12 Entities must maintain and

The proposed Reliability Standard may impose a requirement on any user, owner, or operator of such facilities, but no on
other. Order 672 at P. 322.
11

In the Glossary of Terms Used in NERC Reliability Standards, Protection Systems are not the same as Special Protection
Systems (SPS). An SPS is synonymous with a RAS per that glossary; an SPS is not the same as a Protection System.
12

PRC-001-1.1(ii) System Protection Coordination, Requirements R1 and R2.

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test their PS, and demonstrate efforts to correct identified Unresolved Maintenance Issues. 13
Monitoring and situational awareness are also required14. Finally, TOs and GOs are required to correct
identified and unresolved maintenance Issues.15 These combined NERC Standards meet and exceed the
reliability concerns of Requirement R1 regarding PS.
As for RAS, PRC-004-4 not only calls for analysis it also requires coordination with other entities,
notification of events and findings, and most importantly that corrective actions be planned and
implemented. Elsewhere, applicable entities that own a RAS are required to analyze RAS operation and
misoperation, take corrective actions to ensure misoperation does not reoccur, and to provide
documentation of its activities upon request from the Regional Reliability Organization (RRO). 16 PRC016-1 Remedial Action Scheme Misoperation calls for the inclusion of specific detail in its reports
exceeding the requirement of PRC-004-WECC-2. Further, PRC-017-1 Special Protection System
Maintenance and Testing requires the TO and GO to have a system maintenance and testing program
(to include specific characteristics), and to provide supporting documentation to the RRO on request.
These combined NERC Standards meet and exceed the reliability concerns of PRC-004-WECC-2
Requirement R1 regarding RAS.
Finally, even in the absence of the continent-wide PRC suite, TPL/TOP standards would require
essential analysis and remedial action so long as a facility continues in service with a single PS or RAS.
In many cases, this occurs in less than the 20-day window prescribed in PRC-004-WECC-2 and focuses
on results as opposed to a perfunctory task.17
The continent-wide TPL/TOP standards require time frames to take action that range from as quickly as
possible out to as much as day-ahead planning. So long as a facility continues in service with a single PS
or RAS, the TOP is required by the TOP standards to evaluate the system impacts for that configuration

PRC-005-6 – Protection System, Automatic Reclosing, and Sudden Pressure Relaying Maintenance.

PRC-001-1.1(ii) — System Protection Coordination; TOP-003-3, Operational Reliability Data, R1, part 1.2

PRC-005-6 – Protection System, Automatic Reclosing, and Sudden Pressure Relaying Maintenance, Requirement R5.

PRC-016-1 — Remedial Action Scheme Misoperation; (United States Enforcement Date April 1, 2017)

TPL-001-4 — Transmission System Planning Performance Requirements, focuses on system performance rather than the
method of achieving that performance.
TOP-002-2.1b — Normal Operations Planning, R6 focuses on a different aspect of system performance by analyzing the
system at a minimum of the next N-1 Contingency planning.
TOP-004-2 — Transmission Operations, requires that TOPs operate to maintain reliability following occurrence of their most
severe single contingency and (R3) for any multiple contingencies identified by their RC. These contingencies exclude any
facilities that are already out-of-service (either forced or planned).
TOP-006-3 — Monitoring System Conditions, R3 requires that the RC, TOP, and Balancing Authority “shall provide its
operating personnel with appropriate technical information concerning protective relays within” their areas of
responsibility.
TOP-008-1 — Response to Transmission Limit Violations, R2 requires the TOP “operate to prevent the likelihood that a
disturbance, action or inaction will result in an IROL or SOL violation …” which reinforces the TPL-004-2 R2 requirement.

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at least every day and to take further action if required by the actual circumstances. These TOP time
restrictions are much more rigorous than the WECC 20 business days.18
Because the reliability content of PRC-004-WECC-2 Requirement R1 is covered in other existing NERC
Standards, Requirement R1 can be retired without incurring any negative impact on reliability.
Illusory Time Windows – 20 Business Days
In Requirement R1.2, the 20-day review period has its origins in compliance and not in reliability.
Therefore, it is not essential for reliability.
When the predecessors of PRC-004-WECC-2 were developed (circa 1995-2000), the WECC Relay Work
Group identified the duration of the window (20 business days) to measure performance, not as a time
window essential for reliability.19 Meeting minutes from the WECC Relay Work Group establish the first
draft of what would later be called a Violation Severity Level (VSL) wherein the 20-business-day
window was included in a Level 3 and Level 4 VSL.
The definition of the window (20 business days) makes its regulatory debut in the RMS20 where is it
used as a defined term. A Business Day is defined as “any day other than Saturday, Sunday, or a legal
public holiday as designated in section 6103, of title 5 US Code.” If the 20-business day window was
reliability in nature it would not be predicated on weekends and holidays.
To the extent that any level of reliability now attaches to the 20-day window, other NERC Standards
impute a shorter time window for remedial action thereby rendering the 20-day window moot. As
presented, the review of numerous other NERC Standards shows that operational review of the system
is required to take place much sooner than 20 days.21 Thus, the duration and definition of the time
window are irrelevant to reliability and can be retired without detriment to the system.

