NERC Petition for VAR-002-WECC-2 Retirement (RD18-1-000)

NERC Petition for VAR-002-WECC-2 Retirement (RD18-1-000).pdf

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

NERC Petition for VAR-002-WECC-2 Retirement (RD18-1-000)

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 VAR-002-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 7, 2018

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

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

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

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

Summary of VAR-002-WECC-2 Retirement History.................................................. 6
JUSTIFICATION FOR RETIREMENT ............................................................................. 7

A.
In Practical Application, Regional Reliability Standard VAR-002-WECC-2 is Not More
Stringent than the Continent-Wide VAR Reliability Standard VAR-002-4.1 ............................ 7
B.
The Retirement of the Regional Reliability Standard Would Have No Adverse Impact
on Reliability............................................................................................................................. 11
EFFECTIVE DATE OF RETIREMENT .......................................................................... 13
CONCLUSION ..................................................................................................................... 14

Exhibit A

Mapping Document, Retirement of WECC Regional Reliability Standard VAR002-WECC-2 Automatic Voltage Regulators

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 VAR-002-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 VAR-002-WECC-2 Automatic Voltage Regulators (AVR).
The primary purpose of Regional Reliability Standard VAR-002-WECC-2 is to ensure
that automatic voltage regulators on synchronous generators and condensers shall be kept in
service and controlling voltage. As discussed below, experience with Regional Reliability
Standard VAR-002-WECC-2 has shown that the reliability-related issues addressed in the
regional standard are adequately addressed by the continent-wide Voltage and Reactive (“VAR”)
Reliability Standards and that retention of the regional standard would not provide additional
benefits for reliability. The retirement of the regional standard will thus have no adverse effect
on the reliability of the Bulk-Power System and is in the public interest.

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).
2

NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the following: 4
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, 5 Congress entrusted the Commission with
the duties of approving and enforcing rules to ensure the reliability of the Bulk-Power System,
and with the duties of certifying an ERO that would be charged with developing and enforcing
mandatory Reliability Standards, subject to Commission approval. Section 215(b)(1) 6 of the FPA
states that all users, owners, and operators of the Bulk-Power System in the United States will be
subject to Commission-approved Reliability Standards. Section 215(d)(5) 7 of the FPA authorizes
the Commission to order the ERO to submit a new or modified Reliability Standard. Section
39.5(a) 8 of the Commission’s regulations requires the ERO to file with the Commission for its

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.
5
16 U.S.C. § 824o.
6
Id. § 824o(b)(1).
7
Id. § 824o(d)(5).
8
18 C.F.R. § 39.5(a).

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 Bulk-Power System 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 9 and Section 39.5(c) 10 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. 11 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
Bulk-Power System. 12 The Commission must give due weight to the technical expertise of a

16 U.S.C. § 824o(d)(2).
18 C.F.R. § 39.5(c)(1).
11
16 U.S.C. § 824o(d)(2) and 18 C.F.R. § 39.5(a).
12
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

Regional Entity, like WECC, that is organized on an Interconnection-wide basis with respect to a
Regional Reliability Standard applicable within that Interconnection. 13
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”). 14 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 the standard being
proposed for retirement, WECC Regional Reliability Standard VAR-002-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 VAR Regional Reliability
Standard

On June 8, 2007, the Commission approved WECC Regional Reliability Standard
WECC-VAR-STD-002a-1 - Automatic Voltage Regulators as mandatory and enforceable on
entities within the Western Interconnection. 15 This and other WECC regional standards were
translations of existing reliability criteria under WECC’s Reliability Management System
(“RMS”). As noted in the Commission’s order approving WECC-VAR-STD-002a-1, WECC
developed the RMS predecessor to this standard based on its experience with a 1996 disturbance

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.
15
Order Approving Regional Reliability Standards for the Western Interconnection and Directing
Modifications, 119 FERC ¶ 61,260 (2007).
14

caused by insufficient supply of reactive power from generators, including automatic voltage
regulators that were not operating in voltage control mode. WECC determined that, as a result of
this experience, there should be only very limited circumstances where a generator should
remove its unit from automatic voltage regulation operation. The WECC standard was intended
to be more stringent than the continent-wide VAR standards in place at that time. 16
In 2011, the Commission issued Order No. 751 approving a revised version of the
standard, VAR-002-WECC-1. 17 This standard consisted of two Requirements. Requirement R1
required Generator Operators[18] and Transmission Operators to have automatic voltage
regulation in service and in automatic voltage control mode 98% of all operating hours for
synchronous generators or synchronous condensers, and provided that entities may exclude hours
for certain circumstances when calculating the 98% requirement. Requirement R2 required
entities to maintain documentation identifying the number of hours excluded. 19
The second of the two Requirements was later determined to be an administrative
requirement and was eliminated in the currently-enforceable version of the standard, VAR-002WECC-2.20 The Commission approved VAR-002-WECC-2 on March 3, 2015, finding that the
regional standard continued to be more stringent than its continent-wide counterpart. 21

Id. at P 114.
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
Unless otherwise designated, all capitalized terms shall have the meaning set forth in the Glossary of Terms
Used in NERC Reliability Standards, available at http://www.nerc.com/files/Glossary_of_Terms.pdf.
19
Regional Reliability Standard VAR-002-WECC-1, available at http://www.nerc.com/files/VAR-002WECC-1.pdf.
20
With the retirement of Requirement R2 in VAR-002-WECC-2, the Measure corresponding to Requirement
R1 (M1.4.3) was revised to add information regarding the date of an outage to the documentation entities would
keep in order to demonstrate compliance with the Requirement. The reporting Measure was originally included as a
means of measurement and enforcement, and was not considered a requirement necessary to maintain reliability.
21
Order Approving Two Regional Reliability Standards, 150 FERC ¶ 61,164, at PP 11, 14 (2015) (“VAR002-WECC-2 Approval Order”).
17

Summary of VAR-002-WECC-2 Retirement History

In November 2016, a regional Standard Authorization Request (“SAR”) was submitted to
review WECC Regional Reliability Standard VAR-002-WECC-2 for potential retirement on the
basis that the standard is duplicative of, and not more stringent than, the continent-wide VAR
standards VAR-001-4.2 and VAR-002-4.1. In accordance with WECC’s RSDP, the SAR was
approved by the WECC Standards Committee on December 6, 2016.
Project WECC-0127 was initiated by WECC stakeholders to review the regional standard
on the premise that, in light of changes made in the continent-wide VAR-002 standard and the
addition of the WECC Regional Variance in the continent-wide VAR-001 standard, there was no
longer a need for VAR-002-WECC-2. The standard drafting team for this project evaluated the
regional standard and the relevant continent-wide standards and recommended that the regional
standard be retired. In accordance with the WECC RSDP, the proposed retirement of VAR-002WECC-2 was posted for a 45-day comment period from May 31, 2017 through July 18, 2017.
The WECC Standards Committee approved a request for ballot by the WECC Ballot Pool on
July 31, 2017. The ballot pool was open from August 30, 2017 through September 14, 2017, and
the final ballot was held from September 21, 2017 through October 11, 2017. The proposed
retirement achieved a 80.9% quorum and 100% approval.
In accordance with Section 312 of NERC’s Rules of Procedure, 22 NERC posted the
proposed retirement of VAR-002-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

The NERC Rules of Procedure are available at http://www.nerc.com/AboutNERC/Pages/Rules-ofProcedure.aspx.

Directors approved the retirement of VAR-002-WECC-2 on December 6, 2017. The NERC
Board of Trustees approved the retirement on February 8, 2018.
JUSTIFICATION FOR RETIREMENT
In 2015, the Commission approved Regional Reliability Standard VAR-002-WECC-2 on
the grounds that it was more stringent than the then-effective continent-wide standard VAR-0023. 23 Through its further analysis and experience with the standard, WECC has determined that
VAR-002-WECC-2 is not in fact more stringent than the continent-wide standard when
application of the various exceptions in the WECC regional standard is considered. As the
reliability goal of maintaining voltage stability is addressed adequately in the two continent-wide
VAR standards, WECC has determined that the regional standard should be retired. NERC and
WECC respectfully request that the Commission approve its retirement.
A.

In Practical Application, Regional Reliability Standard VAR-002-WECC-2 is
Not More Stringent than the Continent-Wide VAR Reliability Standard
VAR-002-4.1

Regional Reliability Standard VAR-002-WECC-2 Requirement R1 provides that
“Generator Operators and Transmission Operators shall have [automatic voltage regulators] in
service and in automatic voltage control mode 98% of all operating hours for synchronous
generators or synchronous condensers,” unless they are permitted to not run under any one of ten
possible scenarios described in the standard. 24 In calculating compliance with the 98%
requirement, entities may exclude the following hours:
•

The synchronous generator or synchronous condenser operates for less
than five percent of all hours during any calendar quarter (R1.1).

•

Performing maintenance and testing up to a maximum of seven calendar
days per calendar quarter (R1.2).

See VAR-002-WECC-2 Approval Order at PP 11, 14.
Regional Reliability Standard VAR-002-WECC-1 – Automatic Voltage Regulators,
http://www.nerc.com/files/VAR-002-WECC-1.pdf.
24

•

Automatic voltage regulator exhibits instability due to abnormal system
configuration (R1.3).

•

Due to component failure, the automatic voltage regulator may be out
of service up to 60 consecutive days for repair per incident (R1.4).

•

Due to a component failure, the automatic voltage regulator may be out
of service up to one year provided the Generator Operator or
Transmission Operator submits documentation identifying the need for
time to obtain replacement parts and if required to schedule an outage
(R1.5).

•

Due to a component failure, the automatic voltage regulator may be out
of service up to 24 months provided the Generator Operator or
Transmission Operator submits documentation identifying the need for
time for excitation system replacement (replace the automatic voltage
regulator, limiters, and controls but not necessarily the power source and
power bridge) and to schedule an outage (R1.6).

•

The synchronous generator or synchronous condenser has not achieved
Commercial Operation (R1.7).

•

The Transmission Operator directs the Generator Operator to operate
the synchronous generator, and the automatic voltage regulator is
unavailable for service (R1.8).

•

The Reliability Coordinator directs Transmission Operator to operate
the synchronous condenser, and the automatic voltage regulator is
unavailable for service (R1.9).

•

If the automatic voltage regulator exhibits instability due to operation of
a load tap changer transformer in the area, the Transmission Operator
may authorize the Generator Operator to operate the excitation system
in modes other than automatic voltage control until the system
configuration changes (R1.10).

Continent-wide Reliability Standard VAR-002-4.1 – Generator Operation for
Maintaining Network Voltage Schedules sets forth the requirements applicable to Generator
Operators and Generator Owners for providing the necessary reactive support and voltage
control necessary to protect equipment and maintain reliable operations. 25 Reliability Standard
VAR-002-4.1 Requirement R1 provides that each Generator Operator shall operate each

Reliability Standard VAR-001-4.2 – Voltage and Reactive Control sets forth the requirements applicable to
Transmission Operators (and Generator Operators within the Western Interconnection for the WECC regional
variance) for scheduling, monitoring, and controlling Reactive Power resources to regulate voltage and Reactive
Power flows for the reliable operation of the Bulk-Power System.

generator connected to the interconnected transmission system in the automatic voltage control
mode (with its automatic voltage regulator in service and controlling voltage) unless: (1) it is
instructed to operate in a different control mode by the Transmission Operator; (2) the generator
is exempted by the Transmission Operator; (3) the Generator Operator has notified the
Transmission Operator that the generator is being operated in start-up, shutdown, or testing mode
pursuant to a Real-time communication or a procedure that was previously provided to the
Transmission Operator; or (4) the Generator Operator has notified the Transmission Operator
that the generator is not being operated in automatic voltage control mode or in the control mode
that was instructed by the Transmission Operator for a reason other than start-up, shutdown, or
testing.
In its order approving VAR-002-WECC-2, the Commission determined that the regional
standard was more stringent than then-effective VAR-002-3. Specifically, the Commission
determined that the exceptions in VAR-002-3, which are carried forward into currently-effective
VAR-002-4.1, were broader than the ten exceptions in the regional standard, “particularly the
exception [in VAR-002-3] allowing generator operators not to operate in automatic voltage
control mode or in the control mode that was instructed by the transmission operator for a reason
other than start-up, shutdown, or testing.” 26 Therefore, the Commission approved the regional
standard as consistent with its Order No. 672 regional standard approval criteria. 27
WECC initially drafted the regional standard to reflect exactly the language of the RMS
requirements. In petitioning for approval of the standard, WECC argued that, by identifying the
specific circumstances where an automatic voltage regulator may be exempt from the
requirement to be in service, the Regional Reliability Standard was more stringent than the

26
27

VAR-002-WECC-2 Approval Order at P 14.
Id. at P 11.

continent-wide standard. Because it was not practical to develop a list of all possible
circumstances an automatic voltage regulator could be out of service, and to maintain
consistency with its prior approach toward enforcement of the standard, WECC included a 98%
run time requirement in the standard rather than a 100% run time requirement. WECC’s further
analysis of the regional standard, however, has demonstrated that the regional standard is not in
fact more stringent than the continent-wide standard when practical application of the various
exemptions is considered. By layering each of the regional standard’s specific exemptions, an
entity may remain compliant with the standard and yet have its automatic voltage regulator out
of service for an indeterminate amount of time.
WECC’s analysis of all ten VAR-002-WECC-2 exemptions has demonstrated that an
application of eight of the ten exemptions (R1.1, R1.3, and R1.5 through R.10) could result in an
automatic voltage regulator being out service 100% of the time (i.e., in operation for zero percent
of the time), in some cases for up to two years. An entity using the Requirement R1.2 seven-day
maintenance and testing exemption may end up also using other exemptions depending on the
facts of the particular situation. The automatic voltage regulator may continue to be out of
service beyond the seven-day maintenance and testing window due to instability (R1.3 and
R1.10), component failure (R1.4, R1.5, and R1.6), or unavailability (R1.8 and R.9). Similarly, an
entity using the 60-day “per incident” component failure exemption (R1.4) may continue to have
its automatic voltage regulator out of service due to additional incidents or due to instability,
component failure, or unavailability. 28
Further, WECC has determined that while the VAR-002-WECC-2 exemptions were
intended to be highly specific, certain undefined terms in the exemptions could be interpreted

See Exhibit C, Technical Justification at 3-4.

broadly to further extend the time an automatic voltage regulator may be out of service. For
example, neither Requirement R1.3 nor Requirement R1.10 define what constitutes “instability”
allowing an automatic voltage regulator to be removed from service. The term “component” is
not defined, even though component failure could result in an automatic voltage regulator being
off for up to two years (see Requirement R1.6). Lastly, there is no criteria to define what may
make an automatic voltage regulator “unavailable” under Requirements R1.8 and R1.9 and thus
exempt from the requirement to be in service.
In light of these practical considerations, identified through WECC’s experience with and
further review of the standard, WECC has determined that the 98% run time requirement and
exemptions in the regional standard can no longer be considered more stringent than the
corresponding obligations and exemptions of the continent-wide standard and should not be
retained on that basis.
B.

The Retirement of the Regional Reliability Standard Would Have No
Adverse Impact on Reliability

Retirement of Regional Reliability Standard VAR-002-WECC-2 would have no adverse
impact on reliability. The continent-wide VAR Reliability Standards provide a flexible, resultsoriented means of achieving the reliability goal of maintaining voltage stability and are sufficient
to ensure reliable operations in the Western Interconnection without the need for a separate
regional standard regarding automatic voltage regulators, as described in Exhibit A and below.
Reliability Standard VAR-001-4.2 – Voltage and Reactive Control requires the
Transmission Operator to specify a system voltage schedule (Requirement R1) and to schedule
sufficient reactive resources to regulate voltage levels under normal and Contingency conditions
(Requirement R2). Whereas VAR-002-WECC-2 creates a static setting for automatic voltage
regulators, thereby removing discretion from the Transmission Operator, VAR-001-4.2 allows
11

the Transmission Operator to attain the same reliability goal based on all the surrounding
circumstances in real time. For example, although VAR-002-WECC-2 requires synchronous
condensers to be in service and set to automatic voltage regulation mode, VAR-001-4.2
Requirement R3 and associated schedule-related requirements allow greater flexibility of
operation while meeting the same reliability goal. By creating the voltage schedule, the
Transmission Operator sets the reliability goal to be met without restricting the specific type of
resource to be used. Stated differently, this approach is inclusive of VAR-002-WECC-2 without
specifying how the goal is to be met. Reliability Standard VAR-001-4.2 also contains a Regional
Variance for the Western Interconnection that supersedes continent-wide Requirements R4 and
R5. This Regional Variance works to ensure that voltage levels are within limits to protect
equipment during system disturbances in the Western Interconnection. When applied, this
Variance does not allow the Transmission Operator to exempt the Generator Operator from
operating its automatic voltage regulator; any generator not having a functioning automatic
voltage regulator is required to work with its Transmission Operator to correct the issue. With
the retirement of the VAR-002-WECC-2 standard, the more stringent approach to automatic
voltage regulator operation is retained in the VAR-001-4.2 Regional Variance to ensure
reliability in the Western Interconnection.
Reliability Standard VAR-002-4.1, as discussed above, addresses the Generator
Operator’s responsibilities to have automatic voltage regulators in service and controlling
voltage. The continent-wide Reliability Standard provides benefits for reliability that are not
otherwise reflected in the regional standard. For example, Reliability Standard VAR-002-4.1
requires ongoing communication with the Transmission Operator regarding automatic voltage
regulator or reactive capability status (see, e.g., VAR-002-4.1 Requirements R3 and R4) or when

the Generator Owner is unable to comply with a schedule (Requirement R2.2) and requires
deployment of an alternate means to meet the reliability goal in the event there is a concern with
the automatic voltage regulator (see Requirement R2.1).
For these reasons, retirement of the regional standard VAR-002-WECC-2 would have no
adverse impact on reliability. Because compliance with VAR-002-WECC-2 is structured towards
documentation, an entity may layer exemptions to build up to the 98% requirement to run an
automatic voltage regulator, rather than keeping the equipment in service at all times. Its
retirement would eliminate what has proven to be an administrative requirement to count hours
that ultimately provides little additional benefit to reliability. Indeed, retiring the regional
standard would benefit reliability in the Western Interconnection by focusing the in-service
requirement on the performance of the automatic voltage regulator, rather than counting the
hours each one is online.
For these reasons, NERC and WECC jointly submit that the retirement of Regional
Reliability Standard VAR-002-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 VAR-002-WECC-2 to be effective as of the date of
regulatory approval in accordance with the proposed implementation plan (Exhibit B).

