1. WIRAB Comments to the Peak Reliability Interim Board Doug Larson, WIRAB December 4, 2013

2. WIRAB aims to provide sound and concise advice to Peak Reliability to improve the reliability of the grid WIRAB looks forward to a productive relationship with Peak

3. October 30 WIRAB meeting explored – – Peak staffing (draft discussion paper; presentation)paperpresentation – Performance metrics for Peak (draft discussion paper; presentation)paper – Peak’s services to BAs and TOPs (draft discussion paper; presentation)paper presentation – Information sharing (presentation)presentation – Best practices (draft discussion paper; presentation)paperpresentation Met with WEIL Group on October 11

4. Based on findings from the Sept. 8, 2011 outage, WECC surveys of company reliability practices and the October LBNL report on real-time grid operating technologies, WIRAB’s primary concerns are:report – Inadequate industry reliability practices – Inadequate information sharing – Fragmentation of the Reliability Coordinator function – Funding Peak Reliability – Staffing Peak Reliability

5. WIRAB’s agenda is to -- – Establish performance metrics for Peak Reliability that measure overall reliability, Peak’s internal performance and the performance of BAs and TOPs which is critical to reliability – Expand services Peak Reliability provides to BAs and TOPs – Increase communication with CEOs on their company’s reliability and operational performance – Identify, highlight and convey best practices

6. The value of Peak Reliability depends on – This Board adopting a broad view of its mission focused on the overall reliability of the grid A secure, adequate and independent source of funding that allows no free riders Maintaining a unified RC function across the interconnection Peak operating as a high performing organization

7. Scope of Peak’s Activities W EAK R ELIABILITY P EAK R ELIABILITY Fully staff RC Metrics for directives performance RC establish a daily analysis of deviations between model results and grid performance and post the results on WECCRC.org. Establish and publish RC accuracy metrics RC establish a benchmark of what constitutes an acceptable level of accuracy between model results and actual real- time grid performance. Direct communication with BA/TOP CEOs on company performance Make an RC updated Network Model, SE, RTCA available to all BAs/TOPs Post when BA/TOP tools offline TOPs post on WECCRC.org their internal seasonal studies TOPs post on WECCRC.org day-ahead studies and state the base case used in the analysis TOPs post their current relay settings on WECCRC.org BAs and TOPs compare the accuracy of their day-ahead studies, Network Models, State Estimator results and RTCA results Performance metrics for BAs and TOPs Evaluate better structure for reliable grid operations Focus on RC compliance with standards Bring internal RC operations up-to- speed with other grid operations Achieve quality BA, TOP, RC operations

8. WIRAB will revise its discussion papers to include action recommendations that - 1.Develop benchmarks and metrics for Peak Reliability Peak should to develop a straw proposal and seek comments WIRAB will participate in any work group that is created 2.Create a joint WECC/Peak work group on implementation of best practices by BAs and TOPs Peak and WECC need a system to recognize superior performance by BAs, TOPs and others WIRAB will participate in this work 3.Propose and advocate for better information sharing practices WIRAB will monitor progress on data sharing practices between WECC and Peak following bifurcation, particularly critical UNDA- covered data

9. Revise discussion papers to -- 4.Advocate changes to mandatory standards to require use of State Estimators, RCTA and other tools that are central to good reliability practices 5.Expand information requirements under IRO 10 and make performance under this standard an audit priority 6.Review whether bilateral contracts between Peak and companies improve reliability 7.Expand Peak’s services to BAs and TOPs 8.Pursue opportunities to improve grid operations through the use of advanced technologies (e.g., synchrophasors) WIRAB will continue to intervene at FERC to provide advice in support of a secure, adequate, and independent source of funding for Peak without free riders