WIRAB Library

The Western Interconnection Regional Advisory Body (WIRAB) submitted advice to the Federal Energy Regulatory Commission (FERC) on its Request for Supplemental Comments in the Notice of Proposed Rulemaking (NOPR) on Essential Reliability Services and the Evolving Bulk-Power System – Primary Frequency Response (Docket No.: RM16-6). In the Request for Supplemental Comments on the NOPR, FERC sought supplemental comments related to whether and when electric storage resources should be required to provide primary frequency response, and the costs associated with primary frequency response capabilities from small generating facilities. WIRAB’s advice is aligned with its previous advice to FERC on the need for this rulemaking.

The Western Interconnection Regional Advisory Body (“WIRAB”) submitted comments to the U.S. Department of Energy regarding the Staff Report on Electricity Markets and Reliability. WIRAB referenced research indicating that baseload operation of the coal fleet in the West has decreased from 52 percent of coal unit operating days in 2001 to 22 percent in 2016. This confirms a U.S. DOE finding that many coal-fired generating units that were used for baseload generation in the past are no longer operating in that role at this time. WIRAB also noted that current studies of the Western Interconnection do not indicate there is a shortage of primary frequency response at this time. WIRAB continues to believe that more research and analysis is needed to determine how primary frequency response will be provided, including where such response is needed and which technologies can best and most cost effectively provide it, as the composition of the electric grid changes in the West. WIRAB encourages U.S. DOE to continue to work with Western states and provinces to address the reliability implications of the changing electric grid.

The Western Interconnection Regional Advisory Body (WIRAB) commissioned a report from InPOWERd LLC on the NERC Reliability Issues Steering Committee’s (RISC) November 2016 report on ERO Reliability Risk Priorities. The InPOWERd Report provides a summary of the NERC RISC process and highlights key reliability risk profiles for the Western Interconnection, based on the 2016 ERO report.

The NERC RISC plans to release a new draft 2017 ERO Reliability Risk Priorities Report in mid-September and a Final 2017 ERO Reliability Risk Priorities Report in November 2017. The NERC Board of Trustees will then consider the 2017 ERO Risk Priorities at its February 2018 meeting.

The WIRAB-commissioned InPOWERd report can be used to help prepare WIRAB to review the upcoming November 2017 report on ERO Reliability Risk Priorities. With this information, WIRAB can work with the WECC Member Advisory Committee (MAC) to provide strategic guidance to the WECC Board of Directors on how it should develop its strategic planning process and utilize the work of the NERC RISC in implementing that process.

The Western Interconnection Regional Advisory Body (“WIRAB”) submitted comments on Peak Reliability's 2018 Proposed Budget and Draft Funding Amount. WIRAB reviewed Peak's proposed 2018 Proposed Budget and Draft Funding Amount and wants to ensure Peak prioritizes and funds the goals and objectives set out in its strategic plan.

In response to a Western Electricity Coordinating Council (WECC) Member Advisory Committee (MAC) survey seeking input on the effectiveness of the WECC Board, the Western Interconnection Regional Advisory Body (WIRAB) rated the WECC Board’s performance in several categories and drafted comments to support ratings indicating that the WECC Board exceeds expectations or has specific opportunities to improve. 

The objective of this report is to introduce a framework for objectively reviewing and assessing the reliability and cost implications of a transition from a single Interconnection-wide Reliability Coordinator (RC) against the possibility of providing RC services in the Western Interconnection with multiple RCs with smaller RC footprints. The report identifies the tools and technologies currently used by Peak Reliability (“Peak”) to provide RC services in the Western Interconnection. The report also provides rough estimates of the cost of a new RC providing similar RC services.  In the interests of reliability, policy makers should encourage all interested stakeholders to work with any organization seeking to provide RC services to ensure reliability in the Western Interconnection is maintained at least at the same level and focus as exists today.

This review is focused on the following issues:

  1. The tools and services currently provided by Peak Reliability including a brief exploration of the history of Peak.
  2. The physical and operational differences between the Eastern Interconnection and the Western Interconnection and the associated reliability impacts
  3. A high-level estimate of costs anticipated for establishing a new RC in the Interconnection.