CONCLUSION
For the reasons set forth above, NERC and WECC respectfully request that the
Commission approve the proposed retirement of Regional Reliability Standard VAR-002WECC-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 7, 2018

Exhibit A
Mapping Document, Retirement of WECC Regional Reliability Standard
VAR-002-WECC-2 Automatic Voltage Regulators

Tabular Representation
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
Request to Retire
Tabular Crosswalk
Requirement R1
R1. Generator Operators and Transmission Operators shall have AVR in service and in automatic
voltage control mode 98% of all operating hours for synchronous generators or synchronous
condensers. Generator Operators and Transmission Operators may exclude hours for R1.1 through
R1.10 to achieve the 98% requirement. [Violation Risk Factor: Medium] [Time Horizon: Operations
Assessment]
(Exceptions R1.1 through R1.10 are covered below.)

Analysis Table: Requirement R1
Applicable Entities and Facilities Covered Elsewhere
WECC Standard

NERC Standards

Narrative

VAR-002-WECC-2

VAR-001-4.2

Applicability

4.1 Generator Operators

4.1 Transmission Operators

The Applicable Entities of the WECC
Standard are addressed in VAR-0014.2 and VAR-002-4.1.

4.2 Transmission Operators that
operate synchronous condensers

4.2 Generator Operators within the
Western Interconnection (for the
WECC Variance)

4.3 This VAR-002-WECC-2 Standard
only applies to synchronous
generators and synchronous
condensers that are connected to
the Bulk Electric System.

VAR-002-4.1
Applicability
4.1 Generator Operator
4.2 Generator Owner

Whereas VAR-002-WECC-2 specifically
identifies generators and synchronous
condensers as the applicable facilities,
these specific assets need not be
called out. Rather, by setting the
voltage schedule as a results-oriented
goal, the Transmission Operator can
allow for an array of assets to deploy
without confining the resources to a
specific list.

Page 1 of 5

Tabular Representation
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
Request to Retire
Analysis Table: Requirement R1
AVR in Service and Controlling – Covered Elsewhere
VAR-002-WECC-2

VAR-002-4

VAR-001-4.1

Generator Operator and
Transmission Operator

Generator Operator

Transmission Operator

R1. Generator Operators
and Transmission
Operators shall have AVR
in service and in
automatic voltage control
mode.

R1. The Generator
Operator shall operate
each generator
connected to the
interconnected
transmission system
(with its automatic
voltage regulator (AVR)
in service) in the
automatic voltage
control mode.

R1. Each Transmission
Operator shall specify a
system voltage schedule
(which is either a range or a
target value with an
associated tolerance band)
as part of its plan to
operate within System
Operating Limits and
Interconnection Reliability
Operating Limits.

Narrative

The Generator Operator and
the Transmission Operator’s
reliability tasks are
addressed in VAR-002-4.1
and VAR-001-4.2. and its
Regional Variance. By
creating the voltage
schedule, the Transmission
Operator sets the reliability
goal to be met without
restricting the specific type
of resource to be used.
Restated, the VAR-01-4.2
approach is inclusive of VAR002-WECC-2 without
specifying “how” the goal is
to be met.

R2. Each Transmission
Operator shall schedule
sufficient reactive resources
to regulate voltage levels
under normal and
Contingency conditions.
(Various means are
allowed.)
R3. Each Transmission
Operator shall operate or
direct the Real-Time
operation of device to
regulate transmission
voltage and reactive flow as
necessary.

Page 2 of 5

Tabular Representation
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
Request to Retire
Analysis Table: Requirement R1
Exceptions to the Rule – Covered Elsewhere
VAR-002-WECC-2

VAR-002-4.1

Narrative

General: AVR shall be in service 98%
of the time, unless covered by one of
ten exceptions.

General: AVR shall be in service
100% of the time, unless covered
by an exception.

Because the VAR-002-WECC-2 list of
exceptions can be compounded, the
practical result is that the specific list
of exceptions is not more stringent
than the generalized exception offed
in VAR-002-4.1. Thus, VAR-002-WECC2 is not more stringent than VAR-0024.1.

Exceptions:

R1.1 through R1.10.

[When] the generator is being
operated in start-up, shutdown, or
testing mode pursuant to a realtime communication or a
procedure that was previously
provided to the Transmission
Operator; or,
(AKA: Start up, shutdown, or
testing.)
[When] the generator is not being
operated in automatic voltage
control mode or in the control
mode that was instructed by the
Transmission Operator for a
reason other than start-up, or
testing.
(AKA: Other than start up,
shutdown, or testing.)

R1.1
The synchronous generator
or synchronous condenser operates
for less than five percent of all hours
during any calendar quarter.
R1.2.
Performing maintenance
and testing up to a maximum of

[R1.1] Other than start up,
shutdown, or testing.

[R1.2] Start up, shutdown, or
testing.

Page 3 of 5

Tabular Representation
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
Request to Retire
seven calendar days per calendar
quarter.
R1.3.
AVR exhibits instability due
to abnormal system configuration.
R1.4.
Due to component failure,
the AVR may be out of service up to
60 consecutive days for repair per
incident.
R1.5.
Due to a component failure,
the AVR may be out of service up to
one year provided the Generator
Operator or Transmission Operator
submits documentation identifying
the need for time to obtain
replacement parts and if required to
schedule an outage.
R1.6.
Due to a component failure,
the AVR may be out of service up to
24 months provided the Generator
Operator or Transmission Operator
submits documentation identifying
the need for time for excitation
system replacement (replace the
AVR, limiters, and controls but not
necessarily the power source and
power bridge) and to schedule an
outage.

[R1.3] Other than start up,
shutdown, or testing.
[R1.4] Other than start up,
shutdown, or testing.

[R1.5] Other than start up,
shutdown, or testing.

[R1.6] Other than start up,
shutdown, or testing.

R1.7.
The synchronous generator
or synchronous condenser has not
achieved Commercial Operation.
R1.8.
The Transmission Operator
directs the Generator Operator to
operate the synchronous generator,
and the AVR is unavailable for
service.
R1.9.
The Reliability Coordinator
directs Transmission Operator to
operate the synchronous condenser,

[R1.7] Start up, shutdown, or
testing.

Page 4 of 5

Tabular Representation
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
Request to Retire
and the AVR is unavailable for
service.
R1.10. If AVR exhibits instability due
to operation of a Load Tap Changer
(LTC) transformer in the area, the
Transmission Operator may
authorize the Generator Operator to
operate the excitation system in
modes other than automatic voltage
control until the system
configuration changes.

[R1.8] Other than start up,
shutdown, or testing.

[R1.9] Other than start up,
shutdown, or testing.

[R1.10] Other than start up,
shutdown, or testing.

Page 5 of 5

Exhibit B
Implementation Plan

Implementation Plan
WECC-0127 VAR-002-WECC-2
Request to Retire
Standard Authorization Request (SAR) 1
WECC-0127 SAR
Approvals Required
•
•
•

WECC Board of Directors
NERC Board of Trustees
FERC

December 6, 2017
February 8, 2018
Pending

Applicability Section
4.1.

Generator Operators

4.2.

Transmission Operators that operate synchronous condensers

4.3.

This VAR-002-WECC-2 Standard only applies to synchronous generators
and synchronous condensers that are connected to the Bulk Electric
System.

Conforming Changes to Other Standards
None are required.
Proposed Effective Date
Immediately on receipt of applicable regulatory approval.
Justification
The entirety of WECC VAR-002-WECC-2 should be retired because the reliability-related tasks are
addressed elsewhere, specifically in VAR-002-4.1 and VAR-001-4.2.
Consideration of Early Compliance
The drafting team identified no adverse impacts to reliability should an entity opt for early compliance.
Required Retirements
The entire VAR-002-WECC-2 should be retired.

This Implementation Plan was originally posted as part of the WECC-0127 VAR-002-WECC-2 Posting 1 Technical
Justification document. It was removed from that document for purposes of NERC filing.

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

Exhibit C
Complete Record of Development

Steven Rueckert
Western Electricity Coordinating Council
155 North 400 West, Suite 200
Salt Lake City, Utah 84103
January 2, 2018
Subject:

Notification of Completion
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators (AVR)

To:

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

Dear Mat,
WECC is seeking approval by the NERC Board of Trustees – with subsequent disposition by the Federal
Energy Regulatory Commission (FERC) – to retire VAR-002-WECC-2, Automatic Voltage Regulators in its
entirety, immediately on receipt of applicable regulatory approval.
In accordance with the Western Electricity Coordinating Council’s (WECC) Reliability Standards
Development Procedures (Procedures), the WECC-0127 VAR-002-WECC-2, Automatic Voltage
Regulators Drafting Team (DT) conducted a five-year review of the standard concluding the content of
the standard is: 1) either covered in other NERC Standards, 2) not required for reliability, or 3) does not
meet the minimum acceptable threshold for due process and clarity required in FERC Order 672.
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

For documentation support please contact W. Shannon Black, at (503) 307-5782.
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
Request to Retire
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)
Order 672 Criteria Attachment G (7)
Drafting Team Roster with Biographies Attachment H (8)
Ballot Pool Members Attachment I (9)
Final Ballot Results Attachment J (10)
Minority Issues Attachment K (11)
WECC Standards Committee Roster Attachment L (12)
Responses to Comments – WECC Attachment M
Attachment M1 – Responses to Comments WECC (13)
Attachment M2 – Responses to Comments NERC (14)
Info (15)
VAR-002-WECC-2
(Retirement) (16)
Submit Comments
VAR-002-WECC-2
(Retirement)

Automatic Voltage
Regulators

Standard Under
Development

11/03/17 12/18/17

Technical Justification
for Retirement (17)
Unofficial Comment
Form (Word) (18)
Comments Received
(19)
Consideration of
Comments (20)

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Standard Authorization Request
WECC-0127 VAR-002-WECC-2
Request to Retire
This Standard Authorization request (SAR) was received on November 8, 2016, and deemed complete
the same day. The SAR was vetted for approval during the December 2016 WECC Standards Committee
meeting.

Introduction
This project is a request to retire WECC Regional Reliability Standard VAR-002-WECC-2, Automatic
Voltage Regulators (AVR).

Requester Information
1. Provide your contact information and your alternates contact information:
• Your First Name:
David
• Your Last Name:
Lemmons
• Your Email Address:
[email protected]
• Your Phone Number:
(303) 628-2813
• Organization Name:
Public Service Company of Colorado
• Alternates First Name:
Todd
• Alternates Last Name:
Komaromy
• Alternates Email Address:
[email protected]
• Alternates Phone Number: (602) 250-5171

Type of Request
2. Specify the type of request: (select one)
• Request to Retire a WECC Regional Reliability Standard (RRS)

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)
• Request to Retire a WECC Regional Reliability Standard (RRS)
4. Document Type: (select one)
• WECC Regional Reliability Standard (RRS)
5. Issue: Specify what industry problem this request is trying to resolve.
Due to changes made in VAR-002-4, Generator Operation for Maintaining Network Voltage
Schedules (United States Enforcement Date May 29, 2015) and WECC Regional Variances in
VAR-001-4.1, Voltage and Reactive Control (United States Enforcement Date November 13,

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

Standard Authorization Request

2015), there is no longer a need for VAR-002-WECC-2, Automatic Voltage Regulators (United
States Enforcement Date April 1, 2015). 1
Additionally, the compliance and reporting process used in VAR-002-WECC-2 should be
considered Paragraph 81 material. For these reasons, we are recommending that the standard
be retired.
6. Proposed Remedy: Specify how this request proposes to address the issue described.
Retire WECC VAR-002-WECC-2 because it is redundant to NERC VAR-002-4.
7. Functions: Each function will be reviewed if affected.
• Generator Operator
• Transmission Operators
8. Detailed Description:
The WECC RRS, VAR-002-WECC-2 requires that Generator Operators operate generators with
automatic voltage regulators (AVR) in the automatic voltage mode (automatic) 98 percent of
the time, excluding certain periods that qualify under the listed exemptions.
The NERC Standard, VAR-002-4, requires that Generator Operators operate generators in AVR
mode when connected to the Bulk Electric System, unless instructed otherwise by the
Transmission Operator, or if the Generator Operator has notified the Transmission Operator
that the AVR is not operating in the automatic mode either because the generator is operating
below a level the AVR can operate or for another reason.
These two requirements are duplicative. Originally, one argument for passing the WECC
standard was that VAR-001-4.1 allowed Transmission Operators to exempt generators from
operating the AVR in automatic mode. However, the WECC Regional Variance to VAR-001-4.1
has now removed that allowance for WECC Transmission Operators. This means the
Transmission Operator cannot exempt generators from the requirement to operate the AVR in
automatic.
With the Regional Variance to VAR-001-4.1, arguably the WECC RRS is less stringent than the
continent-wide standard since it only requires that AVRs operate in automatic mode 98 percent
of the time as opposed to all of the time as required under the continent-wide standard.
For these reasons, it is recommended that VAR-002-WECC-2 be retired.
9. Affected Reliability Principles: Which of the following reliability principles is MOST affected by
this request? (select one)
• Reliability Principle 1 — Interconnected bulk electric systems shall be planned and
operated in a coordinated manner to perform reliably under normal and abnormal
conditions as defined in the NERC Standards.

During the development of this project, VAR-002-4, Generator Operation for Maintaining Network Voltage Schedules, was
replaced with Version 4.1. VAR-001-4.1, Voltage and Reactive Control, was replaced with Version 4.2. Both standards have
an effective date of September 26, 2017.

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Standard Authorization Request

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

See Reference Uploads.

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)
NERC VAR-001-4.1, Voltage and Reactive Control
NERC VAR-002-4, Generator Operation for Maintaining Network Voltage Schedules
WECC VAR-002-WECC-2, Automatic Voltage Regulators (AVR)

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WECC Standard VAR-002-WECC-2 — Automatic Voltage Regulators

A. Introduction

1. Title:

Automatic Voltage Regulators (AVR)

2. Number:

VAR-002-WECC-2

3. Purpose:

To ensure that Automatic Voltage Regulators on synchronous
generators and condensers shall be kept in service and controlling
voltage.

4. Applicability
4.1.

Generator Operators

4.2.

Transmission Operators that operate synchronous condensers

4.3.

This VAR-002-WECC-2 Standard only applies to synchronous
generators and synchronous condensers that are connected to the
Bulk Electric System.

5. Effective Date: On the first day of the first quarter, after applicable regulatory
approval.
B.

Requirements

R1.

Generator Operators and Transmission Operators shall have AVR in
service and in automatic voltage control mode 98% of all operating hours for
synchronous generators or synchronous condensers. Generator Operators
and Transmission Operators may exclude hours for R1.1 through R1.10 to
achieve the 98% requirement. [Violation Risk Factor: Medium] [Time Horizon:
Operations Assessment]
R1.1. The synchronous generator or synchronous condenser operates for less
than five percent of all hours during any calendar quarter.
R1.2. Performing maintenance and testing up to a maximum of seven
calendar days per calendar quarter.
R1.3. AVR exhibits instability due to abnormal system configuration.
R1.4. Due to component failure, the AVR may be out of service up to 60
consecutive days for repair per incident.
R1.5. Due to a component failure, the AVR may be out of service up to one
year provided the Generator Operator or Transmission Operator
submits documentation identifying the need for time to obtain
replacement parts and if required to schedule an outage.
R1.6. Due to a component failure, the AVR may be out of service up to 24
months provided the Generator Operator or Transmission
Operator submits documentation identifying the need for time for
excitation system replacement (replace the AVR, limiters, and controls
but not necessarily the power source and power bridge) and to
1

WECC Standard VAR-002-WECC-2 — Automatic Voltage Regulators

schedule an outage.
R1.7. The synchronous generator or synchronous condenser has not achieved
Commercial Operation.
R1.8. The Transmission Operator directs the Generator Operator to
operate the synchronous generator, and the AVR is unavailable
for service.
R1.9. The Reliability Coordinator directs Transmission Operator to
operate the synchronous condenser, and the AVR is unavailable
for service.
R1.10. If AVR exhibits instability due to operation of a Load Tap Changer
(LTC) transformer in the area, the Transmission Operator may
authorize the Generator Operator to operate the excitation
system in modes other than automatic voltage control until the
system configuration changes.
C. Measures

M1.

