RSM REPORT to RSC March 4, 2009 Judith James Reliability Standards Manager

1. RSMREPORTtoRSCMarch 4, 2009Judith JamesReliability Standards Manager Meeting Title (optional) Date

2. Committee RoleinReviewingDraft Standards Meeting Title (optional)

3. Work Product of Standard Drafting Team • Draft standard consistent with SAR on which it was based. • Assessment of the impact of the SAR on neighboring regions. • Implementation plan. • Identification of any existing standard that will be deleted or otherwise impacted. • Technical reports/work papers that provide technical support for the draft standard under consideration. • The perceived reliability impact if the standard is improved. • Questions for a comment form.

4. Role of Standards Committee Reviewing Draft Standard • The Standards Committee shall review draft standards for such factors as: • Consistent with the SAR on which it was developed, • Completeness, • Sufficient detail, • Rational result, • Compatibility with existing standards, • Diligent effort by the team. • The Standards Committee may, at any time, exercise its authority over the Process by directing the SDT to post the standard for comment. • Under no circumstance will the Standards Committee change the substance of a draft standard.

5. Texas RE BOD Update Meeting Title (optional) Date

6. Texas RE BOD Update---SAR-001-Provision to Give ERCOT ISO ¼ Vote • SAR-001 Approved by ERCOT BOD Feb. 17. • Gives ERCOT ISO ¼ Vote in Regional Standards Processes (upon FERC approval). • BOD directed ERCOT ISO to file another SAR to request 1 whole segment vote. • The approved documents, along with NERC application, have been submitted and received by NERC (Feb. 20). • NERC has 30 days (until March 23) to accept the submittal package. • NERC is still contemplating whether a comment period is necessary on SAR-001.

7. LSE Joint Registration Update Meeting Title (optional)

8. LSE Joint Registration Update • The LSE Registration Working Group met on February 27 to negotiate the Joint Registration Organization (JRO) agreement for the NERC LSE Function in the ERCOT region. • The working group reviewed the Standards Applicability Matrix and based on discussion, made changes to the LSE applicability on certain standards

9. LSE Joint Registration Update • Texas RE directed interested parties to submit language they would like to be included in the JRO. • Texas RE will distribute the current version of the Standards Applicability Matrix. • The group suggested that the various functions (QSEs, TOs, DPs) meet to draft common language. • Interested parties will fill in the comments section of the matrix to provide language suggestions. • Responses are due back to Texas RE by Friday, March 13 • Texas RE will compile the responses into a draft JRO to be reviewed at the next meeting on Friday, March 27.

10. Texas RENew LocationWe have moved! 2700 Via Fortuna, Suite 225 Terrace II Austin, TX 78746 Meeting Title (optional) Date

11. Map of 2700 Via Fortuna, Suite 225, Austin, TX 78746

12. Drive from ERCOT Austin Office to TRE New Office

13. Driving Directions From ERCOT Austin to TRE • Directions from ERCOT to TRE: • 1:  Start out going NORTHEAST on METRO CENTER DR toward E RIVERSIDE DR.  0.3 mi • 2:  Turn LEFT onto E RIVERSIDE DR.  0.1 mi • 3:  Turn LEFT onto E BEN WHITE BLVD/TX-71 W/BEN WHITE BLVD E. Continue to follow TX-71 W.  6.6 mi • 4:  Keep RIGHT to take TX-360 LOOP N/S CAPITAL OF TEXAS HWY.  1.2 mi • 5:  Turn RIGHT onto S MO-PAC EXPY.  0.6 mi • 6:  Turn RIGHT onto VIA FORTUNA.  0.1 mi • 7:  End at 2700 Via Fortuna Austin, TX 78746-7911 • Office is on the right. • Estimated Time: 12 minutes Estimated Distance: 8.94 miles

14. Communications and Planning SubcommitteeofNERC Standards Committee Meeting Title (optional) Date

15. Old Members of this NERC Subcommittee • Tom Bradish, Reliant Energy Services • Michael Gildea, Constellation Generation Group • Ron Parsons, Alabama Power Company • Raj Rana*, American Electric Power • Doug Hohlbaugh, FirstEnergy • Pat Huntley, SERC Reliability Corp. • David Schiada, Southern California Edison * Chair

16. Additional New Members of NERC subcommittee • Chris Underwood, Burns & McDonnell • John Hagen, Pacific Gas and Electric Company • Judith A. James, Texas Regional Entity • Greg Lange, Public Utility District No. 2 of Grant County • Chris Scanlon, Exelon • Anne Brown, Florida Reliability Coordinating Council • Raymond Tran, Wood Group Contractual Solutions • Barry Lawson, National Rural Electric Cooperative Association • Farzaneh Tafreshi, ICF International

17. Purpose of this subcommittee • To foster communications with the electric utility industry, trade groups, and associations concerning reliability issues and concerns for input to the NERC Standards Work Plan. • First meeting tentatively planned for April 15, 2009 in Charlotte NC. Coincides with NERC Standards Committee meeting.

18. Top 10 QuestionsonRegional Reliability Standards DevelopmentJudith A. JamesManager, Reliability StandardsMarch 5, 2009 TAC

19. 10. Do you work in the compliance division of TRE? No, I do not.

20. 9. Will submitting a SAR subject me to “spot check”? • See question # 10. • I don’t work in the compliance division. • Submitting a SAR is not turning yourself in for non-compliance with a standard. • When you submit a Request to Authorize the development of a regional Standard (SAR), you are telling Texas RE and the ERCOT region that you see a reliability need for a regional standard that supports a particular national standard (unless it is for “matters not covered” in a national standard).

