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W. Shannon Black Manager, Standards Processes. Results Based Drafting 2013. The Basics. Who? Define the DT The team is subject to open What? Draft a WECC Regional Reliability Standard When? Six months or six years. Why are we Here? . Where? Rarely face-to-face Usually Webinar Why?
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W. Shannon BlackManager, Standards Processes Results Based Drafting 2013
The Basics • Who? • Define the DT • The team is subject to open • What? • Draft a WECC Regional Reliability Standard • When? • Six months or six years
Why are we Here? • Where? • Rarely face-to-face • Usually Webinar • Why? • Reliability • Wear your “WECC Hat” not your “Firm Hat” • How? • In accordance with the “Procedures” and NERC Rules
The Chair and the Team • Chair • Primary • Create work product • Ensure the team keeps moving forward • Facilitate within the four-corners of the Procedures • “Voice” of the team • Secondary • Subject Matter Expert • Team Members • SME with a WECC purpose
WECC Staff • WECC Staff • Manage the Procedures • Stay within the Procedures • Keep the team moving • Manage the document • Document control • First tier quality review • Facilitator plus Technical Writer • Language and Procedure SME • Manage the website
The WSC • Procedural Oversight • Need approval for most everything • Scope • Posting of work product (Versions/Response) • Forward to WECC Board • The Standing Committee no longer control the development process.
Board / NERC / FERC • NERC • Quality Review • Board • Approves, remands or rejects • NERC – again • Board of Trustees • Legal – multiple reviews of the filing • FERC • Approve, remand or reject • Their own calendar
“Procedures” And Principles
The “Procedures” • WECC/NERC/FERC Approved Document • Exhibit “C” of the Delegation Agreement • Basically a Contract • Contains specifics of delegated authority • Is not all inclusive • Needs interpretation • Staff will assist
Procedural Mandates • Meetings require 15 days notice • Comment • 45 days followed by 30 days – until done • Response • 30 days to respond • Impact Statement • Addresses Costs & “Other” • Don’t forget the WSC • Allow WSC “Time”
Procedural Mandates • Posted 30 days before a Ballot Pool • Posted 30 days before the Board • Ballot Body/Ballot Pool • Joint Session – 3 days notice • Vote “at least” 7 days after Session • Vote covers 15 “Business” days • “No” votes require a reason • Added to the record
Responses • Each Comment • Requires a Response • Can be aggregated • Forwarded to WSC • They officially approve and post • 30 days to get Responses posted • Repeat until done
Vote • Requires 2/3 quorum of “Pool” • Abstentions and incomplete votes count • Vote “at least” 7 days after Session • Vote 15 calendar days or extended as needed • If accepted • To the Board “via” the WSC • If rejected • WSC can rewrite, re-ballot or recycle to Session, terminate
Development Principles • The Procedures do not require a quorum of the DT to be present before a DT vote is taken. • The Procedures do not require notice that a DT subset group will meet. • It takes only a simple majority to carry a vote on any DT issue.
Development Principles • All meetings of the DT shall be open to the public and broad participation is encouraged. • Nothing in these Development Principles shall infringe on an individual’s rights to appeal • Among other reasons… • Can appeal for procedural or technical error • All DT members are encouraged to always be present; proxy voting by a DT member is not allowed.
Development Principles • DT voting may take place face-to-face, electronically, in real-time or within a scheduled window. • Voting on which position to adopt on a drafting issue is reserved for the DT members. • Voting on inclusion or exclusion of specific language in the document under development is reserved for the DT members. • Voting on minutes and related business motions is reserved for the DT members. • Straw Polls are of excellent advisory value but the DT is not obligated to abide by a straw poll.
Regulatory - Speak • Follow the ERO or RRO templates • Applicable Entities • NERC Functional Model dictates • Requirement and Measures • Each X shall do Y. Evidence may include… • Avoid • Adjective, pronouns, adverbs • Do not incorporate by reference • Don’t use “C”aps unless defined
Where do we start? • Review the SAR and other documents • Draft the Purpose • This overall document is designed to…. • Fill in that blank • The body should match the Purpose statement • Draft a set of goals • Things we want entities to do • Draft the tasks that need to be done • Can assign entities later • Draft the sequence of those tasks
Pen to Paper • Now we can draft