Generator Operators and Transmission Operators shall provide quarterly
reports to the compliance monitor and have evidence for each synchronous
generator and synchronous condenser of the following:
M1.1 The actual number of hours the synchronous generator or
synchronous condenser was on line.
M1.2 The actual number of hours the AVR was out of service.
M1.3 The AVR in service percentage.
M1.4 If excluding AVR out of service hours as allowed in R1.1 through
R1.10, provide:

M1.4.1

The number of hours excluded,

M1.4.2

The adjusted AVR in-service percentage,

M1.4.3

The date of the outage.

Compliance

Compliance Monitoring Process
1.1

Compliance Monitoring Responsibility
Compliance Enforcement Authority

1.2

WECC Standard VAR-002-WECC-2 — Automatic Voltage Regulators

- Periodic audit as scheduled by the Compliance Enforcement Authority
- Investigations
- Other methods as provided for in the Compliance Monitoring
Enforcement Program
The Reset Time Frame shall be a calendar quarter.
1.3

Data Retention
The Generator Operators and Transmission Operators shall keep
evidence for Measures M1 for three years plus current year,
or since the last audit, whichever is longer.

1.4

Additional Compliance Information
1.4.1 The sanctions shall be assessed on a calendar quarter
basis.
1.4.2 If any of R1.2 through R1.9 continues from one quarter to
another, the number of days accumulated will be the
contiguous calendar days from the beginning of the
incident to the end of the incident. For example, in R1.4 if
the 60 day repair period goes beyond the end of a quarter,
the repair period does not reset at the beginning of the
next quarter.

1.4.3

When calculating the in-service percentages, do not include the
time the AVR is out of service due to R1.1 through R1.10.

1.4.4

The standard shall be applied on a machine-by-machine basis (a
Generator Operator or Transmission Operator can be subject to a
separate sanction for each non-compliant synchronous generator
and synchronous condenser).

Regional Differences

None

WECC Standard VAR-002-WECC-2 — Automatic Voltage Regulators
Table of Compliance Elements

R
R1

Time Horizon
Operational
Assessment

VRF
Medium

Lower VSL
There shall be a
Lower Level of
non-compliance
if AVR is in
service less than
98% but at least
90% or more of
all hours during
which the
synchronous
generating unit
or synchronous
condenser is on
line for each
calendar
quarter.

Violation Severity Levels
Moderate VSL
High VSL
There shall
There shall be a
High Level of nonbe a
compliance if AVR
Moderate
is in service less
Level of nonthan 80% but at
compliance
least 70% or more
if AVR is in
of all hours during
service less
which the
than 90%
synchronous
but at least
generating unit or
80% or
synchronous
more of all
condenser is on
hours
line for each
during
calendar quarter.
which the
synchronou
s generating
unit or
synchronou
s condenser
is on line for
each
calendar
quarter.

Severe VSL
There
shall be a
Severe
Level of
noncomplian
ce if AVR
is in
service
less than
70% of all
hours
during
which
the
synchron
ous
generatin
g unit or
synchron
ous
condense
r is on
line for
each
calendar
quarter.

WECC Standard VAR-002-WECC-2 — Automatic Voltage Regulators

Version History

Version

Date

Action

April 16, 2008

Permanent Replacement Standard
for VAR-STD-002a-1

April 21, 2011

FERC Order issued approving VAR002-WECC-1 (FERC approval
effective June 27, 2011; Effective
Date July 1, 2011)

November 13,
2014

Adopted by NERC Board of Trustees

March 3, 2015

FERC letter order approving VAR002-WECC-2

Change Tracking

Attachment C
Project Roadmap
WECC-0127 VAR-002-WECC-2
Request to Retire

Project Roadmap
Actions
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.

Proposed Date

SAR Filed
Drafting Team solicitation
WSC approved the SAR
Notice of DT Assignment
Notice of DT Solicitation – Augmented
DT meeting
DT meeting
DT meeting
DT meeting
DT meeting
Posting 1 Comments Open
Posting 1 Comments Closed (45-day)
DT meets to answer Comments
WSC approves for Ballot
Notice of Ballot Pool Forming
Ballot Pool Open
Ballot Pool Close
Standards Briefing
Ballot Open
Ballot Close
NERC Posting for 45 days – Open
WSC approves for WECC Board of Directors disposition
WECC Board of Directors approval
NERC Posting for 45 days – Closed
NERC Board of Trustees approval
FERC approval

6
November 21, 2016
December 6, 2016
January 24, 2017
February 27, 2017
March 2, 2017
April 11, 2017
April 18, 2017
April 25, 2017
May 25, 2017
May 31, 2017
July 18, 2017
July 27, 2017
July 31, 2017
August 23, 2017
August 30, 2017
September 14, 2017
September 19, 2017
September 21, 2017
October 11, 2017
November 3, 2017
November 15, 2017
December 6, 2017
December 18, 2017
February 8, 2018
TBD

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

Attachment D
Implementation Plan
WECC-0127 VAR-002-WECC-2
Request to Retire
Standard Authorization Request (SAR) 1
WECC-0127 SAR
Approvals Required
•
•
•

WECC Board of Directors
NERC Board of Trustees
FERC

December 6, 2017
February 8, 2018
Pending

Applicability Section
4.1.

Generator Operators

4.2.

Transmission Operators that operate synchronous condensers

4.3.

This VAR-002-WECC-2 Standard only applies to synchronous generators
and synchronous condensers that are connected to the Bulk Electric
System.

This Implementation Plan was originally posted as part of the WECC-0127 VAR-002-WECC-2 Posting 1 Technical
Justification document. It was removed from that document for purposes of NERC filing.

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

Attachment E
Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators (AVR)

Cover Sheet
Technical Justification
Retirement of WECC Regional Reliability Standard
VAR-002-WECC-2
Automatic Voltage Regulators (AVR)

Attachment G: White Paper
Retirement of WECC Regional Reliability Standard
VAR-002-WECC-2
Automatic Voltage Regulators (AVR)
Subtitle
Author or Author Group
Date

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

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WECC-0127 VAR-002-WECC-2 Request to Retire

Page 3 of 22

Executive Summary
The WECC-0127, VAR-002-WECC-2, Automatic Voltage Regulators Drafting Team (DT) has reviewed
NERC Standards, both in effect and those standards that are approved pending regulatory filing, and
concluded that the substance of the WECC Regional Reliability Standard (RRS) 1 should be retired
immediately and in its entirety because:
•

The standard no longer meets either of the Federal Energy Regulatory Commission’s (FERC)
criteria for a Regional Reliability Standard.

•

The standard falls short of Order 672 requirements for clarity and may obfuscate due process.

•

The reliability-related substance is addressed in peripheral NERC Standards (VAR-002-4.1,
Generator Operation for Maintaining Network Voltage Schedules and VAR-001-4.2 Voltage and
Reactive Control). 2

•

Proposed retirement of Regional Reliability Standard VAR-002-WECC-2 and requiring the
Generator Operator to comply with VAR-002-4.1 will have the Generator Operators providing
Transmission Operators with procedures or other documents in real-time that inform the
Transmission Operator of when an automatic voltage regulator (AVR) will be out-of-service
such as:
1) having the automatic voltage regulator in service at all times except during specific
circumstances;
2) maintaining AVR to stated criteria;
3) installing and completing start-up testing of an automatic voltage regulator; and
4) repairing or replacing an AVR within a specified time. 3

•

The proposed retirement of Regional Reliability Standard VAR-002-WECC-2 and following the
requirements of VAR-002-4.1 improves on the existing regional Reliability Standard by focusing
the in-service requirement on performance of the automatic voltage regulator rather than
counting the hours they are online; stating the automatic voltage regulator policies and
guidelines into the NERC Standard, and reducing administrative requirements with little benefit
to reliability.

If the document is retired, the reliability-related substance is still addressed in peripheral NERC
Standards.

Unless otherwise specified, capitalized terms are those defined in the Glossary of Terms Used in NERC Reliability
Standards, the NERC Functional Model, and the NERC Rules of Procedures.
2
There was a version change from 4.1 to 4.2 during the development of this project.
3

There was a version change from 4 to 4.1 during the development of this project.

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

Overview
The following narrative and crosswalk are offered in support of retiring the entire standard. This
document is presented in three segments: 1) presentation in narrative form, 2) a tabular
representation of the standard and how it is addressed in other NERC standards, and 3) inclusion of the
standard proposed for retirement.4
If you have questions on the narrative, the DT encourages you to contact the DT chair, Mr. David
Lemmons at (770) 407-7584, or WECC staff support Mr. W. Shannon Black at (503) 307-5782.

Development History of VAR-002-WECC-2
WECC filed the Version Zero of the standard after a “1996 disturbance, which was caused by
insufficient supply of reactive power from generators, including automatic voltage regulators that were
not operating in voltage control mode. Because of this experience, WECC determined that there
should be only very limited circumstances where a generator should remove its unit from [Automatic
Voltage Regulation Regulation] operation.” 5
On June 8, 2007, FERC approved eight WECC Regional Reliability Standards that apply in the Western
Interconnection, including WECC-VAR-STD-002a-1 (Automatic Voltage Regulators) and WECC-VAR-STD002b-1 (Power System Stabilizer). FERC subsequently approved revisions to both WECC-VAR-STD-002a1 and WECC VAR-STD-002b-1, which were re-designated VAR-002-WECC-1 and VAR-501-WECC-1,
respectively, in Order No. 751.
On March 15, 2012, FERC issued an order commonly known as the Find, Fix, and Track (FFT) Order in
which Paragraph 81 suggested a review of all standards targeting retirement of redundant or
otherwise unneeded requirements (AKA: P81). In response, NERC and WECC identified for retirement
VAR-002-WECC-1, Requirement R2. Requirement R2 was retired resulting in VAR-002-WECC-2.
In reviewing VAR-002-WECC-2, the WECC-0127 DT determined that full retirement of the standard
would be in order.

Order Approving Regional Reliability Standards for the Western Interconnection and Directing Modifications, Docket No.
RR07-11-000, 119 FERC ¶ 61,260, (Issued June 8, 2007), P.114 (hereafter cited as RRS Order). An “automatic voltage
regulator” is a device that continuously monitors the generator terminal voltage and changes the reactive power output as
required to maintain (or regulate) the voltage within a pre-determined voltage range. For example, if a load increase causes
a decline in system voltages and thereby the terminal voltage of a generator, the automatic voltage regulator will increase
the generator’s reactive output to raise the terminal voltage (RRS Order, Fn 86).

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Criteria for Acceptance of a Regional Reliability Standard (RRS)
A regional difference from a continent-wide Reliability Standard must either be: (1) more stringent
than the continent-wide Reliability Standard, or (2) necessitated by a physical difference in the BulkPower System.6 VAR-002-WECC-2 fails both tests. Further, because the reliability goal of the RRS is
addressed in VAR-002-4.1 and VAR-001-4.2, VAR-002-WECC-2 can be retired without incurring any
negative impact to reliability. Lastly, the language of VAR-002-WECC-2 is so vague as to fail the FERC’s
Order 672 threshold by obfuscating due process.

VAR-002-WECC-2 is less stringent than VAR-002-4.1 7
On March 3, 2015, the FERC approved VAR-002-WECC-2 on the premise that it was more stringent
than its NERC counterpart, VAR-002-3.8 The FERC’s conclusion was based on the premise that VAR002-WECC-2 “requires all synchronous generators to have their voltage regulator in service at all time
with only exceptions for specified circumstances. . . [whereas] [t]he related NERC Reliability
Standard. . . permits a generator to remove its automatic voltage regulator from service for additional
reasons.” 9 Although FERC’s conclusion was accurate, analysis since VAR-002-WECC-2’s inception
shows that the applicable entity(s) could iteratively layer WECC’s exceptions resulting in a standard no
more stringent than VAR-002-3.
Further, the analysis shows the practical impact of VAR-002-WECC-2 is that the applicable entity simply
ends up counting hours of operation without any mandate to deploy automatic voltage regulation
should it not be in service. By contrast, VAR-002-4.1 requires remediation as well as implementation of
alternative operation in the event AVR is not in service. Finally, VAR-002-WECC-2 falls short of the
Order 672 criteria in that ambiguous wording obfuscates due process.

Compounding Exceptions
At first glance, the WECC standard appears to require AVR operation for 98 percent of all hours
whereas the NERC standard requires AVR operation for 100 percent of all hours. Although the prima
facie argument for retirement is met there, on closer examination, neither standard truly requires

Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the

Establishment, Approval, and Enforcement of Electric Reliability Standards, Order No. 672, FERC Stats. & Regs. 31,204, at P
291, order on reh’g, Order No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006).
7

Approval Order, P14.

Docket No. RD15-1-000, Order Approving Two Regional Reliability Standards, Issued March 3, 2015. Hereafter Approval
Order.

Approval Order P14.

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operation for a specified number of hours; therefore, neither the WECC 98 percent threshold nor the
NERC 100 percent threshold is greater when practical application is considered.
In VAR-002-WECC-2, the applicable entities are required to have AVR “in service and in automatic
voltage control mode 98 percent of all operating hours,” unless they are permitted not to run under
any one-of-ten possible scenarios. A first glance this limited set of exceptions is more stringent than
the broader allowance allowed by VAR-002-4.1; however, when practical application is considered the
limited set of exceptions offered by WECC becomes equal to or greater than the set of exceptions
allowed by VAR-002-4.1. As such, VAR-002-WECC-2 is not more stringent than VAR-002-4.1 and fails
the first test for approval as a Regional Reliability Standard.
A review of all ten scenarios shows that an application of eight of the ten exemptions allows the AVR to
be off 100 percent of the time, like VAR-002-4.1 (8760 hours per year), in some cases up to two years.
•

In R1.1 no AVR is required if a unit only runs 43.8 hours per year.

•

In R1.3 no AVR is required if there is “instability due to abnormal system configuration.”

•

In R1.5 no AVR is required if there is component failure with an explanation. (Up to two years.)

•

In R1.6 no AVR is required if there is component failure with an explanation. (Up to two years.)

•

In R1.7 no AVR is required if the unit is not commercially operational.

•

In R1.8/9 no AVR is required if the unit is “unavailable.”

•

In R10 no AVR is required if there are issues with Load Tap Changer operations.

The 100 percent exception offered by these eight exemptions is no more stringent than VAR-002-4.1.
Only in exceptions R1.2 and R1.4 is there an objective and quantifiable mandate to run AVR.
Under Requirement R1.2, an entity is arguably required to run for no less than 7912.8 hours annually. 10
The unit is exempt from operation when performing “maintenance and testing up to a maximum of
seven calendar days per calendar quarter.” However, if the seven-day maintenance and testing
exemption is used up, depending on the precipitating fact pattern, the AVR might continue to be off
due to instability (R1.3 and R1.10), due to component failure for up to two years (R1.4, R1.5, and R1.6),
or simply because the unit was unavailable (R1.8 and R1.9). Depending on the precipitating fact
pattern, the R1.2 exception could be compounded with many of the other exceptions resulting in no
practical mandate to run AVR.
In like fashion, under Requirement R1.4, an entity is arguably required to run for no less than 7147.8
hours annually. 11 The unit is exempt from operation for “60 consecutive days for repair per incident.”
10

8760 hours annual – ((7 calendar days X 24 hours =168 hours) X 4 quarters) = 672 hours exempted)) – (the 2-percent
grace period allowed in the body of Requirement R1 (8760 X .02 = 175.2 hours)) = 7912.8 hours annually.
11

8760 hours annually – (60 days X 24 hours = 1440 hours) – (the 2-percent grace period allowed in the body of
Requirement R1 (8760 X .02 = 175.2 hours)) = 7144.8 hours annually).

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However, the additional qualifier “per incident” would allow the clock to reset on day 61, thereby
defeating the purpose of the limited window requiring the AVR to be on. Even if the 61-day reset
approach was not adopted, arguably the incident could be compounded with any number of the
remaining exemptions resulting in a component not running at all (see R1.2 explanation). In short,
Requirement R1.4 is no firmer in its mandate to run than the other Requirement R1 exemptions. Thus,
it is no more stringent than the allowable exceptions of VAR-002-4.1. Because it is no more stringent it
fails the first prong test for approval as a Regional Reliability Standard and should be retired.
VAR-002-4.1 carries a similarly vague exception to running in that Requirement R1 requires the
applicable entity to operate its generator in AVR mode: 1) except when some other mode is called for
by the Transmission Operator, 2) except when exempted by the Transmission Operator, or 3) except
when the Generator Operator notifies the Transmission Operator that one of a specific number of
exceptions has occurred. VAR-002-4.1’s 100 percent requirement to run, though prima facie evidence
of being more stringent than VAR-002-WECC-2, is further reduced each time: 1) the generator is being
operated in start-up, shutdown, or testing mode, 2) the Transmission Operator exempts the AVR from
running, or 3) the AVR is out-of-service.
In short, like VAR-002-WECC-2, VAR-002-4.1 contains so many exceptions to the rule that neither the
98 percent nor the 100 percent threshold have a concrete numerical meaning. Neither threshold is
better than the other. Ultimately, whether a unit is on or off will be completely fact specific under
each of the standards. As such, the WECC Regional Reliability Standard is no more stringent that the
NERC Standard, fails the Order 672 test, and should not be retained on that premise. Further blurring
the line between the 98 percent and 100 percent thresholds, the language of VAR-002-WECC-2 is
sufficiently ambiguous to either obfuscate due process or to create undefined discretionary powers for
the applicable entities.
VAR-002-WECC-2 Obfuscates Due Process 12
Per Order 672 at P325, the Regional 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.