21. 8. What exactly are regional reliability standards? Four types of regional standards: • Regional Difference: something the region desires to do differently to meet the same reliability objective as the NERC standard and is more stringent than the NERC reliability standard. • Regional Variance: an alternative approach that a region uses to meet the same reliability objective as the NERC standard, necessitated by a physical difference. • Regional Implementation: implements a NERC standard with more detail specific to the region (sometimes called “fill-in-the-blank” and is NERC directed). • Regional Standard that covers matters not covered by an existing NERC standard: brand new reliability objective that NERC has not covered in any NERC standard.

22. 7. Are regional standards really necessary? • Ideally, no. • We have NERC continent-wide standards for reliability and consistency around the nation AND the region must comply with the continent-wide standard. • But, practically, yes. • Regional standards may be necessary in special circumstances to augment, implement, or vary from the national standard (See question 8), and the regional process should be used appropriately when these circumstances occur. • It is everyone’s responsibility in this region to be looking out for circumstances where a regional variance or standard may be appropriate and to submit a SAR.

23. 6. Do you work on national standards too? • Yes and no. • Not formally on any national drafting team, but I do sit in on some of them if they meet locally. • Inform the region of national drafting team openings. • Read and review NERC Projects of Standards Under Development---Currently 39 Projects for potential regional standard development. • Lead and guide Texas RE Reliability Standards Committee (RSC) on projects that have potential. • Attend NERC Standards Committee meetings. • New Member of NERC Communications and Planning Subcommittee.

24. 5. Why does the regional standards development process take so long? • ANSI-approved process intended to develop consensus and the process must meet many criteria with many steps: • SAR, public posting, review of comments, standard drafting team (SDT), drafting the standard (“soup to nuts” can take awhile), public posting of the draft standard, field testing, formal balloting, re-ballot, appeals mechanism, approval by BOD, NERC and FERC, implementation with more field testing. • NERC and other regions are taking anywhere from 18 months to 2 or more years to get through their same process for one standard. • It’s new. It takes awhile to get through something new. (We’ve made it through once with SAR-001.) • Lone Star Resistance. • I feel your pain, so please don’t shoot the RSM!

25. 4. How can I participate in the standards development processes? • Participate in the following Texas RE Activities: • Become member of Texas RE’s RBB, Vote on Regional Standards • Texas RE Reliability Standards Committee • Author and sponsor SARs • Texas RE Standards Drafting Teams • Comment on Texas RE Regional Standards • Attend Texas RE Workshops—Spring and Fall • Get on the Texas RE mailing lists at http://lists.ercot.com • TEXASRE_RSC, TEXASRE_UFLS, TEXASRE_INFO, LSERWG • Participate in the following NERC Activities: • Comment on NERC Standards • Register in the NERC RBB to Vote on NERC Standards • NERC Standard Drafting Teams • Author and sponsor SARs, Request Formal Interpretations • Field Tests for Standards • NERC Standards Workshops + Regional Reliability Standards WG • Get on the NERC mailing lists at http://listserv.nerc.com • sac_plus, rrswg_plus, nercnews

26. 3. Why do you send out so many notices and announcements? • The FERC, NERC, ANSI approved process requires it. • In addition, I do send out “reminders” that are not required, but I do this because the process is so new, and you may need reminding of something. • And occasionally I mistakenly spam you with the same announcement. Sorry. 

27. 2. Can you interpret a standard for me? • No, because currently we don’t have any approved regional standards to interpret. • No, because even if we did have approved regional standards, the IDT (Interpretation Drafting Team) would interpret the standard---not me. (But send the request to me.) • No, because NERC has their own process for interpreting the national NERC standards---fill out their form.

28. 1. Where’s the beef? • Draft of BAL-001-TRE-01. TRE’s first regional standard. • Applicable to BA, GO, GOP in this region. • Under SAR-003 link at http://trackstandard.texasre.org • Technical workshop and Web Ex planned to explain and answer questions on this draft regional standard. • About to be posted for public comment---watch for your announcement.

29. RSCTop 10NERCProjects

30. Top 10 Projects chosen by RSC

31. All Projects chosen by RSC

32. All Projects chosen by RSC (Cont’d)

33. Standard Drafting TeamMember RequirementsSuggested New Policies Meeting Title (optional) Date

34. SDT Participation in General • Anyone may participate by visiting and observing. • So perhaps some who think they want to be members should instead think about being just an observer---not a problem! • Formal membership in SDT should be reserved only for those who intend to work consistently, diligently, and professionally toward the development of the regional standard.

35. Need for policy on SDT membership and what it means • Issue in some TRE regional SDTs of absent SDT members----those members who do not attend SDT meetings either via web ex or in person multiple times in a row. • Puts a burden on those who do attend. • Messes up quorum. • Team then spends inordinate amount of time bringing that person up to date on all they have missed when they do show up eventually. • Need policy to adequately address how to deal with such non-participating members.

36. Suggested policies • Suggest “three strikes and you are out”. • Miss three consecutive meetings either web ex or in person, and you are off the team. • Eventually would become part of the SDT Procedures when they are ultimately modified. • Suggest also that no more than one person from a company be a team member. • Prevents false proxying. (Proxies not allowed on SDTs.) • Prevents quorum issues when both from same company miss meeting. • We need just one representative from a company, and it needs to be the subject matter expert who can contribute to the team’s efforts.