1. Standards Update WECC Board of Directors Technical Session December 5, 2007 Albuquerque, New Mexico Steve Rueckert Director of Standards

2. Standards Update How did we get where we are today? Energy Policy Act Mandatory Standards Some RMS Requirements were mandatory enforcement of existing NERC standards through the contractual RMS obligation Remainder were additional and/or more stringent WECC requirements Regional Standards Task Force (RSTF) formed to review remainder of RMS requirements Essential for reliability Well Defined

3. Standards Update How did we get where we are today? RSTF identified 8 RMS standards for translation to Regional Reliability Standards Went through the expedited WECC process Translated existing RMS requirements to a format acceptable to NERC and FERC WECC Board approved 8 Regional Reliability Standards for submittal to NERC and FERC

4. Standards Update How did we get where we are today? Tier One Standards conditionally approved by NERC and FERC Identified necessary changes for permanent replacements Remove RMS sanction table for enforcement Develop adequate measures for each requirement Add Violation Risk Factors Add Violation Severity Levels FERC expects WECC to complete replacement standards in about a year

5. Standards Update What happens if were not done in about a year? If we dont have replacement standards by June 2008, WECC will need to provide a full explanation why Possibly no serious consequences if: Solid reason is provided Plan for timely completion is provided Standards will not just go away Existing Tier One standards will stay in effect No changes to existing requirements FERC may allow WECC to continue enforcement via RMS sanction table – UNLIKELY? More likely that WECC will be ordered to use the NERC sanction table for enforcement FERC may impose high VRF and/or high/severe VSL

6. Standards Update What happens if were not done? WECC desires to have approved replacement standards ready for Board approval in April of 2008

7. Standards Update Status of Tier One Standards Development Where is each standard in the process Schedule for future actions Major comments received Drafting Team (DT) responses to comments Prediction on whether or not it is likely the standard will receive a positive vote by the OC

8. Standards Update FAC-501-WECC-1 Transmission Maintenance Currently posted for second review period Comment period closes December 10 DT plans to meet in the first 2 weeks of January to develop responses to comments received Post final FAC-501-WECC-1 in time for consideration at the March OC meeting No significant, show stopper type comments received Many comments indicated this should be an FAC (Facilities Design, Connections and Maintenance) standard rather than PRC (Protection and Control) since the standard deals with facilities and not protection and control DT renumbered the Standard – Requirements not changed

9. Standards Update FAC-501-WECC-1 Transmission Maintenance Suggestion that annual review was too often DT does not agree and left requirement for annual review oAnnual review does not require annual modification oRequires review for need to modify oRequires review for confirmation that plan is being followed Some comments indicate the need for more clarity DT implemented changes to the standard intended to add the required clarity Believe this standard will pass OC ballot

10. Standards Update IRO-006-WECC-1 Qualified Path Unscheduled Flow Relief Currently posted for second review period Comment period closes January 2 DT plans to meet during the first 2 weeks of January to develop responses to comments received Post final IRO-006-WECC-1 in time for consideration at the March OC meeting

11. Standards Update IRO-006-WECC-1 Qualified Path Unscheduled Flow Relief DT proposed to add the reliability coordinator as a responsible entity TOP experiencing congestion on a qualified path requests relief WebSAS tool would identify schedules to be cut RC requirement is to approve or deny request for congestion relief If the RC approves the congestion relief webSAS automatically issues Tag adjustments

12. Standards Update IRO-006-WECC-1 Qualified Path Unscheduled Flow Relief Comments indicate general support for RC involvement RC has wide area view RC should be the entity to approve or deny curtailments Initially there was pushback from the RCs DT meet with RC managers and addressed the RC concerns I believe this standard will pass OC balloting

13. Standards Update PRC-004-WECC-1 Protection System and Remedial Action Scheme Misoperation Currently posted for second review period Comment period closes January 2 DT plans to meet during the first 2 weeks of January to develop responses to comments received Post final PRC-004-WECC-1 in time for consideration at the March OC meeting

14. Standards Update PRC-004-WECC-1 Protection System and Remedial Action Scheme Misoperation No show stopper comments received Many comments seeking additional clarity DT made changes to add clarity Comment questioning need to review all operations Must review all operations to determine misoperations Comments seeking reductions in stringency of reporting or action periods DT did not modify existing requirements

15. Standards Update PRC-004-WECC-1 Protection System and Remedial Action Scheme Misoperation Comments continued Several comments questioning RC applicability RC removed from applicability Comments indicating reporting/documentation requirements were over burdensome DT did not make any changes Retained existing RMS reporting/documentation requirements I believe this standard would pass OC balloting

16. Standards Update TOP-007-WECC-1 OTC Violations Currently posted for second review period Comment period closes January 2 DT plans to meet during the first 2 weeks of January to develop responses to comments received Post final TOP-007-WECC-1 in time for consideration at the March OC meeting First draft contained 2 requirements R1 - Actual Flow cannot exceed System Operating Limit (SOL) R2 - Scheduled Flow cannot exceed SOL Comments received suggesting removal of requirement 2 DT revised requirement 2 to require that the schedule not exceed the SOL when the TOP implements its real time schedules for the next hour

17. Standards Update TOP-007-WECC-1 OTC Violations Comments to drop the 20 minute/30 minute limits for stability based SOL vs. thermally based SOL DT removed the 20 minute requirement Thirty minutes is now the requirement for all SOLs that are exceeded With these two changes, I believe this standard will pass OC ballot

18. Standards Update VAR-002-WECC-1 Automatic Voltage Regulators Currently posted for second review period Comment period closes January 2 DT plans to meet during the first 2 weeks of January to develop responses to comments received Post final VAR-002-WECC-1 in time for consideration at the March OC meeting No major concerns identified in first comment period Comments focused on clarifying which generators the standard applied to DT modified applicability section and Requirement 1 wording to add clarity The DT was trying not to duplicate any NERC requirements No major changes from original RMS requirements I believe this standard will pass OC ballot

19. Standards Update VAR-501-WECC-1 Power System Stabilizers Currently posted for second review period Comment period closes January 2 DT plans to meet during the first 2 weeks of January to develop responses to comments received Post final VAR-501-WECC-1 in time for consideration at the March OC meeting No major concerns identified in first comment period Comments focused on clarifying which generators the standard applied to DT modified applicability section and Requirement 1 wording to add clarity The DT was trying not to duplicate any NERC requirements No major changes from original RMS requirements I believe this standard will pass OC ballot

20. Standards Update BAL-002-WECC-1 Contingency Reserve Currently posted for second review period Comment period closes January 2 DT conference calls scheduled for: December 10 January 7 January 15 Standard with the most comments Record of comments received and the DT response is 38 pages long Some comments indicate support while other identify opposition

21. Standards Update Questions Steve Rueckert Director of Standards Western Electricity Coordinating Council 615 Arapeen Drive, Suite 210 Salt Lake City, Utah 84108-1262 801 582-0353