State of Standards and Standards in Development Sean Cavote, Manager of Standards Development WECC Operating Committee Meeting March 26, 2015

RELIABILITY | ACCOUNTABILITY2 Identified 26 projects to be completed in 2014 Four projects were added after plan was developed Twelve projects, or portions of projects, were extended into 2015 Status of Reliability Standards Development Plan

RELIABILITY | ACCOUNTABILITY3 Progress on FERC Directives

RELIABILITY | ACCOUNTABILITY4 Progress on Paragraph 81 and Independent Experts Review Panel (IERP)

RELIABILITY | ACCOUNTABILITY5 Progress on Paragraph 81 and Independent Experts Review Panel (IERP)

RELIABILITY | ACCOUNTABILITY CIP V5 Revisions TOP/IRO Revisions DGR medium priority Protection System Coordination - PRC PRC UVLS (PRC-004) BAL-005 and BAL BAL-004 periodic review Implementation of IRO Periodic Review (IRO-006 and IRO-009) Physical Security Directives Real-time Monitoring and Analysis Phase 2 of Protection System Misoperations: RAS 2014 Projects Continuing Into 2015

RELIABILITY | ACCOUNTABILITY7 Critical Infrastructure Protection Standards Version 5  Addressed five FERC directives  Adopted five standards: CIP-003-6, CIP-004-6, CIP-007-6, CIP-010-2, CIP  Filed February 13, 2015 Dispersed Generation Resources  High priority DGR standards previously Board approved and pending filing at FERC  Adopted three standards: PRC (ii), PRC-019-2, PRC  Filed March 13, 2015 Revisions to TOP/IRO Standards  Eight standards previously adopted  Adopted one standard: TOP  Filed March 18, 2015 February 2015 Board Actions

RELIABILITY | ACCOUNTABILITY Physical Security Directives (Order No. 804 directive) TPL Directives EOP-004, -005, -006 and -008 Periodic Review FAC-010, -011 and -014 Periodic Review Alignment of Glossary and ROP Terms PRC-005 Order No. 803 Directive MOD-031 Order No. 804 Directive 2015 New Projects

RELIABILITY | ACCOUNTABILITY9 Four new standards projects  – Emergency Operations Periodic Review  – Periodic Review of System Operating Limit Standards  – Alignment of Glossary and Rules Of Procedure (ROP) Terms  – System Protection Coordination Teams began meeting in February 2015 Expected to complete in 2015 Robust outreach effort 2015 RSDP Projects First Quarter 2015

RELIABILITY | ACCOUNTABILITY10 FERC Order No. 804 directive on CIP  Remove the term “widespread” or propose modifications  Six-month deadline  Requires informational filing on “High Impact” control centers Team meeting January 2015 Preliminary recommendations  Remove the term “widespread” from: o Purpose Statement o Background Section o Requirement R1 and the Rationale for Requirement R1 o The Guidelines and Technical Basis Section of the standard  Add guidance for Requirement R1 Project Physical Security

RELIABILITY | ACCOUNTABILITY11 The posting runs February 20 to April 9, 2015  45-day comment and initial ballot period Assuming a successful ballot, the standard will be presented to the NERC Board of Trustees in May, 2015 for adoption and subsequent filing with FERC The project has a deadline of July 27, 2015 to file a petition with FERC that addresses the directive Contact Senior Developer Project Physical Security

RELIABILITY | ACCOUNTABILITY12 Periodic review of EOP-004, EOP-005, EOP-006, EOP-008 Team meeting and technical conference February 2015 Initial posting expected April 2015 Preliminary recommendations  EOP o Revise Attachment 1 to improve clarity  EOP o Reaffirm Requirements R7, R8, and R12 o Revise Requirement R6 –Add a Rationale Box to clarify “dynamic simulations” o Withdraw Requirement R10 –Duplicative of proposed PER Project Emergency Operations Periodic Review

