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

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Start Date: 12/07/2018
End Date: 01/22/2019

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End

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Hot Answers

Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

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Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

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Other Answers

All five questions on this comment form reference criteria "above" which have not been provided on the comment form.

PGE does though support the retirement of PRC-004-WECC-2 and the revised retirement date to coordinate its retirement with the effective date of PRC-012-2.

PGE FCD, Segment(s) 5, 1, 3, 6, 9/11/2018

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None

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - WECC - Segments 1, 3, 5, 6

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Extending the retirement effective date perpetuates a merely administrative burden. The additional tracking and reporting requirements mandated by PRC-004-WECC-2 result in expenditures of ratepayer funds. WECC ratepayers would be better served by honoring the original retirement date for this standard.

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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Hot Answers

Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

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Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

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Other Answers

PGE FCD, Segment(s) 5, 1, 3, 6, 9/11/2018

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None

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - WECC - Segments 1, 3, 5, 6

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Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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Hot Answers

Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

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Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

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Other Answers

PGE FCD, Segment(s) 5, 1, 3, 6, 9/11/2018

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None

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - WECC - Segments 1, 3, 5, 6

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The lengthy extension of the proposed retirement date of PRC-004-WECC-2 does not meet the criteria for “balanced” because the proposal was driven by interests contrary to the original interests driving Project WECC-0126; i.e., reducing redundancy and administrative compliance burdens. The SDT did not place proper emphasis on the true impact of Project WECC-0136; i.e., the continuation of redundancies and administrative burdens for multiple additional years. Further, the detrimental nature of the continued redundant and administrative compliance burdens was minimized by the Drafting Team consisting solely of WECC Standards Department personnel, rather than involving industry representatives to fully acknowledge and assess the impacts of the delayed retirement on the industry.

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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Hot Answers

Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

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Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

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Other Answers

PGE FCD, Segment(s) 5, 1, 3, 6, 9/11/2018

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None

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - WECC - Segments 1, 3, 5, 6

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The proposed lengthy extension of the retirement effective date does not meet the criteria for “due process.” The reliability concern for which the original standard was drafted is no longer relieved by the lengthy extension of the retirement date. Rather, extending the retirement date perpetuates the redundancies committed by the original standard and does not offer timely relief from administrative compliance burdens that do not improve BES reliability.

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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Hot Answers

Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

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Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

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Other Answers

PGE FCD, Segment(s) 5, 1, 3, 6, 9/11/2018

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None

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - WECC - Segments 1, 3, 5, 6

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The lengthy extension of the retirement date of this redundant and administrative standard was not transparently presented for industry review. The extensive emphasis on the “alignment of the retirement date” with the future effective date of PRC-012-2 distracted from the true impact of perpetuated compliance with redundant and administrative requirements.

In general, Reclamation supports alignment throughout the nationwide and regional standards; however, the lack of industry interest in Posting 1 of Project WECC-0136 indicates a general misunderstanding of the proposal’s impact. Five entities commented in support of the WECC-0126 immediate retirement proposal, yet only one entity commented on the WECC-0136 alignment proposal to extend the retirement date. Rather than emphasizing lack of immediate relief from the redundancies and administrative burdens originally relieved by Project WECC-0126, the continued requirement for entities to comply with redundant and administrative requirements for additional years was presented as “alignment” under Project WECC-0136, thereby failing to draw proper negative attention from industry during previous substantive comment periods.

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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