WIRAB Library

WIRAB submitted advice supporting the CAISO proposed Tariff amendment to provide Reliability Coordinator (RC) services for entities in the Western Interconnection. The proposed Tariff amendments outlined the rate design, terms and conditions for its RC services and making reference to the formation of a CAISO RC Oversight Committee and the development of an Oversight Committee charter.  The role of the CAISO RC Oversight Committee would be to provide input and guidance to the CAISO RC on matters relating to performance of the RC function.  The Oversight Committee charter would determine membership, responsibilities, and procedures for the Oversight Committee. In its advice to FERC, WIRAB highlighted key principles for RC governance and decision-making to ensured that the provision of RC Services is conducted in a manner that best serves the public interest. These principles include:

  1. Transparent decision making by the RC;
  2. Independent decision making by the RC; and
  3. Meaningful input and advice from WIRAB.

WIRAB worked with the CAISO in an effort to incorporate WIRAB’s key principles into the CAISO RC oversight committee charter and in doing so supports the terms under which the CAISO proposes to provide RC services in the West

WIRAB submitted comments to the Western Electricity Coordinating Council regarding the appropriate treatment of traditionally public Production Cost Model (PCM) data and integrated PCM data.  In this set of comments, WIRAB also provided advice and offered to support WECC’s efforts to improve WECC’s Information Sharing Policy. 

WIRAB submitted advice to the California ISO on its proposal to stand up a Reliability Coordinator in the West. WIRAB provided comments or advice on the CAISO’s RC proposal in three categories:

  • Governance;
  • BA/TOP competency requirements; and
  • General Rate Design, Terms and Conditions

The Western Electricity Coordinating Council (WECC), with the help of WIRAB, the WECC Member Advisory Committee, and other WECC Stakeholders, developed a set of Near-Term Priorities for 2019-2021. WIRAB supports the final Near-Term Priorities and looks forward to working with WECC to successfully execute the WECC Strategic Planning Process.

WIRAB submitted advice to the Western Electricity Coordinating Council's (WECC) Board of Directors on the proposed 2019 Business Plan and Budget (BP&B) for WECC. WIRAB reviewed the proposed 2019 BP&B and finds the budget and assessment to be reasonable and in the public interest.

WIRAB Staff submitted comments on the Western Electricity Coordinating Council’s (WECC’s) proposal to amend its Information Sharing Policy for production cost model (PCM) data to be categorized as Critical Energy Infrastructure Information (CEII).

WIRAB submitted advice to the WECC Board of Directors on setting strategic priorities through WECC's Strategic Planning Process. In the advice, WIRAB recommended that the WECC Board adopt (1) the Changing Resource Mix, (2) the Increasing Complexity in Protection and Control Systems, and (3) the Loss of Situational Awareness as Near-Term Priorities for 2019-2021. WIRAB also recommended that the WECC Board adopt a set of Action Items that will serve to guide WECC in its efforts to mitigate specific risks within each of the Near-Term Priorities. WIRAB suggested that each Action Item include “who” is tasked with completing the work; “what” is to be completed or delivered; and “when” the item is to be completed, but leave “how” these actions are accomplished up to WECC management and the WECC Standing Committees.

The Western Interconnection Regional Advisory Body (WIRAB) commissioned a whitepaper from GridSME on potential seams issues that could occur as the transition to multiple Reliability Coordinators (RCs) occurs in the Western Interconnection. The purpose of this whitepaper is to highlight for public utility commissioners and policymakers the importance of the Reliability Coordination function and to describe the potential issues when multiple RCs share responsibility for the coordinated operation across system boundaries and seams. The purpose is not to describe any solutions to these issues, but rather identify them as issues to be address under this new paradigm. The issues determined to be of greatest concern to reliability are elaborated in Section IV of the document and include:

  • System Operating Limit and Interconnection Reliability Operating Limit Coordination
  • Wide Area View and the Future of the Westwide System Model
  • Outage Coordination
  • Remedial Action Scheme Coordination
  • Oscillatory Dynamics

This whitepaper is compiled through research on the relevant issues, reviews of applicable NERC and Federal Energy Regulatory Commission (FERC) documents, and extensive interviews with relevant personnel at the North American Electric Reliability Corporation (NERC), the Western Electricity Coordinating Council (WECC), Peak Reliability, the Southwestern Power Pool (SPP), and the California ISO (CAISO).

