127 FERC ¶ 61,176 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

18 CFR Part 40 

[Docket No. RM08-12-000; Order No.723] 

Western Electricity Coordinating Council Regional Reliability Standard 

Regarding Automatic Time Error Correction 

(Issued May 21, 2009) 

AGENCY: Federal Energy Regulatory Commission. 

ACTION: Final Rule. 

SUMMARY: Pursuant to section 215 of the Federal Power Act (FPA), the Federal 

Energy Regulatory Commission (Commission) approves regional Reliability Standard 

BAL-004-WECC-01 (Automatic Time Error Correction), as submitted by the North 

American Electric Reliability Corporation. As a separate action, pursuant to section 

215(d)(5) of the FPA, the Commission directs the Western Electricity Coordinating 

Council to develop several modifications to the regional Reliability Standard. The 

regional Reliability Standard requires balancing authorities within the Western 

Interconnection to maintain interconnection frequency within a predefined frequency 

profile and ensure that time error corrections are effectively conducted in a manner that 

does not adversely affect the reliability of the Interconnection. 

EFFECTIVE DATE: This rule will become effective [30 days after publication in the

FEDERAL REGISTER]. 

FOR FURTHER INFORMATION CONTACT: 
Docket No. RM08-12-000 - 2 - 

Jonathan First (Legal Information) 

Office of the General Counsel 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

(202) 502-8529 

Katherine Waldbauer (Legal Information) 

Office of the General Counsel 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

(202) 502-8232 

katherine.waldbauer@ferc.gov

Nick Henery (Technical Information) 

Office of Electric Reliability 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

(202) 502-8636 

nick.henery@ferc.gov 

SUPPLEMENTARY INFORMATION

:
UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

Western Electricity Coordinating Council Regional 

Reliability Standard Regarding Automatic Time Error 

Correction 

Docket No. RM08-12-000 

ORDER NO. 723 

TABLE OF CONTENTS 

 Paragraph Numbers

I. Background .................................................................................................................... 4.

A. Mandatory Reliability Standards.............................................................................. 4.

B. Procedural Background .......................................................................................... 11.

C. Reliability Standard BAL-004-WECC-01 ............................................................. 14.

II. Discussion................................................................................................................... 22.

A. Requirement R1.2................................................................................................... 27.

B. Explanation of 24-Hour Exemption Period of Requirement R2............................ 31.

C. New Glossary Definitions ...................................................................................... 35.

D. Consistency With NERC Reliability Standards..................................................... 41.

E. Violation Risk Factors ............................................................................................ 49.

F. Violation Severity Levels ....................................................................................... 52.

III. Information Collection Statement ............................................................................ 55.

IV. Environmental Analysis ............................................................................................ 60.

V. Regulatory Flexibility Act .......................................................................................... 61.

VI. Document Availability .............................................................................................. 64.

VII. Effective Date and Congressional Notification ....................................................... 67.
 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

Before Commissioners: Jon Wellinghoff, Chairman; 

 Suedeen G. Kelly, Marc Spitzer, 

 and Philip D. Moeller. 

Western Electricity Coordinating Council Regional 

Reliability Standard Regarding Automatic Time Error 

Correction 

Docket No. RM08-12-000 

ORDER NO.723 

FINAL RULE 

(Issued May 21, 2009) 

1. Pursuant to section 215 of the Federal Power Act (FPA),1

 the Commission 

approves regional Reliability Standard BAL-004-WECC-01 (Automatic Time Error 

Correction), submitted to the Commission for approval by the North American Electric 

Reliability Corporation (NERC). As a separate action, pursuant to section 215(d)(5) of 

the FPA, the Commission directs the Western Electricity Coordinating Council (WECC) 

to develop several modifications to the regional Reliability Standard. The regional 

Reliability Standard requires balancing authorities within the WECC region to implement 

an automatic time error correction procedure for the purpose of maintaining 

Interconnection frequency within a predefined frequency profile and ensuring that time 

1

 16 U.S.C. 824o (2006). 
Docket No. RM08-12-000 - 2 - 

 

error corrections are effectively conducted in a manner that does not adversely affect 

reliability.2

2. The Reliability Standard benefits the reliable operation of the Bulk-Power System 

by creating an operating environment that encourages system operators to balance their 

generation and interchange with their load and losses, thereby minimizing the difference 

between the net actual and net scheduled interchanges. This process will result in 

reducing the number of manual time error corrections required by the Western 

Interconnection Time Monitor, and minimize accumulated inadvertent interchange 

energy between Western Interconnection balancing authorities.3

 The Commission also 

accepts three related definitions that are included in the regional Reliability Standard. 

The Commission further approves the violation risk factors for the regional Reliability 

Standard, and directs the Electric Reliability Organization (ERO) and WECC to submit 

revised violation risk factors in a filing within 60 days of the effective date of this Final 

Rule. The Commission also directs the ERO and WECC to submit violation severity 

2

 The proposed regional Reliability Standard will be in effect within the Western 

Interconnection-wide WECC Regional Entity. In this proceeding, the Commission 

proposes to take action to make mandatory the regional Reliability Standard as it applies 

within the U.S. portion of the Western Interconnection. 

3

 Mismatches between generation and interchange and load and losses result in the 

Balancing Area operating at frequencies other than 60 Hertz, which causes both time 

error and inadvertent interchange. 
Docket No. RM08-12-000 - 3 - 

levels for each Requirement and sub-Requirement that has been assigned a violation risk 

factor within 120 days of the effective date of this Final Rule. 

3. As discussed below, the Commission finds that the regional Reliability Standard 

proposed by WECC satisfies the statutory criteria, and is more stringent than the 

applicable continent-wide NERC Reliability Standard. 

