EOP Project Emergency Operations Regional Outreach WECC ISAS Meeting August 20, 21, 2014

RELIABILITY | ACCOUNTABILITY2 Background and overview FERC Directives Five Year Review Attachment 1 of EOP and BAL-002 coordination Project moving forward Discussion and recommendations Agenda

RELIABILITY | ACCOUNTABILITY3 Nov. 11, 2010 – NERC SC authorized moving the Project Emergency Operations SAR forward to standard drafting and appointed a SAR Drafting Team. Project involved reviewing and revising  EOP  EOP  EOP  IRO Project was placed on hold in late 2010/early 2011 due to NERC Standards prioritization effort. Project Background

RELIABILITY | ACCOUNTABILITY4 April 22, 2013 – EOP Up for 5 year Review NERC SC appointed eight SMEs to serve on the Emergency Operations Five-Year Review Team (EOP FYRT) to review and make recommendations regarding:  EOP b  EOP  EOP August 6–September 19, 2013 – The EOP FYRT developed a set of recommendations which were posted for a 45-day comment period. Project Background

RELIABILITY | ACCOUNTABILITY5 October 17, 2013:  NERC SC accepted the recommendations of the EOP FYRT  Appointed a drafting team  Authorized posting the SAR developed by the EOP FYRT November 6–December 5, 2013: SAR posted for comment period. Project Background

RELIABILITY | ACCOUNTABILITY6 EOP was drafted by the Emergency Operations Standard Drafting Team (EOP SDT) through the examination and consideration of:  Applicable FERC directives  EOP FYRT recommendations  Independent Expert Report  Paragraph 81 criteria  SAR EOP was posted for informal comment period so industry could review and help guide the current body of work. Project Background

RELIABILITY | ACCOUNTABILITY7 The informal comment period for EOP was open until Friday, April 28. The EOP SDT held a drafting team meeting May 13–15 to review comments and further develop the EOP standard. EOP is now posted for the first formal comment period. Submittal to the Board and subsequent regulatory filing is targeted for the end of 2014 or early Key Milestones

RELIABILITY | ACCOUNTABILITY8 EOP Standard Drafting Team MemberOrganization David McRee, ChairDuke Energy Bob Staton, Vice ChairXcel Energy Will BehnkeAlliant Energy Richard CobbMidcontinent ISO, Inc. Jen FiegelOncor Electric Delivery Fran HalpinBonneville Power Administration Hal HaugomMadison Gas and Electric Steve LesiutaOntario Power Corporation, Inc. Connie LoweDominion Resources Services, Inc. Greg LeGraveWisconsin Public Service Corp. Brad YoungLG&E/KU

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10 Five-Year Review Overview  Part of NERC’s broader objective to transition to a clear, concise, and stable body of world-class, high-quality reliability standards  Five-year reviews must be conducted on current standards that are due for assessment and have not been revised in recent standards development projects o Required by ANSI-accredited Reliability Standards development process Industry Webinar: Five-Year Review Projects Overview 05/2013 Five-Year Review Projects

RELIABILITY | ACCOUNTABILITY11 Five-Year Review Objective  Determine whether the Reliability Standard should be: o (1) affirmed; o (2) revised; or o (3) withdrawn. Elements of the Five-Year Review  Outstanding FERC directives  Stakeholder requests for clarity or revision  Results-Based Standards (RBS) principles  Paragraph 81 principles EOP FYRT recommendations were submitted to Standards Committee on September 19, 2013 and accepted by SC in October. Five-Year Review Projects

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RELIABILITY | ACCOUNTABILITY13 Project EOP consolidates and replaces EOP b, EOP , and EOP with EOP Project UVLS consolidates and replaces PRC-010-0, PRC , PRC-021-1, and PRC with PRC The respective performance formerly required by EOP-003-2, Requirements R2, R4, and R7 is reflected in PRC The EOP and UVLS projects are progressing simultaneously to properly align legacy standard retirements and revised standard implementations. April 10, 2014 EOP and UVLS Joint Webinar EOP and UVLS Project Coordination

