Document Categorization Policy Chris Albrecht, Legal Counsel Western Electricity Coordinating Council

Western Electricity Coordinating Council FERC Audit of WECC FERC Audit of WECC Recommendation 14: Adopt written criteria for evaluating whether activities should be funded under Section 215 Recommendation 15: Provide detail surrounding WECC’s Regional Business Practice activities sufficient to ensure the appropriateness of funding these activities under section 215 WECC’s Implementation Adopted a funding criteria based on and nearly identical to NERC’s funding criteria that was approved by FERC Criteria V: The activity is required or specified by, or carries out, the provisions of NERC’s Rules of Procedure NERC ROP refer to “Regional Criteria” not “Regional Business Practices” The name “Regional Business Practices” is misleading Western Electricity Coordinating Council

Western Electricity Coordinating Council Recategorization Solution: recategorize “Regional Business Practices” as “Regional Criteria” Required changes to Document Categorization Policy, Process for Monitoring Adherence of RBP, and Process for Seeking an Exemption to RBP Other changes to simplify and streamline the documents Changes to Document Categorization Policy Retained existing treatment of all RC and RBP; both before and after recategorization: Documents referenced in a standard – subject to CMEP Documents not referenced in a standard – subject to WECC Process for Monitoring Adherence of RBP Only terminology has changed Prior to recategorization the terminology was RC and RBP After recategorization the terminology is “RC referenced in a standard” and “RC not referenced in a standard” Western Electricity Coordinating Council

Approval and Aftermath Board Approval Documents posted for notice and comment as Board approval items MAC notified and given opportunity to review and advise the Board OC and MIC Meetings Confusion regarding changes Resolutions stating the MAC should ask Board to rescind changes MAC Formed a task force that did not see a need to ask Board to rescind changes, but suggested documents be posted for member comment Comments Board asked staff to post the documents for member comment Comments submitted by FEUS and Powerex WECC followed up with commenters Western Electricity Coordinating Council

Western Electricity Coordinating Council Requested Changes No commenter is requesting recategorization back to Regional Business Practices Powerex has concerns with some of the other simplifying changes made to the documents and requests changes specifying: Guidelines, Reports and White Papers be developed using a notice and comment process prior to notice and comment process required for approval Concern this change will be overly burdensome on committee work WECC Director of Standards consider the purpose and intent of a Regional Criterion during evaluation of adherence Board be given notice of validated non-adherence WSC consider adding to the Drafting Team (responsible for making a recommendation a proposed exemption) persons from neighboring or adjacent entities Further review disclosed lack of clarity over applicability of policy—substance applies specifically to OC, PCC, MIC, and TEPPC. Western Electricity Coordinating Council