I. Background

A. Mandatory Reliability Standards

4. Section 215 of the FPA requires a Commission-certified ERO to develop 

mandatory and enforceable Reliability Standards, which are subject to Commission 

review and approval. Once approved, the Reliability Standards may be enforced by the 

ERO, subject to Commission oversight, or by the Commission independently.4

 

5. In February 2006, the Commission issued Order No. 672,5

 implementing section 

215 of the FPA. Pursuant to Order No. 672, the Commission certified one organization, 

NERC, as the ERO.6

 Reliability Standards that the ERO proposes to the Commission 

 4 See FPA 215(e)(3), 16 U.S.C. 824o(e)(3). 

5 Rules Concerning Certification of the Electric Reliability Organization; and

Procedures for the Establishment, Approval, and Enforcement of Electric Reliability 

Standards, Order No. 672, FERC Stats. & Regs. ¶ 31,204 (2006), order on reh’g, Order 

No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006). 

6 See North American Electric Reliability Corp., 116 FERC ¶ 61,062, order on 

reh’g and compliance, 117 FERC ¶ 61,126 (2006). 
Docket No. RM08-12-000 - 4 - 

 

may include Reliability Standards that are proposed to the ERO by a Regional Entity.7

 

When the ERO reviews a regional Reliability Standard that would be applicable on an 

Interconnection-wide basis and that has been proposed by a Regional Entity organized on 

an Interconnection-wide basis, the ERO must rebuttably presume that the regional 

Reliability Standard is just, reasonable, not unduly discriminatory or preferential, and in 

the public interest.8

6. In reviewing the ERO’s submission, the Commission will give due weight to the 

ERO’s technical expertise, except concerning the effect of a proposed Reliability 

Standard on competition.9

 The Commission will also give due weight to the technical 

expertise of a Regional Entity organized on an Interconnection-wide basis with respect to 

a proposed Reliability Standard to be applicable within that Interconnection.10 

7. The Commission may approve a proposed Reliability Standard if the Commission 

finds it is just, reasonable, not unduly discriminatory or preferential, and in the public 

interest.11 In addition, the Commission explained in Order No. 672 that "uniformity of 

Reliability Standards should be the goal and the practice, the rule rather than the 

7

 16 U.S.C. 824o(e)(4). 

8

 16 U.S.C. 824o(d)(3); 18 CFR 39.5(b). 

9

 16 U.S.C. 824o(d)(2).

10 Id.

11 Id. 
Docket No. RM08-12-000 - 5 - 

 

exception."12 Yet, the Commission recognized that "the goal of greater uniformity does 

not, however, mean that regional differences cannot exist."13 The Commission then 

provided the following guidance: 

As a general matter, we will accept the following two types of regional 

differences, provided they are otherwise just, reasonable, not unduly 

discriminatory or preferential, and in the public interest, as required by the statute: 

(1) a regional difference that is more stringent than the continent-wide Reliability 

Standard, including a regional difference that addresses matters that the continentwide Reliability Standard does not; and (2) a regional Reliability Standard that is 

necessitated by a physical difference in the Bulk-Power System.14

8. On March 16, 2007, the Commission issued Order No. 693, approving 83 of the 

107 Reliability Standards originally proposed by NERC.15 In addition, pursuant to 

section 215(d)(5) of the FPA, the Commission directed NERC to develop modifications 

to 56 of the 83 approved Reliability Standards.16 Relevant to the immediate proceeding, 

the Commission approved continent-wide Reliability Standard BAL-004-0 (Time Error 

12 Order No. 672, FERC Stats. & Regs. ¶ 31,204 at P 290. 

13 Id. P 291. 

14 Id. 

15 Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, 

FERC Stats. & Regs. ¶ 31,242, order on reh’g, Order No. 693-A, 120 FERC ¶ 61,053 

(2007). 

16 16 U.S.C. 824o(d)(5). Section 215(d)(5) provides, "The Commission . . . may 

order the Electric Reliability Organization to submit to the Commission a proposed 

reliability standard or a modification to a reliability standard that addresses a specific 

matter if the Commission considers such a new or modified reliability standard 

appropriate to carry out this section." 
Docket No. RM08-12-000 - 6 - 

 

Correction), but noted that WECC’s regional approach appears to serve as a more 

effective means of accomplishing time error corrections.17

9. On April 19, 2007, the Commission approved delegation agreements between 

NERC and each of the eight Regional Entities, including WECC.18 Pursuant to such 

agreements, the ERO delegated responsibility to the Regional Entities to enforce the 

mandatory, Commission-approved Reliability Standards. In addition, the Commission 

approved, as part of each delegation agreement, a Regional Entity process for developing 

regional Reliability Standards. In the Delegation Agreement Order, the Commission 

accepted WECC as a Regional Entity organized on an Interconnection-wide basis and 

accepted WECC’s Standards Development Manual, which sets forth the process for 

development of WECC’s Reliability Standards.19 

10. In a June 2007 order, the Commission approved eight regional Reliability 

Standards that apply in the WECC region.20

17 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 377, 382. The Commission 

also directed NERC to develop a modification to BAL-004-0 to include Levels of NonCompliance and additional Measures for Requirement R3. 

18 See North American Electric Reliability Corp., 119 FERC ¶ 61,060, order on 

reh’g, 120 FERC ¶ 61,260 (2007) (Delegation Agreement Order). 