The Federal Energy Regulatory Commission (FERC) Order 740, Docket No. RM09-15-000, P23, noted that “in the Western
Interconnection a significant number of transmission paths are voltage or frequency stability-limited, in contrast to other
regions of the [BES] where transmission paths more often are thermally-limited. Disturbances resulting in a stability-limited
transmission path overload, generally, must be responded to in a shorter time frame than a disturbance that results in a
thermally-limited transmission path overload. [FERC has also noted] its understanding that this physical difference is one of
the reasons for the need for certain provisions of regional Reliability Standards in the Western Interconnection.”

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No Criteria for Instability
In VAR-002-WECC-2, Requirements R1.3 and R.10 allows no AVR if the AVR exhibits “instability due to
abnormal system configuration” (R1.3) or “instability due to operation of a Load Tap Changer” (R1.10).
It should be noted that nowhere in the document is there an explanation of what constitutes
“instability.” Presumably, the operator decides based on its own criteria. If so, this means the
operator has full discretion as to whether the AVR runs or not. Without precise boundaries, the
requirement offers no due process but immense latitude.
No Criteria for Components
VAR-002-WECC-2, Requirements R1.4, R1.5, and R1.6 allow no AVR for up to two years (R1.5 at one
year; R1.6 at two years) if a “component” fails. Like R1.3, what constitutes a component is not defined.
The Glossary of Terms Used in NERC Reliability Standards adds no definitive insights as there, a
component ranges from a generator, transmission line, circuit breaker, switch or electrical element
(see Contingency). What is known about the component is that an Element may contain more than
one component (see Element), an Interconnection contains many of them, they are part of a System
that may include generation, transmission, and distribution “components” (see System), and from R1.6
we know the intended components may include replacing the AVR, limiters, and controls but not
necessarily the power source and power bridge. In summary, like R1.3, the requirement is so vague as
to obfuscate due process and provide the applicable entity with an immense amount of discretion. 13
No Criteria for Unavailability
VAR-002-WECC-2, Requirements R1.8 and R1.9 require no AVR if the Transmission Operator directs the
Generator Operator to operate the generator, and the AVR is “unavailable.” There is no indication as
to who makes that determination or under what circumstances that determination is made. Plainly
defined, unavailable means not suitable for use. Without further definition, the operator could use
any number of undefined criteria to conclude its equipment was “unavailable.” What constitutes
unavailable is so vast that it obfuscates due process and in practice creates in the applicable entity the
ability to have AVR off for nearly any reason, so long as the reason is documented and the applicable
entity counts the associated hours.
In short, if the applicable entity decides the unit is unstable, unavailable, or that an undefined
component is not working well – there is no obligation to run AVR. When compared to the exemptions
allowed in VAR-002-4.1, the analysis shows little if any distinction. Because there is no call for
remediation in the event the AVR does not run, the practical result is a standard that counts hours.

Per Order 672 at P324, a proposed Reliability Standard must contain a technically sound method to achieve the goal.
VAR-002-WECC-2, exception R1. R1.1 requires no AVR if the unit runs for less than five percent of all hours during any
calendar quarter. Of note, the drafting team found no technical support for the five percent threshold lending to the
conclusion that it may be arbitrary.

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Counting Hours vs. Ensuring Reliability
VAR-002-WECC-2 has only one requirement – that the Generator Operators and Transmission
Operators have AVR in service and in AVR mode 98 percent of the time – unless otherwise exempted
under any one or more of the ten allowed exemptions. Because compliance with the standard is
structured toward documentation, in practice the applicable entity can work at building “up” to the 98
percent rather than keeping equipment in service 100 percent of the time. Compliance for the single
requirement is to file reports that count hours – nothing more. VAR-002-WECC-2 has no mandate for
remediation nor call for alternative means to support reliability if the AVR does not run.
By contrast, VAR-002-4.1 contains the additional benefit for reliability not otherwise contained in VAR002-WECC-2. VAR-002-4.1, Requirement R2.1 requires deployment of an alternate means to meet the
reliability goal in the event there is a concern with the AVR; no such deployment is required by the RRS.
VAR-002-4.1, Requirement R2.2 requires the Generator Operator to explain to the Transmission
Operator why it cannot comply with a schedule; no such communication is required by the RRS. VAR002-4.1, Requirement R2.3 requires an alternative means to meet the requirement goal; the RRS does
not. VAR-002-4.1, Requirement R3-R5 require reciprocal communication of events; the RRS requires
no communication. VAR-002-4.1 requires that step-up transformer tap change(s) take place as
needed; the RRS speaks of tap changes but creates no mandate to make the change(s). In each of
these requirements, VAR-002-4.1 exceeds the reliability mandates of VAR-002-WECC-2.
In the event the stringency of the two standards was found to be essentially the same (“Run, except
when you don’t.”), the drafting team argues that the scale of stringency should tip in favor of VAR-0024.1 because the latter requires remedial action whereas VAR-002-WECC-2 does not.
Physical Difference in the Bulk-Power System
A Regional Reliability Standard may be approved when the standard is needed because of a unique
physical difference in the Bulk-Power System. Although the drafting team continues to take note of
the Western Interconnection’s unique configuration and operational needs, the argument of unique
physicality is not applicable to this case.
Covered Elsewhere
Although VAR-002-WECC-2 Requirement R1 requires the Transmission Operator to have AVR in
service, VAR-002-4.1 has no reciprocal requirement for the Transmission Operator. However, the
reliability goal is captured in VAR-001-4.2 – Voltage and Reactive Control. There, Requirements R1 and
R2 require the Transmission Operator to specify a system voltage schedule (R1), and to schedule
sufficient reactive resources to regulate voltage levels under normal and Contingency conditions. To
the extent that VAR-001-4.2 requires the Transmission Operator to specify and schedule reactive
resources such as AVR, R1 and R2 of VAR-001-4.1 meet the reliability goal of VAR-002-WECC-2 without
specifying “how” the task is met (results oriented). Thus, if VAR-002-WECC-2 is retired, the reliability

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task specific to the Transmission Operator remains intact in VAR-001-4.2. Similarly, VAR-002-4.1
covers the Generator Operator’s requirements, unless otherwise exempted.
The drafting team noted that VAR-001-4.2 Requirement R3 requires the Transmission Operator to
“operate or direct the Real-time operation of devices to regulate transmission voltage and reactive
flow as necessary.” Whereas VAR-002-WECC-2 creates a static setting for the AVR, thereby removing
discretion from the operator, VAR-001-4.2 allows the operator to attain the same reliability goal based
on all the surrounding circumstances in Real-time. For example, although VAR-002-WECC-2 requires
synchronous condensers to have the AVR in service and in automatic voltage control mode, VAR-0014.2 R3 and associated schedule-related requirements allow greater flexibility of operation while
meeting the same reliability goal. This means that a specific listing of the synchronous condenser need
not be retained in VAR-002-WECC-2 because VAR-001-4.2 allows the Transmission Operator to include
it as needed in reactive power schedules.
Finally, in examining VAR-001-4.2, the drafting team notes that the obligations of the Transmission
Operator are carried into the Regional Variance.
VAR-001-4.2 contains a WECC Regional Variance that supersedes NERC’s Requirements R4 and R5.
When applied, the variance does not allow the Transmission Operator to exempt the Generator
Operator from operating its AVR; therefore, any generator not having a functioning AVR is required to
work with the Transmission Operator to correct the issue. As such, if VAR-002-WECC-2 is retired, the
more stringent approach taken in the variance is retained to ensure reliability.

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Section 2: Tabular Crosswalk – Covered Elsewhere
Requirement R1
R1. Generator Operators and Transmission Operators shall have AVR in service and in automatic
voltage control mode 98 percent of all operating hours for synchronous generators or synchronous
condensers. Generator Operators and Transmission Operators may exclude hours for R1.1 through
R1.10 to achieve the 98 percent requirement. [Violation Risk Factor: Medium] [Time Horizon:
Operations Assessment]
(Exceptions R1.1 through R1.10 are covered below.)

Analysis Table: Requirement R1
Applicable Entities and Facilities Covered Elsewhere

WECC Standard

NERC Standards

Narrative

VAR-002-WECC-2

VAR-001-4.2

Applicability

4.1 Generator Operators

4.1 Transmission Operators

The Applicable Entities of the
WECC Standard are addressed
in VAR-001-4.2 and VAR-0024.1.

4.2 Transmission Operators
that operate synchronous
condensers

4.2 Generator Operators
within the Western
Interconnection (for the
WECC Variance)

4.3 This VAR-002-WECC-2
Standard only applies to
synchronous generators and
synchronous condensers that
are connected to the Bulk
Electric System.

E S T E R N

VAR-002-4.1
Applicability
4.1 Generator Operator
4.2 Generator Owner

L E C T R I C I T Y

Whereas VAR-002-WECC-2
specifically identifies
generators and synchronous
condensers as the applicable
facilities, these specific assets
need not be called out.
Rather, by setting the voltage
schedule as a results-oriented
goal, the Transmission
Operator can allow for an
array of assets to deploy
without confining the
resources to a specific list.

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Analysis Table: Requirement R1
AVR in Service and Controlling – Covered Elsewhere
VAR-002-WECC-2

VAR-002-4

VAR-001-4.1

Generator Operator
and Transmission
Operator

Generator Operator

Transmission Operator

R1. Generator
Operators and
Transmission
Operators shall have
AVR in service and in
automatic voltage
control mode.

R1. The Generator
Operator shall
operate each
generator
connected to the
interconnected
transmission system
(with its automatic
voltage regulator
(AVR) in service) in
the automatic
voltage control
mode.

R1. Each Transmission
Operator shall specify a
system voltage
schedule (which is
either a range or a
target value with an
associated tolerance
band) as part of its plan
to operate within
System Operating
Limits and
Interconnection
Reliability Operating
Limits.

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Narrative

The Generator
Operator and the
Transmission
Operator’s reliability
tasks are addressed in
VAR-002-4.1 and VAR001-4.2. and the
Regional Variance. By
creating the voltage
schedule, the
Transmission Operator
sets the reliability goal
to be met without
restricting the specific
type of resource to be
used. Restated, the
VAR-01-4.2 approach is
inclusive of VAR-002WECC-2 without
specifying “how” the
goal is to be met.

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VAR-002-WECC-2

VAR-002-4

13
VAR-001-4.1

Narrative

R2. Each Transmission
Operator shall
schedule sufficient
reactive resources to
regulate voltage levels
under normal and
Contingency
conditions. (Various
means are allowed.)
R3. Each Transmission
Operator shall operate
or direct the Real-Time
operation of device to
regulate transmission
voltage and reactive
flow as necessary.

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Analysis Table: Requirement R1
Exceptions to the Rule – Covered Elsewhere
VAR-002-WECC-2

VAR-002-4.1

Narrative

General: AVR shall be in
service 98 percent of the time,
unless covered by one of ten
exceptions.

General: AVR shall be in
service 100 percent of the
time, unless covered by an
exception.

Because the VAR-002-WECC-2
list of exceptions can be
compounded, the practical
result is that the specific list of
exceptions is not more
stringent than the generalized
exception offed in VAR-002-4.1.
Thus, VAR-002-WECC-2 is not
more stringent than VAR-0024.1.

Exceptions:

R1.1 through R1.10.

[When] the generator is
being operated in start-up,
shutdown, or testing mode
pursuant to a Real-time
communication or a
procedure that was
previously provided to the
Transmission Operator; or
(AKA: Start up, shutdown, or
testing.)
[When] the generator is not
being operated in automatic
voltage control mode or in
the control mode that was
instructed by the
Transmission Operator for a
reason other than start-up,
or testing.
(AKA: Other than start up,
shutdown, or testing.)

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VAR-002-WECC-2

VAR-002-4.1

R1.1 The synchronous
generator or synchronous
condenser operates for less
than five percent of all hours
during any calendar quarter.

[R1.1] Other than start up,
shutdown, or testing.

R1.2. Performing
maintenance and testing up to
a maximum of seven calendar
days per calendar quarter.

[R1.2] Start up, shutdown, or
testing.

R1.3. AVR exhibits instability
due to abnormal system
configuration.

R1.4. Due to component
failure, the AVR may be out of
service up to 60 consecutive
days for repair per incident.

R1.5. Due to a component
failure, the AVR may be out of
service up to one year
provided the Generator
Operator or Transmission
Operator submits
documentation identifying the
need for time to obtain
replacement parts and if
required to schedule an
outage.

E S T E R N

Narrative

[R1.3] Other than start up,
shutdown, or testing.

[R1.4] Other than start up,
shutdown, or testing.

[R1.5] Other than start up,
shutdown, or testing.

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VAR-002-WECC-2

VAR-002-4.1

Narrative

R1.6. Due to a component
failure, the AVR may be out of
service up to 24 months
provided the Generator
Operator or Transmission
Operator submits
documentation identifying the
need for time for excitation
system replacement (replace
the AVR, limiters, and controls
but not necessarily the power
source and power bridge) and
to schedule an outage.

[R1.6] Other than start up,
shutdown, or testing.

R1.7. The synchronous
generator or synchronous
condenser has not achieved
Commercial Operation.

[R1.7] Start up, shutdown, or
testing.

R1.8. The Transmission
[R1.8] Other than start up,
Operator directs the
shutdown, or testing.
Generator Operator to operate
the synchronous generator,
and the AVR is unavailable for
service.
R1.9. The Reliability
Coordinator directs
Transmission Operator to
operate the synchronous
condenser, and the AVR is
unavailable for service.

[R1.9] Other than start up,
shutdown, or testing.

R1.10. If AVR exhibits
instability due to operation of
a Load Tap Changer (LTC)
transformer in the area, the
Transmission Operator may

[R1.10] Other than start up,
shutdown, or testing.

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VAR-002-WECC-2

VAR-002-4.1

Narrative

authorize the Generator
Operator to operate the
excitation system in modes
other than automatic voltage
control until the system
configuration changes.

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Section 3: Existing Standard Proposed for Retirement

VAR-002-WECC-2
A. Introduction

1. Title:

Automatic Voltage Regulators (AVR)

2. Number:

VAR-002-WECC-2

3. Purpose:

To ensure that Automatic Voltage Regulators on synchronous generators and
condensers shall be kept in service and controlling voltage.

4. Applicability
4.1.

Generator Operators

4.2.

Transmission Operators that operate synchronous condensers

4.3.

This VAR-002-WECC-2 Standard only applies to synchronous generators and
synchronous condensers that are connected to the Bulk Electric System.

5. Effective Date: On the first day of the first quarter, after applicable regulatory
approval.
B.

Requirements

R1.

Generator Operators and Transmission Operators shall have AVR in service and in
automatic voltage control mode 98% of all operating hours for synchronous generators
or synchronous condensers. Generator Operators and Transmission Operators
may exclude hours for R1.1 through R1.10 to achieve the 98% requirement.
[Violation Risk Factor: Medium] [Time Horizon: Operations Assessment]
R1.1. The synchronous generator or synchronous condenser operates for less than
five percent of all hours during any calendar quarter.
R1.2. Performing maintenance and testing up to a maximum of seven calendar days
per calendar quarter.
R1.3. AVR exhibits instability due to abnormal system configuration.
R1.4. Due to component failure, the AVR may be out of service up to 60
consecutive days for repair per incident.
R1.5. Due to a component failure, the AVR may be out of service up to one year
provided the Generator Operator or Transmission Operator submits
documentation identifying the need for time to obtain replacement parts and

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if required to schedule an outage.
R1.6. Due to a component failure, the AVR may be out of service up to 24 months
provided the Generator Operator or Transmission Operator submits
documentation identifying the need for time for excitation system
replacement (replace the AVR, limiters, and controls but not necessarily the
power source and power bridge) and to schedule an outage.
R1.7. The synchronous generator or synchronous condenser has not achieved
Commercial Operation.
R1.8. The Transmission Operator directs the Generator Operator to operate
the synchronous generator, and the AVR is unavailable for service.
R1.9. The Reliability Coordinator directs Transmission Operator to operate the
synchronous condenser, and the AVR is unavailable for service.
R1.10. If AVR exhibits instability due to operation of a Load Tap Changer (LTC)
transformer in the area, the Transmission Operator may authorize the
Generator Operator to operate the excitation system in modes other than
automatic voltage control until the system configuration changes.
C. Measures

M1.