Retirement of Requirement R2
The entirety of Requirement R2 should be retired because it is redundant to other NERC Standards.
The text of Requirement R2 is as follows:

B. Requirements
R.2.

Transmission Owners and Generator Owners shall perform the following actions for each
Misoperation of the Protection System or RAS. It is not intended that Requirements R2.1

IRO-001.1 R3, requires action within 30 minutes. TOP-008 R2, as noted, primarily reinforces TOP-004 R2, basically saying
that the TOP is covered within the IRO timing requirement.
19

WECC Relay Work Group Meeting Minutes, July 20, 2000.

Reliability Management System, I. Protection Relay and Remedial Action Scheme Misoperation, Section 2.d.

TOP-002-2.1b Normal Operations Planning, Requirement R6 requires a minimum of N-1 Contingency planning to meet
unscheduled changes in system configuration and generation dispatch.

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through R2.4 apply to Protection System and/or RAS actions that appear to be entirely
reasonable and correct at the time of occurrence and associated system performance is fully
compliant with NERC Reliability Standards. If the Transmission Owner or Generator Owner later
finds the Protection System or RAS operation to be incorrect through System Protection
personnel analysis, the requirements of R2.1 through R2.4 become applicable at the time the
Transmission Owner or Generator Owner identifies the Misoperation:
R2.1. If the Protection System or RAS has a Security-Based Misoperation and two or more
Functionally Equivalent Protection Systems (FEPS) or Functionally Equivalent RAS
(FERAS) remain in service to ensure Bulk Electric System (BES) reliability, the
Transmission Owners or Generator Owners shall remove from service the Protection
System or RAS that misoperated within 22 hours following identification of the
Misoperation. Repair or replacement of the failed Protection System or RAS is at the
Transmission Owners’ and Generator Owners’ discretion. [Violation Risk Factor: High]
[Time Horizon: Same-day Operations]
R2.2. If the Protection System or RAS has a Security-Based Misoperation and only one FEPS or
FERAS remains in service to ensure BES reliability, the Transmission Owner or Generator
Owner shall perform the following. [Violation Risk Factor: High] [Time Horizon: Sameday Operations]
R2.2.1. Following identification of the Protection System or RAS Misoperation,
Transmission Owners and Generator Owners shall remove from service within 22
hours for repair or modification the Protection System or RAS that misoperated.
R2.2.2. The Transmission Owner or Generator Owner shall repair or replace any
Protection System or RAS that misoperated with a FEPS or FERAS within 20
business days of the date of removal. The Transmission Owner or Generator
Owner shall remove the Element from service or disable the RAS if repair or
replacement is not completed within 20 business days.
R2.3. If the Protection System or RAS has a Security-Based or Dependability-Based
Misoperation and a FEPS and FERAS is not in service to ensure BES reliability,
Transmission Owners or Generator Owners shall repair and place back in service within
22 hours the Protection System or RAS that misoperated. If this cannot be done, then
Transmission Owners and Generator Owners shall perform the following. [Violation Risk
Factor: High] [Time Horizon: Same-day Operations]
R2.3.1. When a FEPS is not available, the Transmission Owners shall remove the
associated Element from service.
R2.3.2. When FERAS is not available, then
2.3.2.1. The Generator Owners shall adjust generation to a reliable operating
level, or

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2.3.2.2. Transmission Operators shall adjust the SOL and operate the facilities
within established limits.
R2.4. If the Protection System or RAS has a Dependability-Based Misoperation but has one or
more FEPS or FERAS that operated correctly, the associated Element or transmission
path may remain in service without removing from service the Protection System or RAS
that failed, provided one of the following is performed.
R2.4.1. Transmission Owners or Generator Owners shall repair or replace any Protection
System or RAS that misoperated with FEPS and FERAS within 20 business days of
the date of the Misoperation identification, or
R2.4.2. Transmission Owners or Generator Owners shall remove from service the
associated Element or RAS. [Violation Risk Factor: Lower] [Time Horizon:
Operations Assessment]
Retirement of Requirement R2
Requirement R2 is divided into two parts, one assigning tasks in the event of Security-Based
Misoperation and the other assigning tasks in the event of Dependability-based Misoperation.22 The
requirement to analyze each Misoperation attaches whenever the Misoperation is discovered
(identified).
If a PS or RAS Misoperation is Security-based, the PS or RAS shall be removed from service within 22
hours of the identification of the Misoperation. Whether the PS or RAS requires repair, removal,
replacement or modification is fact specific and subject to If/Then statements.
If the PS or RAS Misoperation is Dependability-based, but portions of the systems operated as
designed, the PS or RAS can remain in service so long as repair or replacement occurs within 20 days of
the identification of the Misoperation; otherwise, the PS or RAS must be removed from service.
Illusory Time Windows – 22 Hours
On the surface, the 22-hour remediation trigger of PRC-004-WECC-2, Requirement R2.2.1 is quite
attractive and perceptually creates a much higher performance threshold than its peripheral NERC
Standards.23 But when examined, the remedial clock does not begin to run until the Misoperation is
identified. In other words, there is no remediation required until the operation is identified. The system
operator may identify an apparent Misoperation (R1) within the coveted period (R2) and thereby meet

Security-based Misoperations and Dependability-based Misoperations are included in the WECC-specific section of the
Glossary of Terms Used in NERC Reliability Standards.
23
Since a real-time assessment of system performance is being conducted at least once every 30 minutes by the
Transmission Operator, the value of a review within 22 hours is diluted and somewhat redundant. TOP-001-3, Transmission
Operations, R13.

