Regional Reliability Standards Process

Texas Reliability Entity, Inc.  (Texas RE) may develop, through its own FERC-approved processes, separate reliability standards that go beyond, add detail to, or implement NERC Reliability Standards, or that cover matters not addressed in NERC Reliability Standards. Below is a summary of the process of developing a regional reliability standard. For more details, see the procedures below.

Step 1 –  Standard Authorization Request

Any entity impacted by the bulk power system within the ERCOT region may request the development, modification, or deletion of a regional standard. Such requests are originated through a Standard Authorization Request (SAR) form that adequately defines the purpose, scope, impacted parties, and other relevant information of the draft standard. The completed SAR must be e-mailed to the Reliability Standards Manager (RSM) at rsm@texasre.org  for initial review. The SAR is posted for a 15-day comment period on the Reliability Standards Tracking  site. From this point forward, any actions on the SAR are publicly tracked using this site. The Reliability Standards Committee (RSC) reviews the SAR, and, if accepted, directs the RSM to form a Standard Drafting Team (SDT).

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Step 2 – Standard Drafting Team

Upon acceptance of a SAR by the RSC, an SDT is nominated by the RSM in conjunction with the RSC. The SDT consists of stakeholders in the ERCOT region who collectively have the technical expertise and work process skills to draft the standard. No more than one individual from any one company may serve on the SDT.

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Step 3 – Work of the Standard Drafting Team – Drafting the Standard

The SDT meets regularly to draft the standard, and the RSM facilitates and coordinates the SDT meetings. The work product of the SDT submitted to the RSC includes the following: (1) draft standard, (2) its impact on neighboring regions, (3) implementation plan, (4) the impact to existing standards, (5) supporting papers, (6) the standard’s reliability impact, and (7) a draft of recommended Violation Risk Factors (VRFs) and Violation Severity Levels (VSLs). Detailed SDT procedures are available below.

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Step 4 – Posting for Comment

After the RSC accepts the draft standard from the SDT, the RSM posts it, along with the draft VRFs and VSLs, implementation plan and supporting documents on the Reliability Standards Tracking  site for a 30-day commenting period. The RSM announces the commenting period to the Reliability Standards Committee mail list, to which all interested parties may subscribe on the Texas RE Mailing Lists . Any interested party who is registered on the Reliability Standards Tracking site may comment on the draft standard. All comments that are submitted via the site are considered and given a response by some combination of the RSC, the SDT, and the RSM; comments are posted on the Reliability Standards Tracking site. The RSC may direct the SDT to redraft the standard at this point based on comments. Based on the number and significance of revisions, there may be more than one commenting period for a draft standard.

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Step 5 – Posting for Voting

Upon the recommendation of the SDT and agreement by the RSC, the RSM posts the draft standard, along with the implementation plan and supporting documents for ballot on the Reliability Standards Tracking  site. The RSM schedules a vote to commence no sooner than 15 days and no later than 30 days following this posting. A non-binding poll on the VRFs and VSLs is conducted in conjunction with the ballot period.  The RSM announces the upcoming vote/ballot to the Reliability Standards Committee mail list.

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Step 6 – Voting

Voting is allowed for 15 days. All members of the Texas RE Registered Ballot Body (RBB) are eligible to participate in voting on regional standards; however, only those members who (1) have registered on the Reliability Standards Tracking  site, and (2) have elected to be in the ballot pool associated with a particular standard via the Reliability Standards Tracking site will be allowed to vote. For auditing purposes, RBB members use the Reliability Standards Tracking site to vote; no votes are accepted via any other method. The RSM affirms the voting results and posts them on the site. For a detailed explanation of the voting mechanism used within Texas RE and how to become a RBB member and subsequent Ballot Pool member, please read the RBB procedures below.

If a draft standard receives the required affirmative votes, the RSC forwards it to the Texas RE Board of Directors (BOD) for action. If a draft standard does not receive the required affirmative votes, the RSC may direct the SDT to revise the SAR or draft standard and a second ballot will be held.  If the second ballot fails, the RSC will refer the draft standard to the Texas RE BOD. 

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Step 7 – Action by the Texas RE Board of Directors

The draft standard submitted to the BOD for consideration is publicly posted at least 10 days prior to action by the BOD. The BOD considers the results of the voting, comments, dissenting opinions, and any advice of the RSC, RSM, or SDT. The BOD may approve the draft standard; remand the draft standard to the RSC with comments and instructions; or disapprove the draft standard without recourse. The BOD also considers the VRFs and VSLs for approval and may modify the VRFs and VSLs.  The RSM posts the BOD decision on the Reliability Standards Tracking site and notifies market participants via the Reliability Standards Committee mail list.

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Step 8 – Final Approvals and Implementation of Regional Standard

Upon approval of a regional standard by the BOD, the RSM begins the process to have the standard reviewed and approved by the North American Electric Reliability Corporation (NERC) and subsequently the Federal Energy Regulatory Commission (FERC). For more information on the Standard Submittal Process to NERC, please review this procedure below. After approval by NERC and FERC, the RSM notifies Texas RE Compliance Staff and stakeholders of the standard’s effective date via the normal and customary communication procedures and processes. The RSM posts the implementation date on the Reliability Standards Tracking site.

The eight steps above are discussed in more detail in the Texas RE Standards Development Process.