RSC December 2013 Meeting Item 0.0

Northeast Power Coordinating Council, Inc. (NPCC) Antitrust Compliance Guidelines

It is NPCC’s policy and practice to obey the antitrust laws and to avoid all conduct that unreasonably restrains competition. The antitrust laws make it important that meeting participants avoid discussion of topics that could result in charges of anti-competitive behavior, including: restraint of trade and conspiracies to monopolize, unfair or deceptive business acts or practices, price discrimination, division of markets, allocation of production, imposition of boycotts, exclusive dealing arrangements, and any other activity that unreasonably restrains competition.

It is the responsibility of every NPCC participant and employee who may in any way affect NPCC’s compliance with the antitrust laws to carry out this commitment.

Participants in NPCC activities (including those participating in its committees, task forces and subgroups) should refrain from discussing the following throughout any meeting or during any breaks (including NPCC meetings, conference calls and informal discussions):

• Industry-related topics considered sensitive or market intelligence in nature that are outside of their committee’s scope or assignment, or the published agenda for the meeting;

• Their company’s prices for products or services, or prices charged by their competitors; • Costs, discounts, terms of sale, profit margins or anything else that might affect prices; • The resale prices their customers should charge for products they sell them; • Allocating markets, customers, territories or products with their competitors; • Limiting production; • Whether or not to deal with any company; and • Any competitively sensitive information concerning their company or a competitor.

Any decisions or actions by NPCC as a result of such meetings will only be taken in the interest of promoting and maintaining the reliability and adequacy of the bulk power system. Any NPCC meeting participant or employee who is uncertain about the legal ramifications of a particular course of conduct or who has doubts or concerns about whether NPCC’s antitrust compliance policy is implicated in any situation should call NPCC’s Secretary, Andrianne S. Payson at 212-335-4765.

** Item in Meeting Material Page 1 of 12 RSC Meeting Minutes

Note: For reference – Links to the Glossary of Terms Used in NERC Reliability Standards, updated September 10, 2013 and the NPCC Glossary of Terms, updated May 2012, are provided here.

MEETING MINUTES Attendees:

Name Organization Sector Day(s) Comment 1. Kal Ayoub FERC Guest 1 & 2 2. Howard Gugel NERC Guest 2 via phone 3. Guy Zito Northeast Power Coordinating Council 1 & 2 4. Lee Pedowicz Northeast Power Coordinating Council 1 & 2 5. Gerry Dunbar Northeast Power Coordinating Council 1 & 2 6. Damase Hebert Northeast Power Coordinating Council 1 & 2 7. Michael Lombardi Northeast Power Coordinating Council 1 & 2 8. Chris de Graffenried

Sector 3 Proxy for Peter Yost

Consolidated Edison Co. of NY, Inc. 1 / 3 1 & 2

9. Ben Wu Orange and Rockland Utilities 1 1 & 2 10. Brian Shanahan National Grid 1 1 & 2 via phone 11. Mark Kenny Northeast Utilities 1 1 & 2 via phone 12. Ayesha Sabouba Hydro One Networks Inc. 1 1 & 2 via phone 13. Sasa Maljukan Hydro One Networks Inc. 1 1 & 2 14. Si Truc Phan Hydro Québec TransÉnergie 2 1 & 2 15. Helen Lainis Independent Electricity System Operator 2 1 & 2 16. Kathleen Goodman ISO-NE 2 1 & 2 17. Greg Campoli New York Independent System Operator 2 1 & 2 18. Michael Jones National Grid 3 1 & 2 19. Mike Garton Dominion 4 1 & 2 via phone 20. David Ramkalawan Ontario Power Generation Incorporated 4 1 & 2 21. Herb Schrayshuen

Proxy for Silvia Parada Mitchell

Power Advisors, LLC – Proxy for NextEra Energy, LLC

4 1 & 2

22. Bruce Metruck New York Power Authority 5 1

NPCC REGIONAL STANDARDS COMMITTEE

AGENDA FOR MEETING #13-5 October 9, 2013, 10:00 a.m. - 5:00 p.m. ET October 10, 2013, 8:00 a.m. - 3:00 p.m. ET

Marriott Spring Hill Suites, 445 Rue Saint Jean Baptiste, Montreal, QC Attire: Business Casual

Dial-In: 1 888 413 2161 (new number for Montreal meeting) Guest Code 6452793#

Page 2 of 12

Name Organization Sector Day(s) Comment 23. Brian Robinson Utility Services 5 1 via phone 24. Don Nelson Massachusetts DPU Guest 1 & 2 via phone 25. Ron Falsetti AESI Guest 1 & 2 26. Joel Charlebois AESI Guest 1 & 2

Introductions and Chair’s Remarks - Guy Zito called the meeting to order at 10:00 AM on Wednesday October 9, 2013.

NPCC Antitrust Compliance Guidelines** - NPCC Antitrust Compliance Guidelines were read.

Agenda Items: 1.0 Review of Agenda - The review of the agenda resulted in the addition of a CIP item (i.e., “Functional Obligation of

TOP”) under Agenda Item 10.0, RSC Member Items of Interest.

2.0 RSC Meeting Minutes 2.1 Approval of Minutes: August 21 & 22, 2013 RSC Meeting #13-4**

- The August 2013 meeting minutes were reviewed. A motion was made and seconded (by Kathleen Goodman and Chris de Graffenried, respectively) to approve the minutes as written. The motion passed.

3.0 Drafting Team Members and Executive Tracking Summary 3.1 NPCC Members on NERC Drafting Teams**

- The spreadsheet of NPCC Members on NERC Drafting Teams was reviewed. The result of this review identified that the spreadsheet contained outdated information (e.g., retired personnel). It was noted that the source document for the spreadsheet is the NERC Drafting Team Roster. Michael Lombardi was directed to update the spreadsheet and to notify NERC of the changes that are required to the NERC Drafting Team Roster. [Action]

3.2 Executive Tracking Summary** - The NERC Executive Tracking Summary (ETS) spreadsheet was reviewed. Updates to the

spreadsheet, since the last RSC meeting were related to: • NERC Reliability Standards • NPCC Regional Reliability Standards • NPCC Directory tracking 3.3 PMOS Project Tracking Spreadsheet

- A link to the NERC PMOS Project Tracking Sheet (a project tool used by the NERC Standards Committee (SC) and its Project Management and Oversight Subcommittee (PMOS) to track the progress of NERC standards development projects) was included for information.

4.0 Open Action Items** - The Open Action Items from previous RSC meetings were reviewed and status updates

provided. • Item 4.3, “PRC-005 Guidance - Investigate maintenance cycles that are more stringent

than those in the standard”, was reported as completed. [Subsequent to the RSC

Page 3 of 12

meeting, Ron Falsetti provided some additional information. Ron pointed out that the Supplementary Reference and FAQ document includes a section titled “How do I achieve a “grace period” without being out of compliance?” The objective of this section is to create a time extension within your own PSMP to allow your more stringent schedule to have a “grace period” but remember you must complete your maintenance within the maximum intervals of standard.]

• Item 13.3-2, “Present proposed improvements to the NPCC ETS for consideration by the RSC”, was reported as completed. The proposed improvement was to reflect the FERC standard development life cycle on the NERC PMOS spreadsheet rather than expand the NPCC Executive Tracking Summary. Guy Zito will present the proposed change to PMOS. [Action]

• Item 13.4-1, “Incorporate the Ontario notification request into the process for filing completed directories”, was discussed and the remaining action items were determined to be:

o Gerry Dunbar to work with Helen Lainis to ensure distribution emails are up to date [Action]

o Gerry Dunbar to work with Guy Zito to establish a process to periodically validate the email list [Action]

• Items reported as completed since the last RSC meeting were: o Item 13.4-2, “Post the proposed revision of the RSPM for a 45-day comment

period” - Completed – RSPM posted for a 45-day comment period through 10/20/13 o Item 13.4-3, “Post clarification if the applicability of PRC-006-NPCC-1 is

dependent on generator underfrequency trip relay location” - Completed – clarification was reviewed with task force and posted o Item 13.4-4, “Provide feedback to the SCPS on the quality issues that are being

found in the standards recently posted for comment and/or ballot” - Completed – discussed at SCPS meeting held on 9/18/13

5.0 Items Requiring RSC Discussion / Approval 5.1 NPCC Directory Development and Revision Manual

- The Directory Development and Revision Manual was posted for comment through 9/29/13. A concern was raised that the proposed revision to the manual broadened the applicability of the Directories beyond the applicability specified in the NPCC Bylaws. Agreement was reached at the RSC meeting that the Directory Development and Revision Manual should be consistent with the NPCC Bylaws and that it is non-member entities with contractual obligations to abide by NPCC Criteria that may exist with the ISOs are outside the scope of NPCC. Gerry Dunbar and Mike Garton will bring to the December 2013 RSC Meeting a proposed revision to the Directory Development and Revision Manual that is consistent with the NPCC Bylaws. [Action]

5.2 NPCC Regional Standard Processes Manual (RSPM)** - As a result of the comments received during the comment period ending July 5, 2013, the

RSPM has been revised accordingly and re-posted for comment through October 20, 2013. Key changes in the currently proposed revision include:

o The reference to the NPCC Compliance Committee (CC) has been removed from the Section titled “Roles in the NPCC Regional Standard Process”

Page 4 of 12

o Renaming the process for “Interpretations” to “Clarifications” thereby distinguishing between the NERC process (Interpretations) and the NPCC process (Clarifications) for aiding stakeholders in understanding a requirement

o Added a new Section titled “Curtailment of Regional Standard Development” to facilitate terminating the standard development process after RSAR approval but prior to posting a regional standard for industry ballot

- Regarding the proposed change to “clarifications”, Guy Zito indicated that an interpretation policy for NERC standards is an ANSI requirement. Guy encouraged the RSC to closely review and comment on the proposed change for the NPCC Regional Standard Process

5.3 Standards Outreach - As discussed at previous RSC Meetings, the NPCC Standards Staff is looking at options in

developing a Standards Outreach Program, e.g., conduct targeted meetings at entity locations. NYPA conducts outreach meetings within its organization and welcomes NPCC participation in its meeting. Guy Zito welcomed the opportunity to work with NYPA and also asked that the other members provide input and opportunities for development of an outreach program. The NPCC outreach program development will be tracked as an ongoing RSC Open Item to promote additional discussion. [Action]

6.0 NERC Reliability Standards http://www.nerc.com/pa/Stand/Pages/Standards-Under-Development.aspx

6.1 Currently Posted Projects** - The currently posted continent-wide projects were discussed along with a review of the

comments forms and all comments received by NPCC to date. When available, the discussion of each of the posted projects was kicked-off by a NERC Standards Developer by calling into the RSC meeting. The NERC Standards Developer provided an overview of the project (e.g., its purpose, where it is in development process as well as the next steps) and answered questions from the RSC members prior to leaving the call. Following the discussion with a NERC Standards Developer, the RSC members discussed each project during the meeting and Lee Pedowicz added responses to the appropriate Comment Forms. Comments will be finalized and submitted to NERC.

- Project 2013-03: Geomagnetic Disturbance Mitigation o Mark Olson (NERC) called into the RSC and provided a brief overview of the

project timeline and was available to answer questions. Stage 1 standard will require applicable registered entities to develop and implement Operating Procedures that can mitigate the effects of GMD events. Stage 2 standard(s) will require applicable registered entities to conduct initial and on-going assessments of the potential impact of benchmark GMD events on their respective system as directed in order 779. Stage 1 timeline: EOP-010-1 ballot period 10/09/13 - 10/18/03 Targeted for adoption at the November BOT meeting

Stage 2 timeline: Target completion date is January 2015

o Question was asked, why does EOP-010-1, R1 included four time horizons? Mark indicated that the requirement is to “develop, maintain, and implement”

Page 5 of 12

which spans the four time horizons (i.e., Long-term Planning, Operations Planning, Same-day Operations, and Real-time Operations).

o A motion was made and seconded (by Helen Lainis and Kathleen Goodman, respectively) to support the ballot of EOP-010-1. The motion passed.

- Project 2010-17 Proposed Definition of Bulk Electric System (Phase 2) o A motion was made and seconded (by Kathleen Goodman and Chris de

Graffenried, respectively) to support the ballot of phase 2 Definition of BES. The motion passed. Both Hydro One Networks Inc. and Hydro Québec TransÉnergie abstained from the vote.

- Project 2010-01 Training o Jordan Mallory (NERC) called into the RSC and provided a brief overview of the

standards progress and was available to answer questions. A few key points identified by Jordan included: Revised 3.1 from “… comply with Requirement R3 within 6 months of

gaining that authority …” to “… comply with Requirement R3 within 12 months of gaining that authority …”

SDT intent is to preserve the authority and decision making role of the System Operators

NERC will conduct a workshop early next year to train on SAT (systematic approach to training)

o Valerie Agnew joined the call and indicated that although a PER-005-2 RSAW is needed, the completion date of the RSAW is unknown at this time.

o Guy Zito provided a clarification that was of concern to some members of the RSC regarding training for “newly identified IROLs”. The implementation plan identifies a 12 month period for implementing training for those entities that have a newly identified IROL and didn’t previously have any. The standard only requires IROL simulator based training and not “individual newly identified” specific training for these new IROLS if entities already have training in place.

o The ballot period for PER-005-2 closes on November 12, 2013. A motion was not made at this time to approve the proposed PER-005-2 thereby affording the RSC members additional time to review the current posting.

- Project 2010-03 Modeling Data (MOD B) o Steven Noess (NERC) called into the RSC and provided a brief overview of the

project and was available to answer questions. o A motion was made and seconded (by Si Truc Phan and Kathleen Goodman,

respectively) to support the ballot of the MOD B standards (MOD-032-1 and MOD-033-1). The motion passed. Both the Independent Electricity System Operator (IESO) and Utility Services abstained from the vote.

- Project 2012-05 ATC Revisions (MOD A) o Ryan A Stewart (NERC) called into the RSC and provided a brief overview of the

project and was available to answer questions. o The proposed standard contains an exemption for “Functional Entities operating

within the Electric Reliability Council of Texas (ERCOT).” Hydro Québec TransÉnergie expressed that there should be an exemption for HQ as well. Ryan

Page 6 of 12

indicated that MOD-001-2 is posted for comment through November 18, 2013 and asked that the comment be formally submitted to the drafting team.

o The ballot period for MOD-001-2 closes on November 18, 2013. A motion was not made at this time to approve the proposed MOD-001-2 thereby affording the RSC members additional time to review the current posting.

- Project 2008-12 Coordinate Interchange Standards o Cheryl Mendrala (ISO-NE) and Bob Coughlin (ISO-NE) called into the RSC and

provided a brief overview of the project and were available to answer questions. o Clarification provided that pseudo-tie are not required to be included if covered

by congestion management o A motion was made and seconded (by Kathleen Goodman and Helen Lainis,

respectively) to support the ballot of the Coordinate Interchange Standards. The motion passed. Hydro Québec TransÉnergie, New York Independent System Operator, Consolidated Edison Co. of NY, Inc. and the New York Power Authority all abstained from the vote.

- Project 2010-04 Demand Data (MOD C) o On day 1 of the October RSC meeting (10/9/13) it was noted that MOD-031-1 was

posted for a 45-day comment period closing on November 22, 2013 with an additional ballot being conducted the last ten days of the comment period. A motion was not made at this time to approve the proposed MOD-031-1 thereby affording the RSC members additional time to review the current posting.

- 2014-2016 Reliability Standards Development Plan o The 2014-2016 Reliability Standards Development Plan (RSDP) was posted for

comment from October 2 to October 9, 2013. The RSC discussed the RSDP posted for comment and determined that the NPCC RSC will not submit any comments.

6.2 Ballot History (Since last RSC Meeting)** 6.3 Comment Form History (Since last RSC Meeting)** 6.4 Project 2007-11 Disturbance Monitoring – Update

- Lee Pedowicz provided an update and overview of the DM standard development. Draft 2 of PRC-002-2 is expected to be posted for a 45 day comment period and 10 day ballot the end of November or beginning of December, 2013

6.5 Project 2007-02 Waiver** - Included in the meeting materials was the Notice of Request to Waive the Standard Process

for Project 2007-02 Operating Personnel Communications Protocols: COM-003-1. Specifically, NERC Staff and the Chair of the Standards Committee are requesting that the Standards Committee consider reducing the time for the next successive comment and ballot of a standard combining COM-002 and COM-003 from 45 calendar days to 15 calendar days (with the last 10 days for the ballot) and any final ballot from 10 calendar days to 5 calendar days.

- Howard Gugel (NERC) called into the RSC on day 2 (10/10/13) to further discuss Project 2007-02 Operating Personnel Communications Protocols. Howard reported:

o The Project 2007-02 Waiver is on the Standards Committee October 17, 2013 agenda for approval

Page 7 of 12

o The drafting team met on Wednesday October 9, 2013 and will meet again on Friday October 11, 2013 to work on the development of a single standard that combines COM-002 and COM-003

o The standard will be a “zero defect” standard for emergencies only. o It was not clear to the RSC that a waiver request is required to meet the deadline

imposed by the NERC Board of Trustees. 6.6 Project 2007-17.2 PRC-005-3**

- Included in the meeting materials are questions and concerns raised regarding the proposed revision to PRC-005-3 which adds the maintenance of Auto Reclosing systems. These issues were discussed at the RSC and it was determined that Guy Zito will follow up with NERC to seek resolution to the concerns. [Action]

7.0 NERC Drafting Team Nominations** http://www.nerc.com/pa/Stand/Pages/Drafting-Team-Vacancies.aspx

- There are currently no Drafting team vacancies nor are there any open Informal Development Team Solicitations.

7.1 Currently Posted Drafting Team Vacancies 7.2 Closed Drafting Team Nominations (Since last RSC Meeting) 7.3 Solicitation For Informal Development Teams

8.0 NPCC Regional Reliability Standards** https://www.npcc.org/Standards/default.aspx

8.1 Current Activities: Regional Standards - There are not any Regional Standards currently in active development 8.2 Current Activities: Regional Standard Interpretations

- Task Force on System Protection (TFSP) has reviewed the request for clarification by NAES regarding PRC-002-NPCC-1, Requirement R16.1. TFSP responded that it agrees that R16.1 is applicable to Digital Fault Recording (DFR) and Dynamic Disturbance Recording (DDR) data in regards to the COMTRADE data format. It would be sufficient to provide Sequence of Event (SOE) recording data in a commonly used format such as txt, csv, or xls Corporation-Kleen Energy Systems, LLC. A motion was made and seconded (by Chris de Graffenried and Helen Lainis, respectively) to authorize posting of the TFSP response on the NPCC web site. The motion passed.

- Lee Pedowicz announced that a new RFI was recently received from Dave Bertagnolli (ISO-NE). Lee will follow up with Dave to obtain additional information. [Action]

9.0 NPCC Non-Standards** https://www.npcc.org/Standards/SitePages/NonStandardsList.aspx

9.1 Directories In Development - Gerry Dunbar provided an update on Directory #1:

o CO7/CP11 has completed its collaborative review of the document addressing criteria issues as requested by the TFCP and the TFCO.

o CO7/CP11 will review the document appendices and expect to return the completed draft to the Task Forces for Open Process posting by the end of the year.

9.2 Directory Interpretations 9.3 Criteria (A) / Guides (B) / Procedures (C) Documents

Page 8 of 12

10.0 RSC Member Items of Interest 10.1 Cyber Security Standards Transition Guidance

- Guy Zito, as an informational item, indicated that NERC issued a revised Cyber Security Standards Transition Guidance to provide guidance to Regional Entities and Responsible Entities regarding the transition from CIP Version 3 to CIP Version 5.

10.2 CIP – Functional Obligation of TOP - An issue was raised regarding the use of the term, “Functional Obligation”. This term

appears in Version 4 and Version 5 of the CIP standards. NERC’s Reliability Functional Model Version 5 and associated Technical Document provide an overview of the responsibilities of each functional entity and their relationships to one another. Enforceable NERC Reliability Standards identify specific functional responsibilities/obligations of the functional entities in the form of mandatory Requirements. Functional Model tasks may be delegated, but not the Responsibility for those tasks. In reading the below “Extract from CIP-002-5” there seems to be some conflict which is creating potential confusion regarding the basic precepts of the Functional Model, i.e. performing an “obligation” as opposed to a task.

- For instance, entities registered as Transmission Operators (TOPs) have the obligation (responsibility) to operate or direct the operation of the transmission facilities, and maintains local-area reliability. TOPs may accomplish this responsibility by issuing Directives to the Transmission Owners (TOs) who physically operate specific BES assets such as a capacitor bank via their Control Center or control room’s Cyber Systems. The functional obligations or responsibility of a TOP cannot be transferred to another entity outside of a CFR or JRO agreement but functional “tasks” may be. The fact that a TO is complying with a TOP’s Directive by operating a BES asset, should not be viewed as performing the TOP’s functional obligations as defined above, but rather, as performing only a task. Therefore the TO’s Control Center or control room should not be classified as a high in the view of our members. Guy Zito will follow up with NERC to seek clarification. [Action]

10.3 New NERC Tool: US Enforcement Dates/Functional Applicability Excel Spreadsheet - Michael Lombardi, as an informational item, familiarized the RSC with the new NERC “US

Enforcement Dates/Functional Applicability Excel Spreadsheet.” The spreadsheet depicts, by requirement, the applicable functional entity and the associated dates listed below:

o Board Approval o Filing Date o Issue Date of FERC Order o Effective Date of FERC Order o Enforcement Date o Inactive Date

11.0 Standards Activity Post NERC BOT Approval** (Since last RSC Meeting)

- Damase Hebert reviewed the standards activities, post NERC BOT approval, which has transpired since the last RSC meeting.

- A NOPR, dated September 19, 2013, proposes to approve Reliability Standards MOD-025-2, MOD-026-1, MOD-027-1, PRC-019-1 and PRC-024-1 (Project 2007-09, Generator Verification). Comments are due to FERC no later than November 25, 2013. A question was raised regarding the impact of the continent-wide standards on NPCC Directories 9

Page 9 of 12

and 10. Specifically, “will the approval of the continent-wide standards result in the retirement of Directories 9 and 10?” Guy Zito and Gerry Dunbar will review the impact of approving the continent-wide standards on NPCC Directories 9 and 10. [Action]

11.1 NERC Filings to FERC http://www.nerc.com/FilingsOrders/Pages/default.aspx

11.2 FERC Orders / Rules http://www.nerc.com/FilingsOrders/Pages/default.aspx

11.3 Federal Register https://www.federalregister.gov/

12.0 NERC Meetings 12.1 Standards Committee (SC) and Standards Committee Executive Committee (SCEC)

http://www.nerc.com/comm/SC/Pages/default.aspx Since Last RSC Meeting 12.1.1 Conference Call: August 22, 2013, 1:00 to 5:00 p.m. ET, Dial-in Number:

1.866-740-1260, Code: 5247071 12.1.2 Meeting: September 19, 2013 – Denver (8 a.m. to 5 p.m.) 12.1.3 SCEC Conference Call: September 27, 2013, 10:00 – 11:00 a.m. ET,

Dial-in: 866-740-1260 | Access Code: 5247071 | Security Code: 092613 Upcoming 12.1.4 Conference Call: October 17, 2013 conference call from 1 to 5 p.m. ET,

Dial-in Number: 1.866-740-1260, Code: 5247071 12.1.5 Conference Call: November 14, 2013 conference call from 1 to 5 p.m. ET,

Dial-in Number: 1.866-740-1260, Code: 5247071 12.1.6 Meeting: December 11-12, 2013 – Atlanta (1 to 5 p.m. December 11; 8 a.m.

to noon December 12) 12.2 Standards Committee Process Subcommittee (SCPS)

http://www.nerc.com/comm/SC/Pages/Standards%20Committee%20Process%20Subcommittee%20SCPS/Standards-Committee-Process-Subcommittee-SCPS.aspx Since Last RSC Meeting 12.2.1 Meeting: August 29, 2013, 8:00 a.m. to 5:00 p.m. ET, Tampa, FL 12.2.2 Meeting: September 18, 2013, 9:00 a.m. to 5:00 p.m. MT, Denver, CO Upcoming 12.2.3 Meeting: November 7 & 8, 2013, noon to noon ET, Atlanta, GA 12.2.4 December 11, 2013, 8:00 a.m. to 5:00 p.m. ET, Atlanta, GA

12.3 Standards Committee Project Management and Oversight Subcommittee (PMOS) http://www.nerc.com/comm/SC/Pages/ProjectManagementandOversightSubcommittee(PMOS).aspx Since Last RSC Meeting 12.3.1 Meeting: September 18, 2013, 1:00 p.m. to 4:00 p.m. MT, Denver, CO 12.3.2 Conference Call: September 27, 2013, 2:00 p.m. to 3:00 p.m. ET, Dial-in:

Phone: 1-866-740-1260 | Meeting Code: 7686935 | Security Code: 092713

Page 10 of 12

Upcoming 12.3.3 Conference Call: October 28, 2013, 2:30 p.m. to 4:00 p.m. ET, Dial-in:

1.866.740.1260 | Access Code: 7686935 | Security Code: 072913 12.3.4 Conference Call: November 18, 2013, 2:30 p.m. to 4:00 p.m. ET, Dial-in:

1.866.740.1260 | Access Code: 7686935 | Security Code: 072913 12.3.5 Meeting: December 11, 2013, 1:00 to 4:00 p.m. ET, Atlanta, GA

12.4 Member Representatives Committee (MRC) Meeting http://www.nerc.com/gov/bot/MRC/Pages/AgendaHighlightsandMinutes2013.aspx Since Last RSC Meeting 12.4.1 There has not been a MRC meeting since the last RSC meeting Upcoming 12.4.2 Meeting: November 6 & 7, 2013, 1:00 to 5:00 p.m. ET, Atlanta, GA 12.4.3 Meeting: February 5 & 6, 2014 Phoenix, AZ 12.4.4 Meeting: May 7 & 8 2014 Philadelphia, PA or Baltimore, MD 12.4.5 Meeting: August 13 & 14, 2014 Vancouver, Canada 12.4.6 Meeting: November 12 & 13, 2014 Tampa or Jacksonville, FL 12.4.7 Meeting: February 11 & 12, 2015 San Francisco or San Diego, CA 12.4.8 Meeting: May 6 & 7, 2015 Washington, DC (DC/MD/VA area) 12.4.9 Meeting: August 12 & 13, 2015 Toronto, Canada 12.4.10 Meeting: November 4 & 5, 2015 Atlanta, GA

12.5 Board of Trustees (BOT) Meeting http://www.nerc.com/gov/bot/Pages/Agenda-Highlights-and-Minutes-.aspx Since Last RSC Meeting 12.5.1 There has not been a BOT meeting since the last RSC meeting Upcoming 12.5.2 Meeting: November 7, 2013, 8:00 a.m. to 1:00 p.m. ET, Atlanta, GA 12.5.3 Meeting: February 5 & 6, 2014 Phoenix, AZ 12.5.4 Meeting: May 6 & 7, 2014 Philadelphia, PA 12.5.5 Meeting: August 13 & 14, 2014 Vancouver, Canada 12.5.6 Meeting: November 12 & 13, 2014 Chicago/St. Louis 12.5.7 Meeting: February 11 & 12, 2015 San Francisco or San Diego, CA 12.5.8 Meeting: May 6 & 7, 2015 Washington, DC (DC/MD/VA area) 12.5.9 Meeting: August 12 & 13, 2015 Toronto, Canada 12.5.10 Meeting: November 4 & 5, 2015 Atlanta, GA

12.6 Reliability Issues Steering Committee (RISC) http://www.nerc.com/comm/RISC/Pages/AgendasHighlightsandMinutes.aspx Since Last RSC Meeting 12.6.1 Conference Call: August 28, 2013, 8:30 a.m. – 10:00 a.m. ET 12.6.2 Meeting: September 4, 2013 – In-Person Meeting, 10:00am – 3:00pm ET,

Atlanta – NERC Offices

Page 11 of 12

Upcoming 12.6.3 RISC 2013 Leadership Summit: October 24, 2013, 8:30am – 4:30pm ET –

Washington, DC 12.6.4 Meeting: October 25, 2013, 8:00am – 12:00pm ET – Washington, DC 12.6.5 Meeting: February 2014 (details TBD)

13.0 NERC Compliance Tools** (Since last RSC Meeting) - There has not been any new or revised NERC compliance tools published since the last RSC

meeting. 13.1 Compliance Application Notices (CANs)

http://www.nerc.com/pa/comp/Resources/Pages/Compliance-Application-Notices.aspx

13.2 Compliance Analysis Reports (CARs) http://www.nerc.com/pa/comp/Pages/Compliance-Analysis-Reports.aspx

13.3 Reliability Standard Audit Worksheets (RSAWs) http://www.nerc.com/pa/comp/Pages/Reliability-Standard-Audit-Worksheets-(RSAWs).aspx

14.0 NERC Items of Interest (Since last RSC Meeting) 14.1 Lessons Learned

http://www.nerc.com/pa/rrm/ea/Pages/Lessons-Learned.aspx 14.1.1 There have not been any NERC Lessons Learned released since the last

RSC meeting 14.2 Alerts

http://www.nerc.com/pa/rrm/bpsa/Pages/Alerts.aspx 14.2.1 Industry Advisory

“345kV Breaker Failures” distributed on August 27, 2013 [Public: No Restrictions]

- NERC has identified a potential trend of 345 kV SF6 puffer type breakers failing. High voltage circuit breaker failures are one of the leading contributors to severe disturbances on the Bulk Electric System (BES). Circuit breaker failures, in conjunction with another fault, may lead to more BES Facilities removed from service than required to clear the original fault. This poses a risk to the reliability of the BES. Attached is a Manufacturer’s Maintenance Advisory that was issued in 2010 by Hitachi HVB, Inc., (formerly HVB AE Power Systems, Inc.). The purpose of this Advisory is to alert the industry to this trend of breakers failing and to help inform the industry of the Manufacturer’s Maintenance Advisory.

- NERC has created an AC Substation Equipment Task Force (ACSETF) to review substation equipment failures, identify a cause of each failure and recommend actions to prevent recurrence. A final report is scheduled for June 2014. This task force activity has the potential to generate additional NERC alerts addressing substation equipment.

15.0 Other Items of Interest 15.1 NPCC 2013 Fall Compliance & Standards Workshop, Mystic, CT, November 20,

2013 9:00 a.m. through November 22, 2013 Noon ET

Page 12 of 12

15.2 NPCC General Meeting, Boston, MA, December 4, 2013, 1:00m p.m. to 5:00 p.m. ET

16.0 Future RSC Meetings and Conference Calls 16.1 RSC 2013/2014 Meeting Dates

Dec. 5-6, 2013 (General Meeting Dec. 4, 2013), Boston, Mass. Feb. 19-20, 2014, NextEra Energy Offices

- Guy Zito stated that he and Michael Lombardi will propose RSC 2014 meeting dates. The proposed dates will take into account the NPCC BOD meetings and a joint meeting with the NPCC CC in December. [Action]

16.2 RSC 2013 Conference Call Schedule all Calls are planned to start at 10:00 a.m. (call 719-785-1707, Guest Code 8287#)

October 25 November 8 November 22 December 20

- A motion was made and seconded (by Kathleen Goodman and Chris de Graffenried, respectively) to adjourn the meeting. The motion passed. The meeting adjourned at 11:00 AM on Thursday October 10, 2013.

Respectfully Submitted,

Guy V. Zito, Chair RSC Assistant Vice President-Standards Northeast Power Coordinating Council, Inc.