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the original intent to remediate the cause. However, the reality is that the identification will not likely
be determined by the Real-time system operator thus negating the assumed purpose of the 22 hours.
Rather, the higher likelihood is that the system operator may annotate an anomaly in the operations
log and pass the investigation on to protection engineers. After analysis and identification by the
protection engineer, only then would the tolling clock begin to run. So, it could be days or weeks
before the requirement to perform remediation attached. Even though the 22 hours appears to be a
higher standard, in practice it is illusory because it lacks a definitive start time.
Because the 22-hour window appears in the requirement, it is assumed that the original drafters
intended its inclusion for reliability purposes. However, a review of development record shows that the
22-hour time window did not appear in the requirement until drafted into the Reliability Management
System (RMS) agreement. Meeting minutes from a July 20, 2000 WECC Relay Work Group meeting
indicates that the 22-hour period was originally intended for inclusion in what would today be called a
Measure. The minutes indicate that:
“During the Phase 2 evaluation period the relay misoperation requirement was found to be too
loosely defined to enable the assessment of compliance on a consistent basis among all
affected parties, per the requirement, the clock starts as soon as it is determined that a relay
misoperated or probably misoperated. Making this determination could take days or weeks. It
was concluded that compliance with the requirement as originally worded is not measurable on
an accurate or consistent basis. Consequently, the Relay Work group in cooperation with the
WSCC staff developed revisions to the requirement that will enable a consistent and accurate
measure of performance to assess compliance the revised requirement is described in detail
below.” (Italic emphasis added.)
In fact, the intent of the reports is stated in the 1998 predecessor to the RMS in that:
“The transmission path operators for the paths listed in Table 2 are requested to submit data as
specified in detail within this section. For the purpose of maintaining historical records, and in
the event, some or all of the compliance data have to be reviewed to resolve questions that
may arise in the future, the Path Operators are requested to save the data, as defined below,
for at least a one-year period.”24 (Emphasis added.)
The language that found its way into the requirement section of the RMS was originally intended to
serve a compliance purpose. To the extent the 22-hour period may have evolved to address a reliability
task, that task (vegetation management) is now covered in the FAC suite. As such, the 22-hour time
frame can be deleted from the standard without impacting reliability.

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Requirement R2 Conflicts with other Standards / Lessens Reliability
PRC-004-WECC-2 Requirement R2 has a specified set of actions that must be taken once the
Misoperation is identified. Because the operator cannot deviate from the specific actions, all discretion
is removed. Therefore, R2 conflicts with other standards and lessens reliability.
Under the fact pattern identified in PRC-004-WECC-2 Requirement R2.1, the TO and GO “shall remove
from service” the PS or RAS that misoperated. The inflexible mandate leaves the TO/GO no operational
choice. By contrast, PRC-001-1.1(ii) System Protection Coordination, Requirement R2, part 2.1 and 2.2
require that “[if] a protective relay or equipment failure reduces system reliability” then corrective
action is to be taken as soon as possible.25 Likewise, PRC-016-1 Remedial Action Scheme
Misoperations, Requirement R2 allows the TO/GO owning a RAS to take “corrective actions to avoid
Misoperations.” Further, TOP-001-3 Transmission Operations, R1 requires the Transmission Operator
(TOP) to maintain the reliability of its Transmission Operator Area via its own actions (emphasis
added). The Balancing Authority (BA) has a similar mandate in R2 of that document.
To illustrate how retention of PRC-004-WECC-2 Requirement R2 can lessen reliability, the following fact
pattern is offered.
Example 1
A fault occurred on an important path line and the relays at both terminals operated correctly to clear
it. Different makes of reclosing relays are used at the two terminals, which did not allow the recloser
reset time to be set the same at both terminals. The terminal that normally recloses first had a longer
reset delay of 20 cycles (Terminal A), and the terminal that normally recloses after the other terminal
had a shorter reset delay of 15 cycles (Terminal B). A very unusual circumstance occurred when a
second fault occurred on the line after the time that the recloser at Terminal B had reset (15 cycles),
but before the recloser at the Terminal A had reset (20 cycles). Terminal A, therefore, tripped to
lockout after the second fault and did not reclose. Terminal B, which would normally reclose after
Terminal A, tripped for the second fault and then proceeded to reclose. Because this is a very long line,
the switch-onto-fault (SOTF) settings are set sensitively to provide instantaneous tripping for the entire
length of the line. When Terminal B reclosed, The SOTF elements tripped it open due to the line
charging current. It is important to recall that this terminal normally recloses after Terminal A, in which
case the voltage on the line would block the SOTF elements.
Because Terminal B tripped for no fault, it created a misoperation. Because both relays at Terminal B
behaved the same, they both misoperated. This would bring R2.3.1 into play, requiring the line to be
25

Under NERC Project 2007-06.2 Phase 2 of System Protection Coordination, PRC-001-1.1(ii) is proposed for retirement.
Should that occur, system awareness and corrective actions shifts to other applicable entities under numerous existing
NERC Standards. Please refer to that proceeding for a detailed analysis of which NERC Standards would cover the reliability
tasks of PRC-001-1(ii) in the event of retirement. Misoperations that have causes other than failure can be mitigated by
taking corrective action as soon as possible.

