Status: The interpretation was adopted by the NERC Board of Trustees on February 9, 2012, and is pending regulatory approval.
Background:On October 1, 2009, clarification was requested by ISO-RTO Council on Requirement R2, specifically on whether “directives” are limited to actual and anticipated emergency operating conditions, or whether routine operating instructions are also considered “directives.”
The effort was delayed following discussion with the requester based on the anticipation that more clarity regarding the term, “directives” would be identified through standard development work in Project 2007- 02. When it became clear that the work in Project 2007-02 would require considerable industry debate, a drafting team was formed and prepared a draft interpretation, which was posted for a 30-day formal comment period that ended December 18, 2010. Reprioritization of the total standards workload in accordance with guidance from the NERC Board of Trustees issued November 2009 and a delay as the Standards Committee developed more formal processes for addressing interpretations resulted in a delay in further processing; the Standards Committee directed that work resume on the Interpretation in April 2011.
Appeal:On August 30, 2011, the Standards Review Committee of the ISO/RTO Council submitted a Level 1 Appeal for Inaction on Project 2009-22 to the Vice President and Director of Standards requesting that Project 2009-22 be given an “immediate/urgent” priority, and be addressed within 30 days of receiving the Appeal with a formal explanation of the delays associated with the Project.
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