Process for Developing and Approving WECC Regional Criteria Preschedule Process Regional Criteria Drafting Team Meeting Conference Call - Webinar October 7, 2008

Topics WECCs Regional Criteria Development Process Regional Criteria Drafting Team (RDT) Roles Structure of an Excellent Regional Criteria Miscellaneous 2

WECC Development Process Overview SRRC Authorize Posting SR SRRC Authorize Posting SR Submit Standard Request (SR) Submit Standard Request (SR) Draft Standard Draft Standard Post for Comment Post for Comment Field Test Standing Committee Ballot Standing Committee Ballot WECC Board Approves WECC Board Approves Implement SR Complete? Notify SRRC Notify SRRC Assign to Standing Committee Assign to Standing Committee Assign to Subgroup Assign to Subgroup SR Post for Ballot Post for Ballot 3

Process for Developing and Approving WECC Regional Criteria Important to Remember Must follow this process to the letter Failure to do so is basis for appeal 4

Process for Developing and Approving WECC Regional Criteria Steps Request Validation and Routing Notify WECC Membership Drafting Notify WECC Members of DT meetings Post for Comment Address Comments Post for Standing Committee Vote Standing Committee Vote Appeals Process Board Approval Implementation 5

Process for Developing and Approving WECC Regional Criteria Request (1) Submit request Using WECC Standards/Regional Criteria Request Form Individual or Group may request WECC membership is not required 6

Process for Developing and Approving WECC Regional Criteria Validation and Routing (2) WECC Staff will review for completeness Assign a Tracking Number WECC Staff may assist in completion of the form or seek guidance from the Standards Request Routing Committee (SRRC) Request sent to Membership for comment SRRC decides whether request in scope and assigns to Standing Committee Drafting Team formed 7

Process for Developing and Approving WECC Regional Criteria Begin Drafting Phase (3) DT Begin Drafting work 30 Day Meeting Notice Required Drafting team meetings are open to interested stakeholders Applicability identified to NERC Functional Model entities Review request for need 8

Process for Developing and Approving WECC Regional Criteria Post Draft Regional Criteria (4) First Draft posted for 45 days Comments accepted from members and non- members alike Comments accepted from individuals or organizations Impact assessment report required also 9

Process for Developing and Approving WECC Regional Criteria Address Comments (5) Comments must be addressed Within 30 days of close of comment period Not mandatory to implement Implementation of significant comments requires another posting for comments Majority vote of RDT is required to move to Standing Committee 10

Process for Developing and Approving WECC Regional Criteria Submit for Standing Committee Vote (6) Post to WECC web site Official Notification to Standing Committee Report of RDT/Subgroup final vote 11

Process for Developing and Approving WECC Regional Criteria Standing Committee Vote (7) 30-day notice required BOD may shorten period if Urgency is determined Standing Committee may modify or remand Requires 10-day posting for comments Standing Committee Members and Industry Stakeholders may change their original vote or vote for the first time Majority vote (per WECC Bylaws) Required to approve 12

Process for Developing and Approving WECC Regional Criteria Appeals (8) Appeal Process is available Rejection of request by SRRC Due Process Technical Made to Standing Committee or Appeals Committee Must be made within 15 days of Standing Committee decision 13

Process for Developing and Approving WECC Regional Criteria Board Approval (9) Must be posted for 30 days prior to Board consideration Send to NERC at this time for NERC posting and review (NERC process) BOD will consider Standing Committee recommendation and minority opinions BOD may only make nonmaterial changes BOD may remand back to Standing Committee or terminate BOD majority required (per WECC Bylaws) for approval 14

Process for Developing and Approving WECC Regional Criteria Implementation of Regional Criteria (10) Regional Criteria become effective in the WECC upon BOD approval Not mandatorily enforceable through sanctions All applicable industry participants in the WECC are expected to abide 15