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removed from service if the applicable entity could not repair or replace the relays within 22 hours.
Given the large volume of operations that were occurring due to the poor weather, repairing the
problem within 22 hours was not easy. Taking the line out of service would have caused more
problems than it solved because it would have removed an important line during heavy transfer
conditions. With the poor weather that was occurring, other lines were also operating, and every
available line needed to be in service. This did not present a reliability concern since the relays were
only susceptible to Misoperation during a reclose during the very unlikely scenario of a second fault
occurring between 15 and 20 cycles after the first.
This practical example illustrates that PRC-004-WECC-2 Requirement R2 can force undesirable
consequences. Had consideration of all the surrounding circumstances been allowed, strict adherence
to PRC-004-WECC-2 Requirement R2 would not have been the best choice for reliability.
As seen in the example, PRC-004-WECC-2 mandates a specific action without regard to outcome. By
contrast, the alternate approach of PRC-001-1.1(ii) allows the TO/GO owning a RAS to take reasoned
action if the failure reduces reliability. Further, it allows that entity to consider all the surrounding
circumstances and act accordingly. Finally, if retained, PRC-004-WECC-2 could conflict with other
standards wherein applicable entities are provided flexibility to decide the most appropriate actions to
ensure reliability. As such, the alternate approach of PRC-001-1.1(ii) should be adopted over that of the
PRC-004-WECC-2.
Requirement R2 – Failure to Meet Order 672 Criteria
Pursuant to FERC Order 672, a 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.26 PRC-004-WECC-2, Requirement R2 falls
short of that requirement and should deleted.
Requirement R2.1 through R2.4 are not intended to apply to PS and/or RAS actions “that appear to be
entirely reasonable and correct” when “associated system performance is fully compliant with NERC
Reliability Standards.” What appears to be reasonable to one entity may not appear reasonable to the
next. In like fashion, what appears to be reasonable to one auditor may not be reasonable to the next.
What is reasonable is the sum of all the surrounding circumstances. These circumstances will vary each
time the standard is applied.
Because of the ever-changing fact patterns, neither the applicable entity nor the assigned auditor can
be soundly informed as to what action must be taken or what constitutes compliance until after a
violation may have occurred. Further, the language implies that what is reasonable equates to what is
the best course of action to ensure reliability. This is not always the case. As seen above, one may act
to remain perfectly in compliance but those actions may not be in the best interest of reliability.

FERC Order No. 672 at P 325.

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Finally, the requirement requires the applicable entity to stand as a proxy to the compliance auditor in
that it requires the applicable entity to know whether an act is “entirely reasonable and correct”
without further guidance. This is the standards equivalent of drafting a law requiring all vehicles to
stop close to the limit line – without indicating what constitutes close.
Although entities make every effort to remain in compliance, applicable entities are not auditors and
cannot make the definitive determination whether an act complies with a standard. As such, the
ambiguity of the wording robs the applicable entity of the notice required under due process. Thus,
Requirement R2 does not meet FERC’s Order 672 criteria and should be deleted.
Retirement of Requirement R3
The entirety of Requirement R3 should be retired because it is purely administrative in nature and
meets the “P81” criteria for retirement.
The text of Requirement R3 is as follows:
B. Requirements
R.3. Transmission Owners and Generation Owners shall submit Misoperation incident reports to
WECC within 10 business days for the following. [Violation Risk Factor: Lower] [Time Horizon:
Operations Assessment]
R3.1. Identification of a Misoperation of a Protection System and/or RAS,
R3.2. Completion of repairs or the replacement of Protection System and/or RAS that
misoperated.
Retirement of Requirement R3
The language of PRC-004-WECC-2 Requirement R3 can be retired without incurring any negative
impact to reliability because the Requirement is administrative in nature.
The purpose of PRC-004-WECC-2 is “to ensure all transmission and generation Protection System and
Remedial Action Scheme (RAS) Misoperations on Transmission Paths and RAS defined in section 4 are
analyzed and/or mitigated.”
Retirement of R3 would be consistent with FERC’s order27 approving NERC’s Compliance Enforcement
Initiative (“CEI”), including the Find, Fix, Track and Report (“FFT”) program. On March 15, 2012, FERC
issued an order28 approving NERC’s Compliance Enforcement Implementation (CEI), including the FFT
program. Paragraph 81 (“P 81”) of the FFT Order reads:
The Commission notes that NERC’s FFT initiative is predicated on the view that many violations
of requirements currently included in Reliability Standards pose lesser risk to the Bulk-Power
27

North American Electric Reliability Corporation, 138 FERC ¶ 61,193 at P 81 (2012) (“FFT Order”).

FFT Order at P 81.

