MEMORANDUM TO: Holly Mann, Secretary NERC Member Representatives Committee FROM: Tim J. Arlt John DiStasio Bill Gallagher John Twitty DATE: August 6, 2012 SUBJECT: Response to Request for Policy Input The MRC’s State and Municipal and Transmission Dependent Utility Sectors (“SM-TDUs”) appreciate the opportunity to respond to the July 11, 2012 letter from NERC Board Chair John Q. Anderson to Mr. Scott Helyer, acting in his capacity as the Chair of the NERC Member Representatives Committee (“MRC”), requesting policy input on topics to be discussed by the NERC MRC and the NERC Board of Trustees at the upcoming August meetings. This response addresses the two topics raised in Mr. Anderson’s July 11 letter: (i) the 2013 NERC and Regional Entity Common Business Plan and Budget, and (ii) the Recommendations of the Standards Process Input Group (“SPIG”). We also address “zero defect” requirements and Results–Based Standards. I. 2013 Business Plan and Budget SM-TDUs are concerned that the high priority items listed in the 2013 Business Plan and Budget, as revised on June 29, 2012, 1 do not include a priority to identify and retire specific standards and requirements that are no longer needed to meet an adequate level of reliability. Paragraph 81 of the FERC’s order conditionally accepting NERC’s Find, Fix and Track proposal noted that perhaps some current requirements provide “little protection for Bulk Electric System reliability or may be redundant.” 2 FERC went on to invite NERC to make specific proposals identifying the standards or requirements and setting forth in detail the technical basis for their retirement. SM-TDUs recognize that one of the goals of 2013 is to implement process changes to identify and slate for removal administrative requirements from existing standards where feasible. 3 However, there is no mention of standards retirements and the removal of administrative requirements is referred to only as a goal and not a priority. SM-TDUs urge NERC to classify the retirement of unnecessary standards or requirements as a priority and to allocate resources to this 1 http://www.nerc.com/docs/bot/finance/2013%20NERC%20Business%20Plan%20and%20Budget/Draft%202%20NER C%202013%20Business%20Plan%20and%20Budget-Updated06-27-12-clean.pdf 2 North American Electric Reliability Corporation, 138 FERC ¶ 61,193 (2012). 3 2013 Business Plan and Budget at 33.