RSC December 2013 Meeting Item 3.1

Page 1 of 1

NPCC Representatives on NERC Standards Drafting Teams

Project No. Project Title DT Type NPCC Representatives Company Telephone E-mail Address

2006-06 Reliability Coordination Standard Earl Barber National Grid 315-428-5532 earl.barber@us.ngrid.com2007-03 Real Time Operations Standard2007-06 System Protection Coordination Standard David Cirka National Grid 781-907-3240 david.cirka@us.ngrid.com

Ken Stenroos Florida Power & LightVenkat Kolluri EntergyVladimir Stanisic Ontario Power GenerationLee Pedowicz NPCC 212-840-1070 lpedowicz@npcc.orgVladimir Stanisic AESI

2007-02 Operating Personnel Communications Protocols Standard Tom Irvine Hydro One Networks 705-792-3004 tom.irvine@hydroone.com2007-17** Protection System Maintenance & Testing Standard Bob Bentert Florida Power & Light2008-12 Coordinate Interchange Standard Cheryl Mendrala ISO-NE

Brian Evans-Mongeon Utility Services 802-552-4022 brian.evans-mongeon@utilitysvcs.comMichelle Draxton Constellation Energy Group 410-474-2993 Michelle.l.draxton@constellation.com

2010-01 Training (PER) Standard Mark Grear Constellation 410-470-4380 mark.grear@constellation.com2010-03 Modeling Data (MOD B) Standard2010-04 Demand Data (MOD C) Standard Andrey Oks NPCC2010-05.1 Protection Systems: Phase 1 (Misoperations) Standard Paul Difilippo Hydro One Networks 647-328-7068 paul.difilippo@hydroone.com2010-13.2** Phase 2 of Relay Loadability: Generation Standard Steven Hataway Florida Power & Light2010-14.1** Balancing Authority Reliability-Based Control, Phase 1: Reserves Standard Michael Potishnak Representing NPCC2010-14.2 Balancing Authority Reliability-Based Control, Phase 2 Standard Michael Potishnak Representing NPCC2010-02 FAC Five-Year Review Team Standard John Beck Con Edison2008-02 Undervoltage Load Shedding Standard Charles-Eric Langlois Hydro-Quebec TransEnergie

Jennifer Dering NYPA 914-287-3179 Jennifer.Dering@nypa.govBrian Evans-Mongeon Utility Services 802-552-4022 brian.evans-mongeon@utilitysvcs.comPhil Fedora NPCC 212-840-4909 pfedora@npcc.orgAjay Garg Hydro One Networks 416.345.5420 ajay.garg@HydroOne.comJennifer T. Sterling Exelon 630-437-2764 jennifer.sterling@exeloncorp.com

2012-05 ATC Revisions Standard2013-01 Cold Weather Preparedness Standard

Emanual Bernabeu DominionKenneth Fleischer NextEra EnergyLuis Marti Hydro One Networks

2013-04 Voltage and Reactive Control (VAR) Standard Sharma Kolluri Entergy

Source = NERC Standard Drafting Team Rosters - November 2013

Change Control: Changes Since September 2013:Projects Removed:

1. Project 2006-02 Assess Transmission Future Needs & Develop Transmission Plans2. Project 2007-12 Frequency Response3. Project 2007-07 Vegetation Management4. Project 2008-06 Cyber Security for Order 7065. Project 2009-22 Interpretation of COM-002-26. Project 2010-17 Definition of Bulk Electric System - Rules of Procedure7. Project 2013-02 Paragraph 818. CIP Interpretations

Projects Added:1. Project 2010-14.2 Balancing Authority Reliability-Based Control, Phase 22. Project 2010-02 FAC Five-Year Review Team3. Project 2008-02 Undervoltage Load Shedding

**Changes:1. Project 2010-14.1, Balancing Authority Reliability-Based Control, Phase 1: Reserves, Michael Potishnak changed to "Representing NPCC" and removed Guy Quintin2. Project 2007-17 Protection System Maintenance & Testing: Added Bob Bentert, Florida Power & Light3. Project 2010-13.2 Phase 2 of Relay Loadability - Generation: Removed Xiaodong Sun, Ontario Power Generation

2013-03

2007-11

Generator Verification Standard

2010-17

2009-01

2007-09

Disturbance Monitoring Standard

Definition of Bulk Electric System

Geomagnetic Disturbance Mitigation Standard

Standard

Disturbance and Sabotage Reporting Standard

RSC December 2013 Meeting Item 3.2

Page 1 of 11

Revised: 11/21/2013Tab Name Last Revised Summary of Changes

NERC RS Exec Tracking Summary 11/21/2013 - Project WECC-0068: FERC Approved 10/16/13- Project 2010-11, TPL Table 1 Order: FERC Approved 10/17/13- Project 2013-02, P81: FERC Approved 11/21/13- Project 2006-06: NOPR Issued 11/21/13- Project 2010-INT-01: NOPR Issued 11/21/13- Project 2007-03: NOPR Issued 11/21/13- Project 2013-03: NERC Petitioned for FERC Approval on 11/14/13- Project 2012-INT-04: CIP-007-3b / 4b NERC BOT Approved 11/7/13- Project 2007-17.2: PRC-005-3 NERC BOT Approved 11/7/13- Project 2010-17: BES Definition (Phase 2) NERC BOT Approved 11/21/13- Project 2012-INT-06: CIP-003-3a / 4a NERC BOT Approved 11/7/13- Project 2010-14.1: BAL-002-2 posted for comment / ballot thru 12/11/13- Project 2007-02: COM-002-4 posted for comment / ballot thru 11/4/13- Project 2007-06: PRC-027-1 posted for comment / ballot thru 12/18/13- Project 2007-11: PRC-002-2 posted for comment / ballot thru 12/16/13- Project 2008-12: INT Standards posted for comment / ballot thru 11/13/13- Project 2012-05: MOD A Standards posted for comment / ballot thru 11/18/13- Project 2010-03: MOD B Standards posted for comment / ballot thru 11/20/13- Project 2010-04: MOD C Standards posted for comment / ballot thru 11/22/13- Project 2013-04: VAR Standards posted for comment / ballot thru 11/25/13- Project 2009-03: EOP Five year review SAR posted for comment thru 12/5/13- Project 2014-01: Dispersed generation SAR posted for comment thru 12/19/13- Project 2010-13.2: PRC-23-3 NERC BOT Approved 11/7/13

NERC RSAWs 10/15/2013 - EOP-004-2 RSAW posted 10/15/13- MOD-028-2 RSAW posted 10/10/13- MOD-031-1 Draft RSAW posted with Draft Standard- NUC-001-2 RSAW posted 10/10/13- PER-005-1 RSAW posted 10/15/13- PRC-001-1 RSAW posted 10/10/13- PRC-023-2 RSAW posted 10/10/13- TPL-003-0b RSAW posted 10/10/13- TPL-004-0a RSAW posted 10/10/13- VAR-001-4 Draft RSAW posted with Draft Standard- VAR-002-2b RSAW posted 10/10/13- VAR-002-3 Draft RSAW posted with Draft Standard

NPCC RRS Tracking Summary 11/12/2013 - Regional Standard Processes Manual - Posted for ballot thru 12/12/13NPCC Doc Tracking Summary 7/16/2012 - B-01: Draft Revised NPCC Guide for the Application of Autorelosing to the Bulk Power System - Posted to Open Process

- A-07 (retired), Revise Critical Component Definition (Glossary of Terms) - retirement date corrected.

NPCC Directory Tracking Summary 8/15/2013 - Directory Development and Revision Manual - Posted for Comment thru 9/29/13NPCC Directory Interpretations 10/25/2013 - Directory #3 Interpretation on behalf of Hydro One Networks included

RSC December 2013 Meeting Item 3.2

Page 2 of 11

Revised: 11/21/2013Tab Name Last Revised Summary of Changes

Quarterly Filing to NSUARB 8/13/2013 Annotated worksheet to indicate that "Revisions to D#7 and D#12 approved by the Full Members on 7/9/2013. "

Prior RevisionTab Name Last Revised Summary of Changes

Page 3 of 11

Revised: 11/21/2013

Line No. Project No. / Title Associated Standard SAR Posted?Posted for Comment?

Posted For Ballot?

Industry Approved?

NERC BOT Approved?

Petitioned for FERC Approval? FERC Approved Comments Project Status

1 Project 2006-02 ― Assess Transmission and Future Needs TPL-001-2Yes 3rd (Thru

3/16/07)Yes 5th (Formal Thru 5/31/11)

Yes (Recirculation Thru 7/22/11) Yes (7/22/11) Yes (8/4/11) Yes (10/19/11)

***DATA REQUEST PUBLISHED - Comments due 8/30/12***

On April 19, 2012 FERC issued Order 762 remanding TPL-002-2b and FERC proposed to remand TPL-001-2. NERC has been directed to revise footnote 'b' in accordance with the directives of Order Nos. 762 and 693.

Pending Regulatory Approval

2 Project 2006-06 ― Reliability CoordinationIRO-002-3, IRO-005-4, IRO-014-2COM-001-2, COM-002-3, IRO-001-3 and IRO-014-2

Yes 3rd "Supp" (Thru 9/3/10)

Yes (Thru 7/6/12)COM-001-2COM-002-3IRO-001-3

Yes (Recirculation Thru 9/17/12)COM-001-2

(Approved 75.01%)Yes (Recirculation

Thru 7/6/12)COM-002-3IRO-001-3

COM-001-2Yes (9/17/12)COM-002-3IRO-001-3

Yes (7/6/12)IRO-002-3IRO-005-4IRO-014-2

Yes (7/25/11)

COM-001-2,COM-002-3

Yes (11/7/12)IRO-001-3

Yes (8/16/12)IRO-002-3IRO-005-4IRO-014-2

Yes (8/4/11)

IRO-001-3IRO-002-3IRO-005-4IRO-014-2

Yes (4/16/13)

FERC Issued NOPR11/21/13 - FERC issues a Notice of Proposed Rulemaking (NOPR) proposing to remand NERC’s proposed revisions to the Transmission Operations (TOP) [NERC Project 2007-03] and Interconnection Reliability Operations and Coordination (IRO) Reliability Standards [NERC Project 2006-06]. The NOPR also proposes to approve NERC’s proposed revision to Reliability Standard TOP-006-3 [NERC Project 2010-INT-01] Pending Regulatory Approval x

3 Project 2007-03 ― Real-time Operations TOP-001-2, TOP-002-3, TOP-003-2 and PRC-001-2 PER-001-2Yes 2nd (Thru

9/07/07) Yes (Thru 4/20/12)Yes (Successive

Thru 4/20/12) Update 5/6/12 Update 5/9/12 Yes (4/16/13)

FERC Issued NOPR11/21/13 - FERC issues a Notice of Proposed Rulemaking (NOPR) proposing to remand NERC’s proposed revisions to the Transmission Operations (TOP) [NERC Project 2007-03] and Interconnection Reliability Operations and Coordination (IRO) Reliability Standards [NERC Project 2006-06]. The NOPR also proposes to approve NERC’s proposed revision to Reliability Standard TOP-006-3 [NERC Project 2010-INT-01] Pending Regulatory Approval x

4 Project 2007-09 ― Generator VerificationMOD-024-2, MOD-025-2, MOD-026-1, MOD-027-1, PRC-019-1 and PRC-024-1

Yes 1st (Thru 5/21/07)

PRC-024-1Yes (Thru 1/11/13)

Recirculation Thru 3/27/13: PRC-024-1Recirculation Thru 12/21/12:MOD-025-2, MOD-026-1, MOD-027-1, PRC-019-1

Pending (Recirc Ballot 3/27/13)

Yes (Recirc Ballot 12/21/12)

MOD-025-1, MOD-026-1, MOD-027-1, and PRC-019-1 -

Yes 2/7/13 and PRC-024-1 - Yes

5/9/13 Yes (5/30/13) NOPR issued on 9/19/13. Comments due 11/25/13. Pending Regulatory Approval

5 Project 2007-12 ― Frequency Response BAL-003-1Yes 3rd (Thru

3/09/07)Yes 30 day Formal

(thru 11/5/12)Recirculation ballot

thru 12/21/12 Yes (12/21/12) Yes (2/7/13) Yes (3/29/13)

FERC NOPR Issued 7/18/2013 - proposes to approve proposed Reliability Standard BAL-003-1. The Commission also has concerns about certain provisions of the proposed Reliability Standard and, therefore, proposes that NERC submit a report and develop modifications to address the identified concerns. The Commission also proposes to approve four proposed new or revised definitions to the NERC Glossary, NERC’s implementation plan, most proposed violation risk factors and violation severity levels, and NERC’s proposed retirement of currently effective Reliability Standard BAL-003-0.1b. Pending Regulatory Approval

6 Project 2007-17 ― Protection System Maintenance & Testing RE-INITIATED PRC-005-2Yes 1st (Thru

9/28/11) Yes (Thru 8/27/12)Yes (Recirculation

Thru 10/24/12) Yes (10/24/12) Yes (11/7/12) Yes (2/26/13) Pending Regulatory Approval

7 Project 2008-06 ― Cyber Security ― Order 706 -- CIP Version 5 Standards CIP-002-5 thru CIP-009-5, CIP-010-1 and CIP-011-1 x Yes (Thru 11/5/12)Yes (Recirculation

Thru 11/5/12) Yes (11/5/12) Yes (11/26/12) Yes (1/31/13) Pending Regulatory Approval

8 Project 2008-10 ― Interpretation of CIP-006-1 R1.1 by Progress Energy CIP-006-3d / CIP-006-4d, R1.1 x Yes (thru 11/21/11)Yes (Recirculation

Thru 12/19/11) Yes 12/19/11 Yes (2/9/12) Yes (5/23/12)

3/21/13 FERC issues an order remanding NERC's proposed interpretation to CIP-006-4, Requirement R1.1. Docket No. RD12-3-000 Pending Regulatory Approval

9Project 2009-19 ― Interpretation of BAL-002-0 R4 and R5 by NWPP Reserve Sharing Group BAL-002-0 R4 and R5 x

Yes - Draft #2 (Thru 9/4/12)

Yes (Recirculation Thru 10/8/12) Yes (10/8/12) Yes (11/7/12) Yes (2/12/13) Pending Regulatory Approval

10 Project 2010-13.2 Phase 2 of Relay Loadability: Generation PRC-023-3, PRC-025-1 x

Yes (PRC-023-3 Thru 8/5/13)

Yes (PRC-025-1 Thru 7/19/13)

Yes (PRC-023-3 Final Thru 9/13/13)Yes (PRC-025-1

Final Thru 8/12/13)

Yes (PRC-023-3 on 9/13/13)

Yes (PRC-025-1 on 8/12/13)

Yes (PRC-023-3 on11/7/13)

Yes (PRC-025-1 on 8/15/13)

Yes (PRC-025-1 on 90/30/13) Pending Regulatory Approval x

11 Project 2010-INT-01 Interpretation of TOP-006-2 R1.2 and R3 for FMPP TOP-006-3, R1.2 and R3 NAYes - Draft #1 (Thru 7/30/12)

Yes - (Recirculation Thru 9/21/12)

Approved 87.5% 9/21/2012 Yes (11/7/12) Yes (4/5/13)

FERC Issued NOPR11/21/13 - FERC issues a Notice of Proposed Rulemaking (NOPR) proposing to remand NERC’s proposed revisions to the Transmission Operations (TOP) [NERC Project 2007-03] and Interconnection Reliability Operations and Coordination (IRO) Reliability Standards [NERC Project 2006-06]. The NOPR also proposes to approve NERC’s proposed revision to Reliability Standard TOP-006-3 [NERC Project 2010-INT-01] Pending Regulatory Approval x

12 Project 2010-INT-05 CIP-002-1 Requirement R3 for Duke Energy CIP-002-4a, R3 x Yes (Thru 3/23/12)Yes (Recirculation

Thru 4/30/12) Yes (4/30/12) Yes (5/9/12) Yes (8/1/12)

3/21/13 FERC issues an order in which it remands the proposed interpretation to Reliability Standard CIP-002-4, Requirement R3. Docket No. RD12-5-000 Pending Regulatory Approval

13 Project 2012-08.1 ― Phase 1 of Glossary Updates: Statutory Definitions NERC Glossary Of TermsFor Comment (Thru 8/2/12) Yes (Thru 3/22/13)

Yes (Recirculation Thru 4/29/13) Yes (4/29/13) Yes (5/9/13)

Yes (5/10/13)RD13-10-000

Add statutory definitions of Bulk Power System, Reliable Operation, and Reliability Standard to NERC Glossary

14 Project 2013-03 Geomagnetic Disturbance Mitigation EOP-010-1Yes (Thru 8/12/13)

Yes (Thru 10/18/13)

Yes (Final Thru 11/4/13) Yes (11/4/13)

Yes (EOP-010-1 on 11/7/13) Yes (11/14/13) Pending Regulatory Approval x

15 2012-INT-04 Interpretation of CIP-007 for ITC CIP-007-3 NA Yes (Thru 3/22/13)Yes Final (Thru

9/20/13) Yes (9/20/13)Yes (CIP-007-3b &

-4b on 11/7/13) Pending Regulatory Approval x

16Project 2007-17.2 Protection System Maintenance and Testing - Phase 2 (Reclosing Relays) PRC-005-3

Yes (Thru 5/6/13) Yes (Thru 8/23/13)

Yes (Final Thru 10/25/13) Yes (10/25/13)

Yes (PRC-005-3 on11/7/13) Pending Regulatory Approval x

17 Project 2009-22 ― Interpretation of COM-002-2 R2 by the IRC COM-002-2a x2nd (45 day Formal

thru 11/17/11)Yes (Recirculation

Thru 12/23/11) Yes (12/23/11) Yes (2/9/12)

Project 2009-22 (COM-002-2),which applies to real-time emergency communications, was approved by NERC BOT with an amendment that calls for the prioritization of a revised standard and a best practices memorandum shared with industry. Pending Regulatory Approval

18 Project 2010-09 ― Cyber Security Order 706B ― Nuclear Plant Implementation Plan Various CIP StandardsYes 1st (Thru

3/15/10)Yes 1st (Thru

3/15/10)Yes (Recirc Thru

7/2/10) Yes (7/2/10) Yes (8/5/10) Pending Regulatory Approval

19 Project 2010-17 ― Definition of Bulk Electric System - Phase 2 NERC Glossary Of Terms - Revise Definition of Bulk Electric SystemFor Comment (Thru 2/3/12)

Yes (Thru 10/28/13)

Yes (Final Thru 11/18/13) Yes (11/18/13) Yes (11/21/13) Pending Regulatory Approval x

20 Project 2012-INT-05 – Interpretation of CIP-002-3 for OGE CIP-002-3b NAYes (Thru 12/20/12)

Yes (Recirculation Thru 1/23/13) Yes (1/23/13) Yes (2/7/13) Pending Regulatory Approval

NERC Reliability Standards Executive Tracking Summary

Page 4 of 11

Revised: 11/21/2013

Line No. Project No. / Title Associated Standard SAR Posted?Posted for Comment?

Posted For Ballot?

Industry Approved?

NERC BOT Approved?

Petitioned for FERC Approval? FERC Approved Comments Project Status

NERC Reliability Standards Executive Tracking Summary

21 Project 2012-INT-06 CIP-003-3 for Consumers Energy CIP-003-3 NAYes (Formal Thru

3/22/13)Yes Final (Thru

9/20/13) Yes (9/20/13)Yes (CIP-003-3a &

-4a on 11/7/13) Pending Regulatory Approval x

22 Project 2009-20 ― Interpretation of BAL-003-0 R2 and R5 by Energy Mark, Inc. BAL-003-0.1b x xYes (Recirc Thru

2/26/10) Yes (2/26/10) Under Development

23Project 2010-14.1 ― Phase 1 of Balancing Authority Reliability-based Control: Reserves BAL-001, BAL-002, BAL-013 NA

Yes (Thru 4/25/13)Yes (BAL-002-2

12/11/13)

Yes (BAL-001-2 Final 7/25/13)

Yes (BAL-002-2 Additional 12/11/13)

Yes (BAL-001-2 on 7/25/13)

As of July 28, 2010 this project has merges Project 2007-18 - Reliability-based Controls and is now Project 2010-14 - Balancing Authority Reliability-based Control into a single project Under Development x

24 Project 2007-02 ― Operating Personnel Communications Protocols COM-003-1, COM-002-4Yes 2nd (Thru

5/2/07) Yes (Thru 11/4/13)Yes (Additional Thru

11/4/13)11/7/13 - NERC BOT approved Resolution - Operating Personnel Communication Protocols Under Development x

25 Project 2007-06 ― System Protection Coordination PRC-001-3, PRC-027-1Yes 1st (Thru

7/10/07)Yes (PRC-027-1 Thru 12/18/13)

Yes (PRC-027-1 Additional Thru

12/18/13) Under Development x

26 Project 2007-11 ― Disturbance Monitoring PRC-002-2Yes 1st (Thru

4/20/07)Yes (Thru 12/16/13) Yes (Thru 12/16/13)

Associated Cost Effective Analysis (Phase II of the Cost Effective Analysis Process) posted through December 2, 2013 Under Development x

27 Project 2008-12 ― Coordinate Interchange Standards INT-004-3, INT-006-4, INT-009-2, INT-010-2 and INT-011-1Yes 1st (Thru

7/31/08)Yes (Thru 11/13/13) Yes (Thru 11/13/13) Under Development x

28 Project 2010-01 ― Support Personnel Training (PER Informal Development Project) PER-002, PER-005-2Yes (Thru

9/3/13)Yes (Thru 11/12/13) Yes (Thru 11/12/13)

2/15/12 - FERC has granted NERC a two-year extension of time to and including September 30, 2014 to complete the Project pursuant to the Commission’s Order No. 742. [Docket No. RM09-25-000] Under Development

29 Project 2010-03 Modeling Data (MOD B)MOD-032-1 and MOD-033-1 (MOD-010, MOD-011, MOD-012, MOD-013, MOD-014, MOD-015) x

Yes (Thru 11/20/13) Yes (Thru 11/20/13) Under Development x

30 Project 2010-04 Demand Data (MOD C)MOD-031-1 (MOD-016, MOD-017, MOD-018, MOD-019, MOD-020, MOD-021) x

Yes (Thru 11/22/13) Yes (Thru 11/22/13) Under Development x

31 Project 2010-05.1 ― Protection Systems: Phase 1 (Misoperations) PRC-004-3Yes 1st (Informal

Thru 7/11/11)Yes (Draft #3 Thru

2/20/13)

Yes (Draft #3: Successive Thru

2/20/13) ".1" refers to Phase 1 of the Project

32Project 2010-14.1 ― Phase 1 of Balancing Authority Reliability-based Control: Reserves BAL-012 NA Yes (Thru 4/25/13) Yes (Thru 4/25/13)

As of July 28, 2010 this project has merges Project 2007-18 - Reliability-based Controls and is now Project 2010-14 - Balancing Authority Reliability-based Control into a single project This standard will not go forward

33 Project 2012-05 ATC Revisions Order 729 (MOD A) MOD-001, MOD-004, MOD-028, MOD-029, MOD-030Yes (Thru 8/26/13

Yes (Thru 11/18/13) Yes (Thru 11/18/13) Under Development x

34 Project 2013-04: Voltage and Reactive Control VAR-001-4, VAR-002-3Yes (Thru

9/3/13)Yes (Thru 11/25/13)

Yes (Additional Thru 11/25/13) x

35 Project 2009-02 ― Real-time Reliability Monitoring and Analysis Capabilities "New"Yes 2nd (Thru

2/18/10)Yes 1st (Informal

Thru 4/4/11) Concept White Paper posted for informal comment period Under Development

36 Project 2010-02 ― Connecting New Facilities to the GridFAC-001, FAC-002, FAC-003-3, FAC-008-3, FAC-010-2.1, FAC-011-2, FAC-013-2, FAC-014-2 x Yes (Thru 9/16/13)

Two projects (FAC Review, Project 2010-02) were consolidated and are being initiated as a 5-year review

37 Project 2010-16 ― Definition of System Operator NERC Glossary Of TermsYes 1st (Thru

12/3/10)Yes 1st (Thru

12/3/10) Under Consideration for Development

38 Project 2012-09 IRO Five-Year Review Various IRO standards x Yes (Thru 9/20/13) Five year review Under Development

39 Project 2012-13 NUC Review NUC-001Yes (Thru

9/9/13) Yes (Thru 9/9/13) Five year review

40Project 2008-01 ― Voltage and Reactive planning and control (Informal Development Project) VAR-001 and VAR-002

Yes 2nd (Thru 3/26/10) Under Development

41 Project 2008-02 ― Undervoltage Load Shedding PRC-010-0 and PRC-022-1Yes (Thru 10/9/13) Under Development

42Project 2009-03 ― Five-Year Review of Emergency Operations EOP-001, EOP-002, EOP-003, and IRO-001

EOP-001-2b, EOP-002-3, EOP-003-1, EOP-004-2 (P81, RBS), EOP-005-2 (P81, RBS), EOP-006-2 (RBS), EOP-008-1 (RBS), EOP-009-1, IRO-001-5

Yes (Thru 12/5/13)

Project initiated as a 5-year review to clarify scope, avoid potential concurrent revisions to EOP standards (Cold weather SAR) Under Development x

43 Project 2009-05 ― Resource Adequacy Assessments "New"Yes 2nd (Thru

3/30/06) Under Consideration for Development

44 Project 2009-07 ― Reliability of Protection Systems "New"Yes 1st (Thru

2/18/09) Pending prioritization - may be postponed Under Consideration for Development

45 Project 2010-08 ― Functional Model Glossary RevisionsYes 1st (Thru

2/22/10)June 2010 SC meeting - Project deferred until Higher Priority projects are completed Project Deferred

46 Project 2013-01 ― Cold Weather Preparedness "TBD"

Draft for Comment (Thru

10/24/12)

47 Project 2014-01 - Standards Applicability for Dispersed Generation ResourcesYes (Thru 12/19/13 x

48 2012-INT-07 - Interpretation of CIP-005 for AEPThis interpretation is being prepared for an initial 30-day formal comment period.

49 Project 2009-04 ― Phasor Measurement Units Project has not started50 Project 2010-06 ― Results-based Reliability Standards Results-based Reliability Standards Transistion Plan Transistion Plan posted 7/26/10

51Project 2010-14.2 Phase 2 of Balancing Authority Reliability-based Control; Time Error, AGC, and Inadvertent BAL-004, BAL-005-0.1b, BAL-006-2 Under Development

52 Project 2010-INT-03 Interpretation of TOP-002-2a R2, R8, and R19 for FMPP TOP-002-2a, R2, R8 and R19

Standards Committee curtailed work in April 2011 - revived in January 2012 to see if a Rapid Revision was feasible. Overtaken by filing of TOP standards.

53 Project 2012-01 Equipment Monitoring and Diagnostic Devices FUTURE54 Project 2012-02 Physical Protection FUTURE

55 Project 2012-08.2 ― Phase 2 of Glossary Updates NERC Glossary Of TermsModify existing definition of Transmission Operator and Generator Operator

56 Project 2012-INT-03 Interpretation of CIP-007 for TECOThis interpretation is on hold pending finalization of Project 2012-INT-04 (Interpretation of CIP-007 for ITC).

57 Project 2007-07 ― Vegetation Management FAC-003-2Yes 3rd (Thru

7/17/07)Yes 5th (Thru

2/28/11)

Yes 6th (Recirculation Thru

10/13/11) Yes (10/13/11) Yes (11/3/11) Yes (12/21/11) Yes (3/21/13)Posted in Federal Register on 3/28/13 - Standard Enforcement Date 7/1/2014 Completed

58 Project 2008-14 ― Cyber Security Violation Severity Levels CIP family of standardsYes 2nd (Thru

04/20/09)Yes 1st (Thru

04/20/09)Yes (Recirc Thru

7/16/09) Yes (7/16/09) Yes Yes (5/17/10) Yes (9/8/10) Completed

59 Project 2009-01 ― Disturbance and Sabotage Reporting EOP-004-2Yes 1st (Thru

5/21/09) Yes (Thru 9/27/12)Yes (Recirculation

Thru 11/5/12) Yes (11/5/12) Yes (11/7/12) Yes (12/31/12) Yes (6/20/13) EOP-004-2 will be enforceable on January 1, 2014 Completed

60 Project 2009-24 ― Interpretation of EOP-005-1 R7 by FMPA EOP-005-1, R7 x xYes 1st (Intitial Thru

1/15/10) N/A N/A N/A N/A

In March 2011, FERC approved EOP-005-2, which addressed the issue for which FMPA requested interpretation. The SC curtailed work on this interpretation in April 2011 and notified FMPA. Curtailed

61 Project 2009-26 ― Interpretation of CIP-004-1 by WECC CIP-004-3a, R2, R3 and R4 x Yes (Thru 3/23/12)Yes (Recirculation

Thru 4/30/12) Yes (4/30/12) Yes (5/9/12) Yes (8/1/12) Yes (12/12/12) Completed

62 Project 2010-07 ― Generator Requirements at the Transmission Interface FAC-001-1, FAC-003-3, PRC-004-2.1a, PRC-005-1.1bYes 1st (Thru

3/15/10)Yes (45 Day Formal

Thru 4/16/12)Yes (Recirculation

Thru 5/3/12)Yes (12/23/11 and

5/3/12)Yes (2/9/12 and

5/9/12) Yes (7/30/12) Yes (9/19/13)Posted in Federal Register on 9/24/13 - Final Rule effective date 11/25/13. Completed

63 Project 2010-11 ― TPL Table 1 Order TPL-001-4 (TPL-001-2a, TPL-001-3, TPL-002-1c)Yes 1st (Thru

5/26/10)Yes - Formal (Thru

1/11/13)Successive ballot

1/2/13 thru 1/11/13 No (1/11/13) Yes (2/7/13) Yes (2/28/13) Yes (10/17/13)Enforcement Date 1/1/15 (R1 & R7) and 1/1/16 (R2 - R6 & R8) Completed x

64 Project 2010-17 ― Definition of Bulk Electric System NERC Glossary Of TermsYes 1st (Thru

1/21/11)

- Yes 3rd (Definition Thru 10/10/11)- Yes 2nd (ROP & Tech Principles Thru 10/10/11)

Yes (Recirc Thru 11/21/11) Yes 11/21/11 Yes (1/18/12) Yes (1/25/12) Yes (12/20/12) Completed

Page 5 of 11

Revised: 11/21/2013

Line No. Project No. / Title Associated Standard SAR Posted?Posted for Comment?

Posted For Ballot?

Industry Approved?

NERC BOT Approved?