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System. If so, some current requirements likely provide little protection for Bulk-Power System
reliability or may be redundant. The Commission is interested in obtaining views on whether
such requirements could be removed from the Reliability Standards with little effect on
reliability and an increase in efficiency of the ERO compliance program. If NERC believes that
specific Reliability Standards or specific requirements within certain Standards should be
revised or removed, we invite NERC to make specific proposals to the Commission identifying
the Standards or requirements and setting forth in detail the technical basis for its belief. In
addition, or in the alternative, we invite NERC, the Regional Entities and other interested
entities to propose appropriate mechanisms to identify and remove from the Commission
approved Reliability Standards unnecessary or redundant requirements. We will not impose a
deadline on when these comments should be submitted, but ask that to the extent such
comments are submitted NERC, the Regional Entities, and interested entities coordinate to
submit their respective comments concurrently.29
In keeping with the FFT approach, the WECC-0126 DT reviewed the standard to identify requirements
that could be removed from Reliability Standards without negatively impacting the reliability of the
Bulk-Power System. This project identified Requirement R3 as a candidate for retirement under that
criteria.
Requirement R3 P81 Justification
The language of R3 can be retired without incurring any negative impact to reliability because it is
purely administrative in nature. At its core, the requirement calls for the TO and GO to “submit
Misoperation incident reports to WECC” and to prove compliance by having “evidence that they
reported.”
In PRC-004-WECC-2, requiring documentation does not add to or detract from the reliability of the
grid; rather, having documentation is an element of verifying that a reliability task has been completed.
In application, the requirement looks backwards to ensure paperwork was filled out. As drafted, it
neither requires identification of a Misoperation nor remediation of failing elements associated with a
Misoperation. It only requires that a report be made. The Measure advances reliability no further as it
too requires only that a report be presented. As its core, the Measure doesn’t even specify the content
of the report – only that a report be made.30
Further, the implied reliability tasks of R3 are expressly addressed in peripheral NERC Standards. The
stated intent of the Requirement/Measure is to ensure that Misoperation of specific PS and RAS are
analyzed and mitigated. Although the standard under review addresses only specific PS and RAS, these

Joint Petition for Approval of Proposed Regional Reliability Standards, VAR-002-WECC-2 AND VAR-501-WECC-2, Section C.
Project 2013-02 Paragraph 81, page 6. (VAR Order)
30

If not retired, the language of each of the Measures should be redrafted to reflect “will have evidence” as opposed to the
requirement “shall have evidence.”

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specific systems would be included in the broader more general provisions of other existing NERC
Standards. (See Requirement R1 analysis.)
Finally, if the true intent of PRC-004-WECC-2 is to collect data, that data can be collected in accordance
with NERC’s Rules of Procedure via a Rule 1600 data request. In the alternative, specifically for RAS,
PRC-016-1 Requirement R3 requires the TO and GO owning a RAS to “provide documentation of the
misoperations analyses and the correction action plans to” WECC on request. As such, Requirement R3
is fully redundant and can be deleted.
Whereas Requirement R3 is administrative in nature, its implied and explicit reliability tasks are
covered in existing NERC Standards, and the described data collection can occur in accordance with
NERC Rules of Procedure 1600, Requirement R3 can be retired without incurring any negative impact
on reliability.

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Table A
NERC Standard / PRC-004-WECC-2 Cross-reference Table
The Purpose of PRC-004-WECC-2 is to serve as a “Regional Reliability Standard to ensure all
transmission and generation Protection System and Remedial Action Scheme (RAS) Misoperations on
Transmission Paths and RAS defined in section 4 are analyzed and/or mitigated”.
The requirements below only apply to the major transmission paths facilities and RAS listed in the
tables titled “Major WECC Transfer Paths in the Bulk Electric System” and “Major WECC Remedial
Action Schemes (RAS).”
The following table illustrates how each element of the PRC is either addressed elsewhere or simply
not needed for reliability.
Retirement of Regional Reliability Standard
PRC-004-WECC-1 Protection System and Remedial Action Scheme Misoperation
PRC-004-WECC-2
PRC-004-WECC-2
Description and Change Justification
Requirement in Approved Standard
Requirements covered elsewhere
Applicability
Applicability
(Narrow and exclusive)

(Broader and all-inclusive)

The Applicability section is narrowly
crafted to apply only to:

PRC-016-1 applies to TOs, GOs, and
Distribution Providers’ (DP) RAS
regardless of path.

1) Transmission Owners (TO) of
selected facilities with RAS
listed in a specific table;

PRC-004-4 applies to TOs, GOs, and
DPs’ PS regardless of path.

2) Generator Owners (GO) with
RAS listed in a specific table;
and,
3) Transmission Operators
operating facilities and RAS
listed in the specified table.
PRC-004-WECC-2

PRC-004-5(i)

Covers RAS plus PS

Covers PS.

R.1. System Operators and System
Protection personnel of the
Transmission Owners and Generator
Owners shall analyze all Protection
System and RAS operations.
[Violation Risk Factor: Lower] [Time
Horizon: Operations Assessment]

PRC-004-5(I) Protection System
Misoperation Identification and
Correction.

E S T E R N

R1. requires the TO and GO to
identify the reasons for PS
operation and whether the

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The difference in time frames
between PRC-004-WECC-2 and the
other NERC Standards is addressed in
the preceding sections of this filing.

