Submitted Comments on Proposed Charter for Reformed WREGIS Committee

 1/13/2011

Cyrq appreciates the opportunity to review and provide comments on the proposed WREGIS Charter.  Cyrq has reviewed the comments provided by Silicon Valley Power and supports those comments.  Cyrq also has concerns about a WECC staff person holding a position on the WREGIS Committee (WC) similar to those expressed by Geysers Power Company.  Cyrq believes it is important for two WECC Board members to be on the WC.  In addition to its support for the comments referred to above, Cyrq provides the following comments on the WREGIS Charter.

Membership.  WECC has a large board from which to obtain members to serve on the WC and should be able to find two who can call into WC meetings.  These meetings may occur quarterly as suggested by Silicon Valley Power.  Cyrq believes it would be most beneficial to WREGIS if two WECC Board members are personally familiar with the issues discussed at WREGIS that may need to go to the WECC Board for approval.  Two individuals provide the flexibility for one member to be absent and still have another member available to discuss or present WREGIS issues. 

In addition, the WC is a stakeholder group that is intended to provide a stakeholder view when evaluating changes to fee schedules, Terms of Use and Operating Rules.  The WREGIS Charter established a process under which the WC and the WECC Staff discuss and evaluate changes.  The WC cannot provide a potentially different point of view if it also includes WECC Staff.  The intent is to reach consensus results that combine the input from both WECC staff and the WC stakeholder input. 

Purpose/Responsibilities.  The word “substantive” needs to be deleted from the WREGIS Charter as it refers to changes in the fee schedules, etc.  WREGIS staff indicated a desire to make editorial changes to the fee schedules etc without the need for WC review.  Many a lawsuit is fought over the placement of commas in statutes, regulations and contracts.  What may seem editorial to one person could end up changing the meaning and application of an Operating Rule.  Therefore, it is imperative that all changes in fee schedules, Terms of Use and Operating Rules come to the WC. 

Because there remains some questions about whether “Operating Rules” includes changes to functionality, Cyrq recommends the word “functionality” be added to the list of items upon which the WC will confer with WECC staff. 

Cyrq recommends the following edits to address these last two comments, “Share decision-making responsibility with WECC management for proposed substantive changes in fee schedules, functionality, the Terms of Use, and the Operating Rules of the WREGIS program.”  These two changes should be made in the WREGIS Charter wherever they appear. 

Cyrq also has a concern about the “Note” on the top of page 3.  This implies that WECC management can make changes to fee schedules, Terms of Use, and Operating Rules without consultation with the WC.  Cyrq believes all changes need to be reviewed by the WC.  Thus, the “note” should be deleted in its entirety. 

Jane Luckhardt on behalf of Cyrq. 

Jane Luckhardt                                                                                                                                   Downy Brand

 1/13/2012

PacifiCorp respectfully wishes to offer support and concurrence to the changes and edits to the proposed Charter as posted by Janis Pepper on January 12, 2012. Thank you for the opportunity to review and comment on the proposed Charter.

Kristie Sharp, Contract Administrator                                                                      PacifiCorp

1/13/2012

To read comments on the the proposed charter for the reformed WREGIS Committee submitted by the current WREGIS Committee, please click here.

Suzanne Korosec, Chair - WREGIS Committee                                             California Energy Commission

1/13/2012

Please accept this support and concurrence of Shell Energy to the changes and edits to the Charter as proposed by Janis Pepper on January 12, 2012.

Marcie Milner, VP Regulatory Affairs                                                                Shell Energy North America

1/12/2012

Thank you for the opportunity to comment on the proposed charter.  The focus of these comments is on maintaining transparency and stakeholder participation in the continued operation and management of WREGIS via the WREGIS Committee.  Based on this focus, there are a number of areas where we feel some modification of the proposed charter is in order.   

1 - (Section 2A) The WREGIS Committee (WC) will have a total of 7 members, which will include two members from WECC (either 2 WECC board members, or 1 WECC board member and 1 WECC Staff person).  One of the WECC representatives will be appointed by the WECC Board chair to be the chair of the WREGIS Committee.  The WREGIS Committee chair will then recommend the vice chair.  I would suggest that the WREGIS Committee select their own chair and vice chair, and that the WECC representatives on the WREGIS Committee cannot serve as chair or vice chair.  As the WREGIS Committee provides a means for stakeholder input, only stakeholders, rather than WECC representatives, should serve as chair and vice chair of this committee. 