RELIABILITY | ACCOUNTABILITY14 Please contact the respective NERC Standards Developers for more information, to schedule an outreach session, or to be added to a project’s distribution list:  Project EOP: Laura Anderson at Project  Project UVLS: Erika Chanzes at Project Additional Information

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RELIABILITY | ACCOUNTABILITY16 Attachment 1 – EOP and BAL-002 Conflict with BAL 002 on use of Reserves in EEA’s Attachment 1 has been changed. Use of OR was removed from EEA 2 and added to EEA 3  At EEA 2 BA is still able to meet load and maintain reserves  At EEA 3 unable to meet load without dipping into reserves. Utilizing reserve margins is preferable to dropping load to maintain reserves. BAL 002 team will be changing their new standard to align with EOP 011

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RELIABILITY | ACCOUNTABILITY18 EOP Definition Revision Proposed revised definitions: Energy Emergency - A condition when a Load-Serving Entity or Balancing Authority has exhausted all other resource options and can no longer meet its expected Load obligations. This defined term was revised to provide clarity that an Energy Emergency is not necessarily limited to a Load-Serving Entity.

RELIABILITY | ACCOUNTABILITY19 EOP Definition Revision This defined term, or variations of it, is also used in the instances below. The EOP SDT does not believe that the proposed revisions change the reliability intent of these standard or definitions. BAL-002-WECC – Contingency Reserve IRO a — Reliability Coordination — Current Day Operations MOD — Capacity Benefit Margin INT – Dynamic Transfers Defined term Emergency Request for Interchange

RELIABILITY | ACCOUNTABILITY20 EOP Purpose Statement Purpose of the Standard: To mitigate the effects of operating Emergencies by ensuring each Transmission Operator and Balancing Authority has developed Emergency Operating Plans, and that those plans are coordinated within a Reliability Coordinator Area.

RELIABILITY | ACCOUNTABILITY21 EOP Functional Entities Applicable to these Functional Entities: Balancing Authority Transmission Operator Reliability Coordinator Load Serving Entity has been dropped in EOP 011

RELIABILITY | ACCOUNTABILITY22 EOP Requirement R1 R1. Each Transmission Operator shall develop, maintain and implement a Reliability Coordinator-approved Emergency Operating Plan to mitigate operating Emergencies on its Transmission System. At a minimum, the Emergency Operating Plan shall include the following elements: [Violation Risk Factor: High] [Time Horizon: Real-Time Operations, Operations Planning] (The list following was taken from the original attachment 1 of EOP 1 for those elements deemed important for TOP’s)

RELIABILITY | ACCOUNTABILITY23 EOP Requirement R Roles and responsibilities to activate the Emergency Operating Plan; 1.2. Strategies to prepare for and mitigate Emergencies including, at a minimum: Notification to the Reliability Coordinator, to include current and projected System conditions, when experiencing an operating Emergency; Controlling voltage; Cancelling or recalling Transmission and generation outages; System reconfiguration; Requesting the redispatch of generation; Operator-controlled manual Load shedding plan coordinated to minimize the use of automatic Load shedding; Mitigation of reliability impacts of extreme weather conditions; and 1.3. Strategies for coordinating Emergency Operating Plans with impacted Transmission Operators and impacted Balancing Authorities.

RELIABILITY | ACCOUNTABILITY24 EOP Requirement R2 R2. Each Balancing Authority shall develop, maintain and implement a Reliability Coordinator-approved Emergency Operating Plan to mitigate Capacity and Energy Emergencies. At a minimum, the Emergency Operating Plan shall include the following elements: [Violation Risk Factor: High] [Time Horizon: Real-Time Operations, Operations Planning] (again, taken from the original attachment 1 of EOP 1 for those elements deemed important for BA’s) 2.1. Roles and responsibilities to activate the Emergency Operating Plan; 2.2. Notification to the Reliability Coordinator, to include current and forecasted conditions, when experiencing a Capacity Emergency or Energy Emergency; 2.3. Criteria to declare an Energy Emergency Alert, per Attachment 1;

RELIABILITY | ACCOUNTABILITY25 EOP Requirement R Strategies to prepare for and mitigate Emergencies including, at a minimum: Generating resources in its Balancing Authority Area: capability and availability; fuel supply and inventory concerns; fuel switching capabilities; environmental constraints Voluntary Load reductions; Public appeals; Requests to government agencies to implement their programs to achieve necessary energy reductions; Reduction of internal utility energy use;

RELIABILITY | ACCOUNTABILITY26 EOP Requirement R Customer fuel switching; Use of Interruptible Load, curtailable Load and demand response; Operator-controlled manual Load shedding plan coordinated to minimize the use of automatic Load shedding; and Mitigation of reliability impacts of extreme weather conditions Strategies for coordinating Emergency Operating Plans with impacted Balancing Authorities and impacted Transmission Operators.