19 Id. P 469-470. 

20 North American Electric Reliability Corp., 119 FERC ¶ 61,260 (2007). 
Docket No. RM08-12-000 - 7 - 

B. Procedural Background

11. On July 29, 2008, NERC submitted for Commission approval, in accordance with 

section 215(d)(1) of the FPA,21 regional Reliability Standard BAL-004-WECC-01, which 

would apply to balancing authorities within the Western Interconnection. NERC stated 

that the primary purpose of the regional Reliability Standard is to reduce the number of 

time error corrections imposed on the Western Interconnection by requiring balancing 

authorities that operate synchronously in the Western Interconnection to automatically 

correct for their contribution to time error. According to NERC, BAL-004-WECC-01 

provides the added benefit of a superior approach over the current NERC manual time 

error correction (BAL-004-0) for assigning costs and providing for the equitable payback 

of inadvertent interchange.22 

 21 16 U.S.C. 824o(d)(1) (2006). 

22 The NERC glossary defines "interchange" as the energy transfers that cross 

balancing authority boundaries, and defines "inadvertent interchange" as the difference 

between the balancing authority's net actual interchange and its net scheduled 

interchange. Within a synchronous Interconnection, during real-time operations, a 

balancing authority may engage in "inadvertent interchange" if it experiences an 

operational problem that prevents its net actual interchange of energy from matching its 

net scheduled interchange with other balancing authorities within the Interconnection. 

This discrepancy will indicate what is referred to as a "time error" – i.e., because the 

Interconnection will operate at a frequency (number of cycles per second) that is different 

from the Interconnection’s scheduled frequency of 60 Hz (60 cycles per second). Time 

error also serves as a means to measure of how much and which balancing authority 

within the Interconnection is out of balance. To correct the time error using the 

Automatic Time Error Correction (ATEC) method, it is necessary for the balancing 

(continued...) 
Docket No. RM08-12-000 - 8 - 

12. On November 20, 2008, the Commission issued a Notice of Proposed Rulemaking 

(NOPR) that proposed to approve BAL-004-WECC-01.23 In response, four interested 

persons filed comments: NERC, WECC, Consumers Energy Company (Consumers) and 

Xcel Energy Services Inc (Xcel). 

13. In its July 2008 filing, NERC stated that Automatic Time Error Correction or 

ATEC has been a regional reliability practice in WECC, effectively reducing manual 

time error corrections, reducing the number of hours of manual time error correction for 

the Western Interconnection, and reducing the accumulated inadvertent interchange in the 

Western Interconnection since 2003. NERC asserted that the proposed WECC regional 

Reliability Standard is more stringent or covers matters not addressed by NERC’s 

continent-wide Reliability Standards, BAL-004-0 and BAL-006-1 (Inadvertent 

Interchange). 

C. Reliability Standard BAL-004-WECC-01

14. Regional Reliability Standard BAL-004-WECC-01 contains four requirements, 

summarized as follows: 

 

authority that was out of balance to adjust the Interconnection’s frequency so that it 

equalizes its prior inadvertent energy exchange with the Interconnection. 

23 Western Electricity Coordinating Council Regional Reliability Standard 

Regarding Automatic Time Error Correction, Notice of Proposed Rulemaking, 73 FR 

71977 (Nov. 26, 2008), FERC Stats. & Regs. ¶ 32,638(2008). 
Docket No. RM08-12-000 - 9 - 

15. Requirement R1. Requires that all balancing authorities must continuously 

participate in Automatic Time Error Correction through their automatic generation 

control systems. The sub-requirement (R1.1) limits the payback amount to minimize any 

operating metric violations, while R1.2 addresses actions for cases when invalidated 

implementation of the ATEC methodology occurs and requires adjustments. 

16. Requirement R2. Requires a balancing authority that operates in any automatic 

generation control operating mode other than ATEC to notify all other balancing 

authorities of its operating mode. This requirement is necessary to ensure the reliable 

operations of the Western Interconnection by creating an operating environment that 

encourages the Balancing Authorities to minimize the difference between the net actual 

and net scheduled interchanges. To avoid large accumulation of inadvertent 

interchanges, Requirement R2 limits a balancing authority’s use of operating modes other 

than ATEC to a maximum of 24 hours per calendar quarter. 

17. Requirement R3. Requires balancing authorities to have the capability to switch 

between different automatic generation control operating modes as necessary to operate 

reliably during various system conditions. 

18. Requirement R4. Requires each balancing authority to calculate and record its 

hourly "Primary Inadvertent Interchange" when hourly checkout is complete. 

19. The WECC regional Reliability Standard also introduces the following three new 

definitions: 
Docket No. RM08-12-000 - 10 - 

 Automatic Time Error Correction: A frequency control automatic action that a 

Balancing Authority uses to offset its frequency contribution to support the 

Interconnection’s scheduled frequency. 

 Primary Inadvertent Interchange: The component of area (n) inadvertent 

interchange caused by the regulating deficiencies of area (n) itself. 

 Secondary Inadvertent Interchange: The component of area (n) inadvertent 

interchange caused by the regulating deficiencies of area (i). 

20. In its July 2008 filing, NERC asserted that the ATEC procedure provided in the 

proposed regional Reliability Standard has been effective in mitigating three problems 

relating to correction of time errors in the Western Interconnection. First, the ATEC 

procedure has reduced the need for the WECC Time Monitor to conduct manual time 

error corrections from 216 manual time error corrections in 2003 to 106 manual time 

error corrections in 2007. Second, since time error is directly related to inadvertent 

interchange, the ATEC procedure reduces both time error and accumulated inadvertent 

interchange. Third, according to NERC, the ATEC procedure better identifies the 

balancing authorities responsible for inadvertent interchange and provides a more 

equitable and immediate payback of the inadvertent interchange to the balancing 

authorities that should receive it (i.e., the balancing authorities that did not cause the 

inadvertent interchange but supported the interconnection’s scheduled frequency) than 

the current NERC time error correction process in BAL-004-0. 
Docket No. RM08-12-000 - 11 - 

21. NERC also stated that the proposed regional Reliability Standard satisfies the 

factors provided in Order No. 672 that the Commission considers when determining 

whether a proposed Reliability Standard is just, reasonable, not unduly discriminatory or 

preferential and in the public interest.24 According to NERC, BAL-004-WECC-01 is 

clear and unambiguous regarding what is required and who is required to comply 

(balancing authorities). NERC also stated that the proposed regional Reliability Standard 

has clear and objective measures for compliance and achieves a reliability goal (namely, 

creating an operating environment that encourages system operators to minimize the 

difference between the net actual and net scheduled interchanges, and to better control 

frequency) effectively and efficiently. 

