1. WECC Reliability Management System Tagging Requirements Before the WECC MIS Meeting November 13, 2009 By David Lemmons

2. Background WECC RMS began in 1999 There are 6 Amendments in addition to the original document. The RMS is the first “Mandatory” Reliability Standards with Financial Penalty for failing to maintain compliance with Requirements. Amendment 4 dates August 1, 2003 deals with Tagging

3. Section M of RMS Section M deals with Tagging Requirements in the WECC. Three separate areas of Requirements –Submission of Tags by Load Serving Purchasing-Selling Entities –Load Control Area (LCA) (Tag Authority) –Intermediate Control Area, Generation Control Area, Transmission Provider, or Transmission Operator- (Tag Approval Entity (TAE))

4. Submission of Tags by Load Serving Purchasing-Selling Entities Non-compliance Event defined as Failure of the Load Control Area to deny the LSE’s transaction when: –the LSE failed to submit a tag when one was required by NERC or WECC; –the LSE failed to submit a tag when one is required by NERC or WECC in the prescribed timeframe; or –The LSE failed to submit a tag using the E-tag system

5. Current NERC Standard NERC Standard INT-003-2 Requirement R1 reads: –Each Receiving Balancing Authority shall confirm Interchange Schedules with the Sending Balancing Authority prior to implementation in the Balancing Authority’s ACE equation. NERC Standard INT-009-1 Requirement R1 reads: –The Balancing Authority shall provide evidence that Implemented Interchange matches Confirmed Interchange as submitted by the Interchange Authority. NERC Standards INT-007-1 Requirement R1

6. Load Control Area (LCA) Non-compliance events are defined as: –The LCA’s authority service has either not implemented E-tag or fails to maintain an availability in accordance with NERC Policy 3. (99.5% availability at the time) –The LCA set a composite status to IMPLEMENT for a transaction despite the denial by a Tag Approval Entity. –The LCA set a composite status to DEAD for a transaction that has been approved by all Tag Approval entities. –The LCA failed to implement a transaction that has an approved E-tag (approved by all Tag Approval entities). –The LCA implemented a transaction without having a tag, even though a tag was required.

7. Current NERC Standard NERC Standard INT-009-1Requirement R1reads: –The Balancing Authority shall implement Confirmed Interchange as received from the Interchange Authority. NERC Standard INT-009-1 Requirement R2 reads: –Evidence shall demonstrate that the Interchange was implemented in the Balancing Authority’s Area Control Error (ACE) equation, or the system that calculates the ACE equation.

8. Tag Approval Entity Non-compliance events are defined as: –The TAE’s approval service has not implemented or fails to maintain availability at least 99.5% of the time during the month. NERC Policy 3 requires that tag approval services maintain high availability (see Policy 3 Appendix 3A3). –The entity did not actively process (approve or deny) at least 75% of the tags received in a month.

9. Current NERC Standard NERC Standard INT-006-3 Requirement R1 reads: –Prior to the expiration of the reliability assessment period defined in the timing requirements tables in this standard, Column B, the Balancing Authority and Transmission Service Provider shall respond to each On-time Request for Interchange (RFI), and to each Emergency RFI and Reliability Adjustment RFI from an Interchange Authority to transition an Arranged Interchange to a Confirmed Interchange. NERC Standard INT-008-2/3 could also impact compliance.