Key Roles in Regional Criteria Process Standing Committee Stakeholders Drafting Teams WECC Members Board of Directors WECC Staff 16

Responsibilities of Chair Leads the Team in a neutral capacity Ensures the Team makes progress Conducts meetings of the Team Represents the Team to other bodies 17

Responsibilities of all Members Provide knowledge and expertise Participate actively Provide contributions, drafts, comments Represent the interests of the Interconnection as a whole, not individual companies Attend meetings Participate in Industry Forums Provide feedback on Regional Criteria Development activities 18

Responsibilities of WECC Staff Advises the Team in a neutral capacity Monitors, facilitates, reports on, ensures active progress Prepares and circulates Team documents Maintains membership records Prepares for and assists at meetings 19

Structure of an Excellent Regional Criterion

Benchmarks of Excellent Regional Criteria 1. Applicability 2. Purpose 3. Performance requirements 4. Technical basis 5. Completeness 6. Clear language 7. Practicality 8. Consistent terminology 21

Excellent Regional Criteria Who Shall do what? To what result or outcome? Under what conditions How? Prescribe elements Technical adequacy Clear, focused applicability Unambiguous requirements 22

Definitions Limit terms to those with unique definitions Capitalize already defined terms Dont include explanatory information 23

Introduction Section Title – Keep it short; main topic and modifiers; minimize verbs Purpose – from SR (condense into a sentence or two); clear indication of reliability value/benefit; no shall or must requirements Applicability: Functions - lists the functional entities that must comply with the standards requirements along with any specific qualifications (i.e., that own UVLS programs) Facilities – lists any qualifications to limit the scope of facilities addressed (i.e., 100 kV and above) 24

Requirements Section Requirements specifically state the technical, performance, and preparedness details that each entity must meet using the NERC reliability benchmark. The benchmark for a performance requirement is measured by the question: "Who shall do what, under what conditions and to what level, for what reliability result?" The benchmark breaks down into 5 construction elements that follow the sequence below: Who (1) + shall do what (2) + under what conditions (3) and to what level (4) + for what expected reliability result (5)? The word shall is used before the verb to modify the meaning of the main verb, in this case to express necessity. Using the 5 construction elements of the benchmark – with one and two in sequence – ensures that the performance requirement is written in active voice and clearly states the expected reliability objective. 25

Requirements Write in active voice (shall be is passive) Identify any qualifying conditions (if any) under which the performance is required Identify the responsible entity or entities Include the word shall Identify the required performance or outcome Identify what the performance will achieve Write as simply as possible Avoid use of negatives Avoid use of ambiguous or subjective terms Dont tell how 26

Avoid Use of Ambiguous Words Adequate Data Immediately Timely Detailed Sufficient Comprehensive As appropriate Coordinate 27

Miscellaneous

Comment Forms Ask very pointed questions If youve made changes, ask for feedback Ask for feedback on implementation plan Ask if field testing is needed Ask if there are any Variances Ask if there are any known conflicts with existing regulations 29

Consideration of Comments Read through comments to get a sense of stakeholders reactions Consider and respond to every comment Responses must be respectful Responses should provide a justification Develop a summary response to each form question Add an overview of the changes made – including the issues resolved and those that werent resolved Make conforming changes to the standard Cant expand scope of SR but can develop a standard that is smaller than the scope of the SR – if needed, revise the SR to expand the scope 30

What Is Consent of the Industry? Comments 31

Field Tests As needed to validate concepts, methods, measures in a regional criteria Drafting team develops field test plan Standards Committee approves and oversees field test Complete tests before ballot 32

Implementation Plan Part of final regional criterion going to ballot Must be posted for comment at least once Includes Proposed effective date(s) and implementation into compliance program (Must become effective on the first day of a calendar quarter.) Withdrawal or modification of existing regional criteria Any tools, training, or other implementation considerations 33

Process for Developing and Approving WECC Regional Criteria Questions 34