II. Discussion

22. Pursuant to section 215(d) of the FPA, the Commission approves regional 

Reliability Standard BAL-004-WECC-01 as mandatory and enforceable. 

23. Pursuant to the continent-wide NERC Reliability Standard BAL-004-1, when 

accumulated time error increases to a predetermined level, the Interconnection’s Time 

Monitor instructs all balancing authorities in the Interconnection to manually change the 

scheduled Interconnection’s frequency until the Interconnection’s accumulated time error 

has been reduced to a set level. However, the requirements of BAL-004-1 do not require 

 24 Order No. 672, FERC Stats. & Regs. ¶ 31,204 at P 323-337. 
Docket No. RM08-12-000 - 12 - 

 

each balancing authority to determine what portion of the Interconnection’s time error 

that it alone caused. 

24. Under the WECC ATEC methodology, each balancing authority in the Western 

Interconnection is required to calculate its “primary inadvertent interchange”25 and enter 

its “primary inadvertent interchange” into its Area Control Error (ACE) 26 equation. 

When all balancing authorities input their portion of "primary inadvertent interchange" 

into their ACE equation, they continuously correct for their own “primary time error” 

and, in turn, reduce the Western Interconnection’s total time error. 

25. This process differs from the methodology used in NERC's BAL-004-1, in that 

ATEC is designed to place the responsibility to correct primary time error on the 

balancing authority that causes it. Further, the regional Reliability Standard is more 

stringent and covers matters not addressed by the related continent-wide NERC 

25 The balancing authority causing the frequency error is said to have created 

"primary time error" and caused "primary inadvertent interchange." The other balancing 

authorities in the Interconnection responding to correct system frequency are said to have 

created "secondary time error" and caused "secondary inadvertent interchange." 

26 ACE is the instantaneous difference between a Balancing Authority’s net actual 

and scheduled interchange, taking into account the effects of Frequency Bias and 

correction for meter error (NERC glossary of terms used in reliability standards, 

http://www.nerc.com/docs/standards/rs/Glossary_2009April20.pdf, at 1). More 

specifically: ACE = (NIA – NIS) – 10βi(FA – FS) – T0b +IME (Requirement R1 of 

Commission Approved Standard BAL-001-0.1a, see

http://www.nerc.com/docs/standards/sar/Interpretation_WECC_ATEC_BAL001and003_BOT-Approved_23Oct07.pdf).
Docket No. RM08-12-000 - 13 - 

 

Reliability Standards BAL-004-0 and BAL-006-1. The regional Reliability Standard 

provides for automatic correction of time error, using a more refined primary inadvertent 

interchange term than that included in the continent-wide NERC Reliability Standards for 

manual correction of time error.27 Accordingly, the Commission finds that the regional 

Reliability Standard proposed by WECC is more stringent than the continent-wide NERC 

Reliability Standard, because it provides for continuous capture of inadvertent 

interchange, and thereby (1) contributes to better operation of balancing authorities by 

operators, and (2) ensures that discrepancies between a balancing area's net scheduled 

interchange and its net actual interchange are adjusted more quickly and accurately. 

Pursuant to section 215(d) of the FPA, the Commission approves BAL-004-WECC-01 as 

just, reasonable, not unduly discriminatory or preferential and in the public interest.

26. As a separate matter, pursuant to section 215(d)(5) of the FPA, the Commission 

directs WECC to develop, pursuant to its regional Reliability Standards Development 

Procedure, modifications to BAL-004-WECC-01 to address the Commission’s specific 

concerns, as discussed below. Further, the Commission approves some of the proposed 

violation risk factors and violation severity levels, and directs the ERO to submit a filing 

within 60 days of the effective date of this Final Rule revising other specified violation 

risk factors and another filing within 120 days of the effective date of this Final Rule 

27 NERC filing at 10. 
Docket No. RM08-12-000 - 14 - 

providing violation severity levels for each Requirement and sub-Requirement that has 

been assigned a violation risk factor. 

A. Requirement R1.2

27. Requirement R1.2 of BAL-004-WECC-01 provides in part, "[l]arge accumulations 

of primary inadvertent [energy] point to an invalid implementation of ATEC, loose 

control, metering or accounting errors. A [balancing authority] in such a situation should 

identify the source of the error(s) and make the corrections." In the NOPR, the 

Commission noted that the phrases “large accumulation” and “in such a situation” are not 

defined and, while likely obvious in many circumstances, leaves to individual 

interpretation when a “large” amount of primary inadvertent has accumulated.28 The 

Commission proposed to direct WECC to develop revisions to the provision so that a 

balancing authority will know with specificity the circumstances that trigger the actions 

required by Requirement R1.2. 

1. Comments

28. WECC acknowledges the Commission’s concern that the undefined phrases “large 

accumulation” and “in such a situation” in Requirement R1.2 could lead to uncertainty 

among Balancing Authorities as to when they are required to take action. WECC 

comments that, while these terms have a general industry understanding within the 

Western Interconnection, clarifying these terms would remove the potential for 

 28 NOPR at P 36. 
Docket No. RM08-12-000 - 15 - 

controversy over compliance requirements. WECC suggests either defining the terms 

within the regional Reliability Standard or modifying the standard language to better 

identify specific parameters that would trigger actions required under this standard. 