RELIABILITY | ACCOUNTABILITY27 EOP Requirement R3 R3. Each Reliability Coordinator shall approve or disapprove, with stated reasons for disapproval, Emergency Operating Plans submitted by Transmission Operators and Balancing Authorities within 30 calendar days of submittal. [Violation Risk Factor: Medium] [Time Horizon: Operations Planning ]

RELIABILITY | ACCOUNTABILITY28 EOP Requirement R4 R4. Each Reliability Coordinator that receives an Emergency notification from a Transmission Operator or Balancing Authority shall notify, as soon as practical, other impacted Reliability Coordinators, Balancing Authorities and Transmission Operators. [Violation Risk Factor: High] [Time Horizon: Real-Time Operations]

RELIABILITY | ACCOUNTABILITY29 EOP Requirement R5 R5. Each Reliability Coordinator that has a Balancing Authority experiencing a potential or actual Energy Emergency within its Reliability Coordinator Area shall initiate an Energy Emergency Alert, as detailed in Attachment 1. [Violation Risk Factor: High] [Time Horizon: Real-Time Operations]

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RELIABILITY | ACCOUNTABILITY31 FERC Directives In the development of the proposed EOP reliability standard, the EOP SDT addressed the outstanding FERC directives in Order No. 693 related to Emergency Operations and planning.

RELIABILITY | ACCOUNTABILITY32 FERC Directives EOP Emergency Operations Planning: Include reliability coordinators as an applicable entity. Consider Southern California Edison’s and Xcel’s suggestions in the standard development process. Clarify that the 30-minute requirement in requirement R2 to state that Load shedding should be capable of being implemented as soon as possible but no more than 30 minutes. Includes definitions of system states (e.g., normal, alert, emergency), criteria for entering into these states. And the authority that will declare them. Consider a pilot program (field test) for the system states proposal. Clarifies that the actual emergency plan elements, and not the “for consideration” elements of Attachment 1, should be the basis for compliance.

RELIABILITY | ACCOUNTABILITY33 FERC Directives EOP Capacity and Energy Emergencies: Address emergencies resulting not only from insufficient generation but also insufficient Transmission capability, particularly as it affects the implement of the capacity and energy Emergency plan. Include all technically feasible resource options, including demand response and generation resources.

RELIABILITY | ACCOUNTABILITY34 FERC Directives EOP Load Shedding Plans: Develop specific minimum Load shedding capability that should be provided and the maximum amount of delay before Load shedding can be implemented based on overarching nationwide criteria that take into account system characteristics. Require periodic drills of simulated Load shedding. Consider comments from APPA and ISO-NE in the standards development process.

RELIABILITY | ACCOUNTABILITY35 FERC Directives Order No. 693 at P 573 “Demand response covers considerably more resources than interruptible load. Accordingly, the Commission directs the ERO to modify the Reliability Standard to include all technically feasible resource options in the management of emergencies. Order No. 693 at P 595: “The Commission directs the ERO to address the minimum load and maximum time concerns of the Commission through the Reliability Standards development process.” Nick Henery (FERC Staff participating in SDT meetings) feels the SDT has adequately covered the Directives in our process.

RELIABILITY | ACCOUNTABILITY36 Attachment 1 – EOP and BAL-002 Current Status Industry Outreach - ongoing Posted in early July for first “formal” comment and balloting. Comments accepted through August 15 Ballot Pool Registration open through July 31 Balloting August 5 through August 15 (40% approval) Comment Review and further refinement of the Standard EOPDT meeting August 27 – 29.

RELIABILITY | ACCOUNTABILITY37 Viewing Webinars

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