WECC Position Paper for the initial ballot of the Standard Processes Manual
Revisions to Implement SPIG Recommendations,
being balloted October 3-12, 2012
NERC is conducting an initial ballot of revisions to the Standards Processes Manual (SPM) from
October 3-12, 2012. These proposed revisions were developed to implement recommendations
from the NERC Member Representatives Committee’s Standards Process Input Group (SPIG).
Members of the Standard Processes Manual Revisions to Implement SPIG Recommendations
Ballot Pool are encouraged to vote YES to approve the SPM Revisions
A complete copy of the proposed standard and associated materials can be viewed at:
http://www.nerc.com/filez/standards/Standards_Processes_Manual_revisions_SPIG_2012.html
An initial version of the proposed revisions was posted for a formal comment period June 20-July
19, 2012. Based on stakeholder comments during the formal comment period, the following
revisions were made to the initial draft.
 Development of Violation Risk Factors (VRFs) and Violation Severity Levels (VSLs)
during the standard development period was retained. It had been proposed to replace
VRFs and VSLs with a set of predetermined Sanction Tables to reduce the burden on
drafting teams.
 The proposal to exclude negative votes without related comments in determining
consensus was removed from the proposed revisions. However, the proposal to exclude
negative votes with no comment in determining consensus was retained. The intent of
this change is to encourage the submittal of meaningful comments with negative votes
to provide the drafting teams with information to address concerns.
 Includes the development of Reliability Standards Audit Worksheets (RSAWs) during the
standard development period. This will allow for a non-binding poll of the RSAWs as part
of the standard development process rather than developing the RSAWs after the
standard has been approved.
 Added clarifying language that there will not be a comment period during the final
(recirculation) ballot off the standard.
Some stakeholders have expressed concern related to removal of the Expedited Standards
Development Process and its replacement with the Waiver section (Section 16.0). However, a
review of the proposed changes indicates that the Expedited Standard Development Process was
not a separate standards process, but rather a waiver provision by another name with a
prescriptive list of actions that could be taken. The main problem with the current Expedited
Process is that NERC must either announce that a standard developed under the Expedited
Process will expire after two years or repeat the entire standards process again to develop and
approve the same standard using the full standards development process. This is viewed as
redundant and a waste of resources for NERC, the industry, and the drafting teams. Additionally,
industry consensus is still required under the proposed Waiver process. Approval still requires a
75% quorum, a two-thirds segment weighted supermajority approval, and responses to all
comments submitted during comment periods. The waiver provision merely allows the SC to
meet external deadlines and to use industry and NERC resources efficiently.
If you determine that you will vote no, it is important that you provide a comment with your vote
indicating the reason(s) why you voted no and suggested modifications that would make the
SPM revisions acceptable. By submitting comments you are providing the drafters of the
revisions with valuable information to address your concerns. Due to changes in the NERC
balloting software, balloters who wish to submit comments with their ballot may no longer submit
their comments from the balloting screen. Rather, those wishing to submit comments must do so
via the electronic comment form available from the project page identified above.
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All WECC entities that are registered in the Standard Processes Manual Revisions to Implement
SPIG Recommendations Ballot Pool are urged to cast their ballots prior to the close of the ballot
period.
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