Generator Operators and Transmission Operators shall provide quarterly reports to the
compliance monitor and have evidence for each synchronous generator and
synchronous condenser of the following:
M1.1 The actual number of hours the synchronous generator or synchronous
condenser was on line.
M1.2 The actual number of hours the AVR was out of service.
M1.3 The AVR in service percentage.
M1.4 If excluding AVR out of service hours as allowed in R1.1 through R1.10,
provide:

M1.4.1

The number of hours excluded,

M1.4.2

The adjusted AVR in-service percentage,

M1.4.3

The date of the outage.

Compliance

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
1.

Compliance Monitoring Process
1.1

Compliance Monitoring Responsibility
Compliance Enforcement Authority

1.2

Compliance Monitoring Period
Compliance Enforcement Authority may use one or more of the following
methods to assess compliance:
- Reports submitted quarterly
- Spot check audits conducted anytime with 30 days notice
- Periodic audit as scheduled by the Compliance Enforcement Authority
- Investigations
- Other methods as provided for in the Compliance Monitoring
Program

Enforcement

The Reset Time Frame shall be a calendar quarter.
1.3

Data Retention
The Generator Operators and Transmission Operators shall keep
evidence for Measures M1 for three years plus current year,
or since the last audit, whichever is longer.

1.4

Additional Compliance Information
1.4.1 The sanctions shall be assessed on a calendar quarter basis.
1.4.2 If any of R1.2 through R1.9 continues from one quarter to
another, the number of days accumulated will be the contiguous
calendar days from the beginning of the incident to the end of the
incident. For example, in R1.4 if the 60 day repair period goes
beyond the end of a quarter, the repair period does not reset at
the beginning of the next quarter.

1.4.3

When calculating the in-service percentages, do not include the time the
AVR is out of service due to R1.1 through R1.10.

1.4.4

Regional Differences

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

None
Table of Compliance Elements

R
R1

Time Horizon
Operational
Assessment

VRF
Medium

E S T E R N

L E C T R I C I T Y

Violation Severity Levels
Moderate VSL
High VSL
There shall be a
There shall
High Level of nonbe a
compliance if AVR
Moderate
Level of nonis in service less
compliance
than 80% but at
if AVR is in
least 70% or more
service less
of all hours during
than 90%
which the
but at least
synchronous
80% or
generating unit or
more of all
hours
synchronous
during
condenser is on
which the
line for each
synchronou
calendar quarter.
s generating
unit or
synchronou
s condenser
is on line for
each
calendar
quarter.

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

Version History

Version

Date

Action

April 16, 2008

Permanent Replacement Standard
for VAR-STD-002a-1

April 21, 2011

FERC Order issued approving VAR002-WECC-1 (FERC approval
effective June 27, 2011; Effective
Date July 1 2011)
Adopted by NERC Board of Trustees

November 13,
2014

March 3, 2015

E S T E R N

Change Tracking

FERC letter order approving VAR002-WECC-2

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 Standard Submittal Request
Attachment F
Western Electricity Coordinating Council

Region:
Regional Standard Number:
VAR‐002‐WECC‐2
Regional Standard Title:
Automatic Voltage Regulators (AVR)
Date Submitted:
March 2, 2018
Regional Contact Name:
Steven Rueckert
Regional Contact Title:
Director of Standards
Regional Contact Telephone
(801) 883‐6878
Number:
Request (check all that apply):
Retirement of WECC Regional Reliability Standard: VAR‐002‐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 upon 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 Standard 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 This is a request to retire WECC Regional Reliability Standard VAR‐
basis and purpose (scope) 002‐WECC‐2, Automatic Voltage Regulators (AVR).
of request:
See detail that follows.
Concise statement of the The WECC‐0127, VAR‐002‐WECC‐2, Automatic Voltage Regulators
justification of the
Drafting Team (DT) reviewed NERC Standards, both in effect and
request:
those standards that are approved pending regulatory filing,
concluding that VAR‐002‐WECC‐2 should be retired immediately and
in its entirety because:




The reliability content of VAR‐002‐WECC‐2 is addressed in other
NERC Standards (VAR‐002‐4.1, Generator Operation for
Maintaining Network Voltage Schedules and VAR‐001‐4.2
Voltage and Reactive Control).
The standard does not meet either of the Federal Energy
Regulatory Commission’s (FERC) criteria for a Regional Reliability
Standard in that it neither covers unique subject matter nor are
its requirements any more stringent than those required by
NERC.
The standard falls short of Order 672 requirements for clarity and
may obfuscate due process in that it: 1) is ambiguous as to what
constitutes “instability,” 2) is ambiguous as to the “components”
to which it applies, and 3) is ambiguous as to what constitutes
“unavailability.”

2
Regional Reliability Standard Submittal Request



Retirement of VAR‐002‐WECC‐2 with a default to VAR‐002‐4.1,
Generator Operation for Maintaining Network Voltage Schedules
and VAR‐001‐4.2 Voltage and Reactive Control improves upon
VAR‐002‐WECC‐2 by focusing the in‐service requirement on
actual operational performance of the automatic voltage
regulator as opposed to merely counting how many hours the
equipment is in use.

3
Regional Reliability Standard Submittal Request

Attachment G
Order 672 Criteria
WECC-0127 VAR-002-WECC-2
Request to Retire
Not used
A response to FERC Order 672 Criteria to analyze proposed Reliability Standards for approval to ensure
they are just, reasonable, not unduly discriminatory or preferential, and in the public interest is not
provided because the entire standard is proposed for retirement.

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

Attachment H
Drafting Team Roster
WECC-0127 VAR-002-WECC-2
Request to Retire
Below please find a biographical snapshot for the members of the WECC-0127 VAR-002-WECC-2,
Automatic Voltage Regulators (AVR), Request to Retire Drafting Team.

Name

Background

Todd
Komaromy

Mr. Komaromy co-authored the WECC-0127 Standard Authorization Request
(SAR).

Arizona Public
Service

Having spent time as a Senior Associate, with 8 years of law firm experience in
the large law firms of Squire Patton Boggs and Snell & Wilmer, the practice of
administrative law and statutory interpretation before Federal Agencies was
core to his work. Development of precise technical language and associated
explanations was part and parcel to these efforts.
Mr. Komaromy also holds an electrical engineering degree with 14 years’
experience, in the Technical Writing, Fossil Generation, Lobbying, Contracts,
Intellectual Property, Transmission/Distribution, and Compliance arenas. Mr.
Komaromy currently serves in a corporate capacity as the AZPS Manager of
NERC Regulatory Compliance, responsible for leading the planning,
development, implementation and maintenance of the compliance framework
for reliability standards. Included in these duties is providing expertise,
guidance and management of AZPS’s VAR-002 reporting for both the
continental and regional standards.
Mr. Komaromy has a Bachelor of Science degree in Electrical Engineering from
The Ohio State University, MBA and a Juris Doctor degree from the Sandra Day
O’Conner College of Law - Arizona State University.

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

Document Title
David Lemmons

2
Mr. Lemmons began his career in the electric industry with Southwestern
Public Service Company (SPS) in Amarillo, Texas, in 1989. He spent eight years
in the rates and regulation department where he performed rate of return
analyses, designed rates and worked with other regulatory issues.
In 1997, Mr. Lemmons transferred to the energy trading department during the
merger between SPS and Public Service Company of Colorado (PSCo). In this
capacity, with Xcel Energy and its predecessor, New Century Energies, he
analyzed the electric system loads and resources for day-ahead and real-time
operations and trading — working with generation and fuel procurement to
ensure resources were ready and available to serve loads.
In 2001, Mr. Lemmons took the position of Senior Manager, Market
Operations, representing Xcel Energy at electric reliability, RTO development
and system operation meetings throughout the United States, as well as
providing support for state and Federal regulatory proceedings. Mr. Lemmons
has chaired the WECC-0083 BAL-002-WECC-1 Standard Drafting Team, the
NERC Project 2007-12 Standard Drafting team and is a team member on the
NERC Project 2010-14.1 Standard Drafting Team.
In 2013, Mr. Lemmons took his current position, Senior Consultant, Standards
Policy and Compliance. In this position, Mr. Lemmons is responsible for working
with power plants to ensure compliance with Reliability Standards, train plant
operators as needed and to represent Xcel Energy generation in the
development of new standards.
He holds a Master of Science degree in finance and economics from West Texas
A&M University.

Israel Perez

Salt River
Project

E S T E R N

Mr. Perez is a Mechanical Engineer and has worked at Salt River Project (SRP)
for over 10 years. The first three years focused on completing numerous
engineering projects as a rotational engineer in SRP’s generation fleet.
In 2009, Mr. Perez accepted a permanent position at an SRP generating facility
and spent the next six years project managing plant overhauls, budgeting
contracts & services, and developing to a Senior Engineer position as a Turbine
Engineer.

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

3
In 2015, Mr. Perez joined SRP’s Electric Reliability Compliance department in
the Operations and Planning team. In this position, Mr. Perez is responsible to
work with SRP’s responsible departments to ensure compliance with all O&P
Reliability Standards.

Shane
Kronebusch

Mr. Kronebusch is the Lead Electrical Engineer and Subject Matter Expert for
excitation systems, protection and hydro governors and unit controls for L&S
Electric, Inc. He has over 27 years of experience in the utility industry.
Prior to joining, L&S Electric in 2010, Mr. Kronebusch’ s responsibilities included
coordinating and preforming WECC testing of generation assets as an employee
of BC Hydro Generation Engineering and Maintenance Services. He was
responsible for commissioning of both new and rehabilitated units ranging in
size from 30MW to 500MW. Mr. Kronebusch was tasked as a subject matter
expert for exciters and governors as part of the BC Hydro Equipment Health
Rating program.
Mr. Kronebusch first became involved with WECC testing after the July and
August 1996 system disturbances that initiated the testing program. He has
been a member of the WECC Control Work Group since 2006.

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 I
Ballot Pool Members
WECC-0127 VAR-002-WECC-2
Request to Retire
WECC-0127 VAR-002-WECC-2 Ballot Pool
Title

Company

WECC-0127

Arizona Public
Service
Company

Sector

Vote Comments

Created By

Distribution

Yes

Michelle
Amarantos

WECC-0127

Arizona Public
Service
Company

Marketers
and Brokers

Yes

Linda
Henrickson

WECC-0127

Arizona Public
Service
Company

Generation

Yes

Nicholas
Kirby

WECC-0127

Arizona Public
Service
Company

System
Coordination

Yes

Vivian Vo

WECC-0127

Arizona Public
Service
Company

Transmission

Yes

Gary Nolan

WECC-0127

Avista
Corporation

Generation

Yes

Glen
Farmer

WECC-0127

Avista
Corporation

Marketers
and Brokers

Yes

Scott
Kinney

WECC-0127

Balancing
Authority of
Northern
California

System
Coordination

Yes

Joe
Tarantino

WECC-0127

Black Hills
Corporation

Yes

Sheila
Suurmeier

WECC-0127

Bonneville
Power
Administration

Yes

Rebecca
Berdahl

Generation

Distribution

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

Document Title

Title

Company

Sector

Vote Comments

Created By

WECC-0127

Bonneville
Power
Administration

Marketers
and Brokers

Yes

Andrew
Meyers

WECC-0127

Bonneville
Power
Administration

Transmission

Yes

Kammy
RogersHolliday

WECC-0127

Bonneville
Power
Administration

System
Coordination

Yes

Francis
Halpin

WECC-0127

British
Columbia
Hydro & Power System
Authority
Coordination

Yes

Patricia
Robertson

WECC-0127

British
Columbia
Hydro & Power
Authority
Transmission

Yes

Patricia
Robertson

WECC-0127

British
Columbia
Hydro & Power
Authority
Distribution

Hootan
Jarollahi

WECC-0127

British
Columbia
Hydro & Power
Authority
Generation

Helen
Hamilton
Harding

WECC-0127

California
Independent
System
Operator

System
Coordination

Yes

Richard
Vine

WECC-0127

California
Independent
System
Operator

Transmission

Yes

Richard
Vine

WECC-0127

Gridforce
Energy
Management,
LLC

System
Coordination

E S T E R N

L E C T R I C I T Y

David
Blackshear
C

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-0127

Idaho Power
Company

System
Coordination

Yes

Laura
Nelson

WECC-0127

Idaho Power
Company

Yes

Laura
Nelson

WECC-0127

Idaho Power
Company

Distribution

Yes

Laura
Nelson

WECC-0127

Idaho Power
Company

Transmission

Yes

Laura
Nelson

WECC-0127

Los Angeles
Department of
Water and
Power

System
Coordination

Pjoy Chua

WECC-0127

Los Angeles
Department of
Water and
Power

Generation

Pjoy Chua

WECC-0127

Los Angeles
Department of
Water and
Power

Distribution

Pjoy Chua

WECC-0127

Los Angeles
Department of
Water and
Power

Transmission

Pjoy Chua

WECC-0127

Los Angeles
Department of
Water and
Power

Marketers
and Brokers

Pjoy Chua

WECC-0127

Northern
California
Power Agency

Generation

Yes

Marty
Hostler

WECC-0127

Northern
California
Power Agency

Yes

Marty
Hostler

E S T E R N

Generation

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-0127

Northern
California
Power Agency

Marketers
and Brokers

Yes

Marty
Hostler

Yes

Kevin
Salsbury

Yes

Kevin
Salsbury

WECC-0127
WECC-0127

NV Energy

Generation

NV Energy

System
Coordination

WECC-0127

NV Energy

Distribution

Yes

Kevin
Salsbury

WECC-0127

NV Energy

Transmission

Yes

Kevin
Salsbury

WECC-0127

Platte River
Power
Authority

Marketers
and Brokers

Yes

Sabrina
Martz

WECC-0127

Platte River
Power
Authority

Generation

Yes

Tyson
Archie

WECC-0127

Platte River
Power
Authority

Transmission

Yes

Jeff Landis

WECC-0127

Platte River
Power
Authority

System
Coordination

Matthew
Thompson
Gordon
DobsonMack

Yes

Robert
Staton

Yes

Robert
Staton

WECC-0127

Powerex, Inc.

Marketers
and Brokers

WECC-0127

Public Service
Company of
Colorado (Xcel
Energy)

System
Coordination

WECC-0127

Public Service
Company of
Colorado (Xcel
Energy)

E S T E R N

Generation

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-0127

Public Service
Company of
Colorado (Xcel
Energy)

Vote Comments

Created By

Transmission

Yes

Robert
Staton

WECC-0127

Public Utility
District No. 1
of Snohomish
County

Generation

Yes

Franklin Lu

WECC-0127

Public Utility
District No. 1
of Snohomish
County

Distribution

Yes

Franklin Lu

WECC-0127

Public Utility
District No. 1
of Snohomish
County

Transmission

Yes

Franklin Lu

WECC-0127

Public Utility
District No. 1
of Snohomish
County

Marketers
and Brokers

Yes

Franklin Lu

WECC-0127

Public Utility
District No. 2
of Grant
County

System
Coordination

Yes

LeRoy
Patterson

WECC-0127

Public Utility
District No. 2
of Grant
County

Generation

Yes

LeRoy
Patterson

WECC-0127

Public Utility
District No. 2
of Grant
County

Distribution

Yes

LeRoy
Patterson

WECC-0127

Public Utility
District No. 2
of Grant
County

Transmission

Yes

LeRoy
Patterson

E S T E R N

Sector

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-0127

Public Utility
District No. 2
of Grant
County

Marketers
and Brokers

Yes

LeRoy
Patterson

WECC-0127

Puget Sound
Energy, Inc.

Generation

Yes

Eleanor
Ewry

WECC-0127

Puget Sound
Energy, Inc.

Marketers
and Brokers

Yes

Lynda
Kupfer

WECC-0127

Puget Sound
Energy, Inc.

System
Coordination

Theresa
Rakowsky

WECC-0127

Puget Sound
Energy, Inc.

Distribution

Theresa
Rakowsky

WECC-0127

Puget Sound
Energy, Inc.