Petitioned for FERC Approval? FERC Approved Comments Project Status

NERC Reliability Standards Executive Tracking Summary

65 Project 2010-INT-02 Interpretation of TOP-003-1 R2 for FMPP TOP-003-1, R2 N/A N/A N/A N/A N/A N/A N/A

In May 2011,the SC directed that the requester be notified that a CAN was under development addressing the same issue, and asked the requester to determine whether further processing of the interpretation was necessary. In November 2011 the requester notified NERC staff that no further processing of the interpretation was needed. Completed

66 Project 2011-INT-01 Interpretation of MOD-028 for FPL MOD-028-2Yes 1st (Thru

11/16/11)Yes 1st (Thru

11/16/11)Yes (Recirculation

Thru 12/22/11) Yes (12/22/11) Yes (2/9/12) Yes (8/24/12) Yes (7/18/13)

- The standard shall become effective on the first day of the first calendar quarter after Commission approval. - Order effective 60 days after publication in the FEDERAL REGISTER Completed

67 Project 2011-INT-02 - Interpretation of VAR-002 for Constellation VAR-002-2b, R2 x Yes (Thru 6/27/12)Yes (Recirculation

Thru 7/27/12) Yes (7/27/12) Yes (8/16/12) Yes (11/21/12) Yes (4/17/13) "Rapid Revision" Completed

68 Project 2012-INT-02 - Interpretation of TPL-003-0a and TPL-004-0 for SPCS TPL-003-2b and TPL-004-2a NAYes - (Thru

12/5/12)Yes (Recirculation

Thru 1/31/13) Yes (1/31/13) Yes (2/7/13) Yes (4/12/13) Yes (6/20/13)TPL-003-0b and TPL-004-0a became enforceable on June 20, 2013 Completed

69 Project 2013-02 ― Paragraph 81

Retire:• BAL-005-0.2b, R2• CIP-003-3, -4, R1.2• CIP-003-3,-4, R3, R3.1, R3.2, R3.3• CIP-003-3, -4, R4.2• CIP-005-3a, -4a, R2.6• CIP-007-3, -4, R7.3• EOP-005-2 R3.1• FAC-002-1, R2• FAC-008-3 R4, R5• FAC-010-2.1, R5• FAC-011-2, R5• FAC-013-2, R3• INT-007-1, R1.2• IRO-016-1 R2• NUC-001-2, R9.1, 9.1.1, R9.1.2, R9.1.3, R9.1.4• PRC-010-0, R2• PRC-022-1, R2,• VAR-001-2, R5

Draft for Comment (Thru

9/4/12)Yes (Thru 12/10/12)

Yes (Initial Thru 12/10/12)

Recirc Ballot thru 1/17/13 Yes (12/10/12) Yes (2/7/2013) Yes (2/28/2013) Yes (11/21/13) Completed x

70 Project WECC-0068 BAL-004-WECC-02, BAL-001-1 x x x x Yes (12/19/12) Yes (8/20/13) Yes (10/16/13) Enforcement Date 4/1/14 Completed x

Acronyms;SAR- Standards Authorization RequestRS- Reliability StandardDT- Drafting TeamSC- NERC Standards CommitteeTBD- To Be DeterminedBOT- NERC Board of Trustee

Page 6 of 11

Revised: 10/15/2013 Further details regarding the individual documents may be found at:http://www.nerc.com/pa/comp/Pages/Reliability-Standard-Audit-Worksheets-(RSAWs).aspx

RSAW# Title Posted for Comment? Comments Posted? RSAW Issued? CommentsBAL-005-0.2b Automatic Generation Control x x 5/20/2013 Revised RSAWs PostedCIP-001-2a Sabotage Reporting x x 10/13/2012COM-002-2a Communication and Coordination x Yes (4/27/12) 11/14/2012COM-003-1 Operating Personnel Communications Protocols Yes (Thru 4/5/13)EOP-001-2.1b Emergency Operations Planning x x 8/9/2013 Revised RSAWs PostedEOP-002-3.1 Capacity and Energy Emergencies x x 5/20/2013 Revised RSAWs PostedEOP-003-2 Load Shedding Plans x x 10/13/2012EOP-004-2 Event Reporting N/A N/A 10/15/2013 New RSAW xEOP-005-2 System Restoration from Blackstart Resources x x 7/17/2013 Revised RSAWs PostedEOP-006-2 System Restoration Coordination x x 7/17/2013 Revised RSAWs PostedEOP-008-1 Loss of Control Center Functionality x x 6/28/2013 Revised RSAWs PostedFAC-008-3 Facility Ratings x x 11/20/2012

FAC-013-2Assessment of Transfer Capability for the Near-Term Transmission Planning Horizon x x 10/13/2012

IRO-005-3.1a Reliability Coordination - Current-Day Operations x x 5/20/2013 Revised RSAWs Posted

IRO-014-1Procedures, Processes, or Plans to Support Coordination Between Reliability Coordinators x x 10/13/2012

MOD-028-2 Area Interchange Methodology N/A N/A 10/10/2013 New RSAW xMOD-031-1 Demand and Energy Data Yes (Thru 11/22/13) Draft RSAW posted along with Draft Standard x

NUC-001-2 N/A N/A 10/10/2013Revised RSAWs Posted - changes were minor and document was not re-dated x

PER-001-0.2 Operating Personnel Responsibility and Authority x x 5/20/2013 Revised RSAWs PostedPER-003-1 Operating Personnel Credentials x x 1/23/2013PER-005-1 System Personnel Training N/A N/A 10/15/2013 Revised RSAWs Posted xPRC-001-1 System Protection Coordination N/A N/A 10/10/2013 Revised RSAWs Posted x

PRC-004-2aAnalysis and Mitigation of Transmission and Generation Protection System Misoperations x x 8/9/2013 Revised RSAWs Posted

PRC-005-1b Transmission and Generation Protection System Maintenance and Testing x x 4/2/2013PRC-006-1 Automatic Underfrequency Load Shedding x x 6/28/2013 Revised RSAWs PostedPRC-023-2 Transmission Relay Loadability N/A N/A 10/10/2013 Revised RSAWs Posted xPRC-025-1 Generator Relay Loadability Yes (Thru 3/11/13)TOP-001-1a Reliability Responsibilities and Authorities x x 5/20/2013 Revised RSAWs PostedTOP-002-2.1b Normal Operations Planning x x 5/20/2013 Revised RSAWs Posted

TPL-002-0bSystem Performance Following Loss of a Single Bulk Electric System Element (Category B) x x 5/20/2013 Revised RSAWs Posted

TPL-003-0bSystem Performance Following Loss of Two or More Bulk Electric System Elements (Category C) N/A N/A 10/10/2013 Revised RSAWs Posted x

TPL-004-0aSystem Performance Following Extreme Events Resulting in the Loss of Two or More Bulk Electric System Elements (Category D) N/A N/A 10/10/2013 Revised RSAWs Posted x

VAR-001-4 Voltage and Reactive Control Yes (Thru 11/25/13) Draft RSAW posted along with Draft Standard xVAR-002-2b Generator Operation for Maintaining Network Voltage Schedules N/A N/A 10/10/2013 Revised RSAWs Posted xVAR-002-3 Generator Operation for Maintaining Network Voltage Schedules Yes (Thru 11/25/13) Draft RSAW posted along with Draft Standard x

NERC Reliability Standard Audit Worksheet (RSAW) Executive Tracking Summary

Page 7 of 11

Revised: 11/12/2013 Further details regarding the individual documents may be found at: http://www.npcc.org/regStandards/UnderDev.aspx

Line No. Regional Standard ID Regional Reliability Standard TitleRSAR

Posted?Posted for Comment?

Posted For Ballot?

Industry Approved?

NPCC BOD Approved?

NERC BOT Approved?

Petitioned for FERC Approval? FERC Approved Comments Project Status

1 BPS-501-NPCC-01 Classification of Bulk Power System Elements (Withdrawn by RSC 8/07/09)Yes (Thru

2/4/08) NA NA NA NA NA NA NA Withdrawn by RSC 8/07/09 Withdrawn

2 PRC-002-NPCC-01 Disturbance MonitoringYes (Thru 9/10/08)

Yes (Thru 10/24/09) Yes (Thru 1/6/10) Yes (1/6/10) Yes (1/9/10) Yes (11/4/10) Yes (5/31/11) Yes (10/20/11) 10/24/11 - Approved Standard posted publicly Completed

3 PRC-006-NPCC-01 Automatic Underfrequency Load Shedding ProgramYes (Thru 8/25/08) Yes (Thru 11/2/11)

Yes (Pre-ballotThru 11/2/11) Yes (11/18/11) Yes (11/30/11) Yes (2/9/12) Yes (5/4/12) Yes (2/21/13) Completed

4 PRC-006-NPCC-02

- Regional Standard Authorization Request (RSAR) has been submitted and approved- Drafting Team Nomination period ended March 25, 2013- Draft Team kick-off conference call was Monday April 8, 2013 Under Development

5 PRC-002-NPCC-01, Interpretation R1.1 x x xYes (TFSP 10/19/12) N/A N/A N/A N/A

Posted on the NPCC website under "Regional Standards General" on 6/24/13 Completed

6PRC-002-NPCC-01, Interpretation R1.2.2 x x x

Yes (TFSP 4/8/13) N/A N/A N/A N/A

Posted on the NPCC website under "Regional Standards General" on 6/24/13 Completed

7PRC-002-NPCC-01, Interpretation R4, R5, and R6 x x x

Yes (TFSP 5/16/13) N/A N/A N/A N/A

Posted on the NPCC website under "Regional Standards General" on 6/24/13 Completed

8 BAL-002-NPCC-01 Regional Reserve SharingYes (Thru 11/2/10)

Yes (Thru 12/16/11) Yes (Thru 1/6/10) Nomination Form posted - nominations due by 11/10/11 Under Development

9 PRC-012-NPCC-01 Special Protection SystemsYes (thru 8/18/08) On Hold

10 Regional Standard Processes Manual Regional Standard Process Manual (RSPM) N/AYes (Thru 10/20/13) Yes (Thru 12/12/13) x

Acronyms;RSAR- Regional Standards Authorization RequestRRS- Regional Reliability StandardDT- Drafting TeamSC - NERC Standards CommitteeTBD- To Be DeterminedBOD- NPCC Board of DirectorsBOT- NERC Board of Trustee

NPCC Regional Reliability Standards Executive Tracking Summary

Page 8 of 11

Revised: 7/16/2012 Further details regarding the individual documents may be found at: https://www.npcc.org/Standards/SitePages/NonStandardsList.aspx

Line No. Type Document DescriptionEffective

Date Comments Status1 Criteria A-01 Criteria for Review and Approval of Documents2 Criteria A-10 Classification of BPS Elements3 Criteria A-15 Disturbance Monitoring Equipment Criteria 4 Guideline B-01 NPCC Guide for the Application of Autoreclosing to the Bulk Power System5 Guideline B-12 Guidelines for On-Line Computer System Performance During Disturbances6 Guideline B-25 Guide to Time Suynchronization7 Guideline B-26 Guide for Application of Disturbance Recording Equipement 8 Guideline B-27 Regional Critical Asset Identification Methodology9 Guideline B-28 Guide for Generator Sequence of Events Monitoring

10 Procedure C-00 Listing of NPCC Documents by Type

11 Procedure C-01NPCC Emergency Preparedness Conference Call Procedures - NPCC Security Conference Call Procedures

12 Procedure C-05 Monitoring Procedures for Emergency Operation Criteria13 Procedure C-07 Monitoring Procedures for the Guide for Rating Generating Capability

14 Procedure C-15 Procedures for Solar Magnetic Disturbances Which Affect Electric Power Systems15 Procedure C-17 Procedures for Monitoring and Reporting Critical Operating Tool Failures

16 Procedure C-21Monitoring Procedures for Conformance with Normal and Emergency Transfer Limits

17 Procedure C-25 Procedure to Collect Power System Event Data18 Procedure C-29 Procedures for System Modeling:Data Requirements and Facility Ratings

19 Procedure C-30Procedure for Task Force on System Protection Review of Disturbances and Protection Misoperations

20 Procedure C-33 Procedure for Analysis and Classification of Dynamic Control Systems21 Procedure C-36 Procedures for Communications During Emergencies22 Procedure C-39 Procedure to Collect Major Disturbance Event Data23 Procedure C-42 Procedure for Reporting and Reviewing System Disturbances24 Procedure C-43 NPCC Operational Review for the Integration of New facilities25 Procedure C-44 NPCC Regional Methodology and Procedures for Forecasting TTC and ATC26 Procedure C-45 Procedure for Analysis and Reporting of Protection System Misoperations

27 ProcedureCost Effectiveness Analysis Procedure - CEAP

28 Glossary NPCC Glossary of Terms

Acronyms;

NPCC Document Open Process Executive Tracking Summary

Page 9 of 11

Revised: 8/15/2013 Further details regarding the individual documents may be found at: https://www.npcc.org/Standards/SitePages/NonStandardsList.aspx

Line No. DocumentDeveloped

From Title of Directory PhaseTask Force

ReviewPosted Open

Process?RCC

Approval?

Full Membership

Ballot? Comments Status

1 Directory #1 Criteria A-2 Design and Operation of the Bulk Power SystemTFCP(CP11) and TFCO

(CO7)CP11 and CO7 Collaborative review of the Directory #1 Planning and Operating Criteria.

2 Directory #2 Criteria A-3 Emergency Operations TFCO Phase 2 reformatting pending TFCO resources.

3 Directory #3 Criteria A-4 Maintenance Criteria for Bulk Power System Protection TFSPTFSP to identify differences/gaps between Directory #3 and draft revised PRC-005 and evaluate impact of retiring Directory #3 – pending FERC approval of PRC -005-2

4 Directory #4 Criteria A-5 Bulk Power System Protection Criteria TFSP Open Process posting expected in 2013. TFSP currently reviewing D#4.

5 Directory #5 Criteria A-6 Reserve TFCO Revisions to Version 0 of Directory #5 approved by the NPCC Full Members in October 2012.

6 Directory #6 Regional Reserve Sharing 1/2/1900 Passed 04/09/2012

Directory #6 approved by the NPCC Full Members in Phase 2 format in April 2012.

7 Directory #7 Criteria A-11 Special Protection Systems TFSP Passed 7/9/2013 TFSP Revisions.

8 Directory #8 Criteria A-12 System Restoration TFCO TFCO working group CO11 reviewing initial Phase 2 draft of Directory #8.

9 Directory #9 Criteria A-13 Verification of Generator Gross and Net Real Power Capability 1/2/1900 TFCO Passed 12/28/11 Directory#9 Phase 2 reformatting complete December 2011.

10 Directory #10 Criteria A-14 Verification of Generator Gross and Net Reactive Power Capability 1/2/1900 TFCO Passed 12/28/11 Directory#10 Phase 2 reformatting complete December 2011.

11 Directory #11

12 Directory #12 Under frequency Load Shedding Program Requirements TFSS Passed 7/9/2013 TFSS Revisions Directory#12 will be retired once PRC-006-NPCC-1 is fully implemented.

13 Manual Directory Development and Revision Manual Yes (Posted thru 9/29/13) Open Process x

NPCC Directory Executive Tracking Summary

Page 10 of 11

Revised: 10/25/2013 Further details regarding the individual documents may be found at: https://www.npcc.org/Standards/Directory%20Interpretations/Forms/Public%20List.aspx

Line No. Document Title of Directory Date FinalTask Force

ReviewPosted Open

Process?RCC

Approval?

Full Membership

Ballot? Comments Status

1 Directory #8 Interpretation System Restoration 6/18/2012 TFCO N/A N/A Interpretation on behalf of the NYSRC Complete

2 Directory#3 Interpretation Maintenance Criteria for Bulk Power System Protection 8/28/2012 TFSP N/A N/A Interpretation on behalf of Bangor Hydro Complete

3 Directory #3 Interpretation Maintenance Criteria for Bulk Power System Protection 12/14/2012 TFSP N/A N/A Interpretation on behalf of Acumen

Engineered Solutions Complete

4 Directory #3 Interpretation Maintenance Criteria for Bulk Power System Protection 12/14/2012 TFSP N/A N/A Interpretation on behalf of Con Ed Complete

5 Directory#3 Interpretation Maintenance Criteria for Bulk Power System Protection TFSP N/A N/A Interpretation on behalf of IESO Pending TFSP Review

6 Directory#3 Interpretation Maintenance Criteria for Bulk Power System Protection TFSP N/A N/A Interpretation on behalf of Hydro One

Networks x

NPCC Directory Interpretations

Page 11 of 11

Revised: 8/13/2013

Line No. Filing Period Filing Due Filing Submitted Comments

1 October 1 to December 31, 2012 3/1/2013 3/1/2013This filing is NPCC’s initial quarterly filing covering the October 1 to December 31, 2012 period and covers the changes to the NPCC Criteria as a result of voting by the Full Members of NPCC.

2 January 1 to March 31, 2013 6/1/2013 N/A No changes were made during the refeenced period which required filing.3 April 1 to June 30, 2013 9/1/2013 No changes were made during the refeenced period which required filing.4 July 1 to September 30, 2013 12/1/2013 Revisions to D#7 and D#12 approved by the Full Members on 7/9/2013. 5 October 1 to December 31, 2013 3/1/2014

Quarterly Application to the Nova Scotia Utility and Review Board (NSUARB) for Approval of NPCC Regional Reliability Criteria

RSC December 2013 Meeting Item 4.0 RSC Meeting #13-6, Agenda Item 4.0 Open Action Items

Page 1 of 3

Item Description Owner Due Status 4.1 Coordination with the

Compliance Committee to develop Joint Activity Action List

Greg Campoli

RSC Meeting Ongoing

4.2 New York Adoption of More Stringent/Specific NPCC Criteria - determine more stringent criteria and submit filing

Michael Lombardi and Gerry Dunbar

12/31/13 Ongoing

4.3 PRC-005 Guidance - Investigate maintenance cycles that are more stringent than those in the standard

Ron Falsetti 10/9/13 Completed – Ron pointed out that the Supplementary Reference and FAQ document includes a section titled “How do I achieve a “grace period” without being out of compliance?”

13-3-2 Kathleen Goodman agreed to identify and present proposed improvements to the NPCC ETS for consideration by the RSC.

Kathleen Goodman

Completed – proposed improvement was to reflect the FERC standard development life cycle on the NERC PMOS spreadsheet rather than expand the NPCC Executive Tracking Summary – see Item 13-5.2

13-3.8 NPCC Standards Staff to develop outreach proposal.

NPCC Standards Staff

Completed – closed to Item 13-5.6

13-4.1 NPCC to notify Ontario of any new or revised NPCC criteria when approved by the NPCC BOT. Incorporate this request into the process for filing completed directories.

Gerry Dunbar

Completed

13-5.1 Update the spreadsheet of NPCC Members on NERC Drafting Teams and to notify NERC of the changes that are required to the NERC Drafting Team Roster

M. Lombardi Completed

RSC December 2013 Meeting Item 4.0 RSC Meeting #13-6, Agenda Item 4.0 Open Action Items

Page 2 of 3

Item Description Owner Due Status 13-5.2 Present to PMOS a proposed

improvement to reflect the FERC standard development life cycle on the NERC PMOS spreadsheet

G. Zito New

13-5.3 Ensure the distribution email addresses for the Ontario notification of completed Directories are up to date

G. Dunbar H. Lainis

Completed - distribution email addresses were validated

13-5.4 Establish a process to periodically validate the distribution email list addresses for the Ontario notification

G. Zito G. Dunbar

Completed

13-5.5 Proposed revision to the Directory Development and Revision Manual that is consistent with the NPCC Bylaws (i.e., non-member entities with contractual obligations to abide by NPCC Criteria that may exist with the ISOs are outside the scope of NPCC)

G. Dunbar M. Garton

12/5/13 Completed – comments incorporated

13-5.6 NPCC outreach program development – discussion item: members provide input and opportunities for development of an outreach program

RSC Ongoing New

13-5.7 Seek resolution with NERC regarding the concerns with the proposed revision to PRC-005-3 which adds the maintenance of Auto Reclosing systems

G. Zito New

13-5.8 A new RFI was recently received from Dave Bertagnolli (ISO-NE). Lee will follow up with Dave to obtain additional information

L. Pedowicz Withdrawn by requestor

13-5.9 An issue was raised regarding the use of the term, “Functional Obligation”. This term appears in Version 4 and Version 5 of the CIP standards. Follow up with NERC to seek clarification

G. Zito New

RSC December 2013 Meeting Item 4.0 RSC Meeting #13-6, Agenda Item 4.0 Open Action Items

Page 3 of 3

Item Description Owner Due Status 13-5.10 Review the impact of approving

the continent-wide standards on NPCC Directories 9 and 10

G. Zito G. Dunbar

Completed

13-5.11 Propose 2014 RSC meeting dates G. Zito M. Lombardi

Ongoing – RSC to resolve conflicts with the proposed dates

RSC Meeting December 5th and 6th, 2013

November 14th, 2013

Members, Regional Standards Committee

Re: NPCC Directory Development and Revision Manual

Ladies and Gentlemen:

The NPCC Directory project was initiated in order to provide a consistent and comprehensive set of reliability requirements for the Northeast while consolidating related information for NPCC criteria, guidelines, procedures and regional standards into a single document.

The Regional Standards Committee (RSC) working with the lead Task Force for each Directory is charged with the overall responsibility of managing the Directory project.

The Directory Manual was developed and approved by the RSC and is designed to provide guidance regarding the process of establishing a new or revised Directory in addition to clarifying the roles and responsibilities of the NPCC Task Forces which are responsible for Directory content.

The RSC has proposed revisions to the Manual which include:

• Revisions to the process for review and approval of a Criteria Clarification (this process now requires an Open Process posting of a Task Force clarification and ultimately RCC approval of the clarification).

• Renaming the process for ‘Criteria Interpretation’ to ‘Criteria Clarification’.

• The inclusion of an appeals process in the Request for Clarification section of the document.

• Minor formatting revisions.

RSC Meeting December 5th and 6th, 2013

The revised Directory Development and Revision Manual was posted to the NPCC Open Process for two 45 day comment periods and all comments received have been addressed by the NPCC Standards Staff.

Additionally, the revised Manual has been presented to the Reliability Coordinating Committee (RCC) for information at its meeting on December 3rd, 2013.

Accordingly, the Directory Development and Revision Manual is presented to the RSC for its consideration and approval.

Thank you.

Gerry Dunbar Manager, Reliability Criteria Northeast Power Coordinating Council, Inc.

Northeast Power Coordinating Council, Inc.

Directory Development and Revision Manual

Clean Version of Revised Directory Manual for RSC Approval

December 5th and 6th, 2013

Approved by the Reliability Standards Committee

October 26, 2011

NPCC Directory Development and Revision Manual 1

Revision History

Version

Date

Action

Change Tracking (New, Errata or Revisions)

0 10/26/2011 Effective Date New 1 XXXXX Revised Revised Interpretation

Approval Process

NPCC Directory Development and Revision Manual 2

NPCC

DIRECTORY DEVELOPMENT and REVISION MANUAL

Table of Contents

I. EXECUTIVE SUMMARY ....................................................................................... 3

II. INTRODUCTION ..................................................................................................... 3

III. TASK FORCE ROLES AND RESPONSIBILITIES ........................................ 4

IV. DIRECTORY DEVELOPMENT AND REVISION PROCEDURE ............... 4

1. NEW DIRECTORY ..........................................................................................................4

2. DIRECTORY REVISIONS ..............................................................................................7

a. Revisions to the Criteria Section of a Directory ...........................................................................7

b. Revisions to the Appendix Section of a Directory .........................................................................9

c. Revisions to the NPCC Glossary of Terms ................................................................................. 11

d. Withdrawal of Revision Requests ............................................................................................... 13

3. DIRECTORY RETIREMENT ......................................................................................13

4. MAINTENANCE OF LINKS AND ERRATA .............................................................13

V. DIRECTORY CLARIFICATION PROCESS ..................................................... 13

a. Request for Criteria Clarification .............................................................................................. 13

b. Appeals ....................................................................................................................................... 14

VI. REVIEW AND APPROVAL OF THE NPCC DIRECTORY DEVELOPMENT AND REVISION MANUAL .......................................................... 15

VII. DIRECTORY FORMAT AND VERSION CONTROL ................................. 15

VIII. REFERENCES: .............................................................................................. 16

APPENDIX A - DIRECTORY FORMAT TEMPLATE ............................................ 17

APPENDIX B – NPCC REQUEST FOR CLARIFICATION .................................... 21

NPCC Directory Development and Revision Manual 3

I. EXECUTIVE SUMMARY The purpose of the Northeast Power Coordinating Council, Inc. ("NPCC") is to enhance the reliability of the international, interconnected bulk power system in Northeastern North America through the development of more stringent and regionally specific criteria.

NPCC Directories have been developed in order to provide a consistent and comprehensive set of reliability requirements for the Northeast, while consolidating related information for NPCC Criteria, Guidelines, Procedures as well as FERC and NERC approved Regional Standards into one document.

NPCC Directories and the criteria contained within, apply only to NPCC Full Members. However, there may be additional requirements within tariffs or interconnection agreements that hold non Members responsible for complying with the criteria within each Directory.

This document provides guidance to NPCC Task Forces, and NPCC Full Members when establishing a new or revised Directory or when retiring or consolidating an existing Directory and also clarifies the roles and responsibilities of the NPCC Task Forces responsible for Directory content.

II. INTRODUCTION The NPCC Regional Standards Committee (RSC) working with the lead Task Force for each Directory has overall responsibility for managing the Directory project.

The Directories are organized to demonstrate that NPCC regional criteria are more specific than and/or more stringent than and consistent with NERC Reliability Standards.

Each Directory contains an Introduction, along with sections that identify NERC ERO Standards and NPCC Regional Standards that are associated with the Directory.

Additionally, each Directory is comprised of a section that describes the NPCC regionally specific criteria and was developed from the related NPCC ‘A’ documents.

The appropriate Type ‘B’ Guideline and Type ‘C’ Procedure documents are also included within each Directory as Appendices. Although the Appendices in a Directory are functionally associated with the subject criteria in the document, they do not contain NPCC criteria and are included within the Directory in order to achieve acceptable performance and consistent implementation of the criteria.

A mapping document has been provided on the Directory page of the NPCC Website and has been organized in a manner that provides guidance on where a Directory’s content originated (A Criteria, B Guideline, or C Procedure).

The mapping document provides tracking of specific content language from documents that were translated or replaced by Directories and their Appendices. A link to the Directory Flowchart and the Directory Mapping documents is provided in the References section of this manual.

Phase 1 of the Directory Project was initiated by the NPCC Reliability Coordinating Committee (RCC) in order to demonstrate consistency with NERC Standards and to effectively group documents together according to functional topics.

During Phase 1 an initial translation of the existing criteria document was performed in addition to identifying and eliminating language within the criteria that duplicated existing NERC Reliability Standards.

NPCC Directory Development and Revision Manual 4

Additionally, Functional Model language was introduced and the corresponding ‘B’ Guidelines and ‘C’ Procedures were incorporated into each Directory as appendices.

The resulting Directory created a single source reference for all entities while providing a method to demonstrate consistency with NERC Standards.

Phase 2 of the Directory Project was initiated in order to reformat the Criteria section of each document into specific and measurable NERC style requirements which will promote the NPCC regional criteria as more specific or more stringent within each Directory.

Phase 2 will also facilitate the development of the NPCC Criteria Compliance Enforcement Program (CCEP) by providing the respective requirements of that program.

Although the Regional Standards Committee is responsible for the overall Directory program, individual Directories are under the control of a lead NPCC Task Force which is responsible for coordinating review among all other Task Forces which have jurisdiction over either a portion of the criteria or one or more of the Appendices in the Directory.

III. TASK FORCE ROLES AND RESPONSIBILITIES With the development of the Directories it has been recognized that in certain cases the jurisdictional boundaries of Task Force ownership have been crossed and additional guidance when coordinating Directory review among Task Forces is necessary.

In general, revisions and clarifications to a Directory shall be coordinated by the Lead Task Force of the document.

Revisions to a Directory can be initiated in a fully bi-directional manner; that is either by the Lead Task Force responsible for the document or by another Task Force who is responsible for some portion (criteria or appendices) of the document.

This process will allow each Directory to remain under the control of the respective Lead Task Force which has the necessary expertise to keep each document current and accurate while also providing a means to coordinate component review of those segments of the Directory that may be under the control of another Task Force.

The Lead Task Force can initiate a full revision of the Directory in accordance with the NPCC Reliability Assessment Program (NRAP) date of approval or some need to revise the criteria section of the document. A link to the NRAP documents is provided in the References section of this manual.

The Lead Task Force will also notify other Task Forces under whose jurisdiction either a portion of the criteria or Appendices exists in order to coordinate the total document review and revision.

Similarly, a Task Force which is not the Lead Task Force of the Directory, but is responsible for some portion of the document, shall coordinate a necessary revision to their section of the document through the Lead Task Force of the Directory.

IV. DIRECTORY DEVELOPMENT AND REVISION PROCEDURE

1. NEW DIRECTORY Any NPCC Full Member may request the development of a new Directory.

NPCC Directory Development and Revision Manual 5

The request shall be made to the NPCC Manager of Reliability Criteria via email and shall contain the background and justification for the development of the new Directory. The NPCC Manager of Reliability Criteria shall forward the request to the Regional Standards Committee (RSC) in order for the RSC to review the request and assign its development to the appropriate NPCC Task Force.

The Lead Task Force responsible for developing the new Directory shall draft an initial version of the document consistent with the Directory template in Attachment A.

The NPCC Manager of Reliability Criteria shall post the draft Directory to the NPCC Open Process for 45 days.

At the conclusion of the 45 day Open Process, the Lead Task Force will discuss the comments submitted and post responses to comments on the NPCC Open Process portal.

If the responses to comments received on the draft result in substantive changes to the document, then the revised draft shall be reposted to the Open Process for a successive 45 day posting period.

If no substantive changes are developed which would require additional postings of a revised draft, the new Directory is presented to the Reliability Coordinating Council (RCC) for approval.

Upon RCC approval the document is submitted for a ballot to the NPCC Full Member Representatives along with the RCC recommendation of approval.1

The process for establishing a new Directory is represented below in Figure 1:

1 Approval of a new or revised Directory requires a 2/3rd majority of Full Member voting representatives in accordance with the NPCC Bylaws.

NPCC Directory Development and Revision Manual 6

Figure 1: New Directory

NPCC Directory Development and Revision Manual 7

2. DIRECTORY REVISIONS a. REVISIONS TO THE CRITERIA SECTION OF A DIRECTORY

Any NPCC Full Member may request a revision to the criteria within a Directory. A request to revise the criteria section of an NPCC Directory shall be submitted to the Lead Task Force responsible for the document.

The Lead Task Force shall notify each affected NPCC Task Force which has jurisdiction over either a portion of the criteria or one or more of the appendices within the Directory that a request to revise the criteria in the document has been received.

The Lead Task Force shall review the request to revise the criteria and shall also consider conforming changes to appendices as a result of the criteria revision if necessary.

The NPCC Manager of Reliability Criteria shall post the Directory containing the revised criteria to the NPCC Open Process review for 45 days.

At the conclusion of the 45 day Open Process, the Lead Task Force will discuss the comments submitted and post responses to comments on the NPCC Open Process portal.

If the responses to the comments received on the criteria revision result in substantive changes to the document, then the revised Directory criteria shall be reposted to the Open Process for a successive 45 day posting period.

If no substantive changes are developed which would require additional postings of a revised draft of the Directory, then the Directory is presented to the Reliability Coordinating Council (RCC) for approval.

Upon RCC approval the document is submitted for a ballot to the NPCC Full Member Representatives along with the RCC recommendation of approval.

Approval of the revised Directory criteria requires a 2/3rd majority of Full Member voting representatives in accordance with the NPCC Bylaws.

The process for revisions to the criteria in an existing Directory is represented below in Figure 2:

NPCC Directory Development and Revision Manual 8

Figure 2: Revisions to Criteria

NPCC Directory Development and Revision Manual 9

b. REVISIONS TO THE APPENDIX SECTION OF A DIRECTORY Any NPCC Full Member may request an Appendix within a Directory to be revised or retired. Revisions or retirements of Appendices shall only require RCC approval.

A request to revise or retire an Appendix of a NPCC Directory shall be submitted to the Task Force responsible for the Appendix.

The Task Force responsible for the Appendix shall notify the Lead Task Force of the Directory that a request to revise or retire an appendix within the document has been received.

The Lead Task Force of the Directory shall be responsible for notifying all Task Forces which have jurisdiction over either the criteria or one or more of the other Appendices within the Directory that a request to revise or retire an appendix has been received.