29. NERC agrees that further clarity of the identified phrases in Requirement R1.2 is 

appropriate and believes WECC’s proposal in its comments is responsive. 

2. Commission Determination

30. As we explained in the NOPR, the Commission is concerned that the phrases 

“large accumulation” and “in such a situation” as used in Requirement R1.2 leaves to 

individual interpretation when a “large” amount of primary inadvertent has accumulated. 

The ERO and WECC agree that the provision could benefit from further clarity. 

Accordingly, the Commission adopts its NOPR proposal and directs WECC to develop 

revisions to the provision so that a balancing authority will know with specificity the 

circumstances that trigger the actions required by Requirement R1.2. 

B. Explanation of 24-Hour Exemption Period of Requirement R2

31. Requirement R2 of BAL-004-WECC-01 provides that "[e]ach [balancing 

authority] while synchronously connected to the Western Interconnection will be allowed 

to have ATEC out of service for a maximum of 24 hours per calendar quarter, for reasons 

including maintenance and testing." In the NOPR, the Commission proposed to direct 

WECC to develop a modification that clarifies whether the "maximum of 24 hours per 

calendar quarter" refers to a single occurrence of up to 24 hours in the calendar quarter, 
Docket No. RM08-12-000 - 16 - 

or whether several occurrences are permitted as long as they add up to 24 hours or less 

within a calendar quarter.29

1. Comments

32. WECC comments that it intended the 24-hour per calendar quarter limit to permit 

an accumulated total of up to 24 hours, whether resulting from one extended occurrence 

or multiple occurrences. Likewise, NERC understands that WECC intended the 

provision to permit an accumulated total of up to 24 hours from one or more occurrences. 

33. WECC and NERC agree the proposed NOPR modifications will leave the regional 

Reliability Standard more definite and can be addressed through WECC’s stakeholder 

process. 

2. Commission Determination

34. Consistent with the NOPR, pursuant to section 215(d)(5) of the FPA, the 

Commission directs WECC to develop a modification to the regional Reliability Standard 

consistent with WECC’s and NERC’s explanation that the limit set forth in Requirement 

2 of “24 hours per calendar quarter” is an accumulated total for the period, resulting from 

either a singular event or a cumulative time limit from a number of events. 

C. New Glossary Definitions

35. As mentioned above, the WECC regional Reliability Standard includes three new 

definitions: Automatic Time Error Correction, Primary Inadvertent Interchange and 

 29 NOPR at P 37. 
Docket No. RM08-12-000 - 17 - 

Secondary Inadvertent Interchange. In the NOPR, the Commission proposed to approve 

the three new terms.30 

1. Comments

36. Consumers expresses concern regarding the incorporation of three newly defined 

terms (Automatic Time Error Correction, Primary Inadvertent Interchange and Secondary 

Inadvertent Interchange) into the NERC glossary. Consumers states that it is appropriate 

for the three new definitions to apply to WECC regional Reliability Standards. However, 

according to Consumers, the definitions have not been vetted through NERC’s full 

development process for their inclusion in the NERC glossary, applicable to NERC 

Reliability Standards that apply on a continent-wide basis. Specifically, Consumers 

points out that NERC’s Rules of Procedure provide that all definitions must be approved 

in accordance with the standards process.31 Consumers recommends that the 

Commission either clearly designate the proposed definitions as being applicable only to 

WECC regional Reliability Standards or direct NERC to submit the proposed definitions 

for stakeholder review as part of the NERC Reliability Standards development process. 

 30 NOPR at P 26. While the Commission discussed the proposed definitions in 

several places in the NOPR, in one instance the Commission stated that it proposed to 

“accept three related definitions for inclusion in the NERC Reliability Standards Glossary 

(NERC glossary). Id. P 2. In other instances, the Commission simply stated that it 

proposed to approve the definitions. Id. P 26, 34. 

31 Consumers Comments at 4, citing NERC Rules of Procedure, section 300 and 

Appendix 3A (NERC Reliability Standards Development Procedure) at 8. 
Docket No. RM08-12-000 - 18 - 

2. Commission Determination

37. The Commission agrees with Consumers that the three new definitions have not 

been vetted through the ERO’s full development process for their inclusion in the NERC 

glossary; and that the three new definitions approved in this Final Rule apply only to 

WECC regional Reliability Standards. NERC should designate them accordingly. 

Therefore, to ensure that all approved definitions, NERC and regional, are maintained in 

a single location, NERC should add or append the three new regional definitions to the 

NERC Glossary of Terms in such a way as to designate that they apply only in the 

Western Interconnection. 

38. The Commission, however, has a general concern regarding the development of 

definitions that apply only to regional Reliability Standards. The Commission 

understands that, prior to NERC’s development of the “Version 0” Reliability Standards, 

there were multiple regional standards and protocols, with each region having its own 

definitions of terms. In some instances, the same or similar terms were defined 

differently within different regions. The Version 0 process included developing the 

NERC glossary, which eliminated many inconsistencies in terminology across regions 

and created a single source for defining terms used in Reliability Standards. 

39. We are concerned about a potential re-proliferation of regional terminology, and 

consequently, the need to prevent possible inconsistent use of terminology among 

regions. While NERC has only submitted WECC regional Reliability Standards to the 
Docket No. RM08-12-000 - 19 - 

 

Commission at this time, other regions are in the process of developing regional 

standards. Similar to our policy set forth in Order No. 672 that favors the development of 

uniform Reliability Standards,32 the Commission believes NERC, as a rule, should 

develop definitions that apply uniformly across the different interconnections. As a 

general goal, NERC should work to minimize the use of regional definitions and 

terminology and, assure that proposed regional definitions and terminology are as well 

defined as, do not conflict and are not redundant with nor redefine, NERC glossary 

definitions. We therefore direct NERC to develop in its Rules of Procedure, a 

methodology for organizing and managing regional definitions and terminology 

consistent with the principles discussed above. 