Transmission

Theresa
Rakowsky

WECC-0127

Sacramento
Municipal
Utility District

System
Coordination

Yes

Joe
Tarantino

WECC-0127

Sacramento
Municipal
Utility District

Yes

Joe
Tarantino

WECC-0127

Sacramento
Municipal
Utility District

Yes

Joe
Tarantino

WECC-0127

Sacramento
Municipal
Utility District

Transmission

Yes

Joe
Tarantino

WECC-0127

Sacramento
Municipal
Utility District

Marketers
and Brokers

Yes

Joe
Tarantino

WECC-0127

Salt River
Project

Marketers
and Brokers

Bobby
Olsen

WECC-0127

Salt River
Project

Generation

Yes

Kevin
Nielsen

WECC-0127

Salt River
Project

Yes

Rudy
Navarro

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

Sector

Vote Comments

Created By

WECC-0127

San Diego Gas
& Electric

System
Coordination

Yes

Bridget
Silvia

WECC-0127

San Diego Gas
& Electric

Yes

Jerome
Gobby

WECC-0127

San Diego Gas
& Electric

Distribution

Yes

ANNIE
RUIZ

WECC-0127

San Diego Gas
& Electric

Transmission

Yes

Martine
Blair

WECC-0127

Seattle City
Light

Transmission

Yes

Hao Li

WECC-0127

Seattle City
Light

Marketers
and Brokers

Yes

Charles
Freeman

WECC-0127

Southern
California
Edison
Company

System
Coordination

Yes

Romel
Aquino

WECC-0127

Southern
California
Edison
Company

Distribution

Yes

Steven
Mavis

WECC-0127

Southern
California
Edison
Company

Transmission

Yes

Steven
Mavis

WECC-0127

Southern
California
Edison
Company

Yes

Thomas
Rafferty

WECC-0127

Southern
Power
Company

Generation

Yes

William D
(Bill) Shultz

Tacoma Power

System
Coordination

Yes

Twila Hofer

Yes

Karen
Hedlund

WECC-0127
WECC-0127

E S T E R N

Tacoma Power

Generation

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
WECC-0127

8
Company
Tacoma Power

Sector
Transmission

Vote Comments

Created By

Yes

Joseph
Wilson

Tacoma Power

Distribution

Yes

Chad
Edinger

WECC-0127

Tacoma Power

Marketers
and Brokers

Yes

Todd Lloyd

WECC-0127

Tri-State
Generation &
Transmission Reliability

System
Coordination

Yes

Tracy
Sliman

WECC-0127

Tri-State
Generation &
Transmission Reliability

Transmission

Yes

Tracy
Sliman

WECC-0127

Tri-State
Generation &
Transmission Reliability

Distribution

Janelle Gill

WECC-0127

Tri-State
Generation &
Transmission Reliability

Generation

Mark Stein

WECC-0127

Western Area
Power
Administration

System
Coordination

Patrick
Harwood

WECC-0127

E S T E R N

L E C T R I C I T Y

Yes

O O R D I N A T I N G

O U N C I L

Attachment J
Final Ballot Results
WECC-0127 VAR-002-WECC-2
Request to Retire
Ballot Name:

WECC-0127 VAR-002-WECC-2 Automatic Voltage Regulator
Request to Retire
The project requests complete retirement of VAR-002-WECC-2 on receipt of applicable
regulatory approval.

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

08/30/2017
09/14/2017
09/19/2017
10/11/2017
89
72
80.9%
100.0%
The request to retire VAR-002-WECC-2 was approved by the WECC-0127 Ballot Pool.
Total
In
Ballot
Pool

Votes
NonAbstain

Abstain

Total
Votes
for
Quorum

Sector
Weight

Didn't
Vote

0.0%

Generation

100.0%

Marketers and
Brokers

100.0%

0.0%

System
Coordination

100.0%

Transmission

100.0%

Totals

100.0%

Yes
Votes

Weighted
Segment
Vote

No
Votes

100.0%

Other NonRegistered

State and
Provincial
Representatives

Voting Sectors
Distribution
End User
Representative

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

Attachment K
Minority Issues
WECC-0127 VAR-002-WECC-2
Request to Retire
Following a ballot period from September 21 through October 11, 2017, the WECC Ballot Pool
approved retirement of WECC-0127 VAR-002-WECC-2 Automatic Voltage Regulators.
Development Phase Comments – Minority Opinion
Comment Response Forms and comments received during the development phase of this project are
included with this filing as Attachment R1.
This project was posted for comment on one occasion. The drafting team reviewed and considered all
comments received. The following minority opinions were expressed by the industry during the
development phase but were not accepted by the drafting team.
•

There were no minority opinions. This project received only one comment; that comment was in
support of immediate retirement. This project was approved with a 100-percent affirmative
ballot and no abstentions.

Ballot Phase Comments - Minority Opinion
The WECC Reliability Standards Development Procedures (Procedures) do not require a drafting team
to respond to comments provided during the balloting phase of a project.
During the balloting phase, the following minority opinions were expressed by the Ballot Pool.
•

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

Attachment L
WECC Standards Committee Roster
WECC-0127 VAR-002-WECC-2
Request to Retire
The following individuals are those assigned to the WECC Standards Committee as of October 1, 2017.
Sector

Name

Organization

1 Transmission

Dana Cabbell

Southern California Edison Company

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 M1
WECC Posting 1 Response to Comments
WECC-0127 VAR-002-WECC-2
Request to Retire
Posting 1
The WECC-0127 VAR-002-WECC-2, Automatic Voltage Regulators (AVR), Request to Retire Drafting
Team (DT) thanks everyone who submitted comments on the proposed document.
Posting
This document was posted for a 45-day public comment period from May 31 through July 18, 2017.
On May 25, 2017, WECC distributed notice of the posting via the Standards Email List.
The DT asked stakeholders to provide feedback on the proposed document through a standardized
electronic template. WECC received comments from one entity as shown in the following table.
Location of Comments
All comments received on the document can be viewed in their original format on the WECC-0127
project page under the “Submit and Review Comments” accordion.
Changes in Response to Comment
In response to comments received in Posting 1 the drafting team made no further changes to the
document.
Minority View
There were no minority concerns. The sole respondent was in support of the drafting team’s efforts.
Implementation Plan
The Reliability Standards Development Procedures (Procedures) require that an implementation plan
be posted with at least one posting of the project. The proposed date for retirement is immediately
upon receipt of regulatory approval. The drafting teams reports that no further actions are necessary
for retirement.
Action Plan
On July 27, the WECC-0127 VAR-002-WECC-2, Automatic Voltage Regulator Drafting Team agreed to
forward the document to WECC Standards Committee (WSC) with a request for ballot.
No further postings are anticipated.

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

Comment Report Form for WECC-0127
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC
Consultant. In addition, the WECC Reliability Standards Appeals Process can be found in the Reliability
Standards Development Procedures.

Comment Report Form for WECC-0127
WECC Standards Comment Table
Commenter
1 Laura Nelson

Organization
Idaho Power Company

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

Comment Report Form for WECC-0127

1. Response Summary
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment
Idaho Power Company

Response
Idaho Power agrees with the drafting team’s
justification and decision to retire VAR-002WECC-2.

The drafting team appreciates Idaho’s continued involvement in the standards development
process.

Attachment M2
Responses to Comments NERC
WECC-0127 VAR-002-WECC-2
Request to Retire
November 3 through December 18, 2017
Posting 1
The WECC-0127 VAR-002-WECC-2, Automatic Voltage Regulators, Request to Retire Drafting Team (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 six entities as shown in the following table.
Location of Comments
All comments received on the project can be viewed in their original format on the WECC-0127 project
page under the “Submit and Review Comments” accordion. Additionally, the raw data provided to
WECC by NERC in support of this filing is appended to this response form.
Changes in Response to Comment
No changes were made to the project based on the comments received during this posting.
Minority View
There were no minority concerns.
Effective Date and Implementation Plan
The Reliability Standards Development Procedures (Procedures) require that an implementation plan
be posted with at least one posting of the project. The proposed date for retirement is immediately
upon receipt of regulatory approval. The drafting team reports that no further actions are necessary
for retirement.

Comment Report Form for VAR-002-WECC-2
Action Plan
As of January 10, 2018, this project is awaiting filing at NERC.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC
Consultant. In addition, the WECC Reliability Standards Appeals Process can be found in the Reliability
Standards Development Procedures.

Comment Report Form for VAR-002-WECC-2
WECC Standards Comment Table
Commenter
1 Aaron Cavanaugh
2 John Tolo

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

Laurie Williams

Sandra Shaffer

PNM Resources - Public Service Company of New
Mexico (PNM)
Berkshire Hathaway – PacifiCorp (PAC)

5
6

Glen Farmer
Michelle Amarantos

Avista
Arizona Public Service Company (APS)

Index to Questions, Comments, and Responses
Questions
1. Do you agree the development of the Regional Reliability Standard met the “Open” criteria as
outlined above? If “No”, please explain in the comment area below:
2. Do you agree the development of the Regional Reliability Standard met the “Inclusive” criteria as
outlined above? If “No”, please explain in the comment area below:
3. Do you agree the development of the Regional Reliability Standard met the “Balanced” criteria as
outlined above? If “No”, please explain in the comment area below:
4. Do you agree the development of the Regional Reliability Standard met the “Due Process” criteria as
outlined above? If “No”, please explain in the comment area below:
5. Do you agree the development of the Regional Reliability Standard met the “Transparent” criteria as
outlined above? If “No”, please explain in the comment area below:

Comment Report Form for VAR-002-WECC-2
1. Response Summary
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment

Response

The WECC-0127 VAR-002-WECC-2, Automatic Voltage Regulators, Request to Retire 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 VAR-002-WECC-2
bar

Raw Data
provided by
NERC
Comment
Report
Project Name:

Regional Reliability Standard (WECC) | VAR-002-WECC-2 Retirement

Comment Period Start
Date:

11/3/2017

Comment Period End
Date:

12/18/2017

Associated Ballots:

There were 6 sets of responses, including comments from approximately 6 different
people from approximately 6 companies representing 4 of the Industry Segments as
shown in the table on the following pages.

Comment Report Form for VAR-002-WECC-2

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 VAR-002-WECC-2

Organization Name Segment(s) Region
Name

Group
Name

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

Comment Report Form for VAR-002-WECC-2

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

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
Document Name
Comment

Yes

Comment Report Form for VAR-002-WECC-2

Likes

Dislikes

Response

Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Yes

Document Name
Comment

Likes

Dislikes
Response

Comment Report Form for VAR-002-WECC-2
2. Do you agree the development of the Regional Reliability Standard met the “Inclusive”
criteria as outlined above? If “No”, please explain in the comment area below:
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
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
Document Name
Comment

Yes

Comment Report Form for VAR-002-WECC-2

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

Comment Report Form for VAR-002-WECC-2
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

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
Document Name
Comment

Yes

Comment Report Form for VAR-002-WECC-2

Likes

Dislikes

Response

Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Yes

Document Name
Comment

Likes

Dislikes
Response

Comment Report Form for VAR-002-WECC-2
4. Do you agree the development of the Regional Reliability Standard met the “Due
Process” criteria as outlined above? If “No”, please explain in the comment area below:
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
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
Document Name
Comment

Yes

Comment Report Form for VAR-002-WECC-2

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

Comment Report Form for VAR-002-WECC-2
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

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
Document Name
Comment

Yes

Comment Report Form for VAR-002-WECC-2

Likes

Dislikes

Response

Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Yes

Document Name
Comment

Likes

Dislikes
Response

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 VAR-002-WECC-2 — Automatic Voltage Regulators

A. Introduction

1. Title:

Automatic Voltage Regulators (AVR)

2. Number:

VAR-002-WECC-2

3. Purpose:

To ensure that Automatic Voltage Regulators on synchronous
generators and condensers shall be kept in service and controlling
voltage.

4. Applicability
4.1.

Generator Operators

4.2.

Transmission Operators that operate synchronous condensers

4.3.

This VAR-002-WECC-2 Standard only applies to synchronous
generators and synchronous condensers that are connected to the
Bulk Electric System.

5. Effective Date: On the first day of the first quarter, after applicable regulatory
approval.
B.

Requirements

R1.

WECC Standard VAR-002-WECC-2 — Automatic Voltage Regulators

M1.

M1.4.1

The number of hours excluded,

M1.4.2

The adjusted AVR in-service percentage,

M1.4.3

The date of the outage.

Compliance

Compliance Monitoring Process
1.1

Compliance Monitoring Responsibility
Compliance Enforcement Authority

1.2

WECC Standard VAR-002-WECC-2 — Automatic Voltage Regulators

Data Retention
The Generator Operators and Transmission Operators shall keep
evidence for Measures M1 for three years plus current year,
or since the last audit, whichever is longer.

1.4

1.4.3

When calculating the in-service percentages, do not include the
time the AVR is out of service due to R1.1 through R1.10.

1.4.4

Regional Differences

None

WECC Standard VAR-002-WECC-2 — Automatic Voltage Regulators
Table of Compliance Elements

R
R1

Time Horizon
Operational
Assessment

VRF
Medium

Violation Severity Levels
Moderate VSL
High VSL
There shall
There shall be a
be a
High Level of noncompliance if AVR
Moderate
Level of nonis in service less
than 80% but at
compliance
least 70% or more
if AVR is in
of all hours during
service less
which the
than 90%
synchronous
but at least
generating unit or
80% or
synchronous
more of all
condenser is on
hours
line for each
during
calendar quarter.
which the
synchronou
s generating
unit or
synchronou
s condenser
is on line for
each
calendar
quarter.

WECC Standard VAR-002-WECC-2 — Automatic Voltage Regulators
Version History

Version

Date

Action

April 16, 2008

Permanent Replacement Standard
for VAR-STD-002a-1

April 21, 2011

FERC Order issued approving VAR002-WECC-1 (FERC approval
effective June 27, 2011; Effective
Date July 1, 2011)

November 13,
2014

Adopted by NERC Board of Trustees

March 3, 2015

FERC letter order approving VAR002-WECC-2

Change Tracking

Attachment G
Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators (AVR)
Cover Sheet
Technical Justification
Retirement of WECC Regional Reliability Standard
VAR-002-WECC-2
Automatic Voltage Regulators (AVR)

Page 1 of 23

WECC-0127 VAR-002-WECC-2 Request to Retire

White Paper
Retirement of WECC Regional Reliability Standard
VAR-002-WECC-2
Automatic Voltage Regulators (AVR)

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

E S T E R N

Developed as WECC-0127

L E C T R I C I T Y
C O U N C I L

O O R D I N A T I N G

Attachment G
Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
Executive Summary
The WECC-0127, VAR-002-WECC-2, Automatic Voltage Regulators Drafting Team (DT) has reviewed
NERC Standards, both in effect and those standards that are approved pending regulatory filing, and
concluded that the substance of WECC Regional Reliability Standard (RRS) 1 should be retired
immediately and in its entirety because:


The standard does not meet either of the Federal Energy Regulatory Commission’s (Commission)
criteria for a Regional Reliability Standard.



The standard falls short of Order 672 requirements for clarity and may obfuscate due process.



The reliability-related substance is addressed in peripheral NERC Standards (VAR-002-4,
Generator Operation for Maintaining Network Voltage Schedules and VAR-001-4.1 Voltage and
Reactive Control).

•

Proposed retirement of Regional Reliability Standard VAR-002-WECC-2 and requiring the
generator operate to comply with VAR-002-4 will have the generator operators providing
transmission operators with procedures or other documents in real-time that inform the
transmission operator of when an automatic voltage regulator will be out-of-service such as: 1)
having the Automatic Voltage Regulator (AVR) in service at all times except during specific
circumstances, 2) maintaining AVR to stated criteria, 3) installing and completing start-up testing
of an automatic voltage regulator; and 4) repairing or replacing a AVR within a specified time
period.

•

The retiring of the proposed Regional Reliability Standard VAR-002-WECC-2 and following the
requirements of VAR-002-4 improves upon the existing regional Reliability Standard by focusing
the in-service requirement on performance of the automatic voltage regulator rather than
counting the hours they are online; stating the automatic voltage regulator policies and
guidelines into the NERC standard, and reducing administrative requirements with little benefit
to reliability.

