Brian Theaker RCWG Chair Regional Criteria Work Group (RCWG) Recommendation for RPIC August 15, 2012 Brian Theaker RCWG Chair

Agenda Background RCWG Recommendation Comments Other issues outside RCWG scope RPIC vote on recommendation Next steps

Background RCWG formed in August 2011 Focus: Regional Criteria (“RegCr”) Joint RPIC/GNC concerns Membership Chairs of standing committees RPIC and GNC members

RCWG Membership Steve Ashbaker, WECC RPIC* John Tolo, TEP (OC Chair) GNC** Dick Ferreira, TANC* Board Bob Harshbarger, PSE (MIC Chair) Vicken Kasarjian, SMUD* Diana Pommen, AESO* Steve Rueckert, WECC John Stout, Mariner Consulting (Board Vice-Chair)** Brian Theaker, NRG Energy, Inc. (RCWG Chair)* Scott Waples, Avista (PCC Chair) Tom Botello, SCE (emeritus)

RegCr Concerns RegCr impose mandatory requirements but are not under the CMEP Only WECC members are required to adhere to RegCr requirements Loss of WECC membership most severe sanction for failing to adhere Perception that RegCr were increasingly being used for reliability purposes Frequency Responsive Reserve

RCWG Charter Develop recommendations to: Eliminate RegCr that do not serve reliability Incorporate RegCr requirements to standards, incl. new as appropriate Annual list of applicable RegCr Estimate impact of non-adherence to RegCr Develop methods of monitoring adherence Minimally burdensome

RCWG Principles Documents that impose mandatory requirements that materially affect reliability should be standards Documents that impose mandatory requirements that do not materially affect reliability but do promote efficient business should be Regional Business Practices

Final RCWG Package Includes RCWG White Paper Mark-up of WECC Document Categorization Policy Proposed Process for Monitoring Adherence to WECC RBP Requirements

Recommendation Retain eight (9) RegCr that satisfy “Fill-In-The-Blank” requirements as RegCr: EOP-007-WECC-CRT-1 Blackstart Unit Testing MOD-[011-013]-WECC-CRT-1 Steady State and Dynamic Data PRC-[012-014]-WECC-CRT-2 Remedial Action Schemes PRC-003-WECC-CRT-1 Relay Mis-operation PRC-006-WECC-CRT-1 Underfrequency Load Shedding

Recommendation (2) Draft SARs to evaluate seven (7) existing RC for promotion to standards: PRC-001-WECC-CRT-1 (Governor Droop criterion) PRC-024-WECC-CRT-1 (Low Voltage Ride-Though Criterion) TPL-[001-004]-WECC-CRT-2 (System Performance Criteria) VAR-502-WECC-CRT-0 (Power System Stabilizer Design and Performance)

Recommendation (3) Request custodian work group (Telecommunications Work Group) to evaluate one (1) existing Regional Criterion for possible demotion to a guideline COM-001-WECC-CRT-1 Digital Circuits Sychronization

Recommendation (4) Rename sixteen (16) existing “INT” RegCr as “Regional Business Practices” INT-001, 003, 004, 005, 007, 008, 009, 010, 011, 014, 015, 016, 017, 018, 020, 021 No fundamental change in the nature of the requirements they impose No desire to derail INT re-write effort underway If parties feel INTs are mis-categorized, they can submit a SAR

Proposed Disposition of RegCr

Recommendation (5) Approve and implement “Process for Monitoring Adherence to WECC Regional Business Practice Requirements”

RBP Adherence Process Components Staff posts list of applicable RBP annually 3rd party reporting of alleged non-adherence WECC staff review allegations of non-adherence Confidentiality maintained If non-adherent, submit plan for adherence Appeals to Board/designated committee WECC posting of confirmed non-adherence Still missing: an exemptions/exceptions process

Member Feedback Initial recommendation posted May 1 Comments received June 1 Ten sets of comments received Opposition to annual officer confirmation Divided on other aspects Revised recommendation posted July 10 Six sets of comments received July 25 With one exception, comments editorial

Powerex Positions Support annual confirmation Indirect impacts of failure to adhere to RBP Guideline development must follow process set forth in Bylaws §8.5.6 Outside RCWG scope Categorization dispute resolution process June RPIC meeting – whom? WSC? RPIC? Need an exemptions/exceptions process RCWG agrees – but whom?

RCWG Charter & Recommendation Develop recommendations to: Eliminate RegCr that do not serve reliability Incorporate RegCr requirements to standards, incl. new as appropriate Annual list of applicable RegCr Estimate impact of non-adherence to RegCr Methods of monitoring adherence Minimally burdensome

Follow-up items: Exceptions/exemptions process Document categorization dispute resolution process

Motion Moved, that the Reliability Policy Issues Committee approve the RCWG recommendation as presented on August 15, 2012

Next steps Seek Board approval at next available Board meeting

Questions? Brian Theaker RCWG Chair NRG Energy, Inc. brian.theaker@nrgenergy.com 530-295-3305