Steve Rueckert Director of Standards

1. Steve RueckertDirector of Standards Standards Update June 3, 2014 CUG Meeting/Salt Lake City, UT

2. Overview • WECC Regional Reliability Standards • Recent FERC Approval • Current Projects • NERC Physical Security Standard

3. Recent FERC ApprovalIRO-006-WECC-2 • FERC issued a Letter Order Approving IRO-006-WECC-2 on May 13, 2014 • Effective July 1, 2014 • No impact on BA or RC requirements • Updated to remove the reference to a specific WECC Unscheduled Flow Mitigation Plan and instead refer to the currently effective Plan regardless of which one it is

4. Current WECC Regional Standards Activities WECC-0101 - Generator Validation Policy Conversion • Proposal to lower the applicable facility thresholds for generator testing and validation identified in recently approved NERC MOD standards • Proposal to modify the periodicity • Would become a Regional Variance to the NERC Standards • Would reflect current WECC Policy

5. Current WECC Regional Standards Activities WECC-0105 – P81 Revisions • VAR-002-WECC-1 (AVR) • VAR-501-WECC-1 (PSS) • Proposing to delete R2 in both Standards and move it to the Measure for R1 • Ballot Pool Formation 5/28 – 6/19 • Ballot Window 6/25 – 7/18

6. Current WECC Regional Standards Activities WECC-0106 – Energy Product Codes • INT-018-WECC-RBP-1 • No changes to the Definitions of the Codes • No changes to the requirement to use the Codes • Formatting • Moved actual definitions to the WECC Glossary • Ballot Pool Formation 5/28 – 6/19 • Ballot Window 6/25 – 7/18

7. Current WECC Regional Standards Activities WECC-0107 – PSS Design and Performance • Originated from an RPIC assignment to review documents for appropriate categorization • WECC CWG identified several PSS documents that are related to reliability and should be considered for inclusion in regional reliability standards • The Drafting Team is still working on the first draft

8. NERC Physical Security StandardApplicability • Transmission Owner (TO) • All 500 kV Facilities • Transmission Facilities Operating between 200 KV and 499 kV if: • Substation is connected at 200 kV or higher to three or more other substations • a substation has an aggregate weighted value exceeding 3000 where: • 200 kV – 299 kV = 700 • 300 kV – 499 kV = 1300

9. NERC Physical Security StandardApplicability • Transmission Operator (TOP) if identified per Requirement R3 • Transmission Facilities at a single substation that are identified as critical to the derivation of Interconnection Reliability Operating Limits • Transmission Facilities identified as Critical to meeting Nuclear Plant Interface Requirements

10. NERC Physical Security StandardRequirement R1 • Each TO shall perform an initial risk assessment and subsequent assessments to identify stations or substations that if rendered inoperable could result in widespread instability, uncontrolled separation or cascading • The initial risk assessment must be completed on or before the effective date of the standard

11. NERC Physical Security StandardRequirement R2 • Each TO shall have an unaffiliated third party verify their risk assessment performed in R1 • Unaffiliated third party may be • PC, TP, RC • Entity with transmission planning or analysis experience • TO must modify its risk assessment findings or document the technical basis for not doing so • TO must implement procedures to protect sensitive or confidential information

12. NERC Physical Security StandardRequirement R3 • Each TO shall notify the TOP of any primary control centers that operationally control a Transmission station or Transmission substation verified according to Requirement R2 and is not under the operational control of the Transmission Owner

13. NERC Physical Security StandardRequirement R4 • Each TO or TOP notified by the TO per R3 shall conduct an evaluation of the potential threats and vulnerabilities of a physical attack to each of their respective stations or substations identified in R1 • Unique characteristics • Prior history • Intelligence or threat warnings

14. NERC Physical Security StandardRequirement R5 • Each TO or TOP required to conduct an evaluation per R4 shall develop and implement a documented physical security plan for their identified stations or substations • Standard identifies attributes that the physical security plans must have • Left intentionally vague to allow for all situations

15. NERC Physical Security StandardRequirement R6 • Each TO or TOP required develop and implement a documented physical security plan per R5 shall have an unaffiliated third party review the evaluation performed under R4 and the security plans developed under R5 • TO or TOP shall ensure the third party review is completed within 90 calendar days • TO or TOP must modify its evaluation or security plans or document the technical basis for not doing so

16. NERC Physical Security StandardImpact on the Western Interconnection • 84 WECC TOs will have to conduct an assessment (Requirements R1 and R2) on approximately 687 substations • 338 500 kV • 81 345 kV • 268 230 kV • Unknown without the assessments how many substations, if rendered inoperable, will result in widespread instability, uncontrolled separation or cascading

17. NERC Physical Security StandardWhere are we in the Process • NERC Board of Trustees Adopted the Standard on May 13 • NERC filed the Standard with FERC on May 23 • Reasonable expectation that FERC will act quickly

18. Questions?