After the Task Force responsible for the revised Appendix request reviews the subject appendix they will forward the Directory containing the draft revised Appendix to the Lead Task Force of the Directory.

The Lead Task Force shall be responsible for posting the Directory which contains the revised or retired Appendix to the NPCC Open Process review for 45 days. Additionally, although the entire Directory will be posted to the open process, the Lead Task Force will limit the comments solicited to only the subject Appendix.

At the conclusion of the 45 day Open Process, the Lead Task Force will forward the comments submitted on the Appendix to the Task Force responsible for the revised or retired Appendix.

If the responses to the comments received on the revised or retired Appendix result in substantive change (s) to the Appendix, then the Directory containing the revised or retired Appendix shall be reposted to the Open Process for a successive 45 day review period by the Lead Task Force of the entire Directory; if no substantive changes are developed which would require additional postings the entire Directory containing the draft of the revised or retired Appendix will be presented to the Reliability Coordinating Council (RCC) for approval.

The process for revisions to the appendices within an existing Directory is represented below in Figure 3:

NPCC Directory Development and Revision Manual 10

Figure 3: Revisions to Appendices

NPCC Directory Development and Revision Manual 11

c. REVISIONS TO THE NPCC GLOSSARY OF TERMS The NPCC Glossary of Terms contains the definitions of all terms found within the NPCC Directories, Criteria, Guidelines, and Procedures and which are not already defined in the NERC Glossary of Terms or are regionally specific. The Glossary of Terms is intended to be a repository of all NPCC defined terms and contains the Full Member approved definition of that term as developed by the Task Force responsible for the Directory in which the term resides.

The Glossary is organized into two sections, one containing all defined terms within the Directories (including Appendices) which support the NPCC Criteria and another section for definitions found within remaining B and C documents.

The process of establishing or revising a NPCC defined term shall be considered a revision to the Directory in which the term resides in order to capture the context of its use within the document.

Accordingly, the entire Glossary is not subject to the Open Process for a revision to an individual definition.

The development and review of a new definition or a revision to an existing NPCC specific definition contained within the Glossary will be coordinated by the Lead Task Force for the Directory in which the defined term resides.

Any NPCC Full Member may request that a new or revised term be added to the NPCC Glossary of Terms by forwarding a request to the Lead Task Force for the Directory in which the defined term resides.

When the subject term resides in multiple Directories, the requestor SHALL forward the request to each of the Task Forces for the Directories in which the defined term resides and the individual Task Forces shall coordinate their review of the request, by assigning one of the Task Forces as the Lead Task Force for the review.

After the Lead Task Force in which the defined term resides has completed its review they will post the subject Directory containing the new or revised term to the NPCC Open Process for 45 days. When the new or revised term appears in multiple Directories, the designated Lead Task Force for the review shall include in the posting notice a comprehensive list of references to all occurrences of the defined term in other NPCC Directories, including each Directory in which the term resides.

At the conclusion of the 45 day Open Process, if responses to comments received on the new or revised term result in further substantive change to the term, then the Directory containing the new or revised term shall be reposted to the Open Process for a successive 45 day posting period by the Lead Task Force for the subject Directory; if no substantive changes to the term are developed which would require an additional posting, then the Directory containing the new or revised term will be presented to the Reliability Coordinating Council (RCC) by the Lead Task Force for approval.

Upon RCC recommendation the Directory containing the new or revised term will be balloted by the Full Members.

Upon Full Member approval of the new or revised term the Glossary will be updated by the Lead Task Force of the document in which the term resides.

The process for revisions to the appendices within an existing Directory is represented below in Figure 4:

NPCC Directory Development and Revision Manual 12

Figure 4: Revisions to the NPCC Glossary of Terms

NPCC Directory Development and Revision Manual 13

d. WITHDRAWAL OF REVISION REQUESTS Any NPCC Full Member which has initiated a request to develop a new Directory, revise an existing Directory or revise an NPCC Glossary Term may withdraw the request by notifying the NPCC Manager of Reliability Criteria.

3. DIRECTORY RETIREMENT Upon identification of the need to retire an existing Directory, the Lead Task Force responsible for the Directory shall notify the NPCC Manager of Reliability Criteria of its proposal to retire a Directory.

The proposal shall include the rationale for the retirement and a statement regarding the impact of retirement on the reliability of the Bulk Power System.

The NPCC Manager of Reliability Criteria shall post the proposal, along with supporting documentation to the NPCC Open Process for 45 days.

At the conclusion of the 45 day Open Process, the Lead Task Force will review the comments submitted and post responses on the NPCC Open Process portal.

The NPCC Manager of Reliability Criteria shall present the proposal to retire the Directory to the Reliability Coordinating Council (RCC) for approval.

Upon RCC approval the proposal to retire the Directory will be submitted for a ballot to the NPCC Full Member Representatives along with the RCC recommendation to retire the document.

4. MAINTENANCE OF LINKS AND ERRATA The maintenance of Links and the correction of errors found in a Directory or its Appendices shall be the responsibility of NPCC Standards staff. An error may be classified as Errata provided its correction does not change the scope or intent of the Directory and has no impact on the end user of the Directory.

Errata and Link revisions are updated as needed and require only the Lead TF approval prior to publishing.

NPCC staff will also maintain a record of the change on the Directory Revision History page within the document.

V. DIRECTORY CLARIFICATION PROCESS

a. REQUEST FOR CRITERIA CLARIFICATION Any NPCC Full Member may request a clarification of the criteria within a Directory.

The NPCC Full Member seeking the clarification shall submit a Request for Criteria Clarification form 2 to the NPCC Manager of Reliability Criteria explaining the clarification required and the specific circumstances surrounding the request.

The NPCC Manager of Reliability Criteria shall review the request and work with the originator to make certain that the request is clearly written, seeks clarity regarding the intent or purpose of the criteria and is not a question on a compliance aspect of the criteria. 2 The Request for Clarification Form is included in Appendix B of this document.

NPCC Directory Development and Revision Manual 14

The Manager of Reliability Criteria shall notify the originator of the Request for Criteria Clarification if the Request has been denied by providing the originator with a written response explaining the circumstances of the denial.

The Manager of Reliability Criteria will forward an approved Request for Criteria Clarification to the NPCC Task Force designated as the Lead Task Force for the subject Directory.

The Lead Task Force shall notify each NPCC Task Force which has jurisdiction over either another portion of the criteria and /or one or more of the appendices within the subject Directory, that a Request for Criteria Clarification has been received. The Lead Task Force shall also forward the request to the affected Task Force(s).

The Lead Task Force for the Directory or the Task Force having jurisdiction shall review the request among its Members and provide a response to the NPCC Manager of Reliability Criteria within 60 calendar days.

The Manager of Reliability Criteria shall post the Request for Criteria Clarification, along with the response(s) provided by the Lead Task Force to the NPCC Open Process for 45 days.

The Lead Task Force will consider all comments received on the posted clarification and if necessary revise the clarification based on these comments.

If the Lead Task Force revises the clarification substantively on the basis of comments received the clarification shall be reposted to the NPCC Open Process for a successive 45 day posting period.

The Manager of Reliability Criteria will coordinate a response to all commenters on behalf of the Lead Task Force.

The Lead Task Force response to a Directory clarification request shall provide the requested explanation without expanding on the criteria and should be sufficiently concise to eliminate any ambiguity.

The NPCC Manager of Reliability Criteria shall review the clarification provided by the Lead Task Force or the Task Force having jurisdiction to insure that it is clear and provides the requested explanation without expanding on the criteria.

The Lead Task Force response to a Request for Criteria Clarification shall be presented to the NPCC Reliability Coordinating Committee (RCC) for final approval prior to posting the clarification to the NPCC website.

The detailed results of the Request for Criteria Clarification shall be retained by the Lead Task Force and the NPCC Standards Staff along with a recommendation on whether the language within the document should be revised in order to provide additional clarity.

b. APPEALS Any NPCC Full Member that has submitted a Request for Clarification may appeal the rendered Task Force response.

The appellant shall submit a written complaint to the NPCC Manager of Reliability Criteria describing the substantive or procedural action or inaction associated with the Clarification Request process.

The appellant shall also describe in the complaint the actual or potential adverse impact to the appellant.

NPCC Directory Development and Revision Manual 15

Assisted by any necessary NPCC Standards Staff and Lead Task Force resources, the NPCC Manager of Reliability Criteria shall prepare a written response addressed to the appellant as soon as practical, but not more than forty-five (45) calendar days after receipt of the complaint.

The process for a Criteria Clarification Request is represented below in Figure 5:

Figure 5: Request for Criteria Clarification

VI. REVIEW AND APPROVAL OF THE NPCC DIRECTORY DEVELOPMENT AND REVISION MANUAL

The NPCC Directory Development and Revision Manual will be reviewed for possible revisions at least once every five (5) years or more frequently if required.

A notification of a pending RSC review and re-approval of the Manual shall be posted on the NPCC website. All revisions to this Manual shall be posted to the NPCC Open Process Review for 45 days.

The Regional Standards Committee (RSC) shall respond to all comments received and shall have final approval over the revised document.

VII. DIRECTORY FORMAT AND VERSION CONTROL

Each Directory will be formatted in accordance with the Directory Template in Appendix A of this document.

NPCC Directory Development and Revision Manual 16

The Task Force Revision Review Record on the cover page of each Directory shall contain the date of the most recent version of the Directory as approved by the Full Members of NPCC.

The Revision History record on page 2 of each Directory shall contain a record of all revisions to the document, including maintenance of errata and links.

VIII. REFERENCES:

1. https://www.npcc.org/Standards/Directories/Directory_Flowchart.pdf.

2. https://www.npcc.org/Standards/Directories/Directory_Mapping.pdf.

3. https://www.npcc.org/Library/NRAP/Forms/Public%20List.aspx

NPCC Directory Development and Revision Manual 17

APPENDIX A - DIRECTORY FORMAT TEMPLATE

NPCC Regional Reliability Reference Directory # XX

Task Force XXXXX Revision Review Record: XX/XX, 20XX

Adopted by the Members of the Northeast Power Coordinating Council, Inc. June 26th, 2009 based on recommendation by the Reliability Coordinating Committee, in accordance with Section VIII of the NPCC Amended and Restated Bylaws dated July 24, 2007 as amended to date.

NPCC Directory Development and Revision Manual 18

Revision History

Version

Date

Action

Change Tracking (New, Errata or Revisions)

0 Effective Date New

NPCC Directory Development and Revision Manual 19

Format for NPCC Directories (Phase 2)

Effective Dates (Denotes date of adoption by the Membership)

Revision History (Depicts revision history and tracks key changes)

Table of Content (Self-explanatory)

A. Introduction

Title: Self-explanatory

Directory #: Self-explanatory

Objective: State the reliability objective that this Directory intended to meet (i.e., achieving specific performance target/outcome, mitigating particular risks, establishing the minimum capability level, etc.)

Effective Date: Identify which parts of the Directory become effective on which dates.

Background: Provide information related to this creation or revision of this Directory, e.g., which A, B or C documents are mapped into this Directory; the general basis of the Directory, etc.

Applicability: Identify the entities that are assigned reliability requirements and/or which facilities need to conform to the stipulated criteria.

B. NERC ERO Reliability Standard Requirements

A list of the NERC standards associated with this Directory.

C. NPCC Regional Reliability Standard Requirements

A list of NPCC Regional Standards associated with this Directory.

D. NPCC Full Member, More Stringent Requirements, Criteria and Measures

Requirements

List the requirements and criteria that the applicable entities or facilities must comply with.

E. Compliance

Compliance with the requirements set forth in this Directory will be in accordance with the NPCC Criteria Compliance and Enforcement Program (CCEP).

NPCC Directory Development and Revision Manual 20

Measures and corresponding Levels of Non Compliance for these requirements are contained within the compliance template associated with this Directory.

Prepared by: Task Force XX (Lead Task Force for the Directory)

Review and Approval: Revision to any portion of this Directory will in accordance with the NPCC Directory Development and Revision Manual and will be posted by the Lead Task Force in the NPCC Open Process for a 45 day review and comment period. Upon satisfactorily addressing all of the comments in this forum, the Directory will be sent to the RCC for its approval.

Upon approval of the RCC, this Directory will be sent to the Full Member Representatives for their final approval if sections pertaining to the Requirements and Criteria portion have been revised. All voting and approvals will be conducted according to the most current "NPCC Bylaws" in effect at the time the ballots are cast.

Revisions pertaining to the Appendices or any other portion of the document such as links, glossary terms, etc., only RCC Members will need to conduct the final approval ballot of the document.

This Directory will be updated at least once every three years and as often as necessary to keep it current and consistent with NERC, Regional Reliability Standards and other NPCC documents.

NPCC Directory Development and Revision Manual 21

APPENDIX B – NPCC REQUEST FOR CLARIFICATION

NPCC Request for Criteria Clarification

Note: an Interpretation cannot be used to revise a Directory.

Request for Criteria Clarification of a Directory Date clarification request submitted:

Date clarification response provided:

Contact information for person requesting the clarification:

Name:

Organization:

Telephone:

E-mail:

Identify the Directory that needs clarification:

Directory Number :

Directory Title:

Identify specifically what portion of the Criteria needs clarification:

Text of Requirement:

Identify the material impact associated with this clarification:

Identify the material impact to your organization or others caused by the lack of clarity within this Directory:

Submit completed Request for Criteria Clarification forms to the NPCC Manager of Reliability Criteria.

NPCC Directory Development and Revision Manual 22

Clarification: Response to Request for Clarification of Directory XX for the XXXX Corporation

The following clarification of Directory was developed by the Task Force on XXXXX

Directory Number and Text of Requirement

Question 1

Response to Question 1

Question 2

Response to Question 2

November 12, 2013

NPCC Full and General Members,

Subject: Open Process Posting of the NPCC Regional Standard Processes Manual (RSPM)

A 30-day pre-ballot review period for the NPCC Regional Standard Processes Manual (RSPM) is now open through December 12, 2013. A 10-day minimum Ballot will be held immediately following the pre-ballot review period beginning on December 13, 2013. Additional notification(s) will be sent out as necessary to achieve quorum and provide notice.

Included in this posting are: • Clean version of the RSPM with proposed revisions • Redline version (to prior posting) of the RSPM with proposed revisions • Consideration and responses to Comments from prior posting

The NPCC RSPM is required to be periodically updated and filed with FERC. The key enhancements in the proposed revision of the NPCC RSPM include:

• The development of separate sections for: 1) the Withdrawal of a Regional Standard Pending Approval; 2) the Retirement of an Approved NPCC Regional Standard; 3) the Discontinuance of Regional Standard Development to facilitate terminating the standard development process after RSAR approval but prior to posting a regional standard for industry ballot; 4) the Approval of a Process Waiver; 5) and the Process for Correcting Errata

• Integrating NPCC’s Cost Effectiveness Analysis Procedure (CEAP) into the RSPM • Further develop NPCC’s interpretation process for regional standards to ensure all

statutory requirements are met while maintaining an expedited process to produce clarifications for stakeholders

• Three new appendices: 1) Appendix A: Regional Standard Authorization Request (RSAR) Completion Guidelines and Form; 2) Appendix B: Selection of Drafting Team Members and Nomination Form; and 3) Appendix C: Maintenance of Regional Standards and Process

• Identifying the Reliability Standard Audit Worksheet (RSAW) as a companion document to a regional standard which is developed by the NPCC Standard Drafting Team and the NPCC Compliance Staff

The NPCC Open Process Review may be accessed through the following link:

https://www.npcc.org/Standards/SitePages/DevStandardsList.aspx

Please contact me with any questions regarding the NPCC Open Process review or the content of this document.

Thank you.

Lee R. Pedowicz Manager Reliability Standards 212-840-1070 lpedowicz@npcc.org

Northeast Power Coordinating Council, Inc.

Regional Standard Processes Manual (RSPM)

Adopted by FERC: XXXX XX, 20XX

Approved by NERC Board of Trustees: XXXX XX, 20XX

Approved by NPCC Board of Directors: XXXX XX, 20XX

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 1 Approved by the NPCC Board xxxx xx, 2013

Revision History

Version NPCC Board of

Directors Approval NERC Board of

Trustees Approval FERC Approval 0 9/19/07 10/23/07 3/21/08 1 xx/xx/xx xx/xx/xx xx/xx/xx

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 2 Approved by the NPCC Board xxxx xx, 2013

NPCC REGIONAL RELIABILITY STANDARDS PROCESS MANUAL

TABLE OF CONTENTS I. EXECUTIVE SUMMARY ................................................................................................. 3 II. INTRODUCTION............................................................................................................ 4

PURPOSE ............................................................................................................................................... 4 BACKGROUND .................................................................................................................................... 4

III. REGIONAL STANDARD CHARACTERISTICS AND ELEMENTS ................... 5 1. CHARACTERISTIC ATTRIBUTES ........................................................................................ 5 2. ELEMENTS OF A REGIONAL STANDARD ........................................................................ 6

TYPES OF RELIABILITY REQUIREMENTS ................................................................................................................ 6 ELEMENTS OF A REGIONAL STANDARD ................................................................................................................. 7

IV. REGIONAL STANDARDS DEVELOPMENT PROCESS ...................................... 9 1. ROLES IN THE NPCC REGIONAL STANDARD PROCESS ............................................ 9

NOMINATION, REVISION, CLARIFICATION, OR RETIREMENT OF A STANDARD: ..................................................... 9 PROCESS ROLES AND RESPONSIBILITIES .............................................................................................................. 9

2. STANDARD DEVELOPMENT PROCESS STEPS ............................................................. 11 STEP 2.1: REGIONAL STANDARDS AUTHORIZATION REQUEST TO DEVELOP, MODIFY OR RETIRE ..................... 11 STEP 2.2: FORMATION OF DRAFTING TEAM FOR NEW OR MODIFIED STANDARD .............................................. 13 STEP 2.3: DEVELOPMENT OF A REGIONAL STANDARD AND ASSOCIATED DOCUMENTS ..................................... 13 STEP 2.4: POSTING FOR COMMENT PERIOD AND RESOLUTION OF COMMENTS ................................................. 14 STEP 2.5: POSTING FOR BALLOT PERIOD IN THE OPEN PROCESS ..................................................................... 16 STEP 2.6: NPCC BOARD OF DIRECTORS APPROVAL.......................................................................................... 18 STEP 2.7: NERC BOARD OF TRUSTEES SUBMITTAL ........................................................................................... 18 STEP 2.8: IMPLEMENTATION OF A NPCC REGIONAL STANDARD ....................................................................... 18

3. STANDARD CLARIFICATION PROCESS STEPS ............................................................ 19 STEP 3.1: REGIONAL STANDARDS CLARIFICATION REQUEST (CR) .................................................................... 19 STEP 3.2: REVIEW AND VALIDATION OF CLARIFICATION REQUEST (CR) .......................................................... 20 STEP 3.3: NPCC REGIONAL STANDARDS COMMITTEE (RSC) ACTIONS ............................................................. 21 STEP 3.4: FORMATION OF DRAFTING TEAM FOR RESPONSE TO CR................................................................... 21 STEP 3.5: DEVELOPMENT OF RESPONSE TO CR ................................................................................................. 21 STEP 3.6: POSTING CR FOR COMMENT PERIOD AND RESOLUTION OF COMMENTS ........................................... 22 STEP 3.7: REGIONAL STANDARDS COMMITTEE APPROVAL OF CR ..................................................................... 22 STEP 3.8: NPCC BOARD OF DIRECTORS APPROVAL OF CR .............................................................................. 22

4. DISCONTINUANCE OF REGIONAL STANDARD DEVELOPMENT .......................... 23 5. WITHDRAWAL OF A REGIONAL STANDARD PENDING APPROVAL ................... 24 6. RETIREMENT OF AN APPROVED NPCC REGIONAL STANDARD.......................... 24 7. APPROVAL OF PROCESS WAIVER ................................................................................... 24 8. PROCESS FOR CORRECTING ERRATA ........................................................................... 25 9. APPEALS ..................................................................................................................................... 25

LEVEL 1 APPEAL ................................................................................................................................................. 26 LEVEL 2 APPEAL ................................................................................................................................................. 26

APPENDIX A: RSAR COMPLETION GUIDELINES ...................................................... A1 APPENDIX B: SELECTION OF DRAFTING TEAM MEMBERS ................................. B1 APPENDIX C: MAINTENANCE OF REGIONAL STANDARDS AND PROCESS ... C1

MAINTENANCE OF REGIONAL STANDARDS ......................................................................................................... C1 MAINTENANCE OF THE REGIONAL STANDARDS PROCESS .................................................................................. C1

APPENDIX D: NPCC CLARIFICATION REQUEST ...................................................... D1

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 3 Approved by the NPCC Board xxxx xx, 2013

I. EXECUTIVE SUMMARY The NPCC Bylaws state “NPCC shall develop a Regional Reliability Standards Development Procedure that provides the design-basis approach to a consensus building process by which NPCC may develop Regional Reliability Standards and Regional Variances to be proposed to the ERO for adoption, under delegated authority by the FERC and the Canadian Provincial regulatory and/or governmental authorities.”

The NPCC Regional Reliability Standards Development Procedure was originally adopted by the NPCC Board of Directors on September 19, 2007. The NPCC Reliability Standards Staff in concert with the NPCC Regional Standards Committee (RSC) has completed a revision to the NPCC Regional Reliability Standards Process Manual to incorporate process improvements, provide greater clarity and reflect the new NPCC Cost Effectiveness Analysis Procedure (CEAP).

Key changes addressed in this revision include:

• Replacing interpretation with clarification and expanding the Clarification Section narrative into process steps and including an associated flowchart

• Creating separate sections for: 1) Withdrawal of a Regional Standard Pending Approval; 2) Retirement of an Approved NPCC Regional Standard; and 3) Approval of Process Waiver; 4) Process for Correcting Errata

• Recognizing the new NPCC Cost Effectiveness Analysis Procedure (CEAP)

• Identifying the Reliability Standard Audit Worksheet (RSAW) as a companion document to a regional standard that needs to be collaboratively developed by the drafting team and NPCC Compliance Staff

• Creating three new appendices: 1) Appendix A: Regional Standard Authorization Request (RSAR) Completion Guidelines and Form; 2) Appendix B: Selection of drafting team Members and Nomination Form; and 3) Appendix C: Maintenance of Regional Standards and Process

In addressing areas for improvement in the NPCC Regional Reliability Standards Development Procedure, recent improvements made to the NERC Standards Process Manual (e.g., Standards Process Input Group (SPIG) recommendations) as well as the manuals of other Regional Entities were benchmarked to identify best practices for inclusion in this manual.

The process improvements and clarity captured in this revision to the NPCC Regional Reliability Standards Development Procedure, will result in a more timely and efficient manner to address the development of regional standards to ensure the reliability of the Bulk Electric System within the NPCC geographical area.

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 4 Approved by the NPCC Board xxxx xx, 2013

II. INTRODUCTION PURPOSE

This manual defines the characteristics of a Northeast Power Coordinating Council, Inc. (NPCC) regional Reliability Standard (hereinafter referred to as “regional standard”) and establishes the process by which NPCC regional standards are developed, approved, revised, clarified and retired. The NPCC regional standards process is a stakeholder process that is approved by the NPCC members to ensure a transparent standard development process that is “open, fair, and inclusive.”

NPCC regional standards address the reliability of the international and interconnected Bulk Electric System in Northeast North America. NPCC regional standards shall enable or support one or more NERC/ERO reliability principles1 and will, in all cases, not be inconsistent with or less stringent than any requirements of the North American Electric Reliability Council/Electric Reliability Organization (NERC/ERO) continent-wide Reliability Standards.

The development of NPCC regional standards is performed according to the following principles using the process contained in this manual:

• Developed in a fair and open process that provides an opportunity for all interested parties to participate;

• Does not have an adverse impact on commerce that is not necessary for reliability;

• Provides a level of Bulk Electric System reliability that is adequate to protect public health, safety, welfare, and national security and would not have a significant adverse impact on reliability; and

• Based on a justifiable difference between Regions or between sub-Regions within the Regional geographic area.

Following industry approval, NPCC regional standards process and NPCC regional standards require approval by the NPCC Board of Directors, NERC as the Electric Reliability Organization (ERO) and the applicable regulatory authorities in the United States (FERC) and Canada.

BACKGROUND

Northeast Power Coordinating Council, Inc. (NPCC) is responsible for promoting and improving the reliability of the international, interconnected Bulk Electric System in Northeastern North America. NPCC carries out its mission through (i) the development of regional standards and compliance assessment and enforcement of continent-wide and regional standards, coordination of system planning, design and operations, and assessment of reliability, (collectively, “Regional Entity activities”), and (ii) the establishment of regionally-specific criteria, and monitoring and enforcement of compliance with such criteria (collectively, “criteria services activities”).

The Energy Policy Act (EPA) of 2005 (Section 1211) amended the Federal Power Act (FPA) by adding Section 215, Electric Reliability. Specifically regarding standards development and pursuant with Section 215(e)(4) of the FPA, NPCC as a Regional Entity with delegated authority from NERC may propose regional standards to NERC for eventual enforcement within the NPCC region.

1 Available on the NERC website: Reliability Principles

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 5 Approved by the NPCC Board xxxx xx, 2013

As a condition of NPCC membership, NPCC General and Full Members2 agree to adhere to NERC Reliability Standards. NERC Reliability Standards are comprised of both continent-wide and regional standards. The NPCC regional standards apply only to that part of the Eastern Interconnection within the NPCC geographical area.

III. REGIONAL STANDARD CHARACTERISTICS AND ELEMENTS 1. CHARACTERISTIC ATTRIBUTES

The NPCC regional standards development process has the following key characteristics:

• Fair due process — The NPCC regional standards development process provides for reasonable notice and opportunity for public comment. At a minimum, the procedure shall include public notice of the intent to develop a standard, a public comment period on the proposed standard, due consideration of those public comments, and a ballot of interested stakeholders. Upon approval by the NPCC Members, the NPCC Board of Directors then votes to approve submittal of the regional standard to NERC for ERO approval, followed by submission to FERC and Canadian Authorities for their approvals.

• Openness — Participation in the NPCC regional standards development process is open to all persons and organizations that are directly and materially affected by the reliability of the NPCC’s Bulk Electric System. There is no undue financial burden to participation. Participation shall not be conditioned upon membership in the ERO, NPCC or any organization, and shall not be unreasonably restricted on the basis of technical qualifications or other such requirements.

• Inclusive — Any entity (person, organization, company, government agency, individual, etc.) with a direct and material interest in the reliability of NPCC’s Bulk Electric System has the right to participate by: (a) expressing an opinion and its basis; (b) having their position considered, and (c) having the right to appeal a response through an established appeal process.

• Balanced — The NPCC regional standards development process strives to have an appropriate balance of interest and shall not be dominated by any two interest categories and no single interest category shall be able to defeat a matter. Pursuant with the NPCC By-Laws3 there are seven (7) stakeholder voting sectors and the votes for each sector are weighted to achieve an appropriate balance.

• Transparent — All actions material to the development of NPCC regional standards are transparent and information regarding the progress of a standard’s development action is made available to the public through postings on the NPCC website as well as through E-mail lists.

• Without undue delay — The NPCC regional standards development process shall be performed within a reasonable time.

In as much as NPCC is one of six Regional Entities within the Eastern Interconnection of North America, there will be no presumption of validity by the ERO for any NPCC regional standard.

2 As defined in the NPCC By-Laws – available on the NPCC website 3 NPCC By-Laws are available on the NPCC website

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 6 Approved by the NPCC Board xxxx xx, 2013

In order to receive the approval of the ERO, the NPCC regional standards development process must also achieve the following objectives:

• No Adverse Impact on Reliability of the Interconnection — A NPCC regional standard provides an Adequate Level of Reliability4 as defined by NERC.

• Justifiable Difference — A NPCC regional standard addresses a justifiable difference within the NPCC geographical area that results from a physical difference5 or operating difference in the Northeast’s Bulk Electric System. Although a justifiable difference allows for a unique regional standard, a NPCC regional standard shall be no less stringent than a continent-wide standard.

• Uniformity — To the extent possible, the NPCC regional standards provides uniformity with Reliability Standards across the interconnected Bulk Electric System of North America.

• No Undue Adverse Impact on Commerce — A NPCC regional standard will not cause any undue adverse impact on business activities that are not necessary for reliability of the Region and its interconnected Regions. All regional standards shall be consistent with NERC’s market principles6.

2. ELEMENTS OF A REGIONAL STANDARD

To ensure uniformity of regional standards and avoid inconsistency with NERC continent-wide standards, a NPCC regional standard shall be consistent with the elements identified in this section of the procedure. These elements are intended to apply a systematic discipline in the development and revision of regional standards. The application of a systematic discipline is necessary for achieving regional standards that are measurable, enforceable, and consistent as well as results oriented7, i.e.:

• Performance-based,

• Risk-based, and

• Capability-based. TYPES OF RELIABILITY REQUIREMENTS

Regional reliability standards should be viewed as a portfolio of requirements designed to achieve an effective defense-in-depth strategy. Each requirement should identify a clear and measurable expected outcome, such as: a) a stated level of reliability performance, b) a reduction in a specified reliability risk, or c) a necessary competency.

a) Performance-based - defines a specific reliability objective or outcome that has a direct, observable effect on the reliability of the Bulk Electric System, i.e. an effect that can be measured using power system data or trends.

4 Available on the NERC website: Adequate Level of Reliability 5 The meaning of the phrase “physical difference” will be consistent with FERC’s Order, issued September 22,

2004, Granting Request For Clarification regarding Docket No. PL04-5-000, Policy Statement on Matters Related to Bulk Power System Reliability.

6 Available on the NERC website: www.nerc.com 7 Results-based Standards see

http://www.nerc.com/pa/Stand/Resources/Documents/ResultsBasedStandardGuidance.pdf

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 7 Approved by the NPCC Board xxxx xx, 2013

b) Risk-based - defines actions of entities that reduce a stated risk to the reliability of the Bulk Electric System and can be measured by evaluating a particular product or outcome resulting from the required actions.

c) Capability-based - defines capabilities needed to perform reliability functions and can be measured by demonstrating that the capability exists as required.

Each regional standard shall enable or support one or more of the reliability principles 8 as identified in the most recent set posted on the NERC website. Each regional standard shall also be consistent with all of the reliability principles. The intent of the set of NPCC regional standards is to deliver an Adequate Level of Reliability9 as defined by NERC.

Recognizing that Bulk Electric System reliability and electricity markets are inseparable and mutually interdependent, all regional standards shall be consistent with the most recent set of Market Principles10 as posted on the NERC website. Consideration of the Market Principles is intended to ensure that regional standards are written such that they achieve their reliability objective without placing undue restrictions or causing adverse impacts on competitive electricity markets.

ELEMENTS OF A REGIONAL STANDARD

A regional standard includes several components designed to work collectively to identify what entities must do to meet their reliability-related obligations as an owner, operator or user of the Bulk Electric System. The components of a NPCC regional standard identified below are based on the NERC Standard Processes Manual (SPM) that was approved by the NERC Board of Trustees at its February 2013 meeting. Future revisions of the NERC SPM will be used at the time of development of a NPCC regional standard if different from the elements listed below.

The only mandatory and enforceable components of a regional standard are the: (1) Applicability, (2) Requirements, and (3) the Effective Dates. The additional components are included in the regional standard for informational purposes, to establish the relevant scope and technical paradigm, and to provide guidance to functional entities concerning how compliance will be assessed by the Compliance Enforcement Authority.

The components of a regional standard may include the following: Title: A brief, descriptive phrase identifying the topic of the regional standard.

