Overview of WECC Comments to FERC on the NOPR Steve Rueckert Director – Standards and Compliance Joint Guidance Committee Meeting January 23-24, 2007 Salt Lake City, Utah

WECC Process Distributed a letter to membership seeking top five issues Small team formed to review responses Standing Committee chairs Additional member support WECC Staff

NOPR Comments Team reviewed all responses Focused on high level issues Agreed not to make comments on specific standards Developed proposed draft response and distributed to WECC Board Agenda item at December BOD meeting

NOPR Comments – Summary Did NOT push for Trial Period Generally supported FERCs proposed actions Standards proposed for approval No remands Utilize NERC process for modifying standards Concern that large number of appeals could complicate process and damage relationships

NOPR Comments – Summary Regional Entities should be given flexibility and discretion for at least six month in imposing penalties on all entities Flexibility should continue for those standards identified as needing modification Recognize importance of collaborative effort with the Canadian Provinces and Mexico