40. Further, NERC should be vigilant to assure that a regional definition is consistent 

with both NERC definitions and the approved terms used in other regions. The 

Commission considers an inconsistency or conflict in terms to be reasonable grounds to 

remand a regional definition and, if appropriate, the regional Reliability Standard that 

employs that definition. 

32 Order No. 672, FERC Stats. & Regs. ¶ 31,204 at P 290 ("The Commission 

believes that uniformity of Reliability Standards should be the goal and the practice, the 

rule rather than the exception. Greater uniformity will encourage best practices, thereby 

enhancing reliability and benefiting consumers and the economy"). 
Docket No. RM08-12-000 - 20 - 

D. Consistency With NERC Reliability Standards

1. Comments 

41. Xcel comments that, while it generally supports the adoption of BAL-004-WECC01, it is concerned that the regional Reliability Standard creates a potential conflict with 

two NERC Reliability Standards, BAL-001-0a (Real Power Balancing Control 

Performance) and BAL-002-0 (Disturbance Control Performance). Xcel requests that the 

Commission establish priority for compliance in the event that WECC regional 

Reliability Standards conflict with those of NERC. Xcel’s concern involves the 

difference in the ACE equation between the regional and the NERC Reliability Standards 

and the compliance elements regarding this equation. 

42. Xcel states that BAL-001-0a requires that ACE be kept within specific parameters, 

while BAL-004-WECC-01 requires a measurement of ACE that is outside those 

parameters to be maintained at all times. According to Xcel, BAL-004-WECC-01 

requires ATEC operation at all times except up to 24 hours per calendar quarter, but is 

not clear if this period covers times when complying with BAL-001-0a requires noncompliance with BAL-004-WECC-01. Xcel notes that Requirement R3 of BAL-004-

WECC-01 requires the ACE used for NERC reports to be the same as the ACE used in 

the current AGC operating mode. According to Xcel, this requires the use of the 

ACEATEC set forth in BAL-004-WECC-01 rather than the BAL-001-0a ACE equation in 

most situations. 
Docket No. RM08-12-000 - 21 - 

43. Xcel claims that BAL-004-WECC-01 may also conflict with BAL-002-0 

Requirement R4.2, which requires that the balancing authority restore ACE to specified 

parameters within a defined timeframe. Xcel posits that in most situations it will be 

impossible for an entity attempting to recover from a disturbance to operate at an ACE 

calculated in accordance with the NERC standard and ACEATEC simultaneously. 

According to Xcel, the use of the BAL-004-WECC-01, Requirement R2 exception, 

allowing ATEC to be out of service for 24 hours per calendar quarter, should be 

acceptable for alleviating this circumstance. Xcel contends that, where the 24-hour 

maximum is exceeded for the purpose of ACE complying with BAL-002-0, the balancing 

authority should be given express authority to deviate from the requirements of BAL004-WECC-01. 

2. Commission Determination

44. We are not persuaded by Xcel’s comments on this matter. We believe that our 

approval, in Order No. 713,33 of an ERO interpretation addresses Xcel’s concern. 

Specifically, WECC requested that the ERO provide a formal interpretation whether the 

use of WECC’s automatic time error correction factor that is applied to the net 

interchange portion of the ACE equation violates Requirement R1 of NERC Reliability 

 33 Modification of Interchange and Transmission Loading Relief Reliability 

Standards; and Electric Reliability Organization Interpretation of Specific Requirements 

of Four Reliability Standards, Order No. 713, 73 FR 43613, 124 FERC ¶ 61,071 (July 21, 

2008). 
Docket No. RM08-12-000 - 22 - 

 

Standard BAL-001-0a. In response, the ERO interpreted BAL-001-0 Requirement R1 as 

follows: 

• The [WECC automatic time error correction or WATEC] procedural 

documents ask Balancing Authorities to maintain raw ACE for [control 

performance standard or CPS134] reporting and to control via WATECadjusted ACE. 

• As long as Balancing Authorities use raw (unadjusted for WATEC) ACE 

for CPS reporting purposes, the use of WATEC for control is not in 

violation of BAL-001 Requirement 1.35

45. The Commission-approved interpretation makes clear that a balancing authority is 

in compliance with BAL-001-1a provided that it uses the equation identified in R1 for 

reporting CPS1 and achieves the performance required by CPS1. The balancing 

authority's ability to use the ACE calculation also to assist in time error correction and 

inadvertent interchange payback is not precluded. 

46. Further, the Commission is not persuaded by Xcel’s claims that BAL-004-WECC01 may also conflict with BAL-002-0, Requirement R4.2, which requires that the 

balancing authority restore ACE to specified parameters within a defined timeframe. 

Requirements R2 and R3 of Standard BAL-004-WECC-0 direct that ATEC will be the 

primary operating mode used by all balancing authorities in the WECC region. However, 

34 The Control Performance Standard (CPS) is defined in the NERC Glossary as 

"[t]he reliability standard that sets the limits of a Balancing Authority’s Area Control 

Error over a specified time period." 

35 Order No. 713, 124 FERC ¶ 61,071 at P 17. 
Docket No. RM08-12-000 - 23 - 

balancing authorities may modify their ACE operating mode to account for various 

operating situations, including the need to respond to meeting the Disturbance Recovery 

Criterion within the Disturbance Recovery Period in Requirement R4.2 of BAL-002-0.36 

47. Nor does the Commission agree with Xcel’s concern about the 24-hour per quarter 

ATEC operating mode exception period. Giving due consideration to the Western 

Interconnection’s participants, the Commission finds that a 24-hour per quarter ATEC 

operating mode exception period encourages the Western Interconnection’s balancing 

authorities to maintain a high standard of operations to support the reliability of the 

Western Interconnection. 