This framework attempts to identify the tools and capabilities an additional provider of RC services would need to have to provide comparable reliability in the Western Interconnection. The report identifies those tools and technologies that must be provided to deliver minimum reliability per the North American Electric Reliability Corporation (NERC) Reliability Standards, and additionally, it identifies those tools developed over time in the Western Interconnection to improve reliability above and beyond the minimum standards. If another entity can demonstrate it can provide comparable reliability in the West at a lower cost to its specific customers, then it should be considered a viable RC service provider.

The Western Interconnection Regional Advisory Body (“WIRAB”) submitted advice to Peak Reliability regarding if Peak’s Universal Data Sharing Agreement (“UDSA”) should be amended to include a third party data sharing review process. WIRAB recommended that the UDSA be amended to include a third party data sharing review process while ensuring continued security and protection for Critical Electric Infrastructure Information (“CEII”). WIRAB recommended that Peak reengage immediately with stakeholders on a third party data sharing review process that can allow for the sharing of information that is not CEII and to set up another trigger point for Peak and stakeholders to discuss how to allow for information that is considered CEII to be shared appropriately.
The Western Interconnection Regional Advisory Body (“WIRAB”) staff submitted comments dated May 16, 2017 to the Western Electricity Coordinating Council (WECC) on the Draft Anchor Data Set (ADS) Workflow diagram. While the current draft ADS Workflow is a good start for building a consistent process for gathering planning data, WIRAB staff identifies four areas for improving the future ADS workflow process and the future use of the ADS.

The Western Interconnection Regional Advisory Body (“WIRAB”) submitted comments to the Western Electricity Coordinating Council (WECC) on WECC’s proposed 2018 Business Plan and Budget (BP&B).  WIRAB reviewed WECC’s proposed 2018 BP&B and finds the budget and assessment to be reasonable and in the public interest.

The Western Interconnection Regional Advisory Body (“WIRAB”) staff submitted comments to the Peak Reliability Board of Directors on proposed amendments to the Peak Bylaws that would establish biennial director elections and extend director terms from three to four years. The WIRAB staff comments express general support for the proposed amendments and recommend that the Bylaws be further amended to implement term limits for Board directors. The WIRAB staff comments also recommend that the Peak Board adopt a formal process for considering proposed Bylaw amendments that supports thorough and timely stakeholder engagement.

The Western Interconnection Regional Advisory Body (“WIRAB”) submitted advice to the Western Electricity Coordinating Council (WECC) Member Advisory Committee’s (MAC’s) Nominating Committee Composition Work Group (Work Group) on the composition of the WECC Nominating Committee (NC).  In response to concerns about Member Class representation on the NC, the Work Group developed a whitepaper exploring possible alternatives to the current NC structure.  WIRAB reviewed the Work Group’s whitepaper and proposed an additional NC structure that addresses concerns about Member Class representation while still maintaining a reasonable balance between Board and MAC representatives and maintaining a reasonable balance between industry representatives and non-industry representatives.

The Western Interconnection Regional Advisory Body (WIRAB) submitted advice to the Federal Energy Regulatory Commission (FERC) on its 2016 Notice of Proposed Rulemaking (NOPR) on Essential Reliability Services and the Evolving Bulk-Power System – Primary Frequency Response (Docket No.: RM16-6). FERC proposed to revise its regulations to require all newly interconnecting large and small generating facilities (exempting nuclear facilities) to install and enable primary frequency response capability as a condition of interconnection. Among other things, the proposed requirements would require new generating facilities to install a governor or equivalent controls; require specific maximum droop and deadband settings; require a timely and sustained response; and require droop parameters to be based on nameplate capability with a linear operating range of 59 to 61 HZ. WIRAB’s advice is aligned with its previous advice to FERC on the need for this rulemaking, which is available here.

The Western Interconnection Regional Advisory Body (“WIRAB”) submitted comments on the Western Electricity Coordinating Council’s (WECC’s) Strategic Direction Planning Process, 2017-2020 Operating Plan, and Strategic Direction Outline.  WIRAB’s comments encourage the WECC Board to adopt an open and transparent procedural process to develop WECC’s strategic priorities and direction; recommend specific strategic priorities for WECC’s 2017-2020 planning cycle; and advise the WECC Board to redefine its Strategic Direction Outline document as Key Reliability Challenges in order to transform the Outline into a durable document, capable of enduring multiple planning cycles.

