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Bob Thomas

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Illinois Municipal Electric Agency

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NA

1) Subsequent to a review performed by NERC staff, the SDT has reformatted and modified certain requirements of the draft PRC-006-RFC-01 standard. Do you agree with the reformatted structure and modified requirements of the standard?

Abstain

1) If not, please provide specific suggestions.

 

2) Time Horizons have been added to the Requirements. Do you agree that the Time Horizons are appropriate for the requirements?

Abstain

2) If not, please provide specific suggestions.

 

3) The Measures have been modified to include more examples on how to assess performance and outcomes for the purpose of determining compliance with the requirements.  Do you agree that the Measures are appropriate?

Abstain

3) If not, please provide specific suggestions.

 

4) The Violation Severity Levels (VSLs) have been modified to be consistent with the modified requirements and based on NERC and the FERC guidelines.  Do you agree that the VSLs are appropriate?

Abstain

4) If not, please provide specific suggestions.

 

5) The Violation Risk Factors (VRFs) have been modified to be consistent with the modified requirements and based on NERC and the FERC guidelines.  Do you agree that the VRFs are appropriate?

Abstain

5) If not, please provide specific suggestions.

 

6) The Standard Drafting Team believes the standard is ready for Category Ballot.  Do you agree?

No

6) If not, please provide specific suggestions that would make it acceptable to you.

Illinois Municipal Electric Agency (IMEA) appreciates the SDT's efforts and responsiveness leading to the development of Draft 6; however, it is our understanding from Sector representatives and representatives on the NERC PRC-006-1 SDT that region-specific UFLS standards are no longer necessary.  If the PRC-006-RFC-01 SDT believes this region-specific standard is necessary, IMEA would appreciate the SDT addressing that point before the Category Ballot.  In addition, if the SDT decides to move forward with this proposed region-specific UFLS standard, IMEA recommends that the SDT address inconsistencies with entity applicability and requirements as specified in NERC's PRC-006-1.  Finally, IMEA supports the GO-related comments to this survey as submitted by Indiana Municipal Power Agency.

Created at 9/7/2012 10:09 AM by System Account
Last modified at 9/7/2012 10:09 AM by System Account