R1. The TO and GO…shall
analyze…its RAS operations and
maintain a record of all
misoperations in accordance with
the Regional RAS review procedure
specified in PRC-012. R1.32
PRC-012-2, Remedial Action
Schemes33
R5. Requires the TO and GO to
review its RAS within 120 days of
operation or failure. (The term
analyze is used in R5.2.)34
PRC-004-WECC-2

PRC-012-2
Covering RAS

R1.1 System Operators shall review
all tripping of transmission elements
and RAS operations to identify
apparent Misoperations within 24
hours.

R5. Requires the TO and GO to
analyze each RAS operation, within
120 days, to determine: 1) 5.1.1,
what caused the operation, 2) 5.1.2
and 5.1.3, if the device worked
properly, and 3) 5.1.4., whether

The language of PRC-004-WECC-2
fails to meet the FERC Order 672
criteria for clarity in that “apparent,”
“reasonable,” characterization” and
“correctness” are ambiguous.

United States Enforcement Date is April 2, 2017.

Becomes Inactive on March 31, 2017.

PRC-012-2 has been filed with FERC and is pending regulatory disposition as of March 29, 2017.

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Retirement of Regional Reliability Standard
PRC-004-WECC-1 Protection System and Remedial Action Scheme Misoperation
PRC-004-WECC-2
PRC-004-WECC-2
Description and Change Justification
Requirement in Approved Standard
Requirements covered elsewhere
there were any unintended
Both PRC-012-2 and PRC-004-5(i)
R1.2. System Protection
consequences.
require review after operation to
personnel shall analyze all
determine the cause, and in some
PRC-004-5(i)
operations of Protection Systems
cases, even determine whether
Covers PS
and RAS within 20 business days for
unforeseen consequences resulted.
PRC-004-5(i), R1. Requires the TO
correctness to characterize whether
Although the more specific analysis is
and GO owning a PS that operates,
a Misoperation has occurred that
arguably included in the more
to identify whether that PS caused
may not have been identified by
general PRC-004-WECC-2 analysis,
a Misoperation, within 120 days of
System Operators.
adoption of the superior PRC-012-2
the event the threshold analysis,
and PRC-004-5(i) requirements add
the applicable entity is required to
clarity and conformity without
determine: 1) R1.1, if the PS was
sacrificing reliability. As such, analysis
the cause of the Misoperation, 2)
of both RAS and PS operation is
R1.2, who owns the components,
covered in greater detail outside of
and 3) R1.3 whether the operation
PRC-004-WECC-2 making PRC-004was automatic or manual.
WECC-2 redundant. Its retirement
would have no negative impact on
reliability because the tasks are
covered elsewhere.
See above analysis pertaining to 22hours, and 20 days for time window
differential.

2000-07-20-RWG-M
eeting.pdf

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Covers PS

R.2. Transmission Owners and
Generator Owners shall perform the
following actions for each
Misoperation of the Protection
System or RAS.

PRC-016-1 — Remedial Action
Scheme Misoperations

It is not intended that Requirements
R2.1 through R2.4 apply to
Protection System and/or RAS
actions that appear to be entirely
reasonable and correct at the time
of occurrence and associated system
performance is fully compliant with
NERC Reliability Standards. If the
Transmission Owner or Generator
Owner later finds the Protection
System or RAS operation to be
incorrect through System Protection
personnel analysis, the
requirements of R2.1 through R2.4
become applicable at the time the
Transmission Owner or Generator
Owner identifies the Misoperation:

PRC-012-2

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R2. Each TO, GO, and DP, owing a
RAS shall take corrective actions to
avoid future misoperations.

Whereas the reliability tasks of PRC004-WECC-2 Requirement R2 are
included in PRC-016-1 and PRC-0122, PRC-004-WECC-2 Requirement R2
is redundant and can be retired.

Covers RAS
R5. Each RAS-entity, within 120 full
calendar days of a RAS operation or
a failure of its RAS to operate when
expected, or on a mutually agreed
upon schedule with its reviewing
Reliability Coordinator(s), shall
analyze and communicate RAS
performance.
PRC-012-2, Requirements R6 and
R7 further cover RAS
Requirement R6 requires the TO,
GO, and DP develop and submit a
Corrective Action Plan (CAP) to the
Reliability Coordinator within six
months of: 1) notification of a RAS
deficiency (see R4 and R5), or
identifying a deficiency while
performing a functional test (R8).
PRC-001-1.1(ii)

PRC-001-1.1(ii)

R2. Each Generator Operator and
Transmission Operator shall notify
reliability entities of relay or
equipment failures as follows:

R2.1. If a protective relay or
equipment failure reduces system
reliability, the Generator Operator

