1. RiversidePublicUtilities.com Arts & Innovation RiversidePublicUtilities.com MOD-032-1 GENERATOR TESTING REQUIREMENTS RESOURCE PLANNERS LeeAnne Uhler, Regulatory and Energy Risk Manager

2. RiversidePublicUtilities.com RIVERSIDE PUBLIC UTILITIES Registered as a Resource Planner and Distribution Provider Riverside interconnects with SCE Vista Substation at 69kV Load and generating facilities are not connected to the Bulk Electric System 2

3. RiversidePublicUtilities.com RIVERSIDE PUBLIC UTILITIES Local Generation – Four 48.5 MW LM6000 simple-cycle peaking units – Four 9 MW GE10 simple-cycle turbine generators – Single 28 MW LM2500 combined-cycle generator Peak Demand – 604.4 on 9/16/2014 3

4. RiversidePublicUtilities.com POLICIES AND PROCEDURES NERC Reliability Standards – MOD-032-1 – MOD-010-0 and MOD-012-0 CAISO/SCE Joint Transmission Planning Base Case Preparation Process (2015) WECC Generating Unit Model Validation Policy (2012) NERC Registration Criteria (2014) NERC Reliability Functional Model (2010) 4

5. RiversidePublicUtilities.com MOD-032-1 Requirement 1 effective 7/1/2015 – Applicable to Planning Coordinator and Transmission Planner Requirements 2, 3, 4 effective 7/1/2016 – R2, R3 applicable to Resource Planner 5

6. RiversidePublicUtilities.com MOD-032-1 R2 Each Balancing Authority, Generator Owner, Load Serving Entity, Resource Planner, Transmission Owner, and Transmission Service Provider shall provide steady-state, dynamics, and short circuit modeling data to its Transmission Planner(s) and Planning Coordinator(s) according to the data requirements and reporting procedures developed by its Planning Coordinator and Transmission Planner in Requirement R1. For data that has not changed since the last submission, a written confirmation that the data has not changed is sufficient. [Violation Risk Factor: Medium] [Time Horizon: Long-term Planning] 6

7. RiversidePublicUtilities.com MOD-032-1 R3 Upon receipt of written notification from its Planning Coordinator or Transmission Planner regarding technical concerns with the data submitted under Requirement R2, including the technical basis or reason for the technical concerns, each notified Balancing Authority, Generator Owner, Load Serving Entity, Resource Planner, Transmission Owner, or Transmission Service Provider shall respond to the notifying Planning Coordinator or Transmission Planner as follows: [Violation Risk Factor: Lower] [Time Horizon: Long-term Planning] 3.1. Provide either updated data or an explanation with a technical basis for maintaining the current data; 3.2. Provide the response within 90 calendar days of receipt, unless a longer time period is agreed upon by the notifying Planning Coordinator or Transmission Planner. 7

8. RiversidePublicUtilities.com CAISO/SCE JOINT TRANSMISSION PLANNING BASE CASE PREPARATION PROCESS (Joint Procedure) CAISO (PC, BA) and SCE developed the Joint Procedure to provide guidance to RP for providing steady-state, dynamics, and short circuit modeling data (R2) and notification process (R3) 8

9. RiversidePublicUtilities.com CAISO/SCE JOINT TRANSMISSION PLANNING BASE CASE PREPARATION PROCESS RPU’s data is modeled into WECC’s base cases WECC's base cases are computer models of projected or starting power system conditions for a specific point in time. These base cases include both steady state and dynamic data, and contain very large amounts of data necessary to model power system behavior.​​ 9

10. RiversidePublicUtilities.com WECC Generating Unit Model Validation (WECC Policy) MOD-010-0 and MOD-012-0 Applied to RPU as an owner of generation meeting the “Facilities Affected” section – Generating facilities =>10/20 MVA, and – Connected at or above 60kV 10

11. RiversidePublicUtilities.com WECC Generating Unit Model Validation (WECC Policy) MOD-010-0 and MOD-012-0 Requires generator testing every five years – $56,250 in 2014 for RERC 1 & 2 and Springs 1-4 – $65,000 in 2011 for RERC 3 & 4 and Clearwater – $59,900 in 2009 for RERC 1 & 2 and Springs 1-4 MOD-032-1 supersedes MOD-010 -012 11

12. RiversidePublicUtilities.com Generator Owner RPU is not a Generator Owner (GO) or Generator Operator (GOP) pursuant to the NERC Registration Criteria The Joint Procedure describes information to be submitted by “Generator Owners” – RPU interprets to mean NERC-registered GO WECC’s definition of GO ? – NERC Registration Criteria – NERC Functional Model 12

13. RiversidePublicUtilities.com Generator Owner 13

14. RiversidePublicUtilities.com Ambiguous Reporting Requirements Clarification of how “Generator Owner” is defined Clarification in the Joint Procedure regarding Resource Planners providing modeling data from non-BES generators – No technical changes – No relative system changes 14

15. RiversidePublicUtilities.com Recommendations Revise the WECC Generating Unit Model Validation Policy to define Generator Owner in accordance with the NERC Registration Criteria Revise the CAISO/SCE Joint Transmission Planning Base Case Preparation Process to exclude Resource Planners with non-BES generators from the five-year generator testing requirements 15

16. RiversidePublicUtilities.com Thank You LeeAnne Uhler City of Riverside Public Utilities (951) 826-2216 luhler@riversideca.gov 16