NERC Exhibit B, Order No. 672 Criteria Rel Standard TOP-007- WECC-1a

Exhibit B
Order No. 672 Criteria

Order 672 Criteria
WECC-0111 TOP-007-WECC-1a
System Operating Limits
NERC is responsible for ensuring that the Reliability Standards, Violation Risk Factors (VRF),
Violation Severity Levels (VSL), definitions, Variances, and Interpretations developed by drafting
teams are developed in accordance with NERC processes. They must also meet NERC’s
benchmarks for Reliability Standards, as well as criteria for governmental approval.
In FERC Order No. 672, 1 the Federal Energy Regulatory Commission (FERC) identified a number
of criteria that it will use to analyze Reliability Standards proposed for approval to ensure that
they are just, reasonable, not unduly discriminatory or preferential, and in the public interest.
The discussion below identifies these factors, and explains how the proposed retirement of the
Regional Reliability Standard meets or exceeds the criteria:
1.

Proposed Reliability Standards must be designed to achieve a specified, reliability
goal.
NERC Reliability Standards are based on certain reliability principles that define the
foundation of reliability for North American bulk power systems. Each Reliability
Standard shall enable or support one or more of NERC’s reliability principles, thereby
ensuring that each standard serves a purpose in support of reliability of the North
American bulk power systems.
This project is designed to retire TOP-007-WECC-1a, System Operating
Limits because the reliability-related substance is contained in other
existing NERC Standards.
The principle on which the currently approved underlying NERC Standard
is premised is as follows:
•

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.

2. Proposed Reliability Standards must contain a technically sound method to achieve
the goal.
The proposed Reliability Standard must be designed to achieve a specified
reliability goal and must contain a technically sound means to achieve this goal.
Although any person may propose a topic for a Reliability Standard to the
Electric Reliability Organization (ERO), in the ERO’s process, the specific
1

http://www.nerc.com/files/final_rule_reliability_Order_672.pdf

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Order 672 Criteria
WECC-0111 TOP-007-WECC-1a
System Operating Limits
proposed Reliability Standard should be developed by persons within the electric
power industry and community who have a high level of technical expertise and
it should be based on sound technical and engineering criteria. It should be
based on actual data and lessons learned from past operating incidents, where
appropriate. The process for ERO approval of a proposed Reliability Standard
should be fair and open to all interested persons. Order No. 672 at Paragraph
324.
Standard Development
This request to retire currently approved NERC Standard TOP-007-WECC1a, System Operating Limits, was developed using the NERC and WECC
Standards development processes approved by FERC.
Among other things, these processes include drafting of the standard by
a drafting team composed of subject matter experts (SME). Biographies
of those SMEs are provided with this filing. These processes also include
repeated public iterative comment/response cycles whereby comments
are received from the industry and considered by the drafting team, and
responses to those comments are provided by the drafting team.
Technically Sound
A detailed analysis of existing NERC Standards as well as those approved and
pending regulatory approval was conducted by the WECC-0111 drafting team.
That technical analysis is included in this filing as Attachment B1, Supporting
Narrative and Crosswalk to Retire, Section 1: Tabular Crosswalk and Section 2:
Supporting Narrative. Those sections depict where the reliability-related
substance is already covered as well as a narrative describing that conclusion.
3. Proposed Reliability Standards must be applicable to users, owners, and operators of
the Bulk-Power System, and not others.
The proposed Reliability Standard may impose a requirement on any user,
owner, or operator of such facilities, but not on others. Order No. 672 at P322.
TOP-007-WECC-1a, System Operating Limits, complies with Order 672 in that it
applies only to applicable entities, stated in the standard as follows:
“4.

Applicability:

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Order 672 Criteria
WECC-0111 TOP-007-WECC-1a
System Operating Limits
4.1
Transmission Operators for the transmission paths in the
most current Table titled “Major WECC Transfer Paths in the Bulk
Electric System” provided at:
https://www.wecc.biz/Reliability/TableMajorPaths4-28-08.pdf”
4. Proposed Reliability Standards must be clear and unambiguous as to what is required
and who is required to comply.
The proposed Reliability Standard should be clear and unambiguous regarding
what is required and who is required to comply. Users, owners, and operators of
the Bulk Power System must know what they are required to do to maintain
reliability. Order No. 672 at P325.
Each Requirement identifies the specific applicable entity assigned to an associated task.
Each Requirement follows the typical NERC drafting construct that, “Each [Applicable
Entity] shall [perform the assigned task] [and, where applicable, under what stated
circumstances].”
Although this filing does not propose any added regulatory language, the
drafting team made every endeavor to ensure the narrative describing its
rationale for retirement of TOP-001-WECC-1a, System Operating Limits was clear
and unambiguous.
The project was posted for comment on two different occasions. In Posting 1,
three respondents submitted comments. In Posting 2, only one respondent
provided a comment. None of the comments received indicated a concern with
the clarity of the language or raised any question as to the intent of the project.
The project was also posted at NERC for a 45-day comment period. All
respondents reported the project was developed in an open, inclusive, balanced
and transparent manner, and that the process afforded adequate due process.
5. Proposed Reliability Standards must include clear and understandable consequences
and a range of penalties (monetary and/or non-monetary) for a violation.
This project is designed to retire TOP-007-WECC-1a, System Operating
Limits because the reliability-related substance is contained in other
existing NERC Standards. As such, addition or modification of compliance
elements was not required.