The Western Interconnection Regional Advisory Body (“WIRAB”) Staff submitted comments to the Western Electricity Coordinating Council (WECC) Board of Directors (Board) regarding proposed amendments to the WECC bylaws, including: 1) WECC’s proposed “Bucket 1” amendments, which include administrative amendments requiring Board approval; and 2) WECC’s proposed “Bucket 2” amendments, which include administrative amendments requiring approval from both the Board and WECC members.

The WIRAB Staff submitted comments on the proposed changes to the Western Electricity Coordinating Council’s (WECC) Information Sharing Policy. WIRAB Staff’s comments advise WECC to have an Information Sharing Policy that encourages the broadest sharing possible, to establish clear criteria for categorizing information, create clear criteria for determining if an individual should be granted access to information, and institute a fair and balance review process for information sharing disputes.

The Western Interconnection Regional Advisory Body (“WIRAB”) staff submitted comments on the Peak Reliability (Peak) draft Audit Committee Charter which, if approved, will establish an Audit Committee to assist the Peak Board’s oversight of the integrity of Peak’s financial statements, Peak’s compliance with legal and regulatory requirements, and the performance of Peak’s independent auditors. WIRAB is authorized to provide advice on the governance of Peak Reliability. WIRAB made several observations and recommendations regarding Peak’s proposed Audit Committee Charter.

The Western Interconnection Regional Advisory Body (“WIRAB”) submitted comments to the Federal Energy Regulatory Commission (“FERC”) in support of the Western Electricity Coordinating Council’s (“WECC”) 2017 Statutory budget and assessment. WIRAB reviewed WECC’s 2017 Business Plan and Budget and finds all of the proposed activities to be eligible and appropriate for funding under Section 215 of the Federal Power Act and respectfully requests the FERC to approve the 2017 statutory budget and assessment.

The Western Interconnection Regional Advisory Body (“WIRAB”) submitted comments to the Federal Energy Regulatory Commission (“FERC”) on the notice of proposed rulemaking issued June 16, 2016 regarding Critical Electric Infrastructure Information (“CEII”). WIRAB provided five recommendations on two subsections of the recently enacted Federal Power Act Section 215A requiring FERC to promulgate regulations surrounding CEII.

The Western Interconnection Regional Advisory Body (“WIRAB”) submitted comments on the Peak Reliability 2017 Draft Funding Amount (also referred to as the Business Plan and Budget). WIRAB is authorized to provide advice on the funding of Peak Reliability and determine if the fees assessed within the region are just, reasonable, not unduly discriminatory or preferential, and in the public interest. WIRAB made two overarching recommendations and four specific recommendations regarding Peak Reliability’s 2017 Business Plan and Budget.

The Western Interconnection Regional Advisory Body (WIRAB) submitted final comments on Peak Reliability’s 2016-2020 Strategic Plan. In the comments, WIRAB takes an expansive view of Peak’s role in ensuring “excellent reliability performance in the Western Interconnection” and provides three overarching recommendations as Peak moves forward with its Strategic Plan.

GE Energy Consulting completed a report for the Western Interconnection Regional Advisory Body (“WIRAB”) on primary frequency response (“PFR”). PFR is crucial in the reliable operation of the electric grid. With the rapidly changing resource mix in the West and the rest of the country, there is a concern that there may not be enough PFR in the future to protect the system in the case of a large system disturbance. In this report, GE Energy Consulting provides a technical introduction to PFR, some of the advantages and disadvantages of certain resources providing PFR, some of the current issues with PFR, and what the future of PFR might hold. WIRAB used this report, as well as other work, to help provide advice to the Federal Energy Regulatory Commission’s 2016 Notice on Inquiry on Essential Reliability Services and the Evolving Bulk-Power System – Primary Frequency Response (Docket No.: RM16-6).

The Western Interconnection Regional Advisory Body (“WIRAB”), Western Resource Advocates (“WRA”), Natural Resources Defense Council (“NRDC”), and Western Grid Group (“WGG”) submitted supplemental comments to the Peak Reliability Member Advisory Committee regarding the direction Peak should take with its Universal Data Sharing Agreement (“UDSA”) since the Fixing America’s Surface Transportation Act (“FAST Act”) was signed into law. On March 1, 2016, Peak winnowed down the options for the Peak Board to consider at its March 2016 Board Meeting to three options. The group recommended a combination of two options that would: (1) put a hold on the third-party data sharing review process, but would allow for the sharing of a limited amount of predefined data and (2) would lead to the termination of the agreement in the case that the parties to the agreement cannot agree upon conforming changes to UDSA to address third-party sharing.

