Top 10 Questions on Regional Reliability Standards Development Judith A. James Manager, Reliability Standards March 5, 2009 June 2008 TAC

10. Do you work in the compliance division of TRE? I do not. TAC March 2009

9. Will submitting a SAR subject me to “spot check”? See question # 10. I don’t work in the compliance division. Submitting a SAR is not turning yourself in for non-compliance with a standard. When you submit a Request to Authorize the development of a regional Standard (SAR), you are telling Texas RE and the ERCOT region that you see a reliability need for a regional standard that supports a particular national standard (unless it is for “matters not covered” in a national standard). TAC March 2009

8. What exactly are regional reliability standards? Four types of regional standards: Regional Difference: something the region desires to do differently to meet the same reliability objective as the NERC standard and is more stringent than the NERC reliability standard. Regional Variance: an alternative approach that a region uses to meet the same reliability objective as the NERC standard, necessitated by a physical difference. Regional Implementation: implements a NERC standard with more detail specific to the region (sometimes called “fill-in-the-blank” and is NERC directed). Regional Standard that covers matters not covered by an existing NERC standard: brand new reliability objective that NERC has not covered in any NERC standard. TAC March 2009

7. Are regional standards really necessary? Ideally, no. We have NERC continent-wide standards for reliability and consistency around the nation AND the region must comply with the continent-wide standard. But, practically, yes. Regional standards may be necessary in special circumstances to augment, implement, or vary from the national standard (See question 8), and the regional process should be used appropriately when these circumstances occur. It is everyone’s responsibility in this region to be looking out for circumstances where a regional variance or standard may be appropriate and to submit a SAR. TAC March 2009

6. Do you work on national standards too? Yes and no. Not formally on any national drafting team, but I do sit in on some of them if they meet locally. Inform the region of national drafting team openings. Read and review NERC Projects of Standards Under Development---Currently 39 Projects for potential regional standard development. Lead and guide Texas RE Reliability Standards Committee (RSC) on projects that have potential. Attend NERC Standards Committee meetings. New Member of NERC Communications and Planning Subcommittee. TAC March 2009

5. Why does the regional standards development process take so long? ANSI-approved process intended to develop consensus and the process must meet many criteria with many steps: SAR, public posting, review of comments, standard drafting team (SDT), drafting the standard (“soup to nuts” can take awhile), public posting of the draft standard, field testing, formal balloting, re-ballot, appeals mechanism, approval by BOD, NERC and FERC, implementation with more field testing. NERC and other regions are taking anywhere from 18 months to 2 or more years to get through their same process for one standard. It’s new. It takes awhile to get through something new. (We’ve made it through once with SAR-001.) Lone Star Resistance. I feel your pain, so please don’t shoot the RSM! TAC March 2009

4. How can I participate in the standards development processes? Participate in the following Texas RE Activities: Become member of Texas RE’s RBB, Vote on Regional Standards Texas RE Reliability Standards Committee Author and sponsor SARs Texas RE Standards Drafting Teams Comment on Texas RE Regional Standards Attend Texas RE Workshops—Spring and Fall Get on the Texas RE mailing lists at http://lists.ercot.com TEXASRE_RSC, TEXASRE_UFLS, TEXASRE_INFO, LSERWG Participate in the following NERC Activities: Comment on NERC Standards Register in the NERC RBB to Vote on NERC Standards NERC Standard Drafting Teams Author and sponsor SARs, Request Formal Interpretations Field Tests for Standards NERC Standards Workshops + Regional Reliability Standards WG Get on the NERC mailing lists at http://listserv.nerc.com sac_plus, rrswg_plus, nercnews TAC March 2009

3. Why do you send out so many notices and announcements? The FERC, NERC, ANSI approved process requires it. In addition, I do send out “reminders” that are not required, but I do this because the process is so new, and you may need reminding of something. And occasionally I mistakenly spam you with the same announcement. Sorry.  TAC March 2009

2. Can you interpret a standard for me? No, because currently we don’t have any approved regional standards to interpret. No, because even if we did have approved regional standards, the IDT (Interpretation Drafting Team) would interpret the standard---not me. (But send the request to me.) No, because NERC has their own process for interpreting the national NERC standards---fill out their form. TAC March 2009

Draft of BAL-001-TRE-01. TRE’s first regional standard. 1. Where’s the beef? Draft of BAL-001-TRE-01. TRE’s first regional standard. Applicable to BA, GO, GOP in this region. Under SAR-003 link at http://trackstandard.texasre.org Technical workshop and Web Ex planned to explain and answer questions on this draft regional standard. About to be posted for public comment---watch for your announcement. TAC March 2009

LSERWG meeting on Feb 27 to begin drafting a joint agreement. LSE Update Regional standards not on the plate anymore—not appropriate to develop a regional standard to eliminate a function, especially when the tasks associated with the function are being performed in this region. LSERWG meeting on Feb 27 to begin drafting a joint agreement. Plans to meet each Friday until agreement is drafted. TAC March 2009

Manager, Reliability Standards Judith A. James, J.D., P.E. Manager, Reliability Standards rsm@texasre.org TAC March 2009