Number: A unique identification number assigned in accordance with a published classification system to facilitate tracking and reference to the regional standards.

Purpose: The reliability outcome achieved through compliance with the requirements of the regional standard.

Applicability: Identifies which entities are assigned reliability requirements; i.e., the specific functional entities and facilities to which the regional standard applies.

Effective Dates: Identification of the date or pre-conditions determining when each Requirement becomes effective in each jurisdiction.

8 Available on the NERC website: Reliability Principles 9 Available on the NERC website: Adequate Level of Reliability 10 Available on the NERC website: Market Principles

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 8 Approved by the NPCC Board xxxx xx, 2013

Requirement: An explicit statement that identifies the functional entity responsible, the action or outcome that must be achieved, any conditions achieving the action or outcome, and the reliability-related benefit of the action or outcome. Each requirement shall be a statement for which compliance is mandatory.

Compliance Elements: Elements to aid in the administration of compliance monitoring and enforcement responsibilities.

Measure: Provides identification of the evidence or types of evidence that may demonstrate compliance with the associated requirement.

Violation Risk Factors and Violation Severity Levels:

Violation risk factors (VRFs) and violation severity levels (VSLs) are used as factors when determining the size of a penalty or sanction associated with the violation of a requirement in an approved Reliability Standard. Each requirement in each Reliability Standard has an associated VRF and a set of VSLs. VRFs and VSLs are developed by the drafting team, working with NPCC Standards Staff and Compliance Staff, at the same time as the associated Reliability Standard, but are not part of the Reliability Standard. The Board of Directors is responsible for approving VRFs and VSLs.

• Violation Risk Factors VRFs identify the potential reliability significance of noncompliance with each requirement. Each requirement is assigned a VRF in accordance with the latest approved set of VRF criteria.

• Violation Severity Levels VSLs define the degree to which compliance with a requirement was not achieved. Each requirement shall have at least one VSL. While it is preferable to have four VSLs for each requirement, some requirements do not have multiple “degrees” of noncompliant performance and may have only one, two, or three VSLs. Each requirement is assigned one or more VSLs in accordance with the latest approved set of VSL criteria.

Version History: The version history is provided for informational purposes and lists information regarding prior versions of the regional standard.

Variance: As applied to a NPCC regional standard is a Requirement (to be applied in the place of the NPCC region-wide Requirement) that is applicable to a specific geographic area or to a specific set of Registered Entities.

Compliance Enforcement Authority (CEA):

The entity that is responsible for assessing performance or outcomes to determine if an entity is compliant with the associated regional standard. The Compliance Enforcement Authority will be NERC or the Regional Entity in their respective roles of monitoring and enforcing compliance with the ERO regional standards.

Reliability Standard Audit Worksheets (RSAWs)11

Reliability Standard Audit Worksheets (RSAWs) are developed as companion documents to regional and continent-wide Reliability Standards to facilitate the CEA assessment of a registered entity’s compliance with a standard.

11 While RSAWs are not part of the regional standard, they are developed through collaboration of the drafting team and NPCC Compliance Staff.

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 9 Approved by the NPCC Board xxxx xx, 2013

Informational Elements: Elements to aid in the implementation of the regional standard. Application Guidelines:

Guidelines or reference documents to support the implementation of the associated regional standard.

Procedures: Procedures to support implementation of the associated regional standard.

IV. REGIONAL STANDARDS DEVELOPMENT PROCESS 1. ROLES IN THE NPCC REGIONAL STANDARD PROCESS

NOMINATION, REVISION, CLARIFICATION, OR RETIREMENT OF A STANDARD:

Any member of NPCC or group within the NPCC region shall be allowed to request that a NPCC regional standard be developed, modified, clarified, or retired. Additionally, any person (organization, company, government agency, individual, etc.) who is directly and materially affected by the reliability of the NPCC Bulk Electric System shall be allowed to request that a NPCC regional standard be developed, modified, clarified, or retired. The following section identifies the process roles in the NPCC regional standards process. Refer to Step 2 STANDARD DEVELOPMENT PROCESS STEPS and FIGURE 1: FLOWCHART OF REGIONAL STANDARDS DEVELOPMENT PROCESS OVERVIEW for the regional standards development process steps and associated flowchart. Refer to Step 3 STANDARD CLARIFICATION PROCESS STEPS and FIGURE 2: FLOWCHART OF REGIONAL STANDARDS CLARIFICATION PROCESS OVERVIEW for the regional standards clarification process steps and associated flowchart.

PROCESS ROLES AND RESPONSIBILITIES

BOARD OF DIRECTORS The NPCC Board of Directors (Board) shall consider for adoption regional standards, definitions, variances and clarifications and associated implementation plans that have been processed according to the processes identified in this manual. Once the Board adopts a regional standard, definition, variance or clarification, the Board shall direct NPCC Standards Staff to submit the document(s) for approval to the NERC Board of Trustees.

DRAFTING TEAM The drafting team (DT) should strive to achieve a portfolio of performance, risk, and capability-based mandatory reliability requirements that support an effective defense-in-depth strategy. The drafting team develops standards-related regional products as directed by the NPCC RSC and within the scope of an approved Regional Standard Authorization Request (RSAR) or a Request for Clarification (RFC). The product that is developed is typically a new or revised regional standard, but could also be a definition, a reference document, a set of Violation Risk Factors, a set of Violation Severity levels, or the team could be appointed to assist an author in refining a Regional Standard Authorization Request (RSAR). The drafting team also works collaboratively with NPCC Compliance Staff to develop Reliability Standard Audit Worksheets (RSAWs) at the same time regional standards are developed. The drafting team shall remain in place until such time as the NERC Board of Trustees adopts the regional standard.

MANAGER OF RELIABILITY STANDARDS The NPCC Manager of Reliability Standards has the overall responsibility for managing the NPCC regional standards processes in accordance with this manual. As used herein, the NPCC

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 10 Approved by the NPCC Board xxxx xx, 2013

Manager of Reliability Standards will be the NPCC Manager of Reliability Standards or his/her designee.

NPCC MEMBERS NPCC members may participate in the comment and ballot periods associated with the development and industry approval of regional standards. The ballot body is comprised of all entities or individuals that qualify for one of the stakeholder sectors within NPCC as stated in the most recently approved NPCC Bylaws. All General and Full Members of NPCC can participate in the balloting of regional standards. Any entity or person, including non-NPCC members, may submit comments during the open process comment periods for standards.

NON-NPCC MEMBERS Any entity or person that is neither a General nor Full Member of NPCC is not eligible to participate in the ballot body voting on a regional standard. However, any entity or person, including non-NPCC members, may submit comments during the open process comment periods for standards. Subject Matter Experts (SMEs), regardless of NPCC membership status, are encouraged to participate in comment periods for regional standards.

NPCC STANDARDS STAFF The Standards Staff is responsible for assisting the NPCC Manager of Reliability Standards and the RSC in administering the NPCC regional standards processes in accordance with this manual.

NPCC COMMITTEES, TASK FORCES AND WORKING GROUPS The Committees, Task Forces and Working Groups within NPCC serve an active role in the standards process. Activities performed by these groups include, but are not limited to, the following:

• Identify the need for new or modified regional standards

• Initiate NPCC Standards actions by developing Regional Standard Authorization Requests (RSARs)

• Develop comments (views and objections) to standards actions

• Participate in NPCC Standard drafting

• Dispensation of Request for Clarifications (RFCs)

• Provide technical oversight in response to changing industry conditions and ERO Requirements

• Conduct Field Tests, as required REGIONAL STANDARDS COMMITTEE (RSC)

The NPCC Regional Standards Committee (RSC), a committee of the NPCC Board of Directors, is charged with oversight of all drafting team activities and managing the NPCC regional standards development process in accordance with this manual.

The RSC is responsible for maintenance of the Regional Standard Processes Manual (RSPM), including the endorsement of RSPM revisions for NPCC Board review and approval.

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 11 Approved by the NPCC Board xxxx xx, 2013

RELIABILITY COORDINATING COMMITTEE (RCC) The Reliability Coordinating Committee (RCC) supports the standards development process through the assignment of NPCC Task Forces to serve as technical resources for: (1) staffing drafting teams, and (2) performing a technical advisory role in the regional standards process through comments, recommendations and technical justifications.

REQUESTER Any individual representing an organization (entity, company, government agency, etc.) that is directly and materially affected by the reliability of the Bulk Electric System within the NPCC geographical area may request a regional standard be developed or an existing regional standard be modified, clarified, or deleted.

QUALITY REVIEW TEAM The NPCC Standards Staff shall coordinate a quality review of the “final draft” of the regional standard, implementation plan, VRFs and VSLs to assess whether the documents are within the scope of the associated RSAR, whether the regional standard is clear and enforceable as written and the VRFs and VSLs are developed according to NERC and FERC guidelines. The Quality Review Team may be comprised of legal and compliance representatives, a technical writer, and NPCC Standards Staff. It will not involve individuals who participated on the drafting team of the standard undergoing the Quality Review.

2. STANDARD DEVELOPMENT PROCESS STEPS

STEP 2.1: REGIONAL STANDARDS AUTHORIZATION REQUEST TO DEVELOP, MODIFY OR RETIRE

A Regional Standard Authorization Request12 (RSAR) is the form used to document the scope and reliability benefit of a proposed project for one or more new or modified regional standards or the benefit of retiring one or more approved regional standards.

A RSAR shall be used to seek approval and initiate the development, modification or retirement of a NPCC regional standard. A RSAR is not used to seek a Request for Clarification (RFC) of a NPCC regional standard. The initiation and handling of a RFC is covered in Step 3 STANDARD CLARIFICATION PROCESS STEPS, of this manual.

Any individual representing an organization which is directly or materially impacted by the operation of the Bulk Electric System within the geographical footprint of NPCC may request, via a submittal of a RSAR to the NPCC Manager of Reliability Standards, the development, modification, or deletion of a NPCC regional standard. The individual completing the form is referred to herein as the Requester.

STEP 2.1.A. REQUESTER ACTIONS

Note: The NPCC Manager of Reliability Standards will assist the Requester, as necessary, to ensure all required information is submitted on the RSAR.

The Requester shall complete a RSAR form in accordance with the guidance provided in APPENDIX A: RSAR COMPLETION GUIDELINES.

The Requester shall submit the completed RSAR to the NPCC Manager of Reliability Standards, via npccstandard@npcc.org, for processing.

12 The RSAR is located on the NPCC website under Standards – Regional Standards General

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 12 Approved by the NPCC Board xxxx xx, 2013

STEP 2.1.B. NPCC MANAGER OF RELIABILITY STANDARDS ACTIONS

The NPCC Manager of Reliability Standards shall review the submitted RSAR and verify that the submitted form has been adequately completed. Within fifteen (15) calendar days 13 of receipt of the submitted RSAR, the NPCC Manager of Reliability Standards will electronically acknowledge receipt of the RSAR. If, at that time, the NPCC Manager of Reliability Standards finds the RSAR to be deficient, the Requester will be contacted to determine how to proceed.

Within ten (10) calendar days of the receipt of an adequately completed RSAR, the NPCC Manager of Reliability Standards shall forward the properly completed RSAR to the NPCC Regional Standards Committee (RSC) for its review and processing. Included in the transmittal of the RSAR to the RSC, the NPCC Manager of Reliability Standards shall include a statement indicating the applicability of the NPCC Cost Effectiveness Analysis Procedure (CEAP) for the proposed change.

STEP 2.1.C. NPCC REGIONAL STANDARDS COMMITTEE (RSC) ACTIONS

Note: The RSC shall meet to review all pending RSARs. The frequency of this review process will depend on workload, but in no case shall a properly completed RSAR wait for RSC action more than 60 calendar days from the date of receipt by the RSC.

The RSC shall review the RSAR and take one of the following actions:

• Remand the RSAR back to the NPCC Manager of Reliability Standards for additional work. In this case, the NPCC Manager of Reliability Standards shall work with the Requester to provide additional information or clarification for the RSAR as specified by the RSC.

• Reject the RSAR. In this case, the RSC will provide its determination to the NPCC Manager of Reliability Standards, who will then provide a written explanation for rejection to the Requester within ten (10) calendar days of the rejection decision.

Note: Before the RSC can accept a RSAR for a new or modified standard the applicable CEAP process steps shall be completed.

• Accept the RSAR. o If a new or modified standard has been authorized, within ten (10) calendar days of the

authorization the NPCC Manager of Reliability Standards shall: 1) post notification on the NPCC website of the intent to develop or modify a regional standard; 2) notify the ERO for processing in accordance with its process, as applicable; and 3) notify the Requester of the acceptance of the RSAR.

o If the retirement of an existing regional standard has been authorized, within ten (10) calendar days of the authorization the NPCC Manager of Reliability Standards shall: 1) post notification on the NPCC website of the intent to retire an existing regional standard; 2) notify the ERO for processing in accordance with its process, as applicable; and 3) notify the Requester of the acceptance of the RSAR. The process to

13 Time periods specified in this manual may be extended as deemed appropriate by NPCC Staff. When business days are specified, this provision could be used to take into account differing Canadian and US holiday schedules. When calendar days are specified, this provision could be used to take into account due dates that fall on a weekend.

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 13 Approved by the NPCC Board xxxx xx, 2013

retire an existing regional standard is included in Step 6 RETIREMENT OF AN APPROVED NPCC REGIONAL STANDARD.

STEP 2.2: FORMATION OF DRAFTING TEAM FOR NEW OR MODIFIED STANDARD

A RSAR that has been accepted by the RSC shall, within ten (10) calendar days of the acceptance of the RSAR, be submitted by the NPCC Manager of Reliability Standards to the NPCC Reliability Coordinating Committee (RCC). The RCC shall, within sixty (60) calendar days, assign the development of the regional standard to a NPCC Task Force, and notify the NPCC Manager of Reliability Standards of its decision within ten (10) calendar days.

After receipt of the notification of drafting team assignment, the NPCC Manager of Reliability Standards shall oversee solicitation and recommendation of a list of additional qualified 14 candidates over and above the appropriate NPCC Task Force members, for appointment to the drafting team. The Requester and a NPCC Compliance Staff person will be included on the drafting team. Within sixty (60) calendar days of the drafting team assignment notification from the RCC, the NPCC Manager of Reliability Standards shall submit the list of the entire drafting team membership to the RSC for acceptance. The RSC may accept the recommendations of the NPCC Manager of Reliability Standards as presented or revise the recommendations as necessary.

Upon acceptance of the drafting team slate, the RSC shall provide a target date on which the drafting team is expected to have ready a completed draft regional standard and associated supporting documentation available for consideration by the NPCC membership. Additionally, the RSC shall provide the drafting team with any preliminary development products including, but not limited to, a draft standard, comments, and related white papers.

The RSC shall designate one of its members to actively monitor and assist NPCC staff in the oversight of drafting team milestones and deadlines, and extend or expedite milestones and deadlines, as appropriate, acting as a liaison between the drafting team and the RSC to help resolving any issues.

STEP 2.3: DEVELOPMENT OF A REGIONAL STANDARD AND ASSOCIATED DOCUMENTS

Prior to beginning work on the development of a new or revised regional standard and the associated supporting documentation, the drafting team should develop a work plan for completing the regional standard development work, including the establishment of milestones for completing critical elements of the work in sufficient detail to ensure that the drafting team will meet the target date established by the RSC, or the drafting team shall propose an alternative date. This work plan must be submitted to the RSC for its concurrence. When a drafting team begins its work, it shall regularly (at least quarterly) report progress against that aforementioned work plan to the NPCC Manager of Reliability Standards for presentation to the RSC.

14 Refer to Appendix B: Selection of Drafting Team Members

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 14 Approved by the NPCC Board xxxx xx, 2013

Note: During the regional standards development, the drafting team will deliberate on whether the requirements in the regional standard are developed enough to begin the Cost Effectiveness Analysis (CEA) of the NPCC Cost Effectiveness Analysis Procedure (CEAP). When appropriate, the drafting team shall request that the RSC initiate the second phase (CEA) of the CEAP process.

The drafting team shall create and manage its work structure (e.g., sub-teams) and meeting schedule (face-to-face as well as electronic meetings), as necessary, to meet the milestone dates and project deliverables outlined in the work plan.

The work products of the drafting team should consist of the following

• A draft regional standard consistent with the RSAR on which it was based

• An implementation plan, including the nature, extent and duration of field-testing, if any

• Identification of any existing regional standard and NPCC criteria that will be deleted, in part or whole, or otherwise impacted by the implementation of the draft regional standard

• Technical reports, white papers and/or work papers that provide technical justification for the draft regional standard under consideration

• Reliability Standard Audit Worksheet (RSAW) collaboratively developed by the drafting team and NPCC Compliance Staff

Any proposed changes to definitions in existing regional standards should be sent to the appropriate Task Force (TF) for consideration of the impact to the standard. If necessary, the TF can produce a RSAR.

NPCC Standards Staff can assist in the drafting of the regional standard including compliance measures, process and elements. The drafting of measures and compliance administration aspects of the standard will be coordinated with the NPCC Compliance Staff.

The drafting team shall submit the initial and subsequent interim drafts of the regional standard and associated documents to the NPCC Manager of Reliability Standards to obtain RSC concurrence to post documents for comment.

STEP 2.4: POSTING FOR COMMENT PERIOD AND RESOLUTION OF COMMENTS

Note: There are no limits to the number of public comment periods and ballots that can be conducted to result in a regional standard that is clear and enforceable, and achieves a quorum and sufficient affirmative votes for approval.

STEP 2.4.A. COMMENT PERIOD

Note: For Final Comment Period skip this step and proceed to STEP 2.4.B. FINAL COMMENT PERIOD.

As authorized by the RSC, the NPCC Manager of Reliability Standards shall post the draft of the regional standard on the NPCC website, along with a draft implementation plan and available supporting documents, for a forty-five (45) calendar day comment period. The NPCC Manager of Reliability Standards shall also notify NERC to process the draft document in accordance with NERC’s regional standards review procedure, as applicable.

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 15 Approved by the NPCC Board xxxx xx, 2013

Following the conclusion of the NPCC comment period, the NPCC Manager of Reliability Standards will assemble the comments on the draft regional standard and associated documents and provide all comments to the drafting team for consideration.

Within thirty (30) calendar days of the conclusion of the comment period the drafting team shall convene and consider changes to the draft Standard, the implementation plan and/or supporting technical documents based upon comments received. All submitted comments shall be addressed, and each commenter shall be advised of the disposition, with reasons, of their comments. The NPCC Manager of Reliability Standards shall publicly post all of the drafting team’s responses to stakeholder comments on the NPCC website.

Based on the comments received, the drafting team may elect to:

• Return to STEP 2.3: DEVELOPMENT OF A REGIONAL STANDARD AND ASSOCIATED DOCUMENTS to revise the draft regional standard, the implementation plan and/or supporting technical documents.

• Recommend that the RSC authorize Field Testing of the draft regional standard. Upon completion of the Field Test, return to STEP 2.3: DEVELOPMENT OF A REGIONAL STANDARD AND ASSOCIATED DOCUMENTS to revise the draft regional standard based on insights learned during the Field Test.

• Obtain RSC concurrence to post documents for Final Comment Period and request that the RSC initiate the second phase (CEA) of the CEAP process

STEP 2.4.B. FINAL COMMENT PERIOD The NPCC Standards Staff shall coordinate a Quality Review of “final draft” of the regional standard, implementation plan, VRFs and VSLs to assess whether the documents are within the scope of the associated RSAR, whether the regional standard is clear and enforceable as written and the VRFs and VSLs are developed according to NERC and FERC guidelines. Upon Completion of the Quality Review, including resolution of comments, the drafting team shall submit the regional standard to the NPCC Manager of Reliability Standards to obtain RSC concurrence to post these documents for comment.

As authorized by the RSC, the NPCC Standards Staff shall post the “final draft” of the regional standard on the NPCC website, along with the implementation plan, supporting documents and the Cost Effectiveness Analysis (CEA) survey15 for a forty-five (45) calendar day comment period. NPCC Standards Staff shall also notify NERC to process the proposed final document in accordance with NERC’s regional standards review procedure, as applicable.

Following the conclusion of the NPCC comment period, the NPCC Manager of Reliability Standards will assemble the comments on the posted regional standard and associated documents and provide all comments to the drafting team for consideration.

In addition, the RSC, pursuant with the requirements of the Cost Effectiveness Analysis Procedure (CEAP), will use the responses to the posted CEA survey to develop a recommendation based on the cost effectiveness of the proposed regional standard.

15 In accordance to the Cost Effectiveness Analysis Procedure (CEAP) the Cost Effectiveness Analysis (CEA) survey may be assigned directly to NPCC Task Forces (TFs) or Working Groups (WGs) in addition to the posting process.

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 16 Approved by the NPCC Board xxxx xx, 2013

The NPCC Task Forces (TFs) or Working Groups (WGs) may develop recommendations for submittal to the RSC. Following the RSC deliberations to determine a course of action, the RSC will communicate to the drafting team to:

• Return to STEP 2.3: DEVELOPMENT OF A REGIONAL STANDARD AND ASSOCIATED DOCUMENTS to revise the Standard to address the results of the CEAP

• Accept the Standard “as is” to move forward through the remainder of the process

• Hold the Standard in abeyance until such time as additional guidance can be provided regarding whether or how to continue

• Decide not to pursue the development of certain requirements or the entire Standard due to cost effectiveness considerations

Upon Completion of the final comment period the drafting team shall submit the proposed regional standard, along with any supporting materials, consideration of comments and field test results, to the NPCC Manager of Reliability Standards to obtain RSC concurrence to post the regional standard for ballot and concurrently provide an information copy to the RCC.

The NPCC Manager of Reliability Standards shall also publicly post all of the drafting team’s responses to stakeholder comments on the NPCC website.

STEP 2.5: POSTING FOR BALLOT PERIOD IN THE OPEN PROCESS

Note: There are no limits to the number of public comment periods and ballots that can be conducted to result in a regional standard that is clear and enforceable, and achieves a quorum and sufficient affirmative votes for approval.

As authorized by the RSC, the NPCC Manager of Reliability Standards shall post the proposed regional standard on the NPCC website, along with supporting documentation 16 (e.g., implementation plan, consideration of comments, technical reports, white papers and any field test results), for a thirty (30) day pre-ballot review period and a subsequent ten (10) day ballot period. The ten (10) day ballot period will commence immediately following the pre-ballot review period. In the event that a quorum exists for purposes of an electronic vote but the ballot purpose has not been resolved, NPCC may continue to solicit additional responses in order to resolve the matter by electronic voting. In the event that quorum has not been achieved for purposes of an electronic vote, NPCC may continue to solicit electronic ballots, including abstentions, to obtain quorum and resolve the matter.

At the time the regional standard is posted for ballot, the NPCC Manager of Reliability Standards shall also notify NERC to process the proposed regional standard in accordance with NERC’s regional standards review procedure, as applicable.

During the ballot period, the NPCC Members of the ballot body can cast their vote as follows:

• Affirmative, with or without comments

• Negative with comments

• Abstain

16 The ballot posting is for the regional standard, definition, variance or clarification. Supporting documentation is

included for information only and is not balloted.

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 17 Approved by the NPCC Board xxxx xx, 2013

In accordance with the NPCC Bylaws, a quorum and receipt of a two-thirds (2/3) affirmative majority of the weighted sector votes is required for a ballot to pass.

The NPCC Manager of Reliability Standards shall post the final outcome of the ballot process on the NPCC website.

STEP 2.5.A. BALLOT DOES NOT RECEIVE 2/3 AFFIRMATIVE VOTE If a ballot fails to achieve the 2/3 majority vote the NPCC Manager of Reliability Standards may:

• Direct the drafting team to respond to ballot comments and return to STEP 2.5: POSTING FOR BALLOT PERIOD IN THE OPEN PROCESS to re-ballot the regional standard. The consideration of comments from prior ballot will be included with the re-posting.

• Return to STEP 2.3: DEVELOPMENT OF A REGIONAL STANDARD AND ASSOCIATED DOCUMENTS to revise the regional standard to address the comments received.

• Pursue the discontinuance of the regional standard development by soliciting the Requester to withdraw the RSAR or by soliciting the RSC to reject the RSAR pursuant with STEP 2.1.C. NPCC REGIONAL STANDARDS COMMITTEE (RSC) ACTIONS. The NPCC Manager of Reliability Standards, in the event of a discontinuance of the development of a regional standard, shall post a notice of the discontinuance and will post and archive all comments submitted during the process for future consideration, if required. The NPCC Manager of Reliability Standards will also notify NERC to process the proposed regional standard in accordance with NERC’s regional standards review procedure, as applicable.

STEP 2.5.B. BALLOT RECEIVES ≥ TWO-THIRDS (2/3) AFFIRMATIVE VOTE A ballot that achieved two-thirds or greater affirmative vote has successfully passed. However, negative votes with comments should still be reconciled. If there is at least one negative vote with comments proceed to STEP 2.5.B.1 APPROVED BALLOT WITH “NEGATIVE VOTE WITH COMMENT”. If there was not any negative vote with comments proceed to STEP 2.5.B.2 APPROVED BALLOT WITHOUT “NEGATIVE VOTE WITH COMMENT”.

STEP 2.5.B.1 APPROVED BALLOT WITH “NEGATIVE VOTE WITH COMMENT” Following the conclusion of the NPCC ballot period, the NPCC Manager of Reliability Standards will assemble the comments on the posted regional standard and provide all comments to the drafting team for consideration. The drafting team shall review all negative votes with comments and elect to:

• Recommend to the RSC to accept the regional standard “as is” and seek RSC endorsement to move forward through the remainder of the process. Upon receiving RSC endorsement to proceed, the regional standard and associated documents, approved by the NPCC ballot body, shall be forwarded by the Assistant Vice President Standards to the NPCC Board of Directors for final Regional approval. If comments that were received during balloting should be considered in future revisions to the regional standard then the NPCC Manager of Reliability Standards should log comments in an issues database.

• Return to STEP 2.3: DEVELOPMENT OF A REGIONAL STANDARD AND ASSOCIATED DOCUMENTS to revise the regional standard to address the comments received.

• Respond to ballot comments and recommend to the RSC endorse the return to STEP 2.5: POSTING FOR BALLOT PERIOD IN THE OPEN PROCESS to re-ballot the regional standard.

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 18 Approved by the NPCC Board xxxx xx, 2013

The NPCC Manager of Reliability Standards should include the consideration of comments from the prior ballot with the re-posting.

STEP 2.5.B.2 APPROVED BALLOT WITHOUT “NEGATIVE VOTE WITH COMMENT” Regional standard and associated documents, approved by the NPCC ballot body, shall be forwarded by the Assistant Vice President Standards to the NPCC Board of Directors for final Regional approval.

STEP 2.6: NPCC BOARD OF DIRECTORS APPROVAL

Following approval by the NPCC Members, regional standards require review and approval by the NPCC Board of Directors. The NPCC Board of Directors may take the following actions:

• Approve the regional standard as presented.

• Approve the regional standard with comments to incorporate non-substantive revisions. [The NPCC Board of Directors may not make substantive revisions to the standard.]

• Remand the regional standard back to the RSC and the drafting team to address their concerns. The RSC / drafting team can address the BOD comments and re-submit for BOD approval or return to STEP 2.3: DEVELOPMENT OF A REGIONAL STANDARD AND ASSOCIATED DOCUMENTS to revise the regional standard to address the comments received.

STEP 2.7: NERC BOARD OF TRUSTEES SUBMITTAL

Upon approval by the NPCC Board of Directors, the NPCC Manager of Reliability Standards shall submit the regional standard to NERC, as the Electric Reliability Organization, for approval and subsequent filing with FERC and the applicable Canadian Provincial regulatory and/or governmental authorities for adoption.

STEP 2.8: IMPLEMENTATION OF A NPCC REGIONAL STANDARD

Following the approval of a NPCC regional standard by FERC and the applicable Canadian Provincial regulatory and/or governmental authorities, all users, owners, and operators of the Bulk Electric System in the NPCC geographic area are required to comply with the standard as of its enforcement date.

ERO approved Reliability Standards (both continent-wide and regional) are included in both the NERC and NPCC Compliance Monitoring and Enforcement Programs (CMEPs).

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 19 Approved by the NPCC Board xxxx xx, 2013

FIGURE 1: FLOWCHART OF REGIONAL STANDARDS DEVELOPMENT PROCESS OVERVIEW

3. STANDARD CLARIFICATION PROCESS STEPS

This section applies to NPCC regional standards that have been approved17 and are currently enforceable or have a future enforcement date. A clarification request is not permitted for regional standards under development. For regional standards under development, an explanation of a requirement or its meaning can be sought during a comment period. Refer to Step 2, STANDARD DEVELOPMENT PROCESS STEPS of this manual for details on the comment process for a standard under development.

STEP 3.1: REGIONAL STANDARDS CLARIFICATION REQUEST (CR)

Any member of NPCC or group within the NPCC region shall be allowed to submit a Clarification Request (CR) for a NPCC regional standard.

17 Approval is granted by FERC and the Canadian Provincial regulatory and/or governmental authorities, as

applicable.

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 20 Approved by the NPCC Board xxxx xx, 2013

Additionally, any person (organization, company, government agency, individual, etc.) who is directly and materially affected by the reliability of the NPCC Bulk Electric System shall be allowed to submit a Clarification Request (CR) for a NPCC regional standard.

Note: A valid Clarification Request is one that seeks additional clarity about one or more requirements in an approved regional standard, but does not request approval as to how to comply with any requirements of the standard.

The Requester should submit a Clarification Request 18 (CR) for a NPCC regional standard directly to the NPCC Manager of Reliability Standards, via npccstandard@npcc.org, for processing. Alternatively, the Requester can submit a Request for Interpretation (RFI) of a NPCC regional standard under the NERC process for developing an interpretation 19 to the NERC Reliability Standards Staff explaining the clarification required, the specific circumstances surrounding the request, and the impact of not having the clarification provided. A copy of the completed RFI form should also be sent to the NPCC Manager of Reliability Standards.

NERC Reliability Standards Staff will refer the RFI to NPCC and delegate its resolution to NPCC. NPCC will process the NERC delegation pursuant with the NPCC Clarification Request (CR) process described herein.

STEP 3.2: REVIEW AND VALIDATION OF CLARIFICATION REQUEST (CR)

Upon receipt of a Clarification Request (CR) for a NPCC regional standard, the NPCC Manager of Reliability Standards shall review the CR to determine whether:

• It meets the requirements for a valid Clarification Request

• A compliance process or approach could be used in lieu of a clarification The NPCC Manager of Reliability Standards will utilize, as necessary, the NPCC Standards Staff, NPCC Compliance and Legal Staffs when determining the validity of the CR. Based on this review, the NPCC Manager of Reliability Standards will recommend to the RSC whether to accept or reject the CR. The recommendation to the RSC should be made within thirty (30) calendar days of the receipt of the CR.

The following examples identify situations that may warrant a recommendation from the NPCC Manager of Reliability Standards to reject the CR:

• Requests approval of a particular compliance approach

• Identifies a gap or perceived weakness in the approved regional standard (Requester should be redirected to initiate a RSAR rather than a CR)

• Where an issue can be addressed by an active (regional or continent-wide) standard drafting team

• Where an issue can be better addressed by a compliance process or approach

• Where it requests clarification of any element of a regional standard other than a requirement

18 The NPCC Clarification Request form is included as Appendix D 19 The Request for Interpretation form is posted under Resource Documents on the NERC Standards webpage.