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Retirement of Regional Reliability Standard
PRC-004-WECC-1 Protection System and Remedial Action Scheme Misoperation
PRC-004-WECC-2
PRC-004-WECC-2
Description and Change Justification
Requirement in Approved Standard
Requirements covered elsewhere
System (BES) reliability, the
shall notify its Transmission
appropriate action based on all the
Transmission Owners or Generator
Operator and Host Balancing
surrounding circumstances. Those
Owners shall remove from service
Authority. The Generator Operator actions may or may not include the
the Protection System or RAS that
shall take corrective action as soon specified tasks included in PRC-004misoperated within 22 hours
as possible.
WECC-2 Requirement R2. If the
following identification of the
specifics of that requirement are
R2.2. If a protective relay or
Misoperation. Repair or
retained they limit the operator’s
equipment failure reduces system
replacement of the failed Protection reliability, the Transmission
discretion and could lead to a lessSystem or RAS is at the Transmission Operator shall notify its Reliability
than-favorable operational decision
Owners’ and Generator Owners’
simply to be compliant, thereby
Coordinator and affected
discretion. [Violation Risk Factor:
defeating the reliability-related
Transmission Operators and
High] [Time Horizon: Same-day
intent.
Balancing Authorities. The
Operations]
Transmission Operator shall take
PRC-004-WECC-2 Requirement R2
corrective action as soon as
possible.
R6. Each Transmission Operator
and Balancing Authority shall
monitor the status of each Special
Protection System in their area,
and shall notify affected
Transmission Operators and
Balancing Authorities of each
change in status.
PRC-004-4(i)
R5. Each Transmission Owner,
Generator Owner, and Distribution
Provider that owns the Protection
System component(s) that caused
the Misoperation shall, within 60
calendar days of first identifying a
cause of the Misoperation:
 Develop a Corrective Action
Plan (CAP) for the identified
Protection System
component(s), and an
evaluation of the CAP’s

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requires that the device be taken
out-of-service under specified
circumstances. By contrast, TOP-0013, Requirement R1, requires the TO
to “act to maintain the reliability of
its Transmission Operator Area via its
own actions.” The TOP-001-3,
Requirement R1 mandate to act with
discretion conflicts with the PRC-004WECC-2 Requirement R2 mandate to
perform specific tasks. The PRC-004WECC-2 Requirement R2 approach
has the potential to lead to reliability
concerns; by contrast, the approach
of PRC-001-1.1(ii) and TOP-001-3
provide the operator with discretion
more targeted for remedy of actual
circumstances and not implemented
merely for compliance purposes.
Additionally, the overly prescriptive
PRC-004-WECC-2 Requirement R2
approach may conflict with IRO-017-1
Requirement R1 wherein the
Reliability Coordinator (RC) is

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Retirement of Regional Reliability Standard
PRC-004-WECC-1 Protection System and Remedial Action Scheme Misoperation
PRC-004-WECC-2
PRC-004-WECC-2
Description and Change Justification
Requirement in Approved Standard
Requirements covered elsewhere
applicability to the entity’s
required to ‘develop, implement, and
other Protection Systems
maintain an outage coordination
including other locations; or
process.” If PRC-004-WECC-2
Requirement R2 is retained it
 Explain in a declaration why
mandates a specific action that may
corrective actions are beyond
conflict with the broader authority
the entity’s control or would
not improve BES reliability, and and outage coordination process
established by the RC.
that no further corrective
actions will be taken.
PRC-016-1
R1. The Transmission Owner,
Generator Owner, and Distribution
Provider that owns an RAS shall
analyze its RAS operations and
maintain a record of all
misoperations in accordance with
the Regional RAS review procedure
specified in Reliability Standard
PRC-012-0_R1.
R2. The Transmission Owner,
Generator Owner, and Distribution
Provider that owns a RAS shall take
corrective actions to avoid future
misoperations.
R2.2. If the Protection System or
RAS has a Security-Based
Misoperation and only one FEPS or
FERAS remains in service to ensure
BES reliability, the Transmission
Owner or Generator Owner shall
perform the following. [Violation
Risk Factor: High] [Time Horizon:
Same-day Operations]
R2.2.1. Following identification of
the Protection System or RAS
Misoperation, Transmission Owners

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E S T E R N

As of July 1, 2016, Protection
System Operations and
Misoperations are reported by TOs,
GOs, and DPs, via the Misoperation

L E C T R I C I T Y

Retirement of PRC-004-WECC-2
Requirement R3 fits the retirement
criteria established under FERC’s
“P81” criteria. See Retirement of

O O R D I N A T I N G

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WECC-0126 PRC-004-WECC-2 Request to Retire

This renders PRC-004-WECC-2
administrative request redundant.

1999. A records search at WECC and
inquires via corporate memory did
not reveal why the original drafters
believed the 10-days was essential.
However, the 10-day reference was
found in the 1999 WSCC Reliability
Criteria Agreement (Section 5
Determining Compliance, 5.2 Data
Submission and Review) as part of
the document’s compliance section
giving rise to the conclusion that it
was required for accountability and
not reliability.
Considering the NERC 1600
requirement, the 10-days has proven
to be no longer essential.
Currently, Midas will send out
reminder notifications to entities
who have not yet submitted for a
specified quarter. They will also
provide confirmation notifications
upon submittal. Once the submittal is
being by the regions or NERC, they
may send additional notifications to
the MIDAS contacts as questions
arise.
Currently, all WECC entities must
comply under that request, but they
have 60 days to do so while also
complying with the administrative
request under PRC-004-WECC-2.

