Comment Form Revised FRCC Regional Reliability Standard Development Process Document (FRCC-RE-STD-001)
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- Benjamin Fields
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1 Please use this form to submit comments on Version 1 of the FRCC Regional Reliability Standard Development. Comments must be submitted by February 9, You must submit the completed form by ing it to the FRCC Standards Process Manager at FRCCStandard@frcc.com, with the words FRCC Regional SDP (FRCC-RE-STD-001) Comments in the subject line. If you have any questions, please contact Peter Heidrich at pheidrich@frcc.com, or or Christina Rau at crau@frcc.com or ALL COMMENTS SUBMITTED ON THIS FORM WILL BE POSTED ON THE FRCC WEBSITE. DO: DO NOT: Enter text only, with no formatting or styles added. Use punctuation and capitalization as needed (except quotations). Use more than one form if responses do not fit in the spaces provided. Do not insert tabs or paragraph returns in any data field. Do not use numbering or bullets in any data field. Do not use quotation marks in any data field. Do not submit a response in an unprotected copy of this form. Name: Organization: Telephone: Regional Sector: Individual Commenter Information (Complete this section for comments from an individual.) Group/Organization Commenter Information (Complete this section for comments from a group or an organization.) Group/Organization: Duke Energy Primary Contact Name: Colby Bellville Primary Contact Telephone: Primary Contact Colby.Bellville@duke-energy.com Regional Sector: Group/Organization Members: 1
2 Please Enter All Comments in Simple Text Format. Insert a check mark in the appropriate boxes by clicking in the gray areas. Background: The FRCC Standards department has revised and updated the FRCC Regional Reliability Standards Development Process (FRCC-RE-STD-001) (Appendix C to the FRCC Delegation Agreement) to improve and clarify the process and establish consistency in standard development with NERC and the other Regional Entities. In addressing areas for improvement in the FRCC Regional Reliability Standards Development Procedure, recent improvements made to the NERC Standards Process Manual (e.g., Standards Process Input Group (SPIG) recommendations) as well as the manuals of other Regional Entities were benchmarked to identify best practices for inclusion in this manual. Significant revisions include: Process Improvements: Incorporation of the Results Based Standards principles. Improved clarity in defining the responsibilities and roles of participants in the FRCC Regional Reliability Standard Development Process. Incorporation of the NERC Standard Template. Details surrounding the development and approval of Violation Severity Levels (VSLs) and Violation Risk Factors (VRFs). Incorporation of concurrent posting periods which significantly reduces the length of time required for the process. o Concurrent posting periods include: Comment periods, Ballot Pool Formation and Initial Ballots. Updated the Standard Authorization Request document to incorporate functional entity changes and made clarity improvements. Developed a new FRCC Regional Reliability Standard Development Process Flowchart. Oversight Authority: Elimination of the FRCC Operating and Planning Committees oversight of the FRCC Regional Reliability Standard Development Process. Establishment of the FRCC Regional Entity Committee and Compliance Forum (RECCF) oversight of the FRCC Regional Reliability Standard Development Process. Document Maintenance: Updated document into the new FRCC Process Document Format. 2
3 1. The Draft FRCC Regional Reliability Standard Development Process Document (FRCC-RE-STD-001) is based on characteristics that support a fair and open process for the development of Regional Reliability Standards. Section 3.1 FRCC Regional Reliability Standard Principles has been revised to improve clarity and updated to identify all of the characteristics associated with the process. Do you agree that Section 3.1 FRCC Regional Reliability Standard Principles clearly defines the characteristics associated with the FRCC Regional Reliability Standard Development Process? 2. The Draft FRCC Regional Reliability Standard Development Process Document (FRCC-RE-STD-001) has been revised to incorporate the results-based standard requirements used in the development NERC Reliability Standards. Section 3.2 FRCC Regional Reliability Standard Elements has been revised to identify the types of requirements associated with the results-based concepts. Do you agree that the revisions to the FRCC Regional Reliability Standard Development have effectively and accurately incorporated the resulted-based concepts into the Regional Standard Development Process? 3
4 3. The Draft FRCC Regional Reliability Standard Development Process Document (FRCC-RE-STD-001) has been revised to establish the FRCC Regional Entity Committee and Compliance Forum (RECCF) as the oversight authority of the FRCC Regional Reliability Standard Development Process. Additional revisions were made to Section 3.3 Responsibilities and Roles in the FRCC Regional Reliability Standard Development Process to improve clarity. Do you agree with the revisions to Section 3.3 Responsibilities and Roles in the FRCC Regional Reliability Standard Development Process? 4. Section 3.4 Process for Developing an FRCC Regional Reliability Standard of the Draft FRCC Regional Reliability Standard Development Process Document (FRCC-RE-STD- 001) has been updated to incorporate recent process changes in the NERC Standard Development Process. Significant changes include the use of concurrent posting periods which significantly reduces the length of time required for the process. (Concurrent posting periods include: Comment periods, Ballot Pool Formation and Initial Ballots.) Do you agree with the revisions to Section 3.4 Process for Developing an FRCC Regional Reliability Standard in the FRCC Regional Reliability Standard Development Process? 4
5 5. Please provide any other comments that the FRCC Standards Department staff should consider. Duke Energy suggests using either NERC Reliability Standard or ERO Reliability Standard, but not both. Throughout the document it appears that both are used interchangeably, which can be confusing to the reader. 5
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