48. Consequently, the Commission is not persuaded by Xcel’s comments. As 

discussed above, the ERO and the Commission have previously addressed the issue 

raised by Xcel, and the Commission does not believe that remand or further clarification 

is warranted. 

E. Violation Risk Factors

49. In the NOPR, the Commission proposed to direct that the violation risk factors 

assigned to BAL-004-WECC-01, Requirements R1, R2, R3, and R4 be modified from 

 36 R4.2 provides that "[t]he default Disturbance Recovery Period is 15 minutes 

after the start of a Reportable Disturbance," but further states that "[t]his period may be 

adjusted to better suit the needs of an Interconnection based on analysis approved by the 

NERC Operating Committee." 
Docket No. RM08-12-000 - 24 - 

“lower” to “medium.”37 The Commission explained that the participation in an 

interconnection’s time error correction is critical and can directly affect the state of the 

Bulk-Power System.38 Further, the Commission explained that the assignment of a 

“medium” violation risk factor to the Requirements of the WECC regional Reliability 

Standard would make it consistent with the assignment of “medium” violation risk 

factors to NERC Reliability Standard BAL-004-0.

1. Comments

50. WECC comments that, while it is unlikely that a violation of the regional 

Reliability Standard would lead to Bulk-Power System instability, it acknowledges that 

ATEC is not administrative in nature and could affect the electrical status of the BulkPower System making a ‘Medium’ VRF more appropriate. Thus, WECC comments that 

“it does not disagree” with the Commission’s proposal to change the violation risk factors 

from low to medium. NERC also agrees that the Commission’s proposal would promote 

consistency. 

2. Commission Determination

51. We adopt our NOPR proposal and direct that the violation risk factors assigned to 

BAL-004-WECC-01, Requirements R1, R2, R3, and R4 be modified from “lower” to 

 37 NOPR at P 44-47. 

38 Id. P 46. 
Docket No. RM08-12-000 - 25 - 

“medium.” The ERO and WECC must submit a filing within 60 days of the effective 

date of this Final Rule that includes the directed modifications. 

F. Violation Severity Levels

52. The ERO’s July 2008 filing of the WECC regional Reliability Standard included 

proposed violation severity levels that apply generally to all violations of the 

Requirements of BAL-004-WECC-01 and not to any one specific Requirement. In the 

NOPR, the Commission proposed to direct the submission of new violation severity 

levels for each Requirement and sub-Requirement that has been assigned a violation risk 

factor.39 

1. Comments 

53. WECC comments that the Commission’s and NERC’s guidance on the 

development of violation severity levels has evolved since the drafting of the violation 

severity levels for BAL-004-WECC-1. WECC indicates that it will develop violation 

severity levels for each Requirement and sub-Requirement of the regional Reliability 

Standard, and requests that the Commission allow sufficient time to address the issue 

through the WECC stakeholder process. 

 39 NOPR at P 49. We note that, in Version Two Facilities Design, Connections 

and Maintenance Reliability Standards, Order No. 722, 126 FERC ¶ 61,255 at P 45 

(2009), the ERO proposed to develop violation severity levels for Requirements but not 

sub-Requirements. The Commission denied the proposal as “premature” and, instead, 

encouraged the ERO to “develop a new and comprehensive approach that would better 

facilitate the assignment of violation severity levels and violation risk factors.” 
Docket No. RM08-12-000 - 26 - 

2. Commission Determination

54. The Commission adopts its NOPR proposal and directs the ERO and WECC to 

submit violation severity levels for each Requirement and sub-Requirement that has been 

assigned a violation risk factor. To allow adequate time for the development of the 

violation severity levels, the ERO and WECC must submit a filing within 120 days of the 

effective date of this Final Rule that includes the directed violation severity levels. 

III. Information Collection Statement 

55. The Office of Management and Budget (OMB) regulations require that OMB 

approve certain reporting and recordkeeping (collections of information) imposed by 

agency rules.40 The information contained here is also subject to review under section 

3507(d) of the Paperwork Reduction Act of 1995.41 Upon approval of a collection(s) of 

information, OMB will assign an OMB control number and an expiration date. 

Respondents subject to the filing requirements of an agency rule will not be penalized for 

failing to respond to these collections of information unless the collections of information 

display a valid OMB control number. 

56. This Final Rule approves and requires modifications of one regional Reliability 

Standard that was submitted by NERC as the ERO. Section 215 of the FPA authorizes 

the ERO to submit Reliability Standards to provide for the reliable operation of the Bulk-

 40 5 CFR 1320.11. 

41 44 U.S.C. 3507(d). 
Docket No. RM08-12-000 - 27 - 

 

Power System. Pursuant to the statute, the ERO must submit each Reliability Standard 

that it proposes to be made effective to the Commission for approval.42

57. The regional Reliability Standard, which applies to approximately 35 balancing 

authorities in the U.S. portion of the Western Interconnection, does not require balancing 

authorities to file information with the Commission. It does require balancing authorities 

to develop and maintain certain information for a specified period of time, subject to 

inspection by WECC. However, the Commission does not believe that approval of the 

WECC regional Reliability Standard will result in an increase in reporting burdens as 

compared to current practices in WECC. As NERC indicates, since 2003, WECC has 

used the automatic time error correction practice set forth in BAL-004-WECC-01. Thus, 

the Commission finds that the requirement to develop and maintain information in the 

regional Reliability Standard mirrors customary and usual business practice in the area in 

which the Standard will apply and, therefore, imposes a minimal burden on applicable 

balancing authorities and eliminates any possible confusion between current industry 

practice and the standard. The Commission also finds that the modifications to the 

current Reliability Standard effected by this Final Rule will not increase the reporting 

burden nor impose any additional information collection requirements. 

