Standards Development Improvement Opportunities

February 18, 2014

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Overview

• Standards to Directive• Examples of Current Standards• NAESB Definitions• Existing/Revised Standard• Options for Consideration• Discussion

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Standards to Directives

REGULATION

a rule or directive made and maintained by an

authority

DIRECTIVE

an official or authoritative instruction

STANDARD

a required or agreed level of quality or

attainment

“Incorporating these revised standards by reference into the Commission’s regulations” FERC Order 676-E

Note: Definitions from Oxford Dictionary

How do we provide clarity to instructions?

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Example WEQ-011011-1.6 BAs and/or RCs should establish written operational communication procedures with the appropriate gas Transportation Service Provider(s) and/or PPGC(s) [Power Plant Gas Coordinator(s)]. These procedures should be implemented when an extreme condition could occur, as defined in such procedures.

These procedures will govern unless the applicable parties in the gas and electric industry mutually agree to create alternative written communication procedures that are more appropriate and meet the parties' collective regional operational needs.

Training on and testing of such communication procedures should occur periodically.

Assume it is the other entity

Not required to have procedures

Can pick which entity? What/who

determines

Applicable partiesMore

appropriate

If procedures exist

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Example WEQ-001

001-4.9.1 Preconfirmed requests for short-term firm and non-firm point-to-point service shall not be allowed to be WITHDRAWN by the Transmission Customer unless counteroffered by the Transmission Provider, after which the Transmission Customer shall be allowed to withdraw the request.

Condition for optionality and requirement

Optional for Transmission Customer

Requirement for Transmission Provider

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Example WEQ-004

004-11.2 The Requesting PSE shall have the right to request an extension to the Arranged, Confirmed or Implemented Interchange energy profile prior to completion to reflect a desire to flow energy during hours not previously specified.

Optional for the PSE

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NAESB Definitions

May, should, or optional - Define optional requirements that are recommended for implementation but are not specifically required under these Business Practice Standards.

Must, shall, or required - Define specific requirements that are not optional and must be implemented as described under these Business Practice Standards.

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Example WEQ-001-4.10.6.3

EXISTING

The Eligible Customer or Transmission Customer shall be permitted, but is not required, to rebid any Coordinated Request in the Coordinated Group when the Eligible Customer or Transmission Customer has notified the Transmission Provider that one or more of the other Coordinated Requests in the Coordinated Group is part of a NITS Application that has been withdrawn or denied.

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Example WEQ-001-4.10.6.3REVISEDAn Eligible Customer or Transmission Customer may submit a rebid request to the Transmission Provider on any Coordinated Request provided the Eligible Customer or Transmission Customer previously notified the Transmission Provider that one or more of the other Coordinated Requests in the Coordinated Group: a) is part of a NITS Application, and b) have been withdrawn or denied.A Transmission Provider must evaluate a rebid on a Coordinated Request submitted by an Eligible Customer or Transmission Customer provided the Eligible Customer or Transmission Customer notified the Transmission Provider, prior to submitting the rebid, that one or more of the other Coordinated Requests in the Coordinated Request: a) is part of a NITS Application, and b) has been withdrawn or denied.

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Options for Consideration

What we can’t do:

• Re-write of the entire standards

• Reformat of the standards

Do we want to consider:

• Offer/conduct training for subcommittees

• Develop training materials/style guides

• Review future standards against established criteria

• Identify standards that could be improved / revise as we go

• Coordinated approach with other quadrants

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Discussion