A broad-based group of trade associations, including the American Public Power Association, the Edison Electric Institute, the Electricity Consumers, Resource Council, the Electric Power Supply Association, the Large Public Power Counsel, the National Rural Electric Cooperative Association and the Transmission Access Policy Study Group, filed comments in support of the standards development process changes proposed by NERC. Silicon Valley Power (SVP), the municipal utility of Santa Clara, California, filed comments expressing concern that the proposed waiver process would grant too much discretion to the Standards Committee to bypass the standards development process. SVP asked FERC to direct NERC either to withdraw the proposal or further clarify the waiver process or, in the alternative, order procedural revisions to put the burden of proof on NERC to defend a waiver decision. NERC filed comments defending the waiver provisions, arguing the need for flexibility in certain limited circumstances. NERC also emphasized that the waivers will only affect the timing of revisions to the standards, not the actual voting requirements.
The revisions to the SPM are pending before the Commission in FERC Docket No. RR13-2-000.