The Western Interconnection Regional Advisory Body (“WIRAB”), Western Resource Advocates (“WRA”), Natural Resources Defense Council (“NRDC”), Western Grid Group (“WGG”) and Vanry & Associates Inc. (“VAI”) submitted comments to Peak Reliability on the direction Peak should take with its Universal Data Sharing Agreement (“UDSA”) since the Fixing America’s Surface Transportation Act (“FAST Act”) was signed into law. The FAST Act is a federal transit spending law that includes provisions relating to energy security and critical energy infrastructure. Because of pending regulations, Peak has questioned whether the recently adopted UDSA, which includes procedures for sharing data with third parties, should be modified. WIRAB, along with the other commenters, are unsupportive of the options on which Peak requested feedback because the commenters believe that a comprehensive review of the third party data sharing review process should be conducted after regulations are finalized in a fair and balanced process.

WIRAB provided comments on WECC’s Draft Charter for the re-chartered Joint Guidance Committee. During its review of governance and organizational issues, the WECC 4.9 Review Task Force proposed the re-chartered JGC as a way to ensure that WECC committees are aligned with the strategic plan of WECC’s CEO and Board of Directors. WIRAB supported the draft charter and provided two clarifying changes.

Western States and Provinces submitted the following study requests to the Western Electricity Coordinating Council (WECC) as part of the Transmission Expansion Planning Policy Committee's (TEPPC) annual work plan.

WIRAB Staff along with Western Resources Advocates, Natural Resource Defense Council, and Western Grid Group submitted comments on Peak Reliability’s October 12th draft Universal Data Sharing Agreement (UDSA). The comments focused on concerns the group had in the UDSA regarding the process used to evaluate third party data requests.

WIRAB submitted comments on the Draft Report to the WECC Board of Directors on the Section 4.9 Review drafted by the Section 4.9 Review Work Group. Section 4.9 of the WECC Bylaws requires the WECC Board of Directors, every five years, to conduct a review of the governance and structure of WECC to ensure that WECC is fulfilling its purposes outlined in the WECC Bylaw.

WIRAB staff in collaboration with Western Resource Advocates, Natural Resources Defense Council, and Western Grid Group submitted comments to Peak Reliability on its Draft Universal data Sharing Agreement outlining an alternative proposal to the data sharing review process and evaluation criteria as currently proposed. The goal of the alternative proposal is to simplify the data categorization, to provide a vetting and appeal process that applies equally to disagreement with Peak’s decisions to restrict data or to allow its sharing, and to place the ultimate decision-making authority with Peak.

WIRAB/SPSC submitted comments to the Western Planning Region Group (California ISO, ColumbiaGrid, Northern Tier, and WestConnect) on its proposed Interregional Transmission Planning Coordination (ITPC) Procedures. The comments go beyond recommending improvements to the proposed ITPC Procedures and make specific recommendations regarding the future role of the Western Electricity Coordinating Council (WECC) in developing interconnection-wide transmission plans.

Western States and Provinces submitted the following study requests to the Western Electricity Coordinating Council (WECC) as part of the Transmission Expansion Planning Policy Committee's (TEPPC) annual work plan.

Western States and Provinces submitted the following study requests to the Western Electricity Coordinating Council (WECC) as part of the Transmission Expansion Planning Policy Committee's (TEPPC) annual work plan.

Western States and Provinces submitted the following study requests to the Western Electricity Coordinating Council (WECC) as part of the Transmission Expansion Planning Policy Committee's (TEPPC) annual work plan.

Western States and Provinces submitted the following study requests to the Western Electricity Coordinating Council (WECC) as part of the Transmission Expansion Planning Policy Committee's (TEPPC) annual work plan.

Western States and Provinces submitted the following study requests to the Western Electricity Coordinating Council (WECC) as part of the Transmission Expansion Planning Policy Committee's (TEPPC) annual work plan.

Western States and Provinces submitted the following study requests to the Western Electricity Coordinating Council (WECC) as part of the Transmission Expansion Planning Policy Committee's (TEPPC) annual work plan.