If the document is retired, the reliability-related substance is still addressed in peripheral NERC
Standards.
Overview
The following narrative and crosswalk are offered in support of retiring the entire standard. This
document is presented in three segments: 1) presentation in narrative form, 2) a tabular representation

Unless otherwise specified, capitalized terms are those defined in the NERC Glossary of Terms Used in Reliability Standards,
the NERC Functional Model, and the NERC Rules of Procedures.
W E S T E R N E L E C T R I C I T Y C O O R D I N A T I N G
C O U N C I L
Developed as WECC-0127

Attachment G
Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
of the standard and how it is addressed in other NERC standards, and 3) inclusion of the standard
proposed for retirement.2
If you have questions on the narrative, the DT encourages you to contact the DT chair, Mr. David
Lemmons at (770) 407-7584, or WECC staff support Mr. W. Shannon Black at (503) 307-5782.
Development History of VAR-002-WECC-2
WECC filed the original Version Zero of the standard after a “1996 disturbance, which was caused by
insufficient supply of reactive power from generators, including automatic voltage regulators that were
not operating in voltage control mode. Because of this experience, WECC determined that there should
be only very limited circumstances where a generator should remove its unit from [Automatic Voltage
Regulation] operation.”3
On June 8, 2007, the Commission approved eight WECC Regional Reliability Standards that apply in the
Western Interconnection, including WECC-VAR-STD-002a-1 (Automatic Voltage Regulators) and WECCVAR-STD-002b-1 (Power System Stabilizer). The Commission subsequently approved revisions to both
WECC-VAR-STD-002a-1 and WECC VAR-STD-002b-1, which were re-designated VAR-002-WECC-1 and
VAR-501-WECC-1, respectively, in Order No. 751.
On March 15, 2012, the Commission issued an order commonly known as the Find, Fix, and Track (FFT)
Order in which Paragraph 81 suggested a review of all standards targeting retirement of redundant or
otherwise unneeded requirements (AKA: P81). In response, NERC and WECC identified for retirement
VAR-002-WECC-1, Requirement R2. Requirement R2 was retired resulting in VAR-002-WECC-2.
In reviewing VAR-002-WECC-2, the WECC-0127 DT determined that full retirement of the standard
would be in order.
Criteria for Acceptance of a Regional Reliability Standard (RRS)

A developmental roadmap and an implementation plan were included in the originally posted version of this document.
They were removed from this document and presented to NERC/FERC as freestanding documents titled “WECC-0127 VAR002-WECC-2 Request to Retire – Attachment E Project Roadmap” and “WECC-0127 VAR-002-WECC-2 Request to retire –
Attachment F Implementation Plan”.
3
Order Approving Regional Reliability Standards for the Western Interconnection and Directing Modifications, Docket No.
RR07-11-000, 119 FERC ¶ 61,260, (Issued June 8, 2007), P.114. (hereafter cited as RRS Order.) An “automatic voltage
regulator” is a device that continuously monitors the generator terminal voltage and changes the reactive power output as
required to maintain (or regulate) the voltage within a pre-determined voltage range. For example, if a load increase causes
a decline in system voltages and thereby the terminal voltage of a generator, the automatic voltage regulator will increase
the generator’s reactive output to raise the terminal voltage. RRS Order, Fn 86.
W E S T E R N E L E C T R I C I T Y C O O R D I N A T I N G
C O U N C I L
Developed as WECC-0127

Attachment G
Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
A regional difference from a continent-wide Reliability Standard must either be: (1) more stringent than
the continent-wide Reliability Standard, or (2) necessitated by a physical difference in the Bulk-Power
System.4 VAR-002-WECC-2 fails both tests. Further, because the reliability goal of the RRS is addressed
in VAR-002-4 and VAR-001-4.1, VAR-002-WECC-2 can be retired without incurring any negative impact
to reliability. Lastly, the language of VAR-002-WECC-2 is so amorphous as to fail the Commission’s
Order 672 threshold by obfuscating due process.
VAR-002-WECC-2 is less stringent than VAR-002-45
On March 3, 2015, the Commission approved VAR-002-WECC-2 on the premise that it was more
stringent than its NERC counterpart, VAR-002-3.6 The Commission’s conclusion was based on the
premise that VAR-002-WECC-2 “requires all synchronous generators to have their voltage regulator in
service at all time with only exceptions for specified circumstances … [whereas] [t]he related NERC
Reliability Standard…permits a generator to remove its automatic voltage regulator from service for
additional reasons.”7 Although the Commission’s conclusion was accurate, analysis since VAR-002WECC-2’s inception shows that the applicable entity(s) can iteratively layer WECC’s exceptions resulting
in a standard no more stringent than VAR-002-3.
Further, the analysis shows the practical impact of VAR-002-WECC-2 is that the applicable entity simply
ends up counting hours of operation without any mandate to deploy Automatic Voltage Regulation
should it not be in service. By contrast, VAR-002-4 requires remediation as well as implementation of
alternative operation in the event AVR is not in service. Finally, VAR-002-WECC-2 falls short of the
Order 672 criteria in that ambiguous verbiage obfuscates due process.
Compounding Exceptions
At first glance, the WECC standard appears to require AVR operation for 98% of all hours whereas the
NERC standard requires AVR operation for 100% of all hours. Although the prima facie argument for
retirement is met there, on closer examination, neither standard truly requires operation for a specified

Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the
Establishment, Approval, and Enforcement of Electric Reliability Standards, Order No. 672, FERC Stats. & Regs. 31,204, at P
291, order on reh’g, Order No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006).
5
Approval Order, P14.
6
Docket No. RD15-1-000, Order Approving Two Regional Reliability Standards, Issued March 3, 2015. Hereafter Approval
Order.
7
Approval Order P14.
W E S T E R N E L E C T R I C I T Y C O O R D I N A T I N G
C O U N C I L
Developed as WECC-0127

Attachment G
Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
number of hours; therefore, neither the WECC 98% threshold nor the NERC 100% threshold is greater
when practical application is considered.
In VAR-002-WECC-2, the applicable entities are required to have AVR “in service and in automatic
voltage control mode 98% of all operating hours”, unless they are permitted not to run under any one
of ten possible scenarios. A first glance this limited set of exceptions is more stringent than the broader
allowance allowed by VAR-002-4; however, when practical application is considered the limited set of
exceptions offered by WECC becomes equal to or greater than the set of exceptions allowed by VAR002-4. As such, VAR-002-WECC-2 is not more stringent than VAR-002-4 and fails the first test for
approval as a Regional Reliability Standard.
A review of all ten scenarios shows that an application of eight of the ten exemptions allows the AVR to
be off 100% of the time, like VAR-002-4 (8760 hours per year), in some cases up to two years.


In R1.1 no AVR is required if a unit only runs 43.8 hours per year.



In R1.3 no AVR is required if there is “instability due to abnormal system configuration.”



In R1.5 no AVR is required if there is component failure with an explanation. (Up to two years.)



In R1.6 no AVR is required if there is component failure with an explanation. (Up to two years.)



In R1.7 no AVR is required if the unit is not commercially operational.



In R1.8/9 no AVR is required if the unit is “unavailable.”



In R10 no AVR is required if there are issues with Load Tap Changer operations.

The 100% exception offered by these eight exemptions is no more stringent than VAR-002-4. Only in
exceptions R1.2 and R1.4 is there an objective and quantifiable mandate to run AVR.
Under Requirement R1.2, an entity is arguably required to run for no less than 7912.8 hours annually. 8
The unit is exempt from operation when performing “maintenance and testing up to a maximum of
seven calendar days per calendar quarter.” However, if the 7-day maintenance and testing exemption
is used up, depending on the precipitating fact pattern, the AVR might continue to be off due to
instability (R1.3 and R1.10), due to component failure for up to two years (R1.4, R1.5, and R1.6), or
simply because the unit was unavailable (R1.8 and R1.9). Depending on the precipitating fact pattern,
the R1.2 exception could be compounded with many of the other exceptions resulting in no practical
mandate to run AVR.

8760 hours annual – ((7 calendar days X 24 hours =168 hours) X 4 quarters) = 672 hours exempted)) – (the two percent
grace period allowed in the body of Requirement R1 (8760 X .02 = 175.2 hours)) = 7912.8 hours annually.
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Attachment G
Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
In like fashion, under Requirement R1.4, an entity is arguably required to run for no less than 7147.8
hours annually.9 The unit is exempt from operation for “60 consecutive days for repair per incident.”
However, the additional qualifier “per incident” would allow the clock to reset on day 61 thereby
defeating the purpose of the limited window requiring the AVR to be on. Even if the 61-day reset
approach was not adopted, arguably the incident could be compounded with any number of the
remaining exemptions resulting in a component not running at all (see R1.2 explanation). In short,
Requirement R1.4 is no more firm in its mandate to run than the other Requirement R1 exemptions.
Thus, it is no more stringent than the allowable exceptions of VAR-002-4. Because it is no more
stringent it fails the first prong test for approval as a Regional Reliability Standard and should be retired.
VAR-002-4 carries a similar amorphous exception to running in that Requirement R1 requires the
applicable entity to operate its generator in AVR mode: 1) except when some other mode is called for by
the Transmission Operator, 2) except when exempted by the Transmission Operator, or, 3) except when
the Generator Operator notifies the Transmission Operator that one of a specific number of exceptions
has occurred. VAR-002-4’s 100% requirement to run, though prima facie evidence of being more
stringent than VAR-002-WECC-2, is further whittled down each time: 1) the generator is being operated
in start-up, shutdown, or testing mode, 2) the Transmission Operator exempts the AVR from running,
or, 3) the AVR is out-of-service.
In short, like VAR-002-WECC-2, VAR-002-4 contains so many exceptions to the rule that neither the 98%
nor the 100% threshold have a concrete numerical meaning. Neither threshold is better than the other.
Ultimately, whether a unit is on or off will be completely fact specific under each of the standards. As
such, the WECC Regional Reliability Standard is no more stringent that the NERC Standard, fails the
Order 672 test, and should not be retained on that premise. Further blurring the line between the 98%
and 100% thresholds, the language of VAR-002-WECC-2 is sufficiently ambiguous to either obfuscate
due process on the one hand or to create undefined discretionary powers for the applicable entities on
the other.
VAR-002-WECC-2 Obfuscates Due Process10

8760 hours annually – (60 days X 24 hours = 1440 hours) – (the two percent grace period allowed in the body of
Requirement R1 (8760 X .02 = 175.2 hours)) = 7144.8 hours annually).
10
The Federal Energy Regulatory Commission (FERC) Order 740, Docket No. RM09-15-000, P23, noted that “in the Western
Interconnection a significant number of transmission paths are voltage or frequency stability-limited, in contrast to other
regions of the [BES] where transmission paths more often are thermally-limited. Disturbances resulting in a stability-limited
transmission path overload, generally, must be responded to in a shorter time frame than a disturbance that results in a
thermally-limited transmission path overload. [FERC has also noted] its understanding that this physical difference is one of
the reasons for the need for certain provisions of regional Reliability Standards in the Western Interconnection.”
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Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
Per Order 672 at P325, the Regional 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.
No Criteria for Instability
In VAR-002-WECC-2, Requirements R1.3 and R.10 requires no AVR if the AVR exhibits “instability due to
abnormal system configuration” (R1.3) or “instability due to operation of a Load Tap Changer” (R1.10).
It should be noted that nowhere in the document is there an explanation of what constitutes
“instability”. Presumably, the operator decides based on its own criteria. If so, this means the operator
has full discretion as to whether the AVR runs of not. Without precise boundaries, the requirement
offers no due process on the one hand and immense latitude on the other.
No Criteria for Components
VAR-002-WECC-2, Requirements R1.4, R1.5 and R1.6 require no AVR for up to two years (R1.5 at one
year; R1.6 at two years) if a “component” fails. Like R1.3, what constitutes a component is not defined.
The NERC Glossary of Terms Used in Reliability Standards adds no definitive insights as there, a
component ranges from a generator, transmission line, circuit breaker, switch or electrical element (see
Contingency). What is known about the component is that an Element may contain more than one
component (see Element), an Interconnection contains many of them, they are part of a System that
may include generation, transmission, and distribution “components” (see System), and from R1.6 we
know the intended components may include replacing the AVR, limiters, and controls but not
necessarily the power source and power bridge. In sum, like R1.3, the requirement is so vague as to
obfuscate due process on the one hand and provide the applicable entity with an immense amount of
discretion on the other.11
No Criteria for Unavailability
VAR-002-WECC-2, Requirements R1.8 and R1.9 require no AVR if the Transmission Operator directs the
Generator Operator to operate the generator, and the AVR is “unavailable.” There is no indication as to
who makes that determination or under what circumstances that determination is made. Plainly
defined, unavailable means not suitable for use. Without further definition, the operator could use any
11

Per Order 672 at P324, a proposed reliability standard must contain a technically sound method to achieve the goal. VAR002-WECC-2, exception R1. R1.1 requires no AVR if the unit runs for less than five percent of all hours during any calendar
quarter. Of note, the drafting team found no technical support for the five percent threshold lending to the conclusion that
it may be arbitrary.
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Attachment G
Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
number of undefined criteria to conclude its equipment was “unavailable.” What constitutes
unavailable is so vast that it obfuscates due process and in practice creates in the applicable entity the
ability to have AVR off for nearly any reason, so long as the reason is documented and the applicable
entity counts the associated hours.
In short, if the applicable entity decides the unit is unstable, unavailable, or that an undefined
component is not working well – there is no obligation to run AVR. When compared to the exemptions
allowed in VAR-002-4 the analysis shows little if any distinction. Because there is no call for remediation
in the event the AVR does not run, the practical result is a standard that counts hours.
Counting Hours vs. Ensuring Reliability
VAR-002-WECC-2 has only one requirement – that the Generator Operators and Transmission
Operators have AVR in service and in AVR mode 98% of the time – unless otherwise exempted under
any one or more of the ten allowed exemptions. Because compliance with the standard is structured
towards documentation, in practice the applicable entity can work at building “up” to the 98% rather
than keeping equipment in service 100% of the time. Compliance for the single requirement is to file
reports that count hours – nothing more. VAR-002-WECC-2 has no mandate for remediation nor call for
alternative means to support reliability if the AVR does not run.
By contrast, VAR-002-4 contains the additional benefit for reliability not otherwise contained in VAR002-WECC-2. VAR-002-4, Requirement R2.1 requires deployment of an alternate means to meet the
reliability goal in the event there is a concern with the AVR; no such deployment is required by the RRS.
VAR-002-4, Requirement R2.2 requires the Generator Operator to explain to the Transmission Operator
why it cannot comply with a schedule; no such communication is required by the RRS. VAR-002-4,
Requirement R2.3 requires an alternative means to meet the requirement goal; the RRS does not. VAR002-4, Requirement R3-R5 require reciprocal communication of events; the RRS requires no
communication. VAR-002-4 requires that step-up transformer tap change(s) take place as needed; the
RRS speaks of tap changes by creates no mandate to make the change(s). In each of these
requirements, VAR-002-4 exceeds the reliability mandates of VAR-002-WECC-2.
In the event the stringency of the two standards was found to be essentially the same (“Run, except
when you don’t.”), the drafting team argues that the scale of stringency should tip in favor of VAR-002-4
because the latter requires remedial action whereas VAR-002-WECC-2 does not.
Physical Difference in the Bulk-Power System
A Regional Reliability Standard may be approved when the standard is needed because of a unique
physical difference in the Bulk-Power System. Although the drafting team continues to take note of the
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Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
Western Interconnection’s unique configuration and operational needs, the argument of unique
physicality is not applicable to this case.
Covered Elsewhere
Although VAR-002-WECC-2 Requirement R1 requires the Transmission Operator to have AVR in service,
VAR-002-4 has no reciprocal requirement for the Transmission Operator; however, the reliability goal is
captured in VAR-001-4.1 – Voltage and Reactive Control. There, Requirements R1 and R2 require the
Transmission Operator to specify a system voltage schedule (R1), and to schedule sufficient reactive
resources to regulate voltage levels under normal and Contingency conditions. To the extent that VAR001-4.1 requires the Transmission Operator to specify and schedule reactive resources such as AVR, R1
and R2 of VAR-001-4.1 meet the reliability goal of VAR-002-WECC-2 without specifying “how” the task is
met (results oriented). Thus, if VAR-002-WECC-2 is retired, the reliability task specific to the
Transmission Operator remains intact in VAR-001-4.1. Similarly, VAR-002-4 covers the Generator
Operator’s requirements, unless otherwise exempted.
The drafting team noted that VAR-001-4.1 Requirement R3 requires the Transmission Operator to
“operate or direct the Real-time operation of devices to regulate transmission voltage and reactive flow
as necessary.” Whereas VAR-002-WECC-2 creates a static setting for AVR thereby removing discretion
from the operator, VAR-001-4.1 allows the operator to attain the same reliability goal based on all the
surrounding circumstances in real-time. For example, although VAR-002-WECC-2 requires synchronous
condensers to be in service and set to AVR mode, VAR-001-4.1 R3 and associated schedule-related
requirements allow greater flexibility of operation while meeting the same reliability goal. This means
that a specific listing of the synchronous condenser need not be retained in VAR-002-WECC-2 because
VAR-001-4.1 allows the Transmission Operator to include it as needed in reactive power schedules.
Finally, in examining VAR-001-4.1, the drafting team notes that the obligations of the Transmission
Operator are carried in to the Regional Variance.
VAR-001-4.1 contains a WECC Regional Variance that supersedes NERC’s Requirements R4 and R5.
When applied, the variance does not allow the Transmission Operator to exempt the Generator
Operator from operating its AVR; therefore, any generator not having a functioning AVR is required to
work with the Transmission Operator to correct the issue. As such, if VAR-002-WECC-2 is retired the
more stringent approach taken in the variance is retained to ensure reliability.

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Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
Section 2: Tabular Crosswalk – Covered Elsewhere
Requirement R1
R1. Generator Operators and Transmission Operators shall have AVR in service and in automatic voltage
control mode 98% of all operating hours for synchronous generators or synchronous condensers.
Generator Operators and Transmission Operators may exclude hours for R1.1 through R1.10 to achieve
the 98% requirement. [Violation Risk Factor: Medium] [Time Horizon: Operations Assessment]
(Exceptions R1.1 through R1.10 are covered below.)

Analysis Table: Requirement R1
Applicable Entities and Facilities Covered Elsewhere

WECC Standard

NERC Standards

Narrative

VAR-002-WECC-2

VAR-001-4.1

Applicability

4.1 Generator Operators

4.1 Transmission Operators

The Applicable Entities of the
WECC Standard are addressed
in VAR-001-4.1 and VAR-0024.

4.2 Transmission Operators
that operate synchronous
condensers

4.2 Generator Operators
within the Western
Interconnection (for the
WECC Variance)

4.3 This VAR-002-WECC-2
Standard only applies to
synchronous generators and
synchronous condensers that
are connected to the Bulk
Electric System.

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Whereas VAR-002-WECC-2
specifically identifies
generators and synchronous
condensers as the applicable
facilities, these specific assets
need not be called out.
Rather, by setting the voltage
schedule as a results-oriented
goal, the Transmission
Operator can allow for an
array of assets to deploy
without confining the
resources to a specific list.

