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

2. 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

3. 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

4. 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

5. 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