W. Shannon Black Manager, Standards Processes Results Based Drafting 2013

2 Who? o Define the DT  The team is subject to open What? o Draft a WECC Regional Reliability Standard When? o Six months or six years The Basics

3 Where? o Rarely face-to-face o Usually Webinar Why? o Reliability o Wear your “WECC Hat” not your “Firm Hat” How? o In accordance with the “Procedures” and NERC Rules Why are we Here?

Who Does What?

5 Chair o Primary  Create work product  Ensure the team keeps moving forward  Facilitate within the four-corners of the Procedures  “Voice” of the team o Secondary  Subject Matter Expert Team Members o SME with a WECC purpose The Chair and the Team

6 WECC Staff o Manage the Procedures  Stay within the Procedures  Keep the team moving o Manage the document  Document control  First tier quality review  Facilitator plus Technical Writer  Language and Procedure SME o Manage the website WECC Staff

7 Procedural Oversight o Need approval for most everything  Scope  Posting of work product (Versions/Response)  Forward to WECC Board The Standing Committee no longer control the development process. The WSC

8 NERC o Quality Review Board o Approves, remands or rejects NERC – again o Board of Trustees o Legal – multiple reviews of the filing FERC o Approve, remand or reject o Their own calendar Board / NERC / FERC

“Procedures” And Principles

10 WECC/NERC/FERC Approved Document Exhibit “C” of the Delegation Agreement o Basically a Contract o Contains specifics of delegated authority o Is not all inclusive  Needs interpretation  Staff will assist The “Procedures”

11 Meetings require 15 days notice Comment o 45 days followed by 30 days – until done Response o 30 days to respond Impact Statement o Addresses Costs & “Other” Don’t forget the WSC o Allow WSC “Time” Procedural Mandates

12 Posted 30 days before a Ballot Pool Posted 30 days before the Board Ballot Body/Ballot Pool Joint Session – 3 days notice Vote “at least” 7 days after Session Vote covers 15 “Business” days “No” votes require a reason o Added to the record Procedural Mandates

13 Each Comment o Requires a Response o Can be aggregated Forwarded to WSC o They officially approve and post o 30 days to get Responses posted Repeat until done Responses

14 Requires 2/3 quorum of “Pool” o Abstentions and incomplete votes count o Vote “at least” 7 days after Session o Vote 15 calendar days or extended as needed If accepted o To the Board “via” the WSC If rejected o WSC can rewrite, re-ballot or recycle to Session, terminate Vote

Development Principles

16 The Procedures do not require a quorum of the DT to be present before a DT vote is taken. The Procedures do not require notice that a DT subset group will meet. It takes only a simple majority to carry a vote on any DT issue. Development Principles

17 All meetings of the DT shall be open to the public and broad participation is encouraged. Nothing in these Development Principles shall infringe on an individual’s rights to appeal o Among other reasons…  Can appeal for procedural or technical error All DT members are encouraged to always be present; proxy voting by a DT member is not allowed. Development Principles

18 DT voting may take place face-to-face, electronically, in real-time or within a scheduled window. Voting on which position to adopt on a drafting issue is reserved for the DT members. Voting on inclusion or exclusion of specific language in the document under development is reserved for the DT members. Voting on minutes and related business motions is reserved for the DT members. Straw Polls are of excellent advisory value but the DT is not obligated to abide by a straw poll. Development Principles

A Note on Drafting

20 Follow the ERO or RRO templates Applicable Entities o NERC Functional Model dictates Requirement and Measures o Each X shall do Y. Evidence may include… Avoid o Adjective, pronouns, adverbs o Do not incorporate by reference o Don’t use “C”aps unless defined Regulatory - Speak

21 Review the SAR and other documents Draft the Purpose o This overall document is designed to….  Fill in that blank  The body should match the Purpose statement Draft a set of goals o Things we want entities to do Draft the tasks that need to be done o Can assign entities later Draft the sequence of those tasks Where do we start?

22 o Now we can draft Pen to Paper

Questions?