VAR-002-4
Applicability
4.1 Generator Operator
4.2 Generator Owner

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Attachment G
Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators

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Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
Analysis Table: Requirement R1
AVR in Service and Controlling – Covered Elsewhere
VAR-002-WECC-2

VAR-002-4

VAR-001-4.1

Narrative

Generator Operator
and Transmission
Operator

Generator Operator

Transmission Operator

R1. Generator
Operators and
Transmission
Operators shall have
AVR in service and in
automatic voltage
control mode.

R1. The Generator
Operator shall
operate each
generator
connected to the
interconnected
transmission system
(with its automatic
voltage regulator
(AVR) in service) in
the automatic
voltage control
mode.

R1. Each Transmission
Operator shall specify a
system voltage
schedule (which is
either a range or a
target value with an
associated tolerance
band) as part of its plan
to operate within
System Operating
Limits and
Interconnection
Reliability Operating
Limits.

The Generator
Operator and the
Transmission
Operator’s reliability
tasks are addressed in
VAR-002-4 and VAR001-4.1. and its
Regional Variance. By
creating the voltage
schedule, the
Transmission Operator
sets the reliability goal
to be met without
restricting the specific
type of resource to be
used. Restated, the
VAR-01-4.1 approach is
inclusive of VAR-002WECC-2 without
specifying “how” the
goal is to be met.

R2. Each Transmission
Operator shall
schedule sufficient
reactive resources to
regulate voltage levels
under normal and
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Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
Contingency
conditions. (Various
means are allowed.)
R3. Each Transmission
Operator shall operate
or direct the Real-Time
operation of device to
regulate transmission
voltage and reactive
flow as necessary.

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Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
Analysis Table: Requirement R1
Exceptions to the Rule – Covered Elsewhere
VAR-002-WECC-2

VAR-002-4

Narrative

General: AVR shall be in
service 98% of the time, unless
covered by one of ten
exceptions.

General: AVR shall be in
service 100% of the time,
unless covered by an
exception.

Because the VAR-002-WECC-2
list of exceptions can be
compounded, the practical
result is that the specific list of
exceptions is not more
stringent than the generalized
exception offed in VAR-002-4.
Thus, VAR-002-WECC-2 is not
more stringent than VAR-002-4.

Exceptions:

R1.1 through R1.10.

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

[When] the generator is
being operated in start-up,
shutdown, or testing mode
pursuant to a real-time
communication or a
procedure that was
previously provided to the
Transmission Operator; or,



(AKA: Start up, shutdown, or
testing.)



[When] the generator is not
being operated in automatic
voltage control mode or in
the control mode that was
instructed by the
Transmission Operator for a
reason other than start-up,
or testing.

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Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators


(AKA: Other than start up,
shutdown, or testing.)

R1.1 The synchronous
generator or synchronous
condenser operates for less
than five percent of all hours
during any calendar quarter.

[R1.1] Other than start up,
shutdown, or testing.

R1.2. Performing
maintenance and testing up to
a maximum of seven calendar
days per calendar quarter.

[R1.2] Start up, shutdown, or
testing.

R1.3. AVR exhibits instability
due to abnormal system
configuration.
R1.4. Due to component
failure, the AVR may be out of
service up to 60 consecutive
days for repair per incident.
R1.5. Due to a component
failure, the AVR may be out of
service up to one year
provided the Generator
Operator or Transmission
Operator submits
documentation identifying the
need for time to obtain
replacement parts and if
required to schedule an
outage.
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[R1.3] Other than start up,
shutdown, or testing.
[R1.4] Other than start up,
shutdown, or testing.

[R1.5] Other than start up,
shutdown, or testing.

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Attachment G
Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
R1.6. Due to a component
failure, the AVR may be out of
service up to 24 months
provided the Generator
Operator or Transmission
Operator submits
documentation identifying the
need for time for excitation
system replacement (replace
the AVR, limiters, and controls
but not necessarily the power
source and power bridge) and
to schedule an outage.

[R1.6] Other than start up,
shutdown, or testing.

R1.7. The synchronous
generator or synchronous
condenser has not achieved
Commercial Operation.

[R1.7] Start up, shutdown, or
testing.

[R1.8] Other than start up,
R1.8. The Transmission
shutdown, or testing.
Operator directs the
Generator Operator to operate
the synchronous generator,
and the AVR is unavailable for
service.
R1.9. The Reliability
Coordinator directs
Transmission Operator to
operate the synchronous
condenser, and the AVR is
unavailable for service.

[R1.9] Other than start up,
shutdown, or testing.

R1.10. If AVR exhibits
instability due to operation of
a Load Tap Changer (LTC)
transformer in the area, the
Transmission Operator may
authorize the Generator
Operator to operate the

[R1.10] Other than start up,
shutdown, or testing.

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Attachment G
Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
excitation system in modes
other than automatic voltage
control until the system
configuration changes.

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Attachment G
Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
Section 3: Existing Standard Proposed for Retirement

VAR-002-WECC-2
A. Introduction

1. Title:

Automatic Voltage Regulators (AVR)

2. Number:

VAR-002-WECC-2

3. Purpose:

To ensure that Automatic Voltage Regulators on synchronous generators and
condensers shall be kept in service and controlling voltage.

4. Applicability
4.1.

Generator Operators

4.2.

Transmission Operators that operate synchronous condensers

4.3.

This VAR-002-WECC-2 Standard only applies to synchronous generators and
synchronous condensers that are connected to the Bulk Electric System.

5. Effective Date: On the first day of the first quarter, after applicable regulatory
approval.
B.

Requirements

R1.

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Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
documentation identifying the need for time to obtain replacement parts and if
required to schedule an outage.
R1.6. Due to a component failure, the AVR may be out of service up to 24 months
provided the Generator Operator or Transmission Operator submits
documentation identifying the need for time for excitation system replacement
(replace the AVR, limiters, and controls but not necessarily the power source
and power bridge) and to schedule an outage.
R1.7. The synchronous generator or synchronous condenser has not achieved
Commercial Operation.
R1.8. The Transmission Operator directs the Generator Operator to operate the
synchronous generator, and the AVR is unavailable for service.
R1.9. The Reliability Coordinator directs Transmission Operator to operate the
synchronous condenser, and the AVR is unavailable for service.
R1.10. If AVR exhibits instability due to operation of a Load Tap Changer (LTC)
transformer in the area, the Transmission Operator may authorize the
Generator Operator to operate the excitation system in modes other than
automatic voltage control until the system configuration changes.
C. Measures

M1.

Generator Operators and Transmission Operators shall provide quarterly reports to the
compliance monitor and have evidence for each synchronous generator and
synchronous condenser of the following:
M1.1 The actual number of hours the synchronous generator or synchronous
condenser was on line.
M1.2 The actual number of hours the AVR was out of service.
M1.3 The AVR in service percentage.
M1.4 If excluding AVR out of service hours as allowed in R1.1 through R1.10,
provide:

M1.4.1

The number of hours excluded,

M1.4.2

The adjusted AVR in-service percentage,

M1.4.3

The date of the outage.

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Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators

Compliance

Compliance Monitoring Process
1.1

Compliance Monitoring Responsibility
Compliance Enforcement Authority

1.2

Enforcement

The Reset Time Frame shall be a calendar quarter.
1.3

Data Retention
The Generator Operators and Transmission Operators shall keep evidence
for Measures M1 for three years plus current year, or since the last audit,
whichever is longer.

1.4

Additional Compliance Information
1.4.1 The sanctions shall be assessed on a calendar quarter basis.
1.4.2 If any of R1.2 through R1.9 continues from one quarter to another,
the number of days accumulated will be the contiguous calendar
days from the beginning of the incident to the end of the incident.
For example, in R1.4 if the 60 day repair period goes beyond the
end of a quarter, the repair period does not reset at the beginning
of the next quarter.

1.4.3

When calculating the in-service percentages, do not include the time the
AVR is out of service due to R1.1 through R1.10.

1.4.4

The standard shall be applied on a machine-by-machine basis (a

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WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
Generator Operator or Transmission Operator can be subject to a
separate sanction for each non-compliant synchronous generator and
synchronous condenser).
E.

Regional Differences

None
Table of Compliance Elements

R
R1

Time Horizon
Operational
Assessment

VRF
Medium

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Violation Severity Levels
Moderate VSL
High VSL
There shall
There shall be a
be a
High Level of nonModerate
compliance if AVR
is in service less
Level of nonthan 80% but at
compliance
least 70% or more
if AVR is in
of all hours during
service less
which the
than 90%
synchronous
but at least
generating unit or
80% or
synchronous
more of all
condenser is on
hours
line for each
during
calendar quarter.
which the
synchronou
s generating
unit or
synchronou
s condenser
is on line for
each
calendar
quarter.

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Attachment G
Technical Justification
WECC-0127 VAR-002-WECC-2
Automatic Voltage Regulators
Version History

Version

Date

April 16, 2008

Permanent Replacement Standard
for VAR-STD-002a-1

April 21, 2011

FERC Order issued approving VAR002-WECC-1 (FERC approval
effective June 27, 2011; Effective
Date July 1, 2011)

November 13,
2014

Adopted by NERC Board of Trustees

March 3, 2015

FERC letter order approving VAR002-WECC-2

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Action

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Change Tracking

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Unofficial Comment Form

Regional Reliability Standard – Retirement
VAR-002-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 VAR-002-WECC-2 – Automatic Voltage
Regulators. 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

The WECC drafting team recommends the retirement of Regional Reliability Standard VAR-002-WECC-2
due to the following:
• The standard does not meet the FERC criteria for a Regional Reliability Standard;
• The standard does not meet FERC Order No. 672 requirements for clarity; and
• The reliability-related substance is addressed in other continent-wide NERC Standards (VAR002-4 and VAR-001-4.1); and
• Other issues cited in the technical justification document.
NERC Criteria for Developing or Modifying a Regional Reliability Standard

Regional Reliability Standard shall be: (1) a regional reliability standard that is more stringent than the
continent-wide reliability standard, including a regional standard that addresses matters that the
continent-wide reliability standard does not; or (2) a regional reliability standard that is necessitated by a
physical difference in the bulk power system. Regional reliability standards shall provide for as much
uniformity as possible with reliability standards across the interconnected bulk power system of the North
American continent. Regional reliability standards, when approved by FERC and applicable authorities in
Mexico and Canada, shall be made part of the body of NERC reliability standards and shall be enforced
upon all applicable bulk power system owners, operators, and users within the applicable area, regardless
of membership in the region.
The approval process for a regional reliability standard requires NERC to publicly notice and request
comment on the proposed standard. Comments shall be permitted only on the following criteria
(technical aspects of the standard are vetted through the regional standards development process):
Open — Regional reliability standards shall provide that any person or entity that is directly and
materially affected by the reliability of the bulk power system within the regional entity shall be
able to participate in the development and approval of reliability standards. There shall be no
undue financial barriers to participation. Participation shall not be conditional upon membership

in the regional entity, a regional entity or any organization, and shall not be unreasonably
restricted on the basis of technical qualifications or other such requirements.
Inclusive — Regional reliability standards shall provide that any person with a direct and material
interest has a right to participate by expressing an opinion and its basis, having that position
considered, and appealing through an established appeals process, if adversely affected.
Balanced — Regional reliability standards shall have a balance of interests and shall not be
dominated by any two-interest categories and no single-interest category shall be able to defeat a
matter.
Due Process — Regional reliability standards shall provide for reasonable notice and opportunity
for public comment. At a minimum, the standard shall include public notice of the intent to
develop a standard, a public comment period on the proposed standard, due consideration of
those public comments, and a ballot of interested stakeholders.
Transparent — All actions material to the development of regional reliability standards shall be
transparent. All standards development meetings shall be open and publicly noticed on the
regional entity’s Web site.
Review the revised the Regional Reliability Standard regional standard and answer the following
questions.
1. Do you agree the development of the Regional Reliability Standard met the “Open” criteria as
outlined above? If “No”, please explain in the comment area below:
Yes
No
Comments:
2. Do you agree the development of the Regional Reliability Standard met the “Inclusive” criteria as
outlined above? If “No”, please explain in the comment area below:
Yes
No
Comments:
3. Do you agree the development of the Regional Reliability Standard met the “Balanced” criteria as
outlined above? If “No”, please explain in the comment area below:
Yes
No
Comments:

Unofficial Comment Form
Regional Reliability Standard VAR-002-WECC-2| November 2017

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 VAR-002-WECC-2| November 2017

Comment Report
Project Name:

Regional Reliability Standard (WECC) | VAR-002-WECC-2 Retirement

Comment Period Start Date:

11/3/2017

Comment Period End Date:

12/18/2017

Associated Ballots:

There were 6 sets of responses, including comments from approximately 6 different people from approximately 6 companies
representing 4 of the Industry Segments as shown in the table on the following pages.

Questions
1. Do you agree the development of the Regional Reliability Standard met the “Open” criteria as outlined above? If “No”, please explain in the
comment area below:

2. Do you agree the development of the Regional Reliability Standard met the “Inclusive” criteria as outlined above? If “No”, please explain in
the comment area below:

3. Do you agree the development of the Regional Reliability Standard met the “Balanced” criteria as outlined above? If “No”, please explain
in the comment area below:

4. Do you agree the development of the Regional Reliability Standard met the “Due Process” criteria as outlined above? If “No”, please
explain in the comment area below:

5. Do you agree the development of the Regional Reliability Standard met the “Transparent” criteria as outlined above? If “No”, please
explain in the comment area below:

Organization
Name

Name

Segment(s)

Region

Group Name

Group Member
Name

Group
Member
Organization

Group
Member
Segment(s)

Group Member
Region

1. Do you agree the development of the Regional Reliability Standard met the “Open” criteria as outlined above? If “No”, please explain in the
comment area below:
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

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

Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
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:
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
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

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

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

Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
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:
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
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

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

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

Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Yes

Document Name
Comment

Likes

Dislikes
Response

Attachment R2
Responses to Comments NERC
WECC-0127 VAR-002-WECC-2
Request to Retire
November 3 through December 18, 2017
Posting 1
The WECC-0127 VAR-002-WECC-2, Automatic Voltage Regulators, Request to Retire Drafting Team (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 six entities as shown in the following table.
Location of Comments
All comments received on the project can be viewed in their original format on the WECC-0127 project
page under the “Submit and Review Comments” accordion. Additionally, the raw data provided to
WECC by NERC in support of this filing is appended to this response form.
Changes in Response to Comment
No changes were made to the project based on the comments received during this posting.
Minority View
There were no minority concerns.
Effective Date and Implementation Plan
The Reliability Standards Development Procedures (Procedures) require that an implementation plan
be posted with at least one posting of the project. The proposed date for retirement is immediately
upon receipt of regulatory approval. The drafting team reports that no further actions are necessary
for retirement.

Comment Report Form for WECC-0127
Action Plan
As of January 10, 2018, this project is awaiting filing at NERC.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC
Consultant. In addition, the WECC Reliability Standards Appeals Process can be found in the Reliability
Standards Development Procedures.

Comment Report Form for WECC-0127
WECC Standards Comment Table
Commenter
1 Aaron Cavanaugh
2 John Tolo

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

Laurie Williams

Sandra Shaffer

PNM Resources - Public Service Company of New
Mexico (PNM)
Berkshire Hathaway – PacifiCorp (PAC)

5
6

Glen Farmer
Michelle Amarantos

Avista
Arizona Public Service Company (APS)

Comment Report Form for WECC-0127
1. Response Summary
Summary Consideration: See summary in the preamble of this document.
Commenter / Comment

Response

Comment Report Form for WECC-0127
bar

Raw Data
provided by
NERC
Comment
Report
Project Name:

Regional Reliability Standard (WECC) | VAR-002-WECC-2 Retirement

Comment Period Start
Date:

11/3/2017

Comment Period End
Date:

12/18/2017

Associated Ballots:

Comment Report Form for WECC-0127

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-0127

Organization Name Segment(s) Region
Name

Group
Name

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

Comment Report Form for WECC-0127

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

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
Document Name
Comment

Yes

Comment Report Form for WECC-0127

Likes

Dislikes

Response

Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Yes

Document Name
Comment

Likes

Dislikes
Response

Comment Report Form for WECC-0127
2. Do you agree the development of the Regional Reliability Standard met the “Inclusive”
criteria as outlined above? If “No”, please explain in the comment area below:
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
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
Document Name
Comment

Yes

Comment Report Form for WECC-0127

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

Comment Report Form for WECC-0127
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

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
Document Name
Comment

Yes

Comment Report Form for WECC-0127

Likes

Dislikes

Response

Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Yes

Document Name
Comment

Likes

Dislikes
Response

Comment Report Form for WECC-0127
4. Do you agree the development of the Regional Reliability Standard met the “Due
Process” criteria as outlined above? If “No”, please explain in the comment area below:
Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
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
Document Name
Comment

Yes

Comment Report Form for WECC-0127

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

Comment Report Form for WECC-0127
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

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
Document Name
Comment

Yes

Comment Report Form for WECC-0127

Likes

Dislikes

Response

Sandra Shaffer - Berkshire Hathaway - PacifiCorp - 6
Answer

Yes

Document Name
Comment

Likes

Dislikes

Response

Michelle Amarantos - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Yes

Document Name
Comment

Likes

Dislikes
Response

File Type	application/pdf
File Title	WECC VAR-002-WECC-2 Retirement Petition
Author	NERC Legal (ST)
File Modified	2018-03-07
File Created	2018-03-07