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 21 Approved by the NPCC Board xxxx xx, 2013

• Where a question has already been addressed in the record

• Where the clarification identifies an issue and proposes the development of a new or modified regional or continent-wide standard (such issues should be addressed via submission of a RSAR or SAR)

• Where a clarification seeks to expand the scope of a regional standard

• Where the requirement of the regional standard is clear

STEP 3.3: NPCC REGIONAL STANDARDS COMMITTEE (RSC) ACTIONS

The RSC shall review the CR along with the recommendation from the NPCC Manager of Reliability Standards and take one of the following actions:

• Reject the CR. In this case, the RSC will provide its determination to the NPCC Manager of Reliability Standards, who will then provide a written explanation for rejection to the CR to the entity requesting the clarification within ten (10) calendar days of the decision to reject.

• Accept the CR. In this case, the RSC will provide its determination to the NPCC Manager of Reliability Standards, who will then: 1) post notification on the NPCC website of the intent to develop a clarification; 2) notify the NPCC Reliability Coordinating Committee (RCC) of the need to assign the resolution of the CR to one or more Task Forces (if more than one Task Force is assigned, one of them shall be assigned the lead role); and 3) notify the Requester of the acceptance of the CR. The notifications shall be made within ten (10) calendar days of the acceptance of the CR.

STEP 3.4: FORMATION OF DRAFTING TEAM FOR RESPONSE TO CR

A CR that has been accepted by the RSC shall be assigned by the RCC to the responsible NPCC Task Force to make up the clarification drafting team (CDT) and develop the CR response.

STEP 3.5: DEVELOPMENT OF RESPONSE TO CR

Note: A valid clarification response provides additional clarity about one or more requirements, but does not expand on any requirement and does not explain how to comply with any requirement.

Within sixty (60) calendar days from the receipt of being assigned to respond to a CR, the CDT shall submit a proposed clarification response to the NPCC Manager of Reliability Standards. Upon receipt of the proposed clarification response from the CDT, the NPCC Manager of Reliability Standards shall present the response to the RSC to obtain concurrence to post the proposed response for comment.

Along with the proposed clarification response, the drafting team shall also develop and submit a set of questions to be included in the comment form, for approval by the RSC.

If the RSC concurrence is not received, the drafting team will continue to refine the clarification response.

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 22 Approved by the NPCC Board xxxx xx, 2013

Note: There are no limits to the number of public comment periods that can be conducted to result in a clear and concise clarification of a regional standard requirement.

STEP 3.6: POSTING CR FOR COMMENT PERIOD AND RESOLUTION OF COMMENTS

As authorized by the RSC, the NPCC Manager of Reliability Standards shall post the proposed clarification response on the NPCC website for a forty-five (45) calendar day comment period.

Following the conclusion of the NPCC comment period, the NPCC Manager of Reliability Standards will assemble the comments on the proposed clarification response and provide all comments to the drafting team for consideration.

Within thirty (30) calendar days of the conclusion of the comment period the drafting team shall convene and consider changes to the proposed clarification response based upon comments received. All submitted comments shall be addressed, which may be in the form of a summary response addressing each of the issues raised in comments received. The NPCC Manager of Reliability Standards shall publicly post all of the drafting team’s responses to stakeholder comments on the NPCC website.

Based on the comments received, the drafting team may elect to:

• Return to STEP 3.5: DEVELOPMENT OF RESPONSE TO CR to revise the proposed clarification response.

• Accept the proposed clarification response “as is” to move forward through the remainder of the process.

Upon acceptance of the proposed clarification response “as is,” the drafting team shall submit the proposed clarification response to the NPCC Manager of Reliability Standards to obtain RSC endorsement to the submitted CR response.

STEP 3.7: REGIONAL STANDARDS COMMITTEE APPROVAL OF CR

Upon receipt of the CR response from the NPCC Manager of Reliability Standards, the RSC shall elect to:

• Endorse the proposed clarification response and direct the NPCC Assistant Vice President Standards to forward the CR to the NPCC Board of Directors for final Regional approval; or

• Direct the drafting team to return to STEP 3.5: DEVELOPMENT OF RESPONSE TO CR to revise the proposed clarification response

STEP 3.8: NPCC BOARD OF DIRECTORS APPROVAL OF CR

Following endorsement by the RSC, clarification responses require review and approval by the NPCC Board of Directors. The NPCC Board of Directors may take the following actions:

• Approve the clarification response as presented

• Approve the clarification response with comments to incorporate non-substantive revisions. [The NPCC Board of Directors may not make substantive revisions to the clarification response.]

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 23 Approved by the NPCC Board xxxx xx, 2013

• Remand the clarification response back to the RSC and the drafting team to address their concerns

Upon receipt of Board approval, the NPCC Manager of Reliability Standards shall notify the Requestor and post the approved clarification on the NPCC website.

FIGURE 2: FLOWCHART OF REGIONAL STANDARDS CLARIFICATION PROCESS OVERVIEW

4. DISCONTINUANCE OF REGIONAL STANDARD DEVELOPMENT

The term “discontinuance” as used herein refers to terminating the standard development process after RSAR approval but prior to posting a regional standard for industry ballot. From time to time the need or rationale for a regional standard may change thereby necessitating the regional standard development be curtailed. Upon notification or determination that a regional standard under development should be considered for discontinuance due to a perceived change in the need for the standard, the NPCC Manager of Reliability Standards will submit the recommendation for discontinuance to the RSC for approval.

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 24 Approved by the NPCC Board xxxx xx, 2013

5. WITHDRAWAL OF A REGIONAL STANDARD PENDING APPROVAL

The term “withdrawal” as used herein, refers to the revocation of a request for approval of a regional standard, variance, clarification or definition that has been approved by the NPCC Board of Directors and has not been filed with Applicable Governmental Authorities or has been filed but not yet approved by Applicable Governmental Authorities. The RSC may withdraw a regional standard, variance, clarification or definition for good cause subject to approval by the NPCC Board of Directors. Upon approval by the NPCC Board of Directors, the NPCC Manager of Reliability Standards will notify NERC Staff to petition the Applicable Governmental Authorities, as necessary, to allow for withdrawal in the case that the regional standard has been filed.

6. RETIREMENT OF AN APPROVED NPCC REGIONAL STANDARD

The term “retirement” refers to the discontinuation of a regional standard in whole, certain requirements within a regional standard, a variance, clarification or definition that: 1) has been approved by Applicable Governmental Authorities and 2) is not being superseded by or merged into a new or revised regional standard, clarification or definition.

Upon identification of a need for retirement, a RSAR containing the proposal of the retirement will be handled in accordance with the STEP 2.1: REGIONAL STANDARDS AUTHORIZATION REQUEST TO DEVELOP, MODIFY OR RETIRE. The proposal shall include the rationale for the retirement and a statement regarding the impact of retirement on the reliability of the Bulk Electric System. Upon approval by the NPCC Members and the NPCC Board of Directors, the NPCC Manager of Reliability Standards shall submit the request for retirement to NERC, as the Electric Reliability Organization, for approval and to subsequently petition the Applicable Governmental Authorities to allow for retirement.

7. APPROVAL OF PROCESS WAIVER

While it is NPCC’s intent to adhere to this manual under normal circumstances, NPCC may need to develop a new or modified regional standard, implementation plan, variance, clarification or definition under extenuating circumstances. Extenuating circumstances may include, but not be limited to, specific time constraint imposed by a regulatory body and urgent reliability issue that requires expedited handling outside of the normal regional Reliability Standards process.

The RSC, by two-thirds (2/3) majority vote, may waive any of the provisions contained in this manual for good cause shown, but limited to the following circumstances:

• Where necessary to meet regulatory deadlines

• Where necessary to address an urgent reliability issue identified by regulatory and/or governmental authorities, including response to national emergency declared by the United States or Canadian government that involves the reliability of the Bulk Electric System or cyber-attack on the Bulk Electric System

• Where necessary to meet deadlines imposed by the NPCC Board of Directors

• Where the RSC determines that a revision to a proposed regional standard, implementation plan, variance, clarification or definition has already been vetted by the industry through the standards development process or is so insubstantial that developing the revision

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 25 Approved by the NPCC Board xxxx xx, 2013

through the processes contained in this manual will add significant time delay without any corresponding benefit.

In no circumstances shall this provision be used to modify the requirements for achieving quorum or the voting requirements for approval of a standard.

A waiver request may be submitted to the RSC by any entity or individual, including NPCC committees or subgroups and NPCC Standards Staff. Prior to consideration of any waiver request, the NPCC Manager of Reliability Standards must provide notification to stakeholders at least five (5) business days prior to RSC consideration and action. Posting the waiver request on the NPCC website satisfies the notification provision.

Action on the waiver request will be included in the minutes of the RSC. Following the approval of the RSC to waive any provision of the regional Reliability Standards process, the Assistant Vice President Standards shall report the exercise of this waiver provision to the NPCC Board of Directors prior to adoption of the related Reliability Standard, clarification, definition or variance. Actions taken pursuant to an approved waiver request will be posted on the NPCC Standards webpage.

8. PROCESS FOR CORRECTING ERRATA

From time to time, an error may be discovered in a regional standard after it has received final ballot approval by the NPCC ballot body. Such errors may be corrected by the RSC without re-balloting if the RSC agrees that the correction of the error does not change the scope or intent of the associated regional standard, and agrees that the correction has no material impact on the end users of the regional standard.

If the regional standard containing errata is pending approval by the NPCC Board of Directors, the corrected regional standard shall be presented to the NPCC Board for approval in lieu of the regional standard approved by the NPCC ballot body.

If a regional standard containing errata had received prior approval by the NPCC Board of Directors, the corrected regional standard shall be presented to the NPCC Board for approval. Upon approval by the Board, the corrected regional standard will be filed for approval by NERC.

The NPCC Board of Directors has resolved to concurrently approve any errata approved by the RSC associated with a regional standard that has received prior approval by the NPCC Board.

9. APPEALS

Persons who have directly and materially affected interests and who have been or will be adversely affected by any substantive or procedural action or inaction related to the approval, revision, reaffirmation, or withdrawal of a regional standard (appellant) shall have the right to appeal. This appeals process applies only to the regional standards process as defined in this manual.

The burden of proof to show adverse effect shall be on the appellant. Appeals shall be made within thirty (30) calendar days of the date of the action purported to cause the adverse effect, except appeals for inaction, which may be made at any time. In all cases, the request for appeal must be made prior to the next step in the process.

The final decisions of any appeal shall be documented in writing and made public.

NPCC Regional Standard Processes Manual (RSPM)

RSPM Version 1 26 Approved by the NPCC Board xxxx xx, 2013

The appeals process provides two levels, with the goal of expeditiously resolving the issue to the satisfaction of the participants:

LEVEL 1 APPEAL

Level 1 is the required first step in the appeals process. The appellant submits a complaint in writing to the NPCC Manager of Reliability Standards that describes the substantive or procedural action or inaction associated with a Reliability Standard or the standards process. The appellant describes in the complaint the actual or potential adverse impact to the appellant. Assisted by any necessary NPCC Standards Staff and Committee resources, the NPCC Manager of Reliability Standards shall prepare a written response addressed to the appellant as soon as practical, but not more than forty-five (45) calendar days after receipt of the complaint. If the appellant accepts the response as a satisfactory resolution of the issue, both the complaint and response will be made a part of the public record associated with the standard and posted with the standard.

LEVEL 2 APPEAL

If after the Level 1 Appeal the appellant remains unsatisfied with the resolution, as indicated by the appellant in writing to the NPCC Manager of Reliability Standards, the NPCC Board of Directors shall appoint a five member panel to serve as a Level 2 Appeals Panel.

In all cases, Level 2 Appeals Panel members shall have no direct affiliation with the participants in the appeal.

The NPCC Manager of Reliability Standards shall post the complaint and other relevant materials and provide at least a thirty (30) calendar day notice of the meeting of the Level 2 Appeals Panel.

In addition to the appellant, any person that is directly and materially affected by the substantive or procedural action or inaction referenced in the complaint shall be heard by the panel. The panel shall not consider any expansion of the scope of the appeal that was not presented in the Level 1 Appeal. The panel may in its decision find for the appellant and remand the issue to the RSC with a statement of the issues and facts in regard to which unfair and/or inequitable action was taken, or which fair and/or equitable action was not taken. The panel may find for or against the appellant with a specific statement of the facts that demonstrate fair and equitable treatment of the appellant and the appellant’s objections. The panel may not, however, revise, approve, disapprove, or adopt a Reliability Standard. The actions of the Level 2 Appeals Panel shall be publicly posted.

In addition to the foregoing, a procedural objection that has not been resolved may be submitted to the NPCC Board of Directors for consideration at the time the Board decides whether to adopt a particular Reliability Standard. The objection must be in writing, signed by an officer of the objecting entity, and contain a concise statement of the relief requested and a clear demonstration of the facts that justify that relief. The objection must be filed no later than thirty (30) calendar days after the announcement of the vote on the standard in question.

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 A1 Approved by the NPCC Board xxxx xx, 2013

APPENDIX A: RSAR COMPLETION GUIDELINES The Requester shall complete a RSAR form in accordance with the guidance provided below.

The RSAR, at a minimum, shall contain information in the required fields in order to be qualified for consideration. The NPCC Manager of Reliability Standards will assist the Requester to ensure all required information is submitted on the RSAR.

Information in a Regional Standard Authorization Request (RSAR) The tables below identify information to be submitted in a Regional Standard Authorization Request to the NPCC Manager of Reliability Standards, at npccstandard@npcc.org. The NPCC Manager of Reliability Standards shall be responsible for implementing and maintaining this form as needed to support the information requirements of the standards process.

Regional Standard Authorization Request Form Title of Proposed Standard: [Required Field]

Request Date: [Required Field]

RSAR Requester Information

Name: [Required Field] RSAR Type (Check box for one of these selections.)

Company: [Required Field] New Standard

Telephone: [Required Field] Revision to Existing Standard

Fax: Withdrawal of Existing Standard

Email: [Required Field] Urgent Action

Purpose: (Describe the purpose of the proposed standard – what the standard will achieve in support of reliability.)

[Required Field]

Industry Need: (Provide a detailed statement justifying the need for the proposed standard, along with a technical justification and any supporting documentation.)

[Required Field -- must include technical justification (relevant studies, documentation, etc.) for a new standard or revision to an existing standard.]

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 A2 Approved by the NPCC Board xxxx xx, 2013

Brief Description: (Describe the proposed standard in sufficient detail to clearly define the scope in a manner that can be easily understood by others.)

[Required Field]

Reliability Functions [Required Field] The Standard will Apply to the Following Functions (Check all applicable boxes.)

Reliability Coordinator

The entity that is the highest level of authority who is responsible for the reliable operation of the Bulk Electric System, has the Wide Area view of the Bulk Electric System, and has the operating tools, processes and procedures, including the authority to prevent or mitigate emergency operating situations in both next-day analysis and real-time operations. The Reliability Coordinator has the purview that is broad enough to enable the calculation of Interconnection Reliability Operating Limits, which may be based on the operating parameters of transmission systems beyond any Transmission Operator’s vision.

Balancing Authority

The responsible entity that integrates resource plans ahead of time, maintains load-interchange-generation balance within a Balancing Authority Area, and supports Interconnection frequency in real time.

Interchange Authority

Authorizes valid and balanced Interchange Schedules.

Planning Authority

The responsible entity that coordinates and integrates transmission facility and service plans, resource plans, and protection systems.

Transmission Service Provider

The entity that administers the transmission tariff and provides Transmission Service to Transmission Customers under applicable transmission service agreements.

Transmission Owner

The entity that owns and maintains transmission facilities.

Transmission Operator

The entity responsible for the reliability of its “local” transmission system, and that operates or directs the operations of the transmission facilities.

Transmission Planner

The entity that develops a long-term (generally one year and beyond) plan for the reliability (adequacy) of the interconnected bulk electric transmission systems within its portion of the Planning Authority Area.

Resource Planner

The entity that develops a long-term (generally one year and beyond) plan for the resource adequacy of specific loads (customer demand and energy requirements) within a Planning Authority Area.

Generator Operator

The entity that operates generating unit(s) and performs the functions of supplying energy and Interconnected Operations Services.

Generator Owner

Entity that owns and maintains generating units.

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 A3 Approved by the NPCC Board xxxx xx, 2013

Purchasing-Selling Entity

The entity that purchases or sells, and takes title to, energy, capacity, and Interconnected Operations Services. Purchasing-Selling Entities may be affiliated or unaffiliated merchants and may or may not own generating facilities.

Distribution Provider

Provides and operates the “wires” between the transmission system and the customer.

Load-Serving Entity

Secures energy and transmission service (and related Interconnected Operations Services) to serve the electrical demand and energy requirements of its end-use customers.

Reliability and Market Interface Principles Applicable Reliability Principles (Check all boxes that apply.)

1. Interconnected Bulk Electric System shall be planned and operated in a coordinated manner to perform reliably under normal and abnormal conditions as defined in the NERC Standards.

2. The frequency and voltage of interconnected Bulk Electric System shall be controlled within defined limits through the balancing of real and reactive power supply and demand.

3. Information necessary for the planning and operation of interconnected Bulk Electric System shall be made available to those entities responsible for planning and operating the systems reliably.

4. Plans for emergency operation and system restoration of interconnected Bulk Electric System shall be developed, coordinated, maintained, and implemented.

5. Facilities for communication, monitoring, and control shall be provided, used, and maintained for the reliability of interconnected Bulk Electric System.

6. Personnel responsible for planning and operating interconnected Bulk Electric System shall be trained, qualified, and have the responsibility and authority to implement actions.

7. The security of the interconnected Bulk Electric System shall be assessed, monitored, and maintained on a wide-area basis.

Does the proposed Standard comply with all of the following Market Interface Principles? (Select ‘yes’ or ‘no’ from the drop-down box.)

Recognizing that reliability is an Common Attribute of a robust North American economy:

1. A reliability standard shall not give any market participant an unfair competitive advantage. Yes

2. A reliability standard shall neither mandate nor prohibit any specific market structure. Yes

3. A reliability standard shall not preclude market solutions to achieving compliance with that standard. Yes

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 A4 Approved by the NPCC Board xxxx xx, 2013

4. A reliability standard shall not require the public disclosure of commercially sensitive information. All market participants shall have equal opportunity to access commercially non-sensitive information that is required for compliance with reliability standards. Yes

Detailed Description: (Provide enough detail so that an independent entity familiar with the industry could draft a standard based on this description.)

[Required Field – Provide: 1) Necessary information to assist the drafting team (which is to include relevant study results and documentation), to the extent feasible, to allow them to draft the standard, 2) Any existing known cross references to NPCC or NERC documents and 3) Technical background for the RSAR to properly address the need for the standard.]

Related Standards [Required Field, to extent known] Standard No. Explanation

Related SARs or RSARs [Required Field, to extent known] SAR ID Explanation

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 B1 Approved by the NPCC Board xxxx xx, 2013

APPENDIX B: SELECTION OF DRAFTING TEAM MEMBERS A regional standard drafting team shall be comprised of Subject Matter Experts (SMEs) from NPCC Task Forces and Working Groups as determined by the RCC, and from industry. The guidelines provided herein primarily address overall team requirements and more specifically those of a SME.

Formal membership on a drafting team should be reserved only for those individuals who intend to work consistently, diligently, and professionally on what is required to be done for a regional standard. Drafting team members are expected to contribute meaningfully to the ongoing development of the standard.

Drafting Team members must be:

• Committed to participating in scheduled drafting team meetings, teleconferences, as well as industry outreach (e.g., workshops and webinars)

• Willing to lead teams / sub-teams, as necessary

• Champions for standard development and promoters of the approval of the standard

• Open to consider the comments of others and provide constructive feedback

Subject Matter Experts should possess the necessary expertise and knowledge regarding the topic of the standard. The SMEs should represent a cross section of the registered entities applicable to the standard under development as well as geographical areas within the NPCC footprint.

Industry stakeholders may nominate themselves for consideration by the NPCC Regional Standards Committee (RSC) for the specific drafting team vacancies by completing the following drafting team Self Nomination form and submitting it to NPCC Manager of Reliability Standards, at npccstandard@npcc.org.

Nomination Form for NPCC [Name of drafting team] Drafting Team Please return this form as soon as possible. If you have any questions, please contact the NPCC Standards Staff at npccstandard@npcc.org.

By submitting the following information you are indicating your willingness and agreement to actively participate in the drafting team meetings if appointed to the drafting team by the NPCC Regional Standards Committee (RSC). This means that if you are appointed to the DT you are expected to attend all (or at least the vast majority) of the face-to-face DT meetings as well as participate in all the DT meetings held via conference calls. Failure to do so shall result in your removal from the DT.

Name:

Organization:

Address:

Telephone:

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 B2 Approved by the NPCC Board xxxx xx, 2013

E-mail:

Please briefly describe your experience and qualifications to serve on the requested drafting team.

If you are currently a member of any NERC or Regional drafting teams, please list each team here. Not currently on any active SAR or standard drafting team. Currently a member of the following SAR or standard drafting team(s):

If you previously worked on any drafting team please identify the team(s). No prior NERC or Regional SAR or standard drafting team experience. Prior experience on the following team(s):

Select each NERC Region that you represent: Select each Industry Segment that you represent:

ERCOT FRCC MRO NPCC RFC SERC SPP WECC NA – Not Applicable

1 — Transmission Owners

2 — RTOs, ISOs

3 — Load-serving Entities

4 — Transmission-dependent Utilities

5 — Electric Generators

6 — Electricity Brokers, Aggregators, and Marketers

7 — Large Electricity End Users

8 — Small Electricity End Users

9 — Federal, State, and Provincial Regulatory or other Government Entities

10 — Regional Reliability Organizations and Regional Entities

NA – Not Applicable

Select each Function20 in which you have current or prior expertise:

Balancing Authority Compliance Enforcement Authority Distribution Provider Generator Operator Generator Owner Interchange Authority Load-serving Entity Market Operator Planning Coordinator

Transmission Operator Transmission Owner Transmission Planner Transmission Service Provider Purchasing-selling Entity Reliability Coordinator Reliability Assurer Resource Planner

20 These functions are defined in the NERC Functional Model, which is downloadable from the NERC website.

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 B3 Approved by the NPCC Board xxxx xx, 2013

Provide the names and contact information for two references who could attest to your technical qualifications and your ability to work well in a group.

Name: Telephone:

Organization: E-mail:

Name: Telephone:

Organization: E-mail:

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 C1 Approved by the NPCC Board xxxx xx, 2013

APPENDIX C: MAINTENANCE OF REGIONAL STANDARDS AND PROCESS NPCC regional standards and the Regional Standard Processes Manual are living documents that will be updated periodically to remain current and viable (e.g., respond to changing conditions, as well as to incorporate lessons learned and process improvements).

MAINTENANCE OF REGIONAL STANDARDS

NPCC regional standards will be posted for open process review by the RSC for possible revision at least once every five (5) years21 after the first regulatory approval and follow the same process as in the case of a new standard. If no changes are warranted, the Regional Standards Committee (RSC) shall recommend to the NPCC Board that the standard be reaffirmed. If the review indicates a need to revise or retire a regional standard, a Regional Standard Authorization Request shall be prepared by the RSC and submitted in accordance with the NPCC regional standards process. The existing, approved standard subject to revision will remain in effect until such time as the revised version has received FERC or applicable Provincial Governmental Authorities approvals, as appropriate, at which time it will be retired in accordance with any applicable implementation plan associated with the newly approved regional standard.

MAINTENANCE OF THE REGIONAL STANDARDS PROCESS

This NPCC Regional Standards Process will be reviewed for possible revision at least once every five (5) years, or more frequently if needed, and subject to the same procedure as applies to the development of a Regional Standard. All such revisions shall be subject to approval by the NPCC Board of Directors, NERC Board of Trustees, FERC, and may be subject to approval, if required, by Applicable Governmental Authorities in Canada.

21 More frequent reviews of NPCC regional standards may be required to promptly evaluate new or revised NERC reliability standards to ensure NPCC regional standards remain consistent and more stringent than continent-wide reliability standards.

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 D1 Approved by the NPCC Board xxxx xx, 2013

APPENDIX D: NPCC CLARIFICATION REQUEST

Note: A valid clarification request is one that requests additional clarity about one or more requirements in approved NPCC regional standards, but does not request approval as to how to comply with one or more requirements.

Request for an Clarification of a Regional Standard

Date submitted:

Contact information for person requesting the clarification:

Name:

Organization:

Telephone: E-mail:

Identify the standard that needs clarification:

Standard Number (include version number, e.g. PRC-006-NPCC-1 ):

Standard Title:

Identify specifically what requirement needs clarification:

Requirement Number and Text of Requirement:

Identify the nature of clarification that is requested: (Check as many as applicable)

Clarify the required performance

Clarify the conditions under which the performance is required

Clarify which functional entity is responsible for performing an action in a requirement

Clarify the reliability outcome the requirement is intended to produce

Please explain the clarification needed:

Identify the material impact associated with this clarification:

When completed, email this form to: npccstandard@npcc.org For questions about this form or for assistance in completing the form, call Lee Pedowicz at 212-840-1070.

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 D2 Approved by the NPCC Board xxxx xx, 2013

Identify the material impact to your organization or others, if known, caused by the lack of clarity or an incorrect clarification of this standard.

Northeast Power Coordinating Council, Inc.

Regional Standards Processes Manual (RSPM)

Adopted by FERC: XXXX XX, 20XX

Approved by NERC Board of Trustees: XXXX XX, 20XX

Approved by NPCC Board of Directors: XXXX XX, 20XX

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 1 Approved by the NPCC Board xxxx xx, 2013

Revision History

Version NPCC Board of

Directors Approval NERC Board of

Trustees Approval FERC Approval 0 9/19/07 10/23/07 3/21/08 1 xx/xx/xx xx/xx/xx xx/xx/xx

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 2 Approved by the NPCC Board xxxx xx, 2013

NPCC REGIONAL RELIABILITY STANDARDS PROCESS MANUAL

TABLE OF CONTENTS I. EXECUTIVE SUMMARY ................................................................................................. 3 II. INTRODUCTION............................................................................................................ 4

PURPOSE ............................................................................................................................................... 4 BACKGROUND .................................................................................................................................... 4

III. REGIONAL STANDARD CHARACTERISTICS AND ELEMENTS ................... 5 1. CHARACTERISTIC ATTRIBUTES ........................................................................................ 5 2. ELEMENTS OF A REGIONAL STANDARD ........................................................................ 6

TYPES OF RELIABILITY REQUIREMENTS ................................................................................................................ 6 ELEMENTS OF A REGIONAL STANDARD ................................................................................................................. 7

IV. REGIONAL STANDARDS DEVELOPMENT PROCESS ...................................... 9 1. ROLES IN THE NPCC REGIONAL STANDARD PROCESS ............................................ 9

NOMINATION, REVISION, CLARIFICATION, OR RETIREMENT OF A STANDARD: ..................................................... 9 PROCESS ROLES AND RESPONSIBILITIES .............................................................................................................. 9

2. STANDARD DEVELOPMENT PROCESS STEPS ............................................................. 11 STEP 2.1: REGIONAL STANDARDS AUTHORIZATION REQUEST TO DEVELOP, MODIFY OR RETIRE ..................... 11 STEP 2.2: FORMATION OF DRAFTING TEAM FOR NEW OR MODIFIED STANDARD .............................................. 13 STEP 2.3: DEVELOPMENT OF A REGIONAL STANDARD AND ASSOCIATED DOCUMENTS ..................................... 14 STEP 2.4: POSTING FOR COMMENT PERIOD AND RESOLUTION OF COMMENTS ................................................. 15 STEP 2.5: POSTING FOR BALLOT PERIOD IN THE OPEN PROCESS ..................................................................... 16 STEP 2.6: NPCC BOARD OF DIRECTORS APPROVAL.......................................................................................... 18 STEP 2.7: NERC BOARD OF TRUSTEES SUBMITTAL ........................................................................................... 18 STEP 2.8: IMPLEMENTATION OF A NPCC REGIONAL STANDARD ....................................................................... 19

3. STANDARD CLARIFICATION PROCESS STEPS ............................................................ 19 STEP 3.1: REGIONAL STANDARDS CLARIFICATION REQUEST (CR) .................................................................... 20 STEP 3.2: REVIEW AND VALIDATION OF CLARIFICATION REQUEST (CR) .......................................................... 20 STEP 3.3: NPCC REGIONAL STANDARDS COMMITTEE (RSC) ACTIONS ............................................................. 21 STEP 3.4: FORMATION OF DRAFTING TEAM FOR RESPONSE TO CR................................................................... 21 STEP 3.5: DEVELOPMENT OF RESPONSE TO CR ................................................................................................. 22 STEP 3.6: POSTING CR FOR COMMENT PERIOD AND RESOLUTION OF COMMENTS ........................................... 22 STEP 3.7: REGIONAL STANDARDS COMMITTEE APPROVAL OF CR ..................................................................... 23 STEP 3.8: NPCC BOARD OF DIRECTORS APPROVAL OF CR .............................................................................. 23

4. DISCONTINUANCE OF REGIONAL STANDARD DEVELOPMENT .......................... 24 5. WITHDRAWAL OF A REGIONAL STANDARD PENDING APPROVAL ................... 24 6. RETIREMENT OF AN APPROVED NPCC REGIONAL STANDARD.......................... 25 7. APPROVAL OF PROCESS WAIVER ................................................................................... 25 8. PROCESS FOR CORRECTING ERRATA ........................................................................... 26 9. APPEALS ..................................................................................................................................... 26

LEVEL 1 APPEAL ................................................................................................................................................. 27 LEVEL 2 APPEAL ................................................................................................................................................. 27

APPENDIX A: RSAR COMPLETION GUIDELINES ...................................................... A1 APPENDIX B: SELECTION OF DRAFTING TEAM MEMBERS ................................. B1 APPENDIX C: MAINTENANCE OF REGIONAL STANDARDS AND PROCESS ... C1

MAINTENANCE OF REGIONAL STANDARDS ......................................................................................................... C1 MAINTENANCE OF THE REGIONAL STANDARDS PROCESS .................................................................................. C1

APPENDIX D: NPCC CLARIFICATION REQUEST ...................................................... D1

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 3 Approved by the NPCC Board xxxx xx, 2013

I. EXECUTIVE SUMMARY The NPCC Bylaws state “NPCC shall develop a Regional Reliability Standards Development Procedure that provides the design-basis approach to a consensus building process by which NPCC may develop Regional Reliability Standards and Regional Variances to be proposed to the ERO for adoption, under delegated authority by the FERC and the Canadian Provincial regulatory and/or governmental authorities.”

The NPCC Regional Reliability Standards Development Procedure was originally adopted by the NPCC Board of Directors on September 19, 2007. The NPCC Reliability Standards Staff in concert with the NPCC Regional Standards Committee (RSC) has completed a revision to the NPCC Regional Reliability Standards Process Manual to incorporate process improvements, provide greater clarity and reflect the new NPCC Cost Effectiveness Analysis Procedure (CEAP).

Key changes addressed in this revision include:

• Replacing interpretation with clarification and Eexpanding the interpretation Clarification Section narrative into process steps and including an associated flowchart

• Creating separate sections for: 1) Withdrawal of a Regional Standard Pending Approval; 2) Retirement of an Approved NPCC Regional Standard; and 3) Approval of Process Waiver; 4) Process for Correcting Errata

• Recognizing the new NPCC Cost Effectiveness Analysis Procedure (CEAP)

• Identifying the Reliability Standard Audit Worksheet (RSAW) as a companion document to a regional standard that needs to be collaboratively developed by the drafting team and NPCC Compliance Staff

• Creating three new appendices: 1) Appendix A: Regional Standard Authorization Request (RSAR) Completion Guidelines and Form; 2) Appendix B: Selection of drafting team Members and Nomination Form; and 3) Appendix C: Maintenance of Regional Standards and Process

In addressing areas for improvement in the NPCC Regional Reliability Standards Development Procedure, recent improvements made to the NERC Standards Process Manual (e.g., Standards Process Input Group (SPIG) recommendations) as well as the manuals of other Regional Entities were benchmarked to identify best practices for inclusion in this manual.