RELIABILITY | ACCOUNTABILITY13 Preliminary recommendations (continued)  EOP o Reaffirm Requirements R7, R8, R10 o Revise Requirement R1 –Unnecessary action o Withdraw requirements R1 (three subparts) and R9 –Duplicative and redundant  EOP o Revise Requirement R1 –Add clarity to the intended timeframe to restore primary control center functionality Contact Developer Project Emergency Operations Periodic Review

RELIABILITY | ACCOUNTABILITY14 Industry webinar and team meeting March 2015 Initial posting expected April 2015 Standard drafting team objectives  Modify requirements to PRC  Address FERC directives in Order No. 693  Consider appropriate applicable entities  Requirements o Focus on the reliability aspects o Eliminate ambiguity o Identify other similar standards and requirements o Consider if appropriate for the PRC family of standards o Improve measurability Project – System Protection Coordination

RELIABILITY | ACCOUNTABILITY15 SDT Approach  Requirement R1 – Knowledge o SDT anticipates moving R1 to TOP  Requirement R2 – Notification of failures (i.e., degradation) o SDT anticipates moving R2 to TOP (Transmission Operations)  Requirement R5 – Communicating in advance (i.e., planning ahead) o SDT anticipates moving R5 to TOP (Operational Planning)  Requirement R6 – Monitoring and communicating status changes of Special Protection Systems o Considering retiring R6 since it appears other standards cover it Contact Developer Project – System Protection Coordination

RELIABILITY | ACCOUNTABILITY16 April 1, 2015  BAL  EOP (GMD)  PRC July 1, 2015  MOD October 1, 2015  CIP (Physical Security) January 1, 2016  FAC  FAC  NUC  TPL requirements 2-6, 8 April 1, 2016  CIP V5 July 1, 2016  MOD  PER  PRC  PRC July 1, 2017  MOD Standards Subject to Future Enforcement

RELIABILITY | ACCOUNTABILITY17 Deliberate pace of standards development  Response to industry, NERC Board of Trustees, and NERC Standards Committee  Relieve strain on scarce NERC and industry resources  Stagger postings and ballots for standards as well as presentations to the NERC Board for Adoption Steady State Standards  Largely complete in 2015 Enhanced Periodic Reviews  Third or fourth quarter Trends and Expectations

RELIABILITY | ACCOUNTABILITY18 PMOS Annual Planning Calendar

RELIABILITY | ACCOUNTABILITY19 Progress to Steady State February (3)  CIP V5 Revisions  TOP/IRO Revisions  DGR medium priority May (3)  UVLS (PRC-004)  DGR medium priority  Physical Security Directives August (3)  BAL-004 periodic review  EOP-004, -005, -006 and periodic review  PRC-005 Order No. 803 Directive

RELIABILITY | ACCOUNTABILITY20 Progress to Steady State November (7)  BAL-005 and BAL-006  Implementation of IRO Periodic Review (IRO-006 and IRO-009)  FAC-010, -011 and -014 periodic review  Alignment of Glossary and ROP Terms  PRC-001  MOD-031 Order No. 804 Directives  Protection System Coordination (PRC-027) 2016 (2)  Real-time Monitoring and Analysis  Phase 2 of Protection System Misoperations: RAS

RELIABILITY | ACCOUNTABILITY21 Measured, in-depth review to improve quality and content of standards Look for opportunities to make standards more concise  Verify content is appropriate to be included in a standard  Builds on Independent Experts’ work with industry input Plan to be developed by end of Q  Topic will be discussed at the May NERC Board and Member Representatives Committee meetings forpolicy input discussion No mandated timeline Enhanced Periodic Reviews

RELIABILITY | ACCOUNTABILITY22 Recognizes current trend at NERC  Smaller drafting and review teams of 6-10 members  Active observers  Engaged industry throughout standard development process Essential part of standards development  The ballot is an inefficient barometer of industry position  Ad hoc groups have more influence early in the process  Teams often more receptive to comments during early phases of development  Communication bond among industry, teams, NERC, and FERC Industry Outreach

RELIABILITY | ACCOUNTABILITY23 Sean Cavote North American Electric Reliability Corporation 3353 Peachtree Road NE, Suite 600 – North Tower Atlanta, GA (O) (C) Contact

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