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Order 672 Criteria
WECC-0111 TOP-007-WECC-1a
System Operating Limits
6. Proposed Reliability Standards must identify clear and objective criteria or measures
for compliance, so that they can be enforced in a consistent and non-preferential
manner.
This project is designed to retire TOP-007-WECC-1a, System Operating
Limits because the reliability-related substance is contained in other
existing NERC Standards. As such, addition or modification of measures
was not required.
7. Proposed Reliability Standards should achieve a reliability goal effectively and
efficiently - but does not necessarily have to reflect “best practices” without regard to
implementation cost.
This project is designed to retire TOP-007-WECC-1a, System Operating
Limits because the reliability-related substance is contained in other
existing NERC Standards. Because the reliability-related tasks are already
being performed in accordance with other reliability standards there
should be no adverse reliability or financial impact as a result of
immediately implementing the retirement of the standard.
8. Proposed Reliability Standards cannot be “lowest common denominator,” meaning
that they cannot reflect a compromise that does not adequately protect bulk power
system reliability.
The proposed Reliability Standard must not simply reflect a compromise in the
ERO’s Reliability Standard development process based on the least effective
North American practice — the so-called “lowest common denominator” — if
such practice does not adequately protect Bulk Power System reliability.
Although the Commission will give due weight to the technical expertise of the
ERO, it will not hesitate to remand a proposed Reliability Standard if it is
convinced the proposed Reliability Standard is not adequate to protect
reliability. Order No. 672 at Paragraph 329.
This project is designed to retire TOP-007-WECC-1a, System Operating
Limits because the reliability-related substance is contained in other
existing NERC Standards. Because the reliability-related tasks are already
being performed there is no proposed change to the level of reliability or
to the practices in place to achieve the existing level of reliability; thus,
there is no lower of the standard and no migration to a lowest common
denominator.

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Order 672 Criteria
WECC-0111 TOP-007-WECC-1a
System Operating Limits
9. Proposed Reliability Standards may consider costs to implement for smaller entities
but not at consequence of less than excellence in operating system reliability.
A proposed Reliability Standard may take into account the size of the entity that
must comply with the Reliability Standard and the cost to those entities of
implementing the proposed Reliability Standard. However, the ERO should not
propose a “lowest common denominator” Reliability Standard that would
achieve less than excellence in operating system reliability solely to protect
against reasonable expenses for supporting this vital national infrastructure. For
example, a small owner or operator of the Bulk Power System must bear the cost
of complying with each Reliability Standard that applies to it. Order No. 672 at
P330.
This project is designed to retire TOP-007-WECC-1a, System Operating
Limits because the reliability-related substance is contained in other
existing NERC Standards. Because the reliability-related tasks are already
being performed there should be no adverse reliability or financial impact
as a result of immediately implementing the retirement of the standard.
None of the respondents reported any concerns regarding the financial
impact of retiring the document.
10. Proposed Reliability Standards must be designed to apply throughout North America
to the maximum extent achievable with a single reliability standard while not favoring
one area or approach.
A proposed Reliability Standard should be designed to apply throughout the
interconnected North American Bulk Power System, to the maximum extent this
is achievable with a single Reliability Standard. The proposed Reliability Standard
should not be based on a single geographic or regional model, but should take
into account geographic variations in grid characteristics, terrain, weather, and
other such factors. It should also take into account regional variations in the
organizational and corporate structures of transmission owners and operators,
variations in generation fuel type and ownership patterns, and regional
variations in market design - if these affect the proposed Reliability Standard.
Order No. 672 at P331.
This project is designed to retire TOP-007-WECC-1a, System Operating
Limits, a Regional Reliability Standard. If the retirement is approved, the
reliability-related tasks will continue to be performed in accordance with
other currently approved NERC Standards that are applicable across the
continent. This project eliminates a regional standard that duplicates
existing NERC Reliability Standard requirements.