The process improvements and clarity captured in this revision to the NPCC Regional Reliability Standards Development Procedure, will result in a more timely and efficient manner to address the development of regional standards to ensure the reliability of the Bulk Electric System within the NPCC geographical area.

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 4 Approved by the NPCC Board xxxx xx, 2013

II. INTRODUCTION PURPOSE

This manual defines the characteristics of a Northeast Power Coordinating Council, Inc. (NPCC) regional Reliability Standard (hereinafter referred to as “regional standard”) and establishes the process by which NPCC regional standards are developed, approved, revised, formally interpretedclarified and retired. The NPCC regional standards process is a stakeholder process that is approved by the NPCC members to ensure a transparent standard development process that is “open, fair, and inclusive.”

NPCC regional standards address the reliability of the international and interconnected Bulk Electric System in Northeast North America. NPCC regional standards shall enable or support one or more NERC/ERO reliability principles1 and will, in all cases, not be inconsistent with or less stringent than any requirements of the North American Electric Reliability Council/Electric Reliability Organization (NERC/ERO) continent-wide Reliability Standards.

The development of NPCC regional standards is performed according to the following principles using the process contained in this manual:

• Developed in a fair and open process that provides an opportunity for all interested parties to participate;

• Does not have an adverse impact on commerce that is not necessary for reliability;

• Provides a level of Bulk Electric System reliability that is adequate to protect public health, safety, welfare, and national security and would not have a significant adverse impact on reliability; and

• Based on a justifiable difference between Regions or between sub-Regions within the Regional geographic area.

Following industry approval, NPCC regional standards process and NPCC regional standards require approval by the NPCC Board of Directors, NERC as the Electric Reliability Organization (ERO) and the applicable regulatory authorities in the United States (FERC) and Canada.

BACKGROUND

Northeast Power Coordinating Council, Inc. (NPCC) is responsible for promoting and improving the reliability of the international, interconnected Bulk Electric System in Northeastern North America. NPCC carries out its mission through (i) the development of regional standards and compliance assessment and enforcement of continent-wide and regional standards, coordination of system planning, design and operations, and assessment of reliability, (collectively, “Regional Entity activities”), and (ii) the establishment of regionally-specific criteria, and monitoring and enforcement of compliance with such criteria (collectively, “criteria services activities”).

The Energy Policy Act (EPA) of 2005 (Section 1211) amended the Federal Power Act (FPA) by adding Section 215, Electric Reliability. Specifically regarding standards development and pursuant with Section 215(e)(4) of the FPA, NPCC as a Regional Entity with delegated authority from NERC may propose regional standards to NERC for eventual enforcement within the NPCC region.

1 Available on the NERC website: Reliability Principles

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 5 Approved by the NPCC Board xxxx xx, 2013

As a condition of NPCC membership, NPCC General and Full Members2 agree to adhere to NERC Reliability Standards. NERC Reliability Standards are comprised of both continent-wide and regional standards. The NPCC regional standards apply only to that part of the Eastern Interconnection within the NPCC geographical area.

III. REGIONAL STANDARD CHARACTERISTICS AND ELEMENTS 1. CHARACTERISTIC ATTRIBUTES

The NPCC regional standards development process has the following key characteristics:

• Fair due process — The NPCC regional standards development process provides for reasonable notice and opportunity for public comment. At a minimum, the procedure shall include public notice of the intent to develop a standard, a public comment period on the proposed standard, due consideration of those public comments, and a ballot of interested stakeholders. Upon approval by the NPCC Members, the NPCC Board of Directors then votes to approve submittal of the regional standard to NERC for ERO approval, followed by submission to FERC and Canadian Authorities for their approvals.

• Openness — Participation in the NPCC regional standards development process is open to all persons and organizations that are directly and materially affected by the reliability of the NPCC’s Bulk Electric System. There is no undue financial burden to participation. Participation shall not be conditioned upon membership in the ERO, NPCC or any organization, and shall not be unreasonably restricted on the basis of technical qualifications or other such requirements.

• Inclusive — Any entity (person, organization, company, government agency, individual, etc.) with a direct and material interest in the reliability of NPCC’s Bulk Electric System has the right to participate by: (a) expressing an opinion and its basis; (b) having their position considered, and (c) having the right to appeal a response through an established appeal process.

• Balanced — The NPCC regional standards development process strives to have an appropriate balance of interest and shall not be dominated by any two interest categories and no single interest category shall be able to defeat a matter. Pursuant with the NPCC By-Laws3 there are seven (7) stakeholder voting sectors and the votes for each sector are weighted to achieve an appropriate balance.

• Transparent — All actions material to the development of NPCC regional standards are transparent and information regarding the progress of a standard’s development action is made available to the public through postings on the NPCC website as well as through E-mail lists.

• Without undue delay — The NPCC regional standards development process shall be performed within a reasonable time.

In as much as NPCC is one of six Regional Entities within the Eastern Interconnection of North America, there will be no presumption of validity by the ERO for any NPCC regional standard.

2 As defined in the NPCC By-Laws – available on the NPCC website 3 NPCC By-Laws are available on the NPCC website

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 6 Approved by the NPCC Board xxxx xx, 2013

In order to receive the approval of the ERO, the NPCC regional standards development process must also achieve the following objectives:

• No Adverse Impact on Reliability of the Interconnection — A NPCC regional standard provides an Adequate Level of Reliability4 as defined by NERClevel of Bulk Electric System reliability that is necessary and adequate to protect public health, safety, welfare, and North American security and will not have an adverse impact on the reliability of the Interconnection or other Regions within the Interconnection.

• Justifiable Difference — A NPCC regional standard addresses a justifiable difference within the NPCC geographical area that results from a physical difference5 or operating difference in the Northeast’s Bulk Electric System. Although a justifiable difference allows for a unique regional standard, a NPCC regional standard shall be no less stringent than a continent-wide standard.

• Uniformity — To the extent possible, the NPCC regional standards provides uniformity with Reliability Standards across the interconnected Bulk Electric System of North America.

• No Undue Adverse Impact on Commerce — A NPCC regional standard will not cause any undue adverse impact on business activities that are not necessary for reliability of the Region and its interconnected Regions. All regional standards shall be consistent with NERC’s market principles6.

2. ELEMENTS OF A REGIONAL STANDARD

To ensure uniformity of regional standards and avoid inconsistency with NERC continent-wide standards, a NPCC regional standard shall be consistent with the elements identified in this section of the procedure. These elements are intended to apply a systematic discipline in the development and revision of regional standards. The application of a systematic discipline is necessary for achieving regional standards that are measurable, enforceable, and consistent as well as results oriented7, i.e.:

• Performance-based,

• Risk-based, and

• Capability-based. TYPES OF RELIABILITY REQUIREMENTS

The drafting team (DT) should strive to achieve a portfolio of performance, risk, and capability-based mandatory reliability requirements that supportRegional reliability standards should be viewed as a portfolio of requirements designed to achieve an effective defense-in-depth strategy. Each requirement should identify a clear and measurable expected outcome, such 4 Available on the NERC website: Adequate Level of Reliability 5 The interpretation meaning of the phrase “physical difference” will be consistent with FERC’s Order, issued

September 22, 2004, Granting Request For Clarification regarding Docket No. PL04-5-000, Policy Statement on Matters Related to Bulk Power System Reliability.

6 Available on the NERC website: www.nerc.com 7 Results-based Standards see

http://www.nerc.com/pa/Stand/Resources/Documents/ResultsBasedStandardGuidance.pdf http:www.nerc.com/filez/standards/Project2010-06_Results-based_Reliability_Standards.html

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 7 Approved by the NPCC Board xxxx xx, 2013

as: a) a stated level of reliability performance, b) a reduction in a specified reliability risk, or c) a necessary competency.

a) Performance-based - defines a specific reliability objective or outcome that has a direct, observable effect on the reliability of the Bulk Electric System, i.e. an effect that can be measured using power system data or trends.

b) Risk-based - defines actions of entities that reduce a stated risk to the reliability of the Bulk Electric System and can be measured by evaluating a particular product or outcome resulting from the required actions.

c) Capability-based - defines capabilities needed to perform reliability functions and can be measured by demonstrating that the capability exists as required.

Each regional standard shall enable or support one or more of the reliability principles8 as identified in the most recent set posted on the NERC website. Each regional standard shall also be consistent with all of the reliability principles. The intent of the set of NPCC regional standards is to deliver an Adequate Level of Reliability9 as defined by NERC.

Recognizing that Bulk Electric System reliability and electricity markets are inseparable and mutually interdependent, all regional standards shall be consistent with the most recent set of Market Principles10 as posted on the NERC website. Consideration of the Market Principles is intended to ensure that regional standards are written such that they achieve their reliability objective without placing undue restrictions or causing adverse impacts on competitive electricity markets.

ELEMENTS OF A REGIONAL STANDARD

A regional standard includes several components designed to work collectively to identify what entities must do to meet their reliability-related obligations as an owner, operator or user of the Bulk Electric System. The components of a NPCC regional standard identified below are based on the NERC Standard Processes Manual (SPM) that was approved by the NERC Board of Trustees at its February 2013 meeting. Future revisions of the NERC SPM will be used at the time of development of a NPCC regional standard if different from the elements listed below.

The only mandatory and enforceable components of a regional standard are the: (1) Applicability, (2) Requirements, and (3) the Effective Dates. The additional components are included in the regional standard for informational purposes, to establish the relevant scope and technical paradigm, and to provide guidance to functional entities concerning how compliance will be assessed by the Compliance Enforcement Authority.

The components of a regional standard may include the following: Title: A brief, descriptive phrase identifying the topic of the regional standard.

Number: A unique identification number assigned in accordance with a published classification system to facilitate tracking and reference to the regional standards.

Purpose: The reliability outcome achieved through compliance with the requirements of the regional standard.

8 Available on the NERC website: Reliability Principles 9 Available on the NERC website: Adequate Level of Reliability 10 Available on the NERC website: Market Principles

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 8 Approved by the NPCC Board xxxx xx, 2013

Applicability: Identifies which entities are assigned reliability requirements; i.e., the specific functional entities and facilities to which the regional standard applies.

Effective Dates: Identification of the date or pre-conditions determining when each Requirement becomes effective in each jurisdiction.

Requirement: An explicit statement that identifies the functional entity responsible, the action or outcome that must be achieved, any conditions achieving the action or outcome, and the reliability-related benefit of the action or outcome. Each requirement shall be a statement for which compliance is mandatory.

Compliance Elements: Elements to aid in the administration of compliance monitoring and enforcement responsibilities.

Measure: Provides identification of the evidence or types of evidence that may demonstrate compliance with the associated requirement.

Violation Risk Factors and Violation Severity Levels:

Violation risk factors (VRFs) and violation severity levels (VSLs) are used as factors when determining the size of a penalty or sanction associated with the violation of a requirement in an approved Reliability Standard. Each requirement in each Reliability Standard has an associated VRF and a set of VSLs. VRFs and VSLs are developed by the drafting team, working with NPCC Standards Staff and Compliance Staff, at the same time as the associated Reliability Standard, but are not part of the Reliability Standard. The Board of Directors is responsible for approving VRFs and VSLs.

• Violation Risk Factors VRFs identify the potential reliability significance of noncompliance with each requirement. Each requirement is assigned a VRF in accordance with the latest approved set of VRF criteria.

• Violation Severity Levels VSLs define the degree to which compliance with a requirement was not achieved. Each requirement shall have at least one VSL. While it is preferable to have four VSLs for each requirement, some requirements do not have multiple “degrees” of noncompliant performance and may have only one, two, or three VSLs. Each requirement is assigned one or more VSLs in accordance with the latest approved set of VSL criteria.

Version History: The version history is provided for informational purposes and lists information regarding prior versions of the regional standard.

Variance: As applied to a NPCC regional standard is a Requirement (to be applied in the place of the NPCC region-wide Requirement) that is applicable to a specific geographic area or to a specific set of Registered Entities.

Compliance Enforcement Authority (CEA):

The entity that is responsible for assessing performance or outcomes to determine if an entity is compliant with the associated regional standard. The Compliance Enforcement Authority will be NERC or the Regional Entity in their respective roles of monitoring and enforcing compliance with the ERO regional standards.

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 9 Approved by the NPCC Board xxxx xx, 2013

Reliability Standard Audit Worksheets (RSAWs)11

Reliability Standard Audit Worksheets (RSAWs) are developed as companion documents to regional and continent-wide Reliability Standards to facilitate the CEA assessment of a registered entity’s compliance with a standard.

Informational Elements: Elements to aid in the implementation of the regional standard. Application Guidelines:

Guidelines or reference documents to support the implementation of the associated regional standard.

Procedures: Procedures to support implementation of the associated regional standard.

IV. REGIONAL STANDARDS DEVELOPMENT PROCESS 1. ROLES IN THE NPCC REGIONAL STANDARD PROCESS

NOMINATION, REVISION, INTERPRETATIONCLARIFICATION, OR RETIREMENT OF A STANDARD:

Any member of NPCC or group within the NPCC region shall be allowed to request that a NPCC regional standard be developed, modified, interpretedclarified, or retired. Additionally, any person (organization, company, government agency, individual, etc.) who is directly and materially affected by the reliability of the NPCC Bulk Electric System shall be allowed to request that a NPCC regional standard be developed, modified, interpretedclarified, or retired. The following section identifies the process roles in the NPCC regional standards process. Refer to Step 2 STANDARD DEVELOPMENT PROCESS STEPS and FIGURE 1: FLOWCHART OF REGIONAL STANDARDS DEVELOPMENT PROCESS OVERVIEW for the regional standards development process steps and associated flowchart. Refer to Step 3 STANDARD CLARIFICATION PROCESS STEPS and FIGURE 2: FLOWCHART OF REGIONAL STANDARDS CLARIFICATION PROCESS OVERVIEW for the regional standards clarification process steps and associated flowchart.

PROCESS ROLES AND RESPONSIBILITIES

BOARD OF DIRECTORS The NPCC Board of Directors (Board) shall consider for adoption regional standards, definitions, variances and interpretations clarifications and associated implementation plans that have been processed according to the processes identified in this manual. Once the Board adopts a regional standard, definition, variance or clarificationinterpretation, the Board shall direct NPCC Standards Staff to submit the document(s) for approval to the NERC Board of Trustees.

COMPLIANCE COMMITTEE (CC) The NPCC Compliance Committee, a committee of the NPCC Board of Directors, manages the NPCC Compliance Monitoring and Enforcement Program (CMEP). The CMEP is used to monitor, assess and enforce mandatory compliance with both NERC continent-wide and NPCC regional standards. The CC aides in the regional standards development, as necessary, by: (1) performing compliance reviews of technical requirements, (2) assisting the drafting team with the development of Violation Risk Factors (VRFs) and Violation Severity Levels (VSLs), Reliability Standard Audit Work Sheets (RSAWs) and (3) participating on quality review teams.

DRAFTING TEAM The drafting team (DT) should strive to achieve a portfolio of performance, risk, and capability-based mandatory reliability requirements that support an effective defense-in-depth 11 While RSAWs are not part of the regional standard, they are developed through collaboration of the drafting team and NPCC Compliance Staff.

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 10 Approved by the NPCC Board xxxx xx, 2013

strategy. The drafting team develops standards-related regional products as directed by the NPCC RSC and within the scope of an approved Regional Standard Authorization Request (RSAR) or a formal Request for ClarificationInterpretation (RFIRFC). The product that is developed is typically a new or revised regional standard, but could also be a definition, a reference document, a set of Violation Risk Factors, a set of Violation Severity levels, or the team could be appointed to assist an author in refining a Regional Standard Authorization Request (RSAR). The drafting team also works collaboratively with NPCC Compliance Staff to develop Reliability Standard Audit Worksheets (RSAWs) at the same time regional standards are developed. The drafting team shall remain in place until such time as the NERC Board of Trustees adopts the regional standard.

MANAGER OF RELIABILITY STANDARDS The NPCC Manager of Reliability Standards has the overall responsibility for managing the NPCC regional standards processes in accordance with this manual. As used herein, the NPCC Manager of Reliability Standards will be the NPCC Manager of Reliability Standards or his/her designee.

NPCC MEMBERS NPCC members may participate in the comment and ballot periods associated with the development and industry approval of regional standards. The ballot body is comprised of all entities or individuals that qualify for one of the stakeholder sectors within NPCC as stated in the most recently approved NPCC Bylaws. All General and Full Members of NPCC can participate in the balloting of regional standards. Any entity or person, including non-NPCC members, may submit comments during the open process comment periods for standards.

NON-NPCC MEMBERS Any entity or person that is neither a General nor Full Members of NPCC is not eligible to participate in the ballot body voting on a regional standard. However, any entity or person, including non-NPCC members, may submit comments during the open process comment periods for standards. Subject Matter Experts (SMEs), regardless of NPCC membership status, are encouraged to participate in comment periods for regional standards.

NPCC STANDARDS STAFF The Standards Staff is responsible for assisting the NPCC Manager of Reliability Standards and the RSC in administering the NPCC regional standards processes in accordance with this manual.

NPCC COMMITTEES, TASK FORCES AND WORKING GROUPS The Committees, Task Forces and Working Groups within NPCC serve an active role in the standards process. Activities performed by these groups include, but are not limited to, the following:

• Identify the need for new or modified regional standards

• Initiate NPCC Standards actions by developing Regional Standard Authorization Requests (RSARs)

• Develop comments (views and objections) to standards actions

• Participate in NPCC Standard drafting

• Dispensation of Request for Clarifications Interpretations (RFCIs)

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 11 Approved by the NPCC Board xxxx xx, 2013

• Provide technical oversight in response to changing industry conditions and ERO Requirements

• Conduct Field Tests, as required REGIONAL STANDARDS COMMITTEE (RSC)

The NPCC Regional Standards Committee (RSC), a committee of the NPCC Board of Directors, is charged with oversight of all drafting team activities and managing the NPCC regional standards development process in accordance with this manual.

The RSC is responsible for maintenance of the Regional Standards Process ManualRegional Standard Processes Manual (RSPM), including the endorsement of RSPM revisions for NPCC Board review and approval.

RELIABILITY COORDINATING COMMITTEE (RCC) The Reliability Coordinating Committee (RCC) supports the standards development process through the assignment of NPCC Task Forces to serve as technical resources for: (1) staffing drafting teams, and (2) performing a technical advisory role in the regional standards process through comments, recommendations and technical justifications.

REQUESTER Any individual representing an organization (entity, company, government agency, etc.) that is directly and materially affected by the reliability of the Bulk Electric System within the NPCC geographical area may request a regional standard be developed or an existing regional standard be modified, interpretedclarified, or deleted.

QUALITY REVIEW TEAM The NPCC Standards Staff shall coordinate a quality review of the “final draft” of the regional standard, implementation plan, VRFs and VSLs to assess whether the documents are within the scope of the associated RSAR, and whether the regional standard is clear and enforceable as written and the VRFs and VSLs are developed according to NERC and FERC guidelines. The Quality Review Team may be comprised of legal and compliance representatives, a technical writer, and NPCC Standards Staff. It will not involve individuals who participated on the drafting team of the standard undergoing the Quality Review.

2. STANDARD DEVELOPMENT PROCESS STEPS

STEP 2.1: REGIONAL STANDARDS AUTHORIZATION REQUEST TO DEVELOP, MODIFY OR RETIRE

A Regional Standard Authorization Request12 (RSAR) is the form used to document the scope and reliability benefit of a proposed project for one or more new or modified regional standards or the benefit of retiring one or more approved regional standards.

A RSAR shall be used to seek approval and initiate the development, modification or retirement of a NPCC regional standard. A RSAR is not used to seek a formal Request for Clarification Interpretation (RFCI) of a NPCC regional standard. The initiation and handling of a RFCI is covered in Step 3 STANDARD CLARIFICATION PROCESS STEPS, of this manual.

Any individual representing an organization which is directly or materially impacted by the operation of the Bulk Electric System within the geographical footprint of NPCC may request, via a submittal of a RSAR to the NPCC Manager of Reliability Standards, the development, 12 The RSAR is located on the NPCC website under Standards – Regional Standards General

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 12 Approved by the NPCC Board xxxx xx, 2013

modification, or deletion of a NPCC regional standard. The individual completing the form is referred to herein as the Requester.

STEP 2.1.A. REQUESTER ACTIONS

Note: The NPCC Manager of Reliability Standards will assist the Requester, as necessary, to ensure all required information is submitted on the RSAR.

The Requester shall complete a RSAR form in accordance with the guidance provided in APPENDIX A: RSAR COMPLETION GUIDELINES.

The Requester shall submit the completed RSAR to the NPCC Manager of Reliability Standards, via npccstandard@npcc.org, for processing.

STEP 2.1.B. NPCC MANAGER OF RELIABILITY STANDARDS ACTIONS

The NPCC Manager of Reliability Standards shall review the submitted RSAR and verify that the submitted form has been adequately completed. Within fifteen (15) calendar days 13 of receipt of the submitted RSAR, the NPCC Manager of Reliability Standards will electronically acknowledge receipt of the RSAR. If, at that time, the NPCC Manager of Reliability Standards finds the RSAR to be deficient, the Requester will be contacted to decide ondetermine how to proceed.

Within ten (10) calendar days of the receipt of an adequately completed RSAR, the NPCC Manager of Reliability Standards shall forward the properly completed RSAR to the NPCC Regional Standards Committee (RSC) for its review and processing. Included in the transmittal of the RSAR to the RSC, the NPCC Manager of Reliability Standards shall include a statement indicating the applicability of the NPCC Cost Effectiveness Analysis Procedure (CEAP) for the proposed change.

STEP 2.1.C. NPCC REGIONAL STANDARDS COMMITTEE (RSC) ACTIONS

Note: The RSC shall meet to review all pending RSARs. The frequency of this review process will depend on workload, but in no case shall a properly completed RSAR wait for RSC action more than 60 calendar days from the date of receipt by the RSC.

The RSC shall review the RSAR and take one of the following actions:

• Remand the RSAR back to the NPCC Manager of Reliability Standards for additional work. In this case, the NPCC Manager of Reliability Standards shall work with the Requester to provide may request additional information or clarification for the RSAR as specified by the RSCfrom the Requester.

• Reject the RSAR. In this case, the RSC will provide its determination to the NPCC Manager of Reliability Standards, who will then provide a written explanation for rejection to the Requester within ten (10) calendar days of the rejection decision.

13 Time periods specified in this manual may be extended as deemed appropriate by NPCC Staff. When business days are specified, this provision could be used to take into account differing Canadian and US holiday schedules. When calendar days are specified, this provision could be used to take into account due dates that fall on a weekend.

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 13 Approved by the NPCC Board xxxx xx, 2013

Note: Before the RSC can accept a RSAR for a new or modified standard the applicable CEAP process steps shall be completed.

• Accept the RSAR. o If a new or modified standard has been authorized, within ten (10) calendar days of the

authorization the NPCC Manager of Reliability Standards shall: 1) post notification on the NPCC website of the intent to develop or modify a regional standard; 2) notify the ERO for processing in accordance with its process, as applicable; and 3) notify the Requester of the acceptance of the RSAR.

o If the retirement of an existing regional standard has been authorized, within ten (10) calendar days of the authorization the NPCC Manager of Reliability Standards shall: 1) post notification on the NPCC website of the intent to retire an existing regional standard; 2) notify the ERO for processing in accordance with its process, as applicable; and 3) notify the Requester of the acceptance of the RSAR. The process to retire an existing regional standard is included in Step 6 RETIREMENT OF AN APPROVED NPCC REGIONAL STANDARD.

STEP 2.2: FORMATION OF DRAFTING TEAM FOR NEW OR MODIFIED STANDARD

A RSAR that has been accepted by the RSC shall, within ten (10) calendar days of the acceptance of the RSAR, be submitted by the NPCC Manager of Reliability Standards to the NPCC Reliability Coordinating Committee (RCC). The RCC shall, within sixty (60) calendar days, assign the development of the regional standard to a NPCC Task Force, and notify the NPCC Manager of Reliability Standards of its decision within ten (10) calendar days.

After receipt of the notification of drafting team assignment, the NPCC Manager of Reliability Standards shall oversee solicitation and recommendation of a list of additional qualified 14 candidates over and above the appropriate NPCC Task Force members, for appointment to the drafting team. The Requester and a NPCC Compliance Staff person will be included on the drafting team. Within sixty (60) calendar days of the drafting team assignment notification from the RCC, the NPCC Manager of Reliability Standards shall submit the list of the entire drafting team membership to the RSC for acceptance. The RSC may accept the recommendations of the NPCC Manager of Reliability Standards as presented or revise the recommendations as necessary.

Upon acceptance of the drafting team slate, the RSC shall provide a target date on which the drafting team is expected to have ready a completed draft regional standard and associated supporting documentation available for consideration by the NPCC membership. Additionally, the RSC shall provide the drafting team with any preliminary development products including, but not limited to, a draft standard, comments, and related white papers.

The RSC shall designate one of its members to actively monitor and assist NPCC staff in the oversight of drafting team milestones and deadlines, and extend or expedite milestones and deadlines, as appropriate, acting as a liaison between the drafting team and the RSC to help resolving any issues.

14 Refer to Appendix B: Selection of Drafting Team MembersAppendix B: Selection of Drafting Team Members Formatted: Default Paragraph Font

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 14 Approved by the NPCC Board xxxx xx, 2013

STEP 2.3: DEVELOPMENT OF A REGIONAL STANDARD AND ASSOCIATED DOCUMENTS

Prior to beginning work on the development of a new or revised regional standard and the associated supporting documentation, the drafting team should develop a work plan for completing the regional standard development work, including the establishment of milestones for completing critical elements of the work in sufficient detail to ensure that the drafting team will meet the target date established by the RSC, or the drafting team shall propose an alternative date. This work plan must be submitted to the RSC for its concurrence. When a drafting team begins its work, it shall regularly (at least quarterly) report progress against that aforementioned work plan to the NPCC Manager of Reliability Standards for presentation to the RSC.

Note: During the regional standards development, the drafting team will deliberate on whether the requirements in the regional standard are developed enough to begin the Cost Effectiveness Analysis (CEA) of the NPCC Cost Effectiveness Analysis Procedure (CEAP). When appropriate, the drafting team shall request that the RSC initiate the second phase (CEA) of the CEAP process.

The drafting team shall create and manage its work structure (e.g., sub-teams) and meeting schedule (face-to- face as well as electronic meetings), as necessary, to meet the milestone dates and project deliverables outlined in the work plan.

The work products of the drafting team should consist of the following

• A draft regional standard consistent with the RSAR on which it was based

• An implementation plan, including the nature, extent and duration of field-testing, if any

• Identification of any existing regional standard and NPCC criteria that will be deleted, in part or whole, or otherwise impacted by the implementation of the draft regional standard

• Technical reports, white papers and/or work papers that provide technical justification for the draft regional standard under consideration

• Reliability Standard Audit Worksheet (RSAW) collaboratively developed by the drafting team and NPCC Compliance Staff

Any proposed changes to definitions in existing regional standards should be sent to the appropriate Task Force (TF) for consideration of the impact to the standard. If necessary, the TF can produce an RSAR.

NPCC Standards Staff can assist in the drafting of the regional standard including compliance measures, process and elements. The drafting of measures and compliance administration aspects of the standard will be coordinated with the NPCC Compliance Staff.

The drafting team shall submit the initial and subsequent interim drafts of the regional standard and associated documents to the NPCC Manager of Reliability Standards to obtain RSC concurrence to post documents for comment.

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 15 Approved by the NPCC Board xxxx xx, 2013

STEP 2.4: POSTING FOR COMMENT PERIOD AND RESOLUTION OF COMMENTS

Note: There are no limits to the number of public comment periods and ballots that can be conducted to result in a regional standard that is clear and enforceable, and achieves a quorum and sufficient affirmative votes for approval.

STEP 2.4.A. COMMENT PERIOD

Note: For Final Comment Period skip this step and proceed to STEP 2.4.B. FINAL COMMENT PERIOD.

As authorized by the RSC, the NPCC Manager of Reliability Standards shall post the draft of the regional standard on the NPCC website, along with a draft implementation plan and available supporting documents, for a forty-five (45) calendar day comment period. The NPCC Manager of Reliability Standards shall also notify NERC to process the draft document in accordance with NERC’s regional standards review procedure, as applicable.

Following the conclusion of the NPCC comment period, the NPCC Manager of Reliability Standards will assemble the comments on the draft regional standard and associated documents and provide all comments to the drafting team for consideration.

Within thirty (30) calendar days of the conclusion of the comment period the drafting team shall convene and consider changes to the draft Standard, the implementation plan and/or supporting technical documents based upon comments received. All submitted comments shall be addressed, and each commenter shall be advised of the disposition, with reasons, of their comments. The NPCC Manager of Reliability Standards shall publicly post all of the drafting team’s responses to stakeholder comments on the NPCC website.

Based on the comments received, the drafting team may elect to:

• Return to STEP 2.3: DEVELOPMENT OF A REGIONAL STANDARD AND ASSOCIATED DOCUMENTS to revise the draft regional standard, the implementation plan and/or supporting technical documents.

• Recommend that the RSC authorize Field Testing of the draft regional standard. Upon completion of the Field Test, return to STEP 2.3: DEVELOPMENT OF A REGIONAL STANDARD AND ASSOCIATED DOCUMENTS to revise the draft regional standard based on insights learned during the Field Test.

• Obtain RSC concurrence to post documents for Final Comment Period and request that the RSC initiate the second phase (CEA) of the CEAP process

STEP 2.4.B. FINAL COMMENT PERIOD The NPCC Standards Staff shall coordinate a Quality Review of “final draft” of the regional standard, implementation plan, VRFs and VSLs to assess whether the documents are within the scope of the associated RSAR, and whether the regional standard is clear and enforceable as written and the VRFs and VSLs are developed according to NERC and FERC guidelines. Upon Completion of the Quality Review, including resolution of comments, the drafting team shall submit the regional standard to the NPCC Manager of Reliability Standards to obtain RSC concurrence to post these documents for comment.

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 16 Approved by the NPCC Board xxxx xx, 2013

As authorized by the RSC, the NPCC Standards Staff shall post the “final draft” of the regional standard on the NPCC website, along with the implementation plan, supporting documents and the Cost Effectiveness Analysis (CEA) survey15 for a forty-five (45) calendar day comment period. NPCC Standards Staff shall also notify NERC to process the proposed final document in accordance with NERC’s regional standards review procedure, as applicable.

Following the conclusion of the NPCC comment period, the NPCC Manager of Reliability Standards will assemble the comments on the posted regional standard and associated documents and provide all comments to the drafting team for consideration.

In addition, the RSC, pursuant with the requirements of the Cost Effectiveness Analysis Procedure (CEAP), will use the responses to the posted CEA survey to develop a recommendation based on the cost effectiveness of the proposed regional standard.

The NPCC Task Forces (TFs) or Working Groups (WGs) may develop recommendations for submittal to the RSC. Following the RSC deliberations to determine a course of action, the RSC will communicate to the drafting team to:

• Return to STEP 2.3: DEVELOPMENT OF A REGIONAL STANDARD AND ASSOCIATED DOCUMENTS to revise the Standard to address the results of the CEAP

• Accept the Standard “as is” to move forward through the remainder of the process

• Hold the Standard in abeyance until such time as additional guidance can be provided regarding whether or how to continue

• Decide not to pursue the development of certain requirements or the entire Standard due to cost effectiveness considerations

Upon Completion of the final comment period the drafting team shall submit the proposed regional standard, along with any supporting materials, consideration of comments and field test results, to the NPCC Manager of Reliability Standards to obtain RSC concurrence to post the regional standard and implementation plan for ballot and concurrently provide an information copy to the RCC.