The Western Interconnection Regional Advisory Body (“WIRAB”) submitted its response to the 2018 Peak Board Evaluation Questionnaire. Similar to previous year WIRAB responses to Peak Board evaluation questionnaires, WIRAB has submitted a single, unified response based on open deliberations among the states. This response, with accompanying explanation or comments to select questions, is included in the completed Peak Board Evaluation Questionnaire. WIRAB’s evaluation warranted further explanation and discussion. Therefore WIRAB respectfully requested an opportunity to meet with representatives of the Peak Board and Peak Management to discuss the responses and to offer recommendations for Board improvement.

WIRAB submitted advice to the NERC Board of Trustees on the 2017 ERO Reliability Risk Priorities Report. The comments commend the Reliability Issues Steering Committee for developing an important and comprehensive report with many specific recommendations. The comments also recommend that the Board of Trustees focus on a small set of specific recommendations that the ERO Enterprise can act on in the “near-term” time frame to prioritize and track actionable progress on efforts to mitigate the potential risks. WIRAB also identifies specific recommendations that NERC and the ERO Enterprise can focus on that have the potential to provide targeted focus for the ERO in key risk areas. WIRAB identified six recommendations that are: (1) recommendations directed to the ERO Enterprise; (2) “near-term” recommendations that are achievable in the next two-year timeframe; (3) recommendations for mitigating “high” priority risks; and (4) recommendations that are important across the ERO and of particular importance in the Western Interconnection.

WIRAB submitted comments to the NERC Board of Trustees on Improving the Efficiency and Effectiveness of Stakeholder Engagement that express WIRAB’s concern is that any effort to streamline the use of industry subject matter expertise could result in a shift of industry engagement towards NERC and away from WECC, and that the NERC Board should remain cognizant of regional differences while it strives to improve the efficiency and effectiveness of stakeholder engagement.

The Western Interconnection Regional Advisory Body (“WIRAB”) submitted comments to the Western Electricity Coordinating Council (WECC) regarding proposed amendments to the WECC bylaws, which include substantive amendments requiring approval by the WECC Board of Directors.

On October 23, 2017, the Western Interconnection Regional Advisory Body (WIRAB) submitted advice to the Federal Energy Regulatory Commission (FERC) that expressed concern about the accelerated timeline use in the rulemaking process under the U.S. Department of Energy’s (U.S. DOE) Reliability and Resilience Pricing Notice of Proposed Rulemaking (NOPR). WIRAB recommended that FERC ensure that the procedural process used in the rulemaking adequately supports the development of a comprehensive and complete record. 

Background: On September 28, 2017, the U.S. DOE issued a NOPR directing final action by FERC to impose rules on FERC-approved independent system operators (ISOs) and regional transmission organizations (RTOs) to ensure that certain reliability and resilience attributes of electric generation resources are fully valued. The Secretary of the U.S. DOE directed the FERC to take final action within 60-days of publication of the NOPR. On October 11, 2017, the Commission published in the Federal Register the NOPR in Docket RM18-1 Grid Reliability and Resiliency Pricing.  To meet the 60-day timeline directive from the Secretary, the Commission established a 21-day initial comment period and a 15-day period for reply comments. On October 3, 2017 a group of energy industry associations filed a joint motion for an extension of time to provide comments in this docket. On October 11, 2017, the Commission denied the motion for an extension of time and moved forward on the original timeline established.

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.