Regional Standard:
 
Regional Standard Processes Manual
 
Comment Period (5/21/2013 - 7/5/2013)
 DateOrganization 
07/04/2013Independent Electricity System Operator 
 
Comments: 1. We believe a major and necessary step is missing: posting the RSAR for comment after it is accepted by the RSC. Posting of an RSAR is consistent with NERC’s standards development process, and is critical in assessing the need and merit for developing a regional standard with due inputs from NPCC members and those who may be affected by the proposed standards (or their retirement). We suggest DT to add this posting process. 2. Unlike the NERC process, interpretations of the NPCC regional standards do not require balloting by the NPCC’s registered ballot body. Is it an oversight or is it the design of the NPCC interpretation process? If it is the latter, the rationale has not been provided in the manual. Please add the balloting step, or provide the rationale for not having to ballot interpretations. 3. Violation Risk Factor and Violation Severity Level Section: Suggest to add “and Compliance Staff” or “the Compliance Committee” after “working with NPCC Standards Staff” since these are factors and elements that assist in compliance assessment and as such, inputs from NPCC Compliance Staff or the CC (with reference to the role of CC in Section IV – Regional Standards Development Process) should be sought. 4. Suggest to add “or reference documents” after “Guideline” in the Informational Element Section. 5. In the Quality Review Team Section, suggest to remove the word “and” before “whether”, and append to “…is clear and enforceable as written “and the VRFs and VSLs are developed according to NERC and FERC guidelines.” 6. Section 3.2 REVIEW AND VALIDATION OF REQUEST FOR INTERPRETATION (RFI): we suggest to add “request for” between “valid” and “interpretation” since the only assessment that can be made at that time is whether not the request is valid, not whether or not the interpretation itself (which has yet to be developed) is valid. 7. Step 3.5: DEVELOPMENT OF RESPONSE TO RFI - Clarity should be added to indicate whether it is 45 days after NPCC receives the RFI or the Drafting Team (DT) receives the charge to develop a response (i.e. the interpretation). Depending on the activities that may occur after NPCC receives the RFI, the DT may have very little time to develop a response.
07/04/2013 View Attachment
 
Comments: 1. We believe a major and necessary step is missing: posting the RSAR for comment after it is accepted by the RSC. Posting of an RSAR is consistent with NERC’s standards development process, and is critical in assessing the need and merit for developing a regional standard with due inputs from NPCC members and those who may be affected by the proposed standards (or their retirement). We suggest DT to add this posting process. 2. Unlike the NERC process, interpretations of the NPCC regional standards do not require balloting by the NPCC’s registered ballot body. Is it an oversight or is it the design of the NPCC interpretation process? If it is the latter, the rationale has not been provided in the manual. Please add the balloting step, or provide the rationale for not having to ballot interpretations. 3. Violation Risk Factor and Violation Severity Level Section: Suggest to add “and Compliance Staff” or “the Compliance Committee” after “working with NPCC Standards Staff” since these are factors and elements that assist in compliance assessment and as such, inputs from NPCC Compliance Staff or the CC (with reference to the role of CC in Section IV – Regional Standards Development Process) should be sought. 4. Suggest to add “or reference documents” after “Guideline” in the Informational Element Section. 5. In the Quality Review Team Section, suggest to remove the word “and” before “whether”, and append to “…is clear and enforceable as written “and the VRFs and VSLs are developed according to NERC and FERC guidelines.” 6. Section 3.2 REVIEW AND VALIDATION OF REQUEST FOR INTERPRETATION (RFI): we suggest to add “request for” between “valid” and “interpretation” since the only assessment that can be made at that time is whether not the request is valid, not whether or not the interpretation itself (which has yet to be developed) is valid. 7. Step 3.5: DEVELOPMENT OF RESPONSE TO RFI - Clarity should be added to indicate whether it is 45 days after NPCC receives the RFI or the Drafting Team (DT) receives the charge to develop a response (i.e. the interpretation). Depending on the activities that may occur after NPCC receives the RFI, the DT may have very little time to develop a response.
07/02/2013Dominion Resources Inc.View Attachment
 
Comments: Dominion comments attached for the Regional Standard Process Manaul
06/25/2013NPCCView Attachment
 
Comments: Posted on behalf of PSEG