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

WECC-0126 PRC-004-WECC-2 Request to Retire

E S T E R N

L E C T R I C I T Y

O O R D I N A T I N G

O U N C I L

Unofficial Comment Form

Regional Reliability Standard – Retirement
PRC-004-WECC-2
DO NOT use this form for submitting comments. Use the electronic form to submit comments on the
proposed retirement of the Regional Reliability Standard PRC-004-WECC-2 – Protection System and
Remedial Action Scheme Misoperation. 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

During its five-year update, the WECC standard drafting team concluded that retirement of the standard
can be made without incurring a negative impact on reliability due to the following:
• The reliability concern is now specifically covered in FAC-003-4;
• The Applicability section is overly narrow and included in other existing NERC Standards;
• Requirement R1 is covered in other NERC Standards;
• Requirement R2 is covered in other NERC Standards, conflicts with existing NERC Standards, and
its application can lessen reliability as opposed to enhancing it;
• Requirement R3 is entirely administrative in nature and should be retired under FERC P81 criteria;
and
• The language of the standard does not meet the FERC Order 672 criteria in that it fails to assign
the reliability task directly to an entity included in the NERC Functional Model.
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:

Unofficial Comment Form
Regional Reliability Standard PRC-004-WECC-2 | November 2017

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:
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 PRC-004-WECC-2 | November 2017

Comment Report
Project Name:

Regional Reliability Standard (WECC) | PRC-004-WECC-2 Retirement

Comment Period Start Date:

11/3/2017

Comment Period End Date:

12/18/2017

Associated Ballots:

There were 4 sets of responses, including comments from approximately 4 different people from approximately 4 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:
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment

Likes

Dislikes
Response

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:
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer

Yes

Document Name
Comment

Likes

Dislikes
Response

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:
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment

Likes

Dislikes
Response

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:
Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer

Yes

Document Name
Comment

Likes

Dislikes
Response

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:
John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Laurie Williams - PNM Resources - Public Service Company of New Mexico - 1,3
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment

Likes

Dislikes
Response

Attachment R2
WECC-0126 PRC-004-WECC-2
Protection System and Remedial Action Scheme Misoperation
NERC Response to Comments / Posting 1
November 3 through December 18, 2017
Posting 1
The WECC-0126 PRC-004-WECC-2, Protection System and Remedial Action Scheme Misoperation (DT)
thanks everyone who submitted comments on the proposed project.
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 four 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-0126 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. After completing its review, the DT recommends
that the substance of PRC-004-WECC-2 should be retired immediately and in its entirety because the
reliability-related substance is addressed in peripheral NERC Standards. The DT does not believe any
further actions are necessary to implement the proposed changes.
Action Plan
As of January 10, 2018, this project is awaiting filing at NERC.

Comment Report Form for WECC-0126
WECC Standards Comment Table
Commenter
1 Aaron Cavanaugh
2 John Tolo

Organization
Bonneville Power Administration (BPA)
Tucson Electric Power Company (TEP)

Laurie Williams

Glen Farmer

PNM Resources - Public Service Company of New
Mexico (PNM)
Avista

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-0126
1. Response Summary
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment

Response

The WECC-0126 PRC-004-WECC-2, Protection System and Remedial Action Scheme Misoperation
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-0126
bar

Raw Data

Raw Data
provided by
NERC
Comment
Report
Project Name:

Regional Reliability Standard (WECC) | PRC-004-WECC-2
Retirement

Comment Period
Start Date:

11/3/2017

Comment Period End 12/18/2017
Date:
Associated Ballots:

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:

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 Segment(s) Region Group Group
Group
Group
Group
Name
Name Member
Member
Member Member
Name Organization Segment(s) Region

Yes

Document Name
Comment

Likes

Dislikes

Response

Laurie Williams - PNM Resources - Public Service Company of New Mexico 1,3
Answer

Yes

Comment Report Form for WECC-0126
Document Name
Comment

Likes

Dislikes

Response

Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment

Likes

Dislikes
Response

Yes

Document Name
Comment

Likes

Dislikes

Response

Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Laurie Williams - PNM Resources - Public Service Company of New Mexico 1,3
Answer

Yes

Document Name
Comment

Likes

Comment Report Form for WECC-0126
Dislikes

Response

John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Yes

Document Name
Comment

Likes

Dislikes

Response

Laurie Williams - PNM Resources - Public Service Company of New Mexico 1,3
Answer

Yes

Comment Report Form for WECC-0126
Document Name
Comment

Likes

Dislikes

Response

Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment

Likes

Dislikes
Response

Yes

Document Name
Comment

Likes

Dislikes

Response

Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Laurie Williams - PNM Resources - Public Service Company of New Mexico 1,3
Answer

Yes

Document Name
Comment

Likes

Comment Report Form for WECC-0126
Dislikes

Response

John Tolo - Unisource - Tucson Electric Power Co. - 1
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Yes

Document Name
Comment

Likes

Dislikes

Response

Laurie Williams - PNM Resources - Public Service Company of New Mexico 1,3
Answer

Yes

Comment Report Form for WECC-0126
Document Name
Comment

Likes

Dislikes

Response

Glen Farmer - Avista - Avista Corporation - 1,3,5
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Aaron Cavanaugh - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment

Likes

Dislikes
Response

Comment Report Form for WECC-0126

File Type	application/pdf
File Title	WECC PRC-004-WECC-2 Retirement Petition
Author	NERC Legal (ST)
File Modified	2018-03-09
File Created	2018-03-09