2 - (Section 3A) The current WREGIS Committee (WC) meets monthly.  Under this new charter, the WC meets only twice a year.  I would suggest that this be changed to provide at least quarterly meetings. 

3 - (Section 3E) This states first that "Meetings of the WC may be in person or by a conference call noticed as required by the WECC Bylaws. The WC chair will determine whether the meeting will be in person or by phone."  The second sentence should be stricken, as the first sentence says that the WECC Bylaws will be used to determine if the meeting will be in person or by phone. 

4 - (Section 3g) Notice of WREGIS Committee meetings should be noticed to the WREGIS Committee members and all WREGIS stakeholders no later than two weeks prior to the meeting.  (As currently drafted, only WREGIS Committee members are notified which limits the ability for ALL WREGIS stakeholders to be aware of the meetings.) 

5 - (section 3h) If an emergency meeting of the WREGIS Committee is held, email notice of the meeting should be provided to both the WREGIS Committee and all WREGIS stakeholders no later than three business days prior to the meeting.  (As currently drafted, only WREGIS Committee members will be notified which limits the ability for ALL WREGIS stakeholders to be aware of emergency meetings.)

6 - The WREGIS Committee chair can call for a closed session of the WREGIS Committee, which "shall only be attended by members of the WC or the WECC Board, and by any guests invited to attend by the WC chair".  As written, if a WECC staff person or board member serves as the WREGIS Committee chair, this allows WECC to hold a closed session meeting, and exclude all other members of the WREGIS Committee who are not on the WECC Board or WECC staff.  I would suggest that the words "or the WECC Board" be stricken, so that it reads: "Such closed sessions of the WC shall only be attended by members of the WC, and by any guests invited to attend by the WC chair..."  This ensures that all members of the WREGIS Committee will be in attendance, and prevents WECC from making decisions in closed session without any input or awareness from WREGIS stakeholders.

Janis Pepper, P.E.                           Silicon Valley Power and Chair, Stakeholder Advisory Committee

1/11/2012

Geysers Power Company appreciates the opportunity to review and comment on the proposed WREGIS charter.

In reading through and considering the proposed Charter’s language I’ve focused on the relationship  between WECC management, who I believe could alternatively be identified as the WECC CEO and Director of WREGIS but would broadly include anyone listed on the WECC Management Team (http://www.wecc.biz/About/Company/Pages/ManagementTeam.aspx); the WECC CEO; and the WC.

If I substitute “the WECC CEO and/or Director of WREGIS” for WECC management in the seven places that “WECC management” appears in the proposed Charter the substitution seems to work well everywhere except in the Note at the top of page 3, where it seems that the WECC CEO might be more appropriate.  I understand that the proposed wording conforms with the WECC resolution agreeing to host WREGIS, and therefore do not see a change here as necessary. 

If I asked GPC’s counsel to review the proposed Charter, he would note that after identifying the WECC CEO as “(CEO)” on page 2 the two later references under Reporting and under Review and Changes at the bottom of page 5 could be shortened to just CEO.  My alternative would be to revise page 2 to read (WECC CEO).

The one point in the proposal which gnaws at me a little is on Page 3, which identifies one of the seven members of the WC as “Either a second WECC Board member or a WECC staff person.”  While I understand that WECC Board members are not compensated for their time serving on WECC committees, and can see the value of having a WECC staff person with non-WREGIS expertise on the WC, I am mildly troubled that the WECC CEO or the Director of WREGIS would qualify for this position which might then create a situation where one person is filling two roles in the relationship triangle I have noted above.  While I do not see this as a major issue, I would be more comfortable if the bullet on page 3 were revised close to:  “Either a second WECC Board member or a WECC staff person (not including the WECC CEO or a member of WECC’s WREGIS staff).”

Dean Cooley                                                                              Geysers Power Company