42 See 16 U.S.C. 824(d). 
Docket No. RM08-12-000 - 28 - 

58. In response to the NOPR, the Commission received no comments concerning its 

determination with respect to the burden and costs and therefore uses the same 

affirmation here. 

Title: Western Electricity Coordinating Council Regional Reliability Standard Regarding 

Automatic Time Error Correction. 

Action: Final Rule 

OMB Control No.: 1902-0244 

Respondents: Businesses or other for-profit institutions; not-for-profit institutions 

Frequency of Responses: On Occasion 

Necessity of the Information: This Final Rule approves and requires modification to one 

regional Reliability Standard that pertains to automatic time error correction in the 

Western Interconnection. The Final Rule finds the Reliability Standard to be just, 

reasonable, not unduly discriminatory or preferential, and in the public interest. 

59. Interested persons may obtain information on the reporting requirements by 

contacting: Federal Energy Regulatory Commission, Attn: Michael Miller, Office of the 

Executive Director, 888 First Street, N.E. Washington, D.C. 20426, Tel: (202) 502-

8415, Fax: (202) 273-0873, E-mail: <michael.miller@ferc.gov>, or by contacting: 

Office of Information and Regulatory Affairs, Office of Information and Regulatory 

Affairs, Attn: Desk Officer for the Federal Energy Regulatory Commission (Re: OMB 
Docket No. RM08-12-000 - 29 - 

Control No. 1902-0244), Washington, D.C. 20503, Tel: (202) 395-4650, Fax: (202) 

395-7285, E-mail: <oira_submission@omb.eop.gov>. 

IV. Environmental Analysis

60. The Commission is required to prepare an Environmental Assessment or an 

Environmental Impact Statement for any action that may have a significant adverse effect 

on the human environment.43 The Commission has categorically excluded certain 

actions from this requirement as not having a significant effect on the human 

environment. Included in the exclusion are rules that are clarifying, corrective, or 

procedural or that do not substantially change the effect of the regulations being 

amended.44 The actions proposed herein fall within this categorical exclusion in the 

Commission’s regulations. 

V. Regulatory Flexibility Act

61. The Regulatory Flexibility Act of 1980 (RFA)45 generally requires a description 

and analysis of Final Rules that will have significant economic impact on a substantial 

number of small entities. The RFA mandates consideration of regulatory alternatives 

accomplish the stated objectives of a proposed rule and that minimize any signifi

that 

cant 

 43 Regulations Implementing the National Environmental Policy Act, Order No. 

486, FERC Stats. & Regs. ¶ 30,783 (1987). 

44 18 CFR 380.4(a)(2)(ii). 

45 5 U.S.C. 601-12. 
Docket No. RM08-12-000 - 30 - 

economic impact on a substantial number of small entities. The Small Business 

Administration’s Office of Size Standards develops the numerical definition of a small 

business. (See 13 CFR 121.201.) For electric utilities, a firm is small if, including its 

affiliates, it is primarily engaged in the transmission, generation and/or distribution of 

electric energy for sale and its total electric output for the preceding twelve months did 

se 

le will not 

 of small entities. 

bility analysis is required. 

not exceed four million megawatt hours. 

62. As noted above, the regional reliability standard would apply to about 35 

balancing areas in the Western Interconnection. The Commission estimates that of the

balancing areas, approximately two to four qualify as small entities, because the total 

electric output of each of these entities for the preceding twelve months did not exceed 

four million megawatt hours. Thus, few small entities are impacted by the proposed rule. 

63. Based on this understanding, the Commission certifies that this Final Ru

have a significant economic impact on a substantial number

Accordingly, no regulatory flexi

VI. Document Availability

64. In addition to publishing the full text of this document in the Federal Register, the 

Commission provides all interested persons an opportunity to view and/or print the 

contents of this document via the Internet through FERC’s Home Page 

(http://www.ferc.gov) and in FERC’s Public Reference Room during normal business 
Docket No. RM08-12-000 - 31 - 

ing, printing, and/or downloading. To access this document in 

t 1-866-208-

t@ferc.gov>, or the Public Reference Room at (202) 

rence Room at 

hours (8:30 a.m. to 5:00 p.m. Eastern time) at 888 First Street, N.E., Room 2A, 

Washington D.C. 20426. 

65. From FERC’s Home Page on the Internet, this information is available on 

eLibrary. The full text of this document is available on eLibrary in PDF and Microsoft 

Word format for view

eLibrary, type the docket number excluding the last three digits of this document in the 

docket number field. 

66. User assistance is available for eLibrary and the FERC’s website during normal 

business hours from FERC Online Support at (202) 502-6652 (toll free a

3676) or e-mail at <ferconlinesuppor

502-8371, TTY (202) 502-8659. E-mail the Public Refe

<public.referenceroom@ferc.gov>. 

VII. Effective Date and Congressional Notification

67. The Reliability Standard approved in this Final Rule is effective [insert date 30 

days from publication in FEDERAL REGISTER]. The Commission has determined, 

with the concurrence of the Administrator of the Office of Information and Regulatory 

ffairs of OMB, that this rule is not a “major rule” as defined in section 351 of the Small 

usiness Regulatory Enforcement Fairness Act of 1996. 

A

B
Docket No. RM08-12-000 - 32 - 

List of subjects in 18 CFR Part 40 

e Elec ic util ies, R porting and recordkeeping requirements 

y the Commission. 

S E A L ) 

Nathaniel J. Davis, Sr., 

Deputy Secretary. 

Electric pow r, tr it e

B

(