LPPC Comments on NERC MSPP Task Force Final Recommendations for Standards Process Modernization
LPPC submitted comments to NERC’s Modernization of Standards Processes and Procedures Task Force (MSPP TF), generally supporting the Final Recommendations to streamline reliability standards development while flagging implementation concerns. Key points include: requiring written comment opportunities on all Standard Initiation Requests; establishing clear qualifications and term limits for the new RISC Sub-committee; ensuring a transparent transition from the existing Standards Committee; preserving essential guidance documents and updating them to address AI use; clarifying responsibility for key work products (RSAWs, technical rationale, implementation plans, quality reviews); maintaining schedule transparency after elimination of the PMOS; supporting company-based ballot designations; and pushing back on allowing use of Rules of Procedure Sections 321/322 after only a single failed ballot rather than two.
