WECC-0118 Removal of Interchange Authority W. Shannon Black WECC Consultant Western Electricity Coordinating Council

Western Electricity Coordinating Council What does the SAR Say? Modify INT-020-WECC-CRT-1.1 “IA” Retire the impacted Requirements; Either Extract the affected Requirements (WITFR?), or; Retain the Requirements and reassign to a more appropriate Functional Entity Western Electricity Coordinating Council

Western Electricity Coordinating Council What does the INT Say? INT-020-WECC-CRT-1.1 Requires the Interchange Authority to: Monitor real-time operational status of the IA software. (WR1); Report confirmed failure of IA software (WR7); and, Report confirmed restoration of IA software (WR17). Western Electricity Coordinating Council

Western Electricity Coordinating Council Why is this an Issue? No one is accountable No one is registered as the Interchange Authority (IA) No one is registered as the Interchange Coordinator (IC) The tasks are generally performed by software – not people Compliance Registry and Functional Model FERC eliminated the IA from the compliance registry NERC eliminated IA from the Functional Model in favor of the IC WECC can only use Applicable Entities from the Functional Model Western Electricity Coordinating Council

Remedies: Retire or Modify Move the tasks to a more appropriate document such as the WIT Functional Requirements document. In 2009-2010, as part of the INT Redraft Project, numerous tasks were identified as dealing primarily “with the requirements of the software application; and recommended that the references to the software requirements be transferred to a technical document which would address the requirements of the WIT software.” WIT FR, History. The purpose of the WIT FR is to outline “functional requirements of the WECC Interchange Tool, a software application.” Western Electricity Coordinating Council

Remedies: Retire or Modify Assign to the Interchange Coordinator? No one is registered as the IC Ask compliance to force register Not for use in Drafting IC “is” used in NERC CIPs Used in the context of “Responsible Entities” without taking into account that no on is responsible/registered Like Reliability Assurer, Standards Developer, Compliance Enforcement Authority They are in the Model but not used for drafting Western Electricity Coordinating Council

Remedies: Retire or Modify Assign to the Balancing Authority? “The IC tasks are being performed…specifically [by] the “sink BA.” Use of the IC in the FM was forward-looking The FM could have eliminated the IC altogether but “envisioned in the future that the IC Tasks could be performed by entities other than a BA.” “The [FM] accommodates the sink BA as the IC, but does not require it.” Functional Model (FM) Technical Paper, Section 9, Implementing the Interchange Coordinator. Western Electricity Coordinating Council

Remedies: Retire or Modify Remove/Retire/Extract Move the tasks to another document? The WITFR is specifically designed to contain software functionality for the interchange transactions The DT “cannot” modify the WITFR But can recommend changes to the owner The Electric Scheduling Work Group Western Electricity Coordinating Council

Western Electricity Coordinating Council Direction Forward? Modify Assign to IA or IC = Non-starter Assign to the BA Assign to ?? Retire Move the tasks to….? Likely Remedies: Move software tasks to the WITFR or assign tasks to the BA Western Electricity Coordinating Council