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Order 672 Criteria
WECC-0111 TOP-007-WECC-1a
System Operating Limits
11. Proposed Reliability Standards should cause no undue negative effect on competition
or restriction of the grid.
As directed by section 215 of the FPA, the Commission itself will give special
attention to the effect of a proposed Reliability Standard on competition. The
ERO should attempt to develop a proposed Reliability Standard that has no
undue negative effect on competition. Among other possible considerations, a
proposed Reliability Standard should not unreasonably restrict available
transmission capability on the Bulk Power System beyond any restriction
necessary for reliability and should not limit use of the Bulk Power System in an
unduly preferential manner. It should not create an undue advantage for one
competitor over another. Order No. 672 at Paragraph 332
This project is designed to retire TOP-007-WECC-1a, System Operating
Limits because the reliability-related substance is contained in other
existing NERC Standards. Because the reliability-related tasks are already
being performed in accordance with other currently-approved NERC
Standards, there should be no undue negative effect on competition or
restriction of the grid.
12. The implementation time for the proposed Reliability Standards must be reasonable.
In considering whether a proposed Reliability Standard is just and reasonable,
the Commission also will consider the timetable for implementation of the new
requirements, including how the proposal balances any urgency in the need to
implement it against the reasonableness of the time allowed for those who must
comply to develop the necessary procedures, software, facilities, staffing or
other relevant capability. Order No. 672 at P333.
This project is designed to retire TOP-007-WECC-1a, System Operating
Limits because the reliability-related substance is contained in other
existing NERC Standards. Because the reliability-related tasks are already
being performed in accordance with other currently-approved NERC
Standards, immediate retirement of the standard should be seamless.
13. The Reliability Standard development process must be open and fair.
Further, in considering whether a proposed Reliability Standard meets the legal
standard of review, we will entertain comments about whether the ERO
implemented its Commission-approved Reliability Standard development
process for the development of the particular proposed Reliability Standard in a

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Order 672 Criteria
WECC-0111 TOP-007-WECC-1a
System Operating Limits
proper manner, especially whether the process was open and fair. However, we
caution that we will not be sympathetic to arguments by interested parties that
choose, for whatever reason, not to participate in the ERO’s Reliability Standard
development process if it is conducted in good faith in accordance with the
procedures approved by the Commission. Order No. 672 at P334.
In developing its request to retire TOP-007-WECC-1a, WECC followed the
WECC Reliability Standards Development Procedures (Procedures) as
approved by FERC.
All meetings were open to the public.
Between March 11 and August 6, 2015, the WECC-0111 drafting team
conducted eight open meetings. Notice of the meetings was provided to
NERC, posted on WECC’s website, and embedded in the minutes of each
meeting. Meeting minutes are posted on the WECC’s website and
accessible by the public.
All meetings were supported by a telephone conference bridge
associated with an on-line Internet visual capability, allowing all
participants to see the document(s) as they were being developed.
The proposed project was posted for public comment by WECC on two
different occasions and by NERC on one additional occasion. Comments
were solicited, received, considered, and answered. Comments and their
responses are included with this filing and are currently located at the
WECC-0111 TOP-007-WECC-1a Request to Retire Project Page on the
Submit and Review Comments accordion.
While posted at NERC for 45-day comment, respondents were unanimously in
accord that the development process was open, inclusive, balanced, transparent,
and that the process afforded adequate due process.
14. Proposed Reliability Standards must balance with other vital public interests.
Finally, we understand that at times, the development of a proposed Reliability
Standard may require that a particular reliability goal must be balanced against
other vital public interests, such as environmental, social and other
considerations. We expect the ERO to explain any such balancing in its
application for approval of a proposed Reliability Standard. Order No. 672 at
P335.

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Order 672 Criteria
WECC-0111 TOP-007-WECC-1a
System Operating Limits
WECC is not aware of any vital public interests impacted by retirement of
this standard. No such balancing concerns were raised or noted.
15. Proposed Reliability Standards must consider any other relevant factors.
In considering whether a proposed Reliability Standard is just and reasonable,
we will consider the following general factors, as well as other factors that are
appropriate for the particular Reliability Standard proposed. Order No. 672 at P
323.
This project is designed to retire TOP-007-WECC-1a, System Operating
Limits because the reliability-related substance is contained in other
existing NERC Standards. Because the reliability-related tasks are already
being performed in accordance with other currently-approved NERC
Standards, retirement of this standard should be seamless to the
industry.

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