The NPCC Manager of Reliability Standards shall also publicly post all of the drafting team’s responses to stakeholder comments on the NPCC website.

STEP 2.5: POSTING FOR BALLOT PERIOD IN THE OPEN PROCESS

Note: There are no limits to the number of public comment periods and ballots that can be conducted to result in a regional standard that is clear and enforceable, and achieves a quorum and sufficient affirmative votes for approval.

As authorized by the RSC, the NPCC Manager of Reliability Standards shall post the proposed regional standard on the NPCC website, along with supporting documentation 16 (e.g., implementation plan, consideration of comments, technical reports, white papers and any field test results), for a thirty (30) day pre-ballot review period and a subsequent ten (10) day ballot 15 In accordance to the Cost Effectiveness Analysis Procedure (CEAP) the Cost Effectiveness Analysis (CEA) survey may be assigned directly to NPCC Task Forces (TFs) or Working Groups (WGs) in addition to the posting process. 16 The ballot posting is for the regional standard, definition, variance or interpretationclarification. Supporting

documentation is included for information only and is not balloted.

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 17 Approved by the NPCC Board xxxx xx, 2013

period. The ten (10) day ballot period will commence immediately following the pre-ballot review period. In the event that a quorum exists for purposes of an electronic vote but the ballot purpose has not been resolved, NPCC may continue to solicit additional responses in order to resolve the matter by electronic voting. In the event that quorum has not been achieved for purposes of an electronic vote, NPCC may continue to solicit electronic ballots, including abstentions, to obtain quorum and resolve the matter.

At the time the regional standard is posted for ballot, the NPCC Manager of Reliability Standards shall also notify NERC to process the proposed regional standard in accordance with NERC’s regional standards review procedure, as applicable.

During the ballot period, the NPCC Members of the ballot body can cast their vote as follows:

• Affirmative, with or without comments

• Negative with comments

• Abstain In accordance with the NPCC Bylaws, a quorum and receipt of a two-thirds (2/3) affirmative majority of the weighted sector votes is required for a ballot to pass.

The NPCC Manager of Reliability Standards shall post the final outcome of the ballot process on the NPCC website.

STEP 2.5.A. BALLOT DOES NOT RECEIVE 2/3 AFFIRMATIVE VOTE If a ballot fails to achieve the 2/3 majority vote the NPCC Manager of Reliability Standards may:

• Direct the drafting team to respond to ballot comments and return to STEP 2.5: POSTING FOR BALLOT PERIOD IN THE OPEN PROCESS to re-ballot the regional standard. The consideration of comments from prior ballot will be included with the re-posting.

• Return to STEP 2.3: DEVELOPMENT OF A REGIONAL STANDARD AND ASSOCIATED DOCUMENTS to revise the regional standard to address the comments received.

• Pursue the curtailment discontinuance of the regional standard development by soliciting the Requester to withdraw the RSAR or by soliciting the RSC to reject the RSAR pursuant with STEP 2.1.C. NPCC REGIONAL STANDARDS COMMITTEE (RSC) ACTIONS. The NPCC Manager of Reliability Standards, in the event of a discontinuance curtailment of the development of a regional standard, shall post a notice of the discontinuance curtailment and will post and archive all comments submitted during the process for future consideration, if required. The NPCC Manager of Reliability Standards will also notify NERC to process the proposed regional standard in accordance with NERC’s regional standards review procedure, as applicable.

STEP 2.5.B. BALLOT RECEIVES ≥ TWO-THIRDS (2/3) AFFIRMATIVE VOTE A ballot that achieved two-thirds or greater affirmative vote has successfully passed. However, negative votes with comments should still be reconciled. If there is at least one negative vote with comments proceed to STEP 2.5.B.1 APPROVED BALLOT WITH “NEGATIVE VOTE WITH COMMENT”. If there was not any negative vote with comments proceed to STEP 2.5.B.2 APPROVED BALLOT WITHOUT “NEGATIVE VOTE WITH COMMENT”.

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 18 Approved by the NPCC Board xxxx xx, 2013

STEP 2.5.B.1 APPROVED BALLOT WITH “NEGATIVE VOTE WITH COMMENT” Following the conclusion of the NPCC ballot period, the NPCC Manager of Reliability Standards will assemble the comments on the posted regional standard and provide all comments to the drafting team for consideration. The drafting team shall review all negative votes with comments and elect to:

• Recommend to the RSC to accept the regional standard “as is” and seek RSC endorsement to move forward through the remainder of the process. Upon receiving RSC endorsement to proceed, the regional standard and associated documents, approved by the NPCC ballot body, shall be forwarded by the Assistant Vice President Standards to the NPCC Board of Directors for final Regional approval. If comments that were received during balloting should be considered in future revisions to the regional standard then the NPCC Manager of Reliability Standards should log comments in an issues database.

• Return to STEP 2.3: DEVELOPMENT OF A REGIONAL STANDARD AND ASSOCIATED DOCUMENTS to revise the regional standard to address the comments received.

• Respond to ballot comments and recommend to the RSC endorse the return to STEP 2.5: POSTING FOR BALLOT PERIOD IN THE OPEN PROCESS to re-ballot the regional standard. The NPCC Manager of Reliability Standards should include the consideration of comments from the prior ballot with the re-posting.

STEP 2.5.B.2 APPROVED BALLOT WITHOUT “NEGATIVE VOTE WITH COMMENT” Regional standard and associated documents, approved by the NPCC ballot body, shall be forwarded by the Assistant Vice President Standards to the NPCC Board of Directors for final Regional approval.

STEP 2.6: NPCC BOARD OF DIRECTORS APPROVAL

Following approval by the NPCC Members, regional standards require review and approval by the NPCC Board of Directors. The NPCC Board of Directors may take the following actions:

• Approve the regional standard as presented.

• Approve the regional standard with comments to incorporate non-substantive revisions. [The NPCC Board of Directors may not make substantive revisions to the standard.]

• Remand the regional standard back to the RSC and the drafting team to address their concerns. The RSC / drafting team can address the BOD comments and re-submit for BOD approval or return to STEP 2.3: DEVELOPMENT OF A REGIONAL STANDARD AND ASSOCIATED DOCUMENTS to revise the regional standard to address the comments received.

STEP 2.7: NERC BOARD OF TRUSTEES SUBMITTAL

Upon approval by the NPCC Board of Directors, the NPCC Manager of Reliability Standards shall submit the regional standard to NERC, as the Electric Reliability Organization, for approval and subsequent filing with FERC and the applicable Canadian Provincial regulatory and/or governmental authorities for adoption.

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 19 Approved by the NPCC Board xxxx xx, 2013

STEP 2.8: IMPLEMENTATION OF A NPCC REGIONAL STANDARD

Following the approval of a NPCC regional standard by FERC and the applicable Canadian Provincial regulatory and/or governmental authorities, all users, owners, planners, and operators of the Bulk Electric System in the NPCC geographic area are required to comply with the standard as of its enforcement date.

ERO approved Reliability Standards (both continent-wide and regional) are included in both the NERC and NPCC Compliance Monitoring and Enforcement Programs (CMEPs).

FIGURE 1: FLOWCHART OF REGIONAL STANDARDS DEVELOPMENT PROCESS OVERVIEW

3. STANDARD CLARIFICATION INTERPRETATION PROCESS STEPS

This section applies to NPCC regional standards that have been approved17 and are currently enforceable or have a future enforcement date. A request for clarification request interpretation is not permitted for regional standards under development. For regional standards under development, an explanation of a requirement or its meaning clarification can be sought during a 17 Approval is granted by FERC and the Canadian Provincial regulatory and/or governmental authorities, as

applicable.

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 20 Approved by the NPCC Board xxxx xx, 2013

comment period. Refer to Step 2, STANDARD DEVELOPMENT PROCESS STEPS of this manual for details on the comment process for a standard under development.

STEP 3.1: REGIONAL STANDARDS REQUEST FOR CLARIFICATION REQUEST INTERPRETATION (CRFCI)

Any member of NPCC or group within the NPCC region shall be allowed to submit a formal Request for Clarification Request Interpretation (CRFCI) of for a NPCC regional standard.

Additionally, any person (organization, company, government agency, individual, etc.) who is directly and materially affected by the reliability of the NPCC Bulk Electric System shall be allowed to submit a formal Request for Clarification Request Interpretation (CRFCI) of for a NPCC regional standard.

Note: A valid cClarification interpretation rRequest is one that seeks additional clarity about one or more requirements in an approved regional standard, but does not request approval as to how to comply with any requirements of the standard.

The Requester should submit a Request for Clarification Request18 (CR) forInterpretation of a NPCC regional standard directly to the NPCC Manager of Reliability Standards, via npccstandard@npcc.org, for processing. Alternatively, the Requester can submit a Request for Interpretation (RFI) of a NPCC regional standardshall be initiated under the NERC process for developing an interpretation. The entity requesting the clarification interpretation shall submit a Request for Interpretation form19 to the NERC Reliability Standards Staff explaining the clarification required, the specific circumstances surrounding the request, and the impact of not having the clarification interpretation provided. A copy of the completed RFI form should also be sent to the NPCC Manager of Reliability Standards.

Upon receipt of a RFI for a requirement of a NPCC regional standard, NERC Reliability Standards Staff shall forward the RFI to the NPCC Manager of Reliability Standards and in doing so shall delegate the validation of and response to the RFI to NPCCNERC NERC Reliability Standards Staff will refer the RFI to NPCC and delegate its resolution to NPCC. NPCC will process the NERC delegation pursuant with the NPCC Request for Clarification Request (CR) process described herein.

STEP 3.2: REVIEW AND VALIDATION OF CLARIFICATION REQUEST FOR CLARIFICATION INTERPRETATION (CRFCI)

Upon receipt of a Clarification Request (CR) the NERC delegation to NPCC to validate and respond to a RFCI for a requirement of for a NPCC regional standard, the NPCC Manager of Reliability Standards shall review the CRFCI to determine whether:

• It meets the requirements for a valid Clarification Requestclarificationinterpretation

• A compliance process or approach could be used in lieu of an clarificationinterpretation The NPCC Manager of Reliability Standards will utilize, as necessary, the NPCC Standards Staff, NPCC Compliance and Legal Staffs when determining the validity of the CRFCI. Based on this review, the NPCC Manager of Reliability Standards will recommend to the RSC whether

18 The NPCC Clarification Request form is included as Appendix D 19 The Request for Interpretation form is posted under Resource Documents on the NERC Standards webpage.

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 21 Approved by the NPCC Board xxxx xx, 2013

to accept or reject the CRFCI. The recommendation to the RSC should be made within thirty (30) calendar days of the receipt of the CRFCI from NERC.

The following examples identify situations that may warrant a recommendation from the NPCC Manager of Reliability Standards to reject the CRFCI:

• Requests approval of a particular compliance approach

• Identifies a gap or perceived weakness in the approved regional standard (Requester should be redirected to initiate an RSAR rather than a CRFCI)

• Where an issue can be addressed by an active (regional or continent-wide) standard drafting team

• Where an issue can be better addressed by a compliance process or approach

• Where it requests clarification of any element of a regional standard other than a requirement

• Where a question has already been addressed in the record

• Where the clarification interpretation identifies an issue and proposes the development of a new or modified regional or continent-wide standard (such issues should be addressed via submission of a RSAR or SAR)

• Where an clarification interpretation seeks to expand the scope of a regional standard

• Where the requirement of the regional standard is clear STEP 3.3: NPCC REGIONAL STANDARDS COMMITTEE (RSC) ACTIONS

The RSC shall review the RFI CRFC along with the recommendation from the NPCC Manager of Reliability Standards and take one of the following actions:

• Reject the RFICRFC. In this case, the RSC will provide its determination to the NPCC Manager of Reliability Standards, who will then provide a written explanation for rejection to the CRFCI to the entity requesting the clarification interpretation within ten (10) calendar days of the decision to reject.

• Accept the RFICRFC. In this case, the RSC will provide its determination to the NPCC Manager of Reliability Standards, who will then: 1) post notification on the NPCC website of the intent to develop an clarificationinterpretation; 2) notify the NPCC Reliability Coordinating Committee (RCC) of the need to notify the ERO for processing in accordance with its process, as applicableassign the resolution of the CRC to one or more Task Forces (if more than one Task Force is assigned, one of them shall be assigned the lead role); and 3) notify the Requester of the acceptance of the CRFCI. The notifications shall be made within ten (10) calendar days of the acceptance of the CR.

STEP 3.4: FORMATION OF DRAFTING TEAM FOR RESPONSE TO RFICRFC

A CRFCI that has been accepted by the RSC shall , within ten (10) calendar days of the acceptance of the RFCI, be assigned by the NPCC Manager of Reliability StandardsRCC to the responsible NPCC Task Force to make up the clarification interpretation drafting team (ICDT) and develop the RFI CRFC response.

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 22 Approved by the NPCC Board xxxx xx, 2013

STEP 3.5: DEVELOPMENT OF RESPONSE TO CRTO RFIRFC

Note: A valid clarification interpretation response provides additional clarity about one or more requirements, but does not expand on any requirement and does not explain how to comply with any requirement.

The drafting team shall submit a proposed interpretation response wWithin sixtyforty-five (6045) calendar days, from the receipt of the being assigned to respond to a CRFCI, the CDT shall submit a proposed clarification interpretation response to the NPCC Manager of Reliability Standards. Upon receipt of the proposed clarification interpretation response from the CDT, the NPCC Manager of Reliability Standards shall present the response to the to obtain RSC to obtain concurrence to post the proposed response for comment.

Along with the proposed clarification interpretation response, the drafting team shall also develop and submit a set of questions to be included in the comment form, for approval by the RSC.

If the RSC concurrence is not received, the drafting team will continue to refine the clarification interpretation response.

Note: There are no limits to the number of public comment periods that can be conducted to result in a clear and concise clarification interpretation of a regional standard requirement.

STEP 3.6: POSTING RFI CRFC FOR COMMENT PERIOD AND RESOLUTION OF COMMENTS

As authorized by the RSC, the NPCC Manager of Reliability Standards shall post the proposed clarification interpretation response on the NPCC website for a forty-five (45) calendar day comment period. NPCC Manager of Reliability Standards shall also notify NERC for processing in accordance with NERC’s regional standards review procedure, as applicable.

Following the conclusion of the NPCC comment period, the NPCC Manager of Reliability Standards will assemble the comments on the proposed clarification interpretation response and provide all comments to the drafting team for consideration.

Within thirty (30) calendar days of the conclusion of the comment period the drafting team shall convene and consider changes to the proposed clarification interpretation response based upon comments received. All submitted comments shall be addressed, which may be in the form of a summary response addressing each of the issues raised in comments receivedand each commenter shall be advised of the disposition, with reasons, of their comments. The NPCC Manager of Reliability Standards shall publicly post all of the drafting team’s responses to stakeholder comments on the NPCC website.

Based on the comments received, the drafting team may elect to:

• Return to STEP 3.5: DEVELOPMENT OF RESPONSE TO CR to revise the proposed clarification interpretation response.

• Accept the proposed clarification interpretation response “as is” to move forward through the remainder of the process.

Upon acceptance of the proposed clarification response “as is,” Completion of the final comment period the drafting team shall submit the proposed clarification interpretation response to the

Formatted: Font: Not Bold

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 23 Approved by the NPCC Board xxxx xx, 2013

NPCC Manager of Reliability Standards to obtain RSC concurrence endorsement to the submitted proposed interpretationCRC response.

The NPCC Manager of Reliability Standards shall also publicly post all of the drafting team’s responses to stakeholder comments on the NPCC website.

STEP 3.7: REGIONAL STANDARDS COMMITTEE APPROVAL OF CRFCI

Upon receipt of the CRFCI response from the NPCC Manager of Reliability Standards, the RSC shall elect to:

• Endorse the proposed clarification interpretation response and direct the NPCC Assistant Vice President Standards to forward the CRC to the NPCC Board of Directors for final Regional approval; or

• Direct the drafting team to return to STEP 3.5: DEVELOPMENT OF RESPONSE TO CR to revise the proposed clarification interpretation response

• Direct the Assistant Vice President Standards to forward the RFI to the NPCC Board of Directors for final Regional approval

STEP 3.8: NPCC BOARD OF DIRECTORS APPROVAL OF CRFCI

Following endorsement by the RSC, clarification interpretation responses require review and approval by the NPCC Board of Directors. The NPCC Board of Directors may take the following actions:

• Approve the clarification interpretation response as presented

• Approve the clarification interpretation response with comments to incorporate non-substantive revisions. [The NPCC Board of Directors may not make substantive revisions to the clarification interpretation response.]

• Remand the clarification interpretation response back to the RSC and the drafting team to address their concerns

Upon receipt of Board approval, the NPCC Manager of Reliability Standards shall notify the Requestor and post the notify NERC of the approved clarification on the NPCC websiteinterpretation for processing in accordance with NERC procedures, as applicable.

Formatted: Font: Not Bold

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 24 Approved by the NPCC Board xxxx xx, 2013

FIGURE 2: FLOWCHART OF REGIONAL STANDARDS CLARIFICATIONINTERPRETATION PROCESS OVERVIEW

4. CURTAILMENTDISCONTINUANCE OF REGIONAL STANDARD DEVELOPMENT

The term “curtailmentdiscontinuance” as used herein refers to terminating the standard development process after RSAR approval but prior to posting a regional standard for industry ballot. From time to time the need or rationale for a regional standard may change thereby necessitating the regional standard development be curtailed. Upon notification or determination that a regional standard under development should be considered for discontinuance curtailment due to a perceived change in the need for the standard, the NPCC Manager of Reliability Standards will submit the recommendation for discontinuance curtailment to the RSC for approval.

4.5. WITHDRAWAL OF A REGIONAL STANDARD PENDING APPROVAL

The term “withdrawal” as used herein, refers to the revocation of a request for approval of a regional standard, variance, clarification interpretation or definition that has been approved by

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 25 Approved by the NPCC Board xxxx xx, 2013

the NPCC Board of Directors and has not been filed with Applicable Governmental Authorities or has been filed but not yet approved by Applicable Governmental Authorities. The RSC may withdraw a regional standard, variance, clarification interpretation or definition for good cause upon subject to approval by the NPCC Board of Directors. Upon approval by the NPCC Board of Directors, the NPCC Manager of Reliability Standards will notify NERC Staff to petition the Applicable Governmental Authorities, as necessary, to allow for withdrawal in the case that the regional standard has been filed.

5.6. RETIREMENT OF AN APPROVED NPCC REGIONAL STANDARD

The term “retirement” refers to the discontinuation of a regional standard in whole, certain requirements within a regional standard, a variance, clarification interpretation or definition that: 1) has been approved by Applicable Governmental Authorities and 2) is not being superseded by or merged into a new or revised regional standard, clarification interpretation or definition.

Upon identification of a need for retirementto retire a regional standard, variance, interpretation or definition, where the item will not be superseded by a new or revised version, a RSAR containing the proposal of theo retirement a regional standard, variance, interpretation or definition will be handled in accordance with the STEP 2.1: REGIONAL STANDARDS AUTHORIZATION REQUEST TO DEVELOP, MODIFY OR RETIREposted for a comment period and ballot in the same manner as a Reliability Standard. The proposal shall include the rationale for the retirement and a statement regarding the impact of retirement on the reliability of the Bulk Electric System. Upon approval by the NPCC Members and the NPCC Board of Directors, the NPCC Manager of Reliability Standards shall submit the request for retirement to NERC, as the Electric Reliability Organization, for approval and to subsequently petition the Applicable Governmental Authorities to allow for retirement.

6.7. APPROVAL OF PROCESS WAIVER

While it is NPCC’s intent to adhere to this manual under normal circumstances, NPCC may need to develop a new or modified regional standard, implementation plan, variance, clarification interpretation or definition under extenuating circumstances. Extenuating circumstances may include, but not be limited to, specific time constraint imposed by a regulatory body and urgent reliability issue that requires expedited handling outside of the normal regional Reliability Standards process.

The RSC, by two-thirds (2/3) majority vote, may waive any of the provisions contained in this manual for good cause shown, but limited to the following circumstances:

• Where necessary to meet regulatory deadlines

• Where necessary to address an urgent reliability issue identified by regulatory and/or governmental authorities, including response to national emergency declared by the United States or Canadian government that involves the reliability of the Bulk Electric System or cyber-attack on the Bulk Electric System

• Where necessary to meet deadlines imposed by the NPCC Board of Directors

• Where the RSC determines that a revision to a proposed regional standard, implementation plan, variance, clarification interpretation or definition has already been vetted by the industry through the standards development process or is so insubstantial that developing

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 26 Approved by the NPCC Board xxxx xx, 2013

the revision through the processes contained in this manual will add significant time delay without any corresponding benefit.

In no circumstances shall this provision be used to modify the requirements for achieving quorum or the voting requirements for approval of a standard.

A waiver request may be submitted to the RSC by any entity or individual, including NPCC committees or subgroups and NPCC Standards Staff. Prior to consideration of any waiver request, the NPCC Manager of Reliability Standards must provide notification to stakeholders at least five (5) business days prior to RSC consideration and action. Posting the waiver request on the NPCC website satisfies the notification provision.

Action on the waiver request will be included in the minutes of the RSC. Following the approval of the RSC to waive any provision of the regional Reliability Standards process, the Assistant Vice President Standards shall report the exercise of this waiver provision to the NPCC Board of Directors prior to adoption of the related Reliability Standard, clarificationinterpretation, definition or variance. Actions taken pursuant to an approved waiver request will be posted on the NPCC Standards webpage.

In addition,

7.8. PROCESS FOR CORRECTING ERRATA

From time to time, an error may be discovered in a regional standard after it has received final ballot approval by the NPCC ballot body. Such errors may be corrected by the RSC without re-balloting if the RSC agrees that the correction of the error does not change the scope or intent of the associated regional standard, and agrees that the correction has no material impact on the end users of the regional standard.

If the regional standard containing errata is pending approval by the NPCC Board of Directors, the corrected regional standard shall be presented to the NPCC Board for approval in lieu of the regional standard approved by the NPCC ballot body.

If a regional standard containing errata had received prior approval by the NPCC Board of Directors, the corrected regional standard shall be presented to the NPCC Board for approval. Upon approval by the Board, the corrected regional standard will be filed for approval by NERC.

The NPCC Board of Directors has resolved to concurrently approve any errata approved by the RSC associated with a regional standard that has received prior approval by the NPCC Board. If the regional standard containing errata is:

• Pending filing with NERC for approval, the corrected regional standard approved by the RSC shall be filed with NERC for approval in lieu of the regional standard approved by the NPCC Board of Directors

• Filed with NERC for approval, then the correction shall be filed for approval with NERC 8.9. APPEALS

Persons who have directly and materially affected interests and who have been or will be adversely affected by any substantive or procedural action or inaction related to the approval, revision, reaffirmation, or withdrawal of a regional standard (appellant) shall have the right to appeal. This appeals process applies only to the regional standards process as defined in this manual.

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 27 Approved by the NPCC Board xxxx xx, 2013

The burden of proof to show adverse effect shall be on the appellant. Appeals shall be made within thirty (30) calendar days of the date of the action purported to cause the adverse effect, except appeals for inaction, which may be made at any time. In all cases, the request for appeal must be made prior to the next step in the process.

The final decisions of any appeal shall be documented in writing and made public.

The appeals process provides two levels, with the goal of expeditiously resolving the issue to the satisfaction of the participants:

LEVEL 1 APPEAL

Level 1 is the required first step in the appeals process. The appellant submits a complaint in writing to the NPCC Manager of Reliability Standards that describes the substantive or procedural action or inaction associated with a Reliability Standard or the standards process. The appellant describes in the complaint the actual or potential adverse impact to the appellant. Assisted by any necessary NPCC Standards Staff and Committee resources, the NPCC Manager of Reliability Standards shall prepare a written response addressed to the appellant as soon as practical, but not more than forty-five (45) calendar days after receipt of the complaint. If the appellant accepts the response as a satisfactory resolution of the issue, both the complaint and response will be made a part of the public record associated with the standard and posted with the standard.

LEVEL 2 APPEAL

If after the Level 1 Appeal the appellant remains unsatisfied with the resolution, as indicated by the appellant in writing to the NPCC Manager of Reliability Standards, the NPCC Board of Directors shall appoint a five member panel to serve as a Level 2 Appeals Panel.

In all cases, Level 2 Appeals Panel members shall have no direct affiliation with the participants in the appeal.

The NPCC Manager of Reliability Standards shall post the complaint and other relevant materials and provide at least a thirty (30) calendar day notice of the meeting of the Level 2 Appeals Panel.

In addition to the appellant, any person that is directly and materially affected by the substantive or procedural action or inaction referenced in the complaint shall be heard by the panel. The panel shall not consider any expansion of the scope of the appeal that was not presented in the Level 1 Appeal. The panel may in its decision find for the appellant and remand the issue to the RSC with a statement of the issues and facts in regard to which unfair and/or inequitable action was taken, or which fair and/or equitable action was not taken. The panel may find for or against the appellant with a specific statement of the facts that demonstrate fair and equitable treatment of the appellant and the appellant’s objections. The panel may not, however, revise, approve, disapprove, or adopt a Reliability Standard. The actions of the Level 2 Appeals Panel shall be publicly posted.

In addition to the foregoing, a procedural objection that has not been resolved may be submitted to the NPCC Board of Directors for consideration at the time the Board decides whether to adopt a particular Reliability Standard. The objection must be in writing, signed by an officer of the objecting entity, and contain a concise statement of the relief requested and a clear demonstration

NPCC Regional Standards Process ManualRegional Standard Processes Manual (RSPM)

RSPM Version 1 28 Approved by the NPCC Board xxxx xx, 2013

of the facts that justify that relief. The objection must be filed no later than thirty (30) calendar days after the announcement of the vote on the standard in question.

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 A1 Approved by the NPCC Board xxxx xx, 2013

APPENDIX A: RSAR COMPLETION GUIDELINES The Requester shall complete a RSAR form in accordance with the guidance provided below.

The RSAR, at a minimum, shall contain information in the required fields in order to be qualified for consideration. The NPCC Manager of Reliability Standards will assist the Requester to ensure all required information is submitted on the RSAR.

Information in a Regional Standard Authorization Request (RSAR) The tables below identify information to be submitted in a Regional Standard Authorization Request to the NPCC Manager of Reliability Standards, at npccstandard@npcc.org. The NPCC Manager of Reliability Standards shall be responsible for implementing and maintaining this form as needed to support the information requirements of the standards process.

Regional Standard Authorization Request Form Title of Proposed Standard: [Required Field]

Request Date: [Required Field]

RSAR Requester Information

Name: [Required Field] RSAR Type (Check box for one of these selections.)

Company: [Required Field] New Standard

Telephone: [Required Field] Revision to Existing Standard

Fax: Withdrawal of Existing Standard

Email: [Required Field] Urgent Action

Purpose: (Describe the purpose of the proposed standard – what the standard will achieve in support of reliability.)

[Required Field]

Industry Need: (Provide a detailed statement justifying the need for the proposed standard, along with a technical justification and any supporting documentation.)

[Required Field -- must include technical justification (relevant studies, documentation, etc.) for a new standard or revision to an existing standard.]

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 A2 Approved by the NPCC Board xxxx xx, 2013

Brief Description: (Describe the proposed standard in sufficient detail to clearly define the scope in a manner that can be easily understood by others.)

[Required Field]

Reliability Functions [Required Field] The Standard will Apply to the Following Functions (Check all applicable boxes.)

Reliability Coordinator

The entity that is the highest level of authority who is responsible for the reliable operation of the Bulk Electric System, has the Wide Area view of the Bulk Electric System, and has the operating tools, processes and procedures, including the authority to prevent or mitigate emergency operating situations in both next-day analysis and real-time operations. The Reliability Coordinator has the purview that is broad enough to enable the calculation of Interconnection Reliability Operating Limits, which may be based on the operating parameters of transmission systems beyond any Transmission Operator’s vision.

Balancing Authority

The responsible entity that integrates resource plans ahead of time, maintains load-interchange-generation balance within a Balancing Authority Area, and supports Interconnection frequency in real time.

Interchange Authority

Authorizes valid and balanced Interchange Schedules.

Planning Authority

The responsible entity that coordinates and integrates transmission facility and service plans, resource plans, and protection systems.

Transmission Service Provider

The entity that administers the transmission tariff and provides Transmission Service to Transmission Customers under applicable transmission service agreements.

Transmission Owner

The entity that owns and maintains transmission facilities.

Transmission Operator

The entity responsible for the reliability of its “local” transmission system, and that operates or directs the operations of the transmission facilities.

Transmission Planner

The entity that develops a long-term (generally one year and beyond) plan for the reliability (adequacy) of the interconnected bulk electric transmission systems within its portion of the Planning Authority Area.

Resource Planner

The entity that develops a long-term (generally one year and beyond) plan for the resource adequacy of specific loads (customer demand and energy requirements) within a Planning Authority Area.

Generator Operator

The entity that operates generating unit(s) and performs the functions of supplying energy and Interconnected Operations Services.

Generator Owner

Entity that owns and maintains generating units.

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 A3 Approved by the NPCC Board xxxx xx, 2013

Purchasing-Selling Entity

The entity that purchases or sells, and takes title to, energy, capacity, and Interconnected Operations Services. Purchasing-Selling Entities may be affiliated or unaffiliated merchants and may or may not own generating facilities.

Distribution Provider

Provides and operates the “wires” between the transmission system and the customer.

Load-Serving Entity

Secures energy and transmission service (and related Interconnected Operations Services) to serve the electrical demand and energy requirements of its end-use customers.

Reliability and Market Interface Principles Applicable Reliability Principles (Check all boxes that apply.)

1. Interconnected Bulk Electric System shall be planned and operated in a coordinated manner to perform reliably under normal and abnormal conditions as defined in the NERC Standards.

2. The frequency and voltage of interconnected Bulk Electric System shall be controlled within defined limits through the balancing of real and reactive power supply and demand.

3. Information necessary for the planning and operation of interconnected Bulk Electric System shall be made available to those entities responsible for planning and operating the systems reliably.

4. Plans for emergency operation and system restoration of interconnected Bulk Electric System shall be developed, coordinated, maintained, and implemented.

5. Facilities for communication, monitoring, and control shall be provided, used, and maintained for the reliability of interconnected Bulk Electric System.

6. Personnel responsible for planning and operating interconnected Bulk Electric System shall be trained, qualified, and have the responsibility and authority to implement actions.

7. The security of the interconnected Bulk Electric System shall be assessed, monitored, and maintained on a wide-area basis.

Does the proposed Standard comply with all of the following Market Interface Principles? (Select ‘yes’ or ‘no’ from the drop-down box.)

Recognizing that reliability is an Common Attribute of a robust North American economy:

1. A reliability standard shall not give any market participant an unfair competitive advantage. Yes

2. A reliability standard shall neither mandate nor prohibit any specific market structure. Yes

3. A reliability standard shall not preclude market solutions to achieving compliance with that standard. Yes

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 A4 Approved by the NPCC Board xxxx xx, 2013

4. A reliability standard shall not require the public disclosure of commercially sensitive information. All market participants shall have equal opportunity to access commercially non-sensitive information that is required for compliance with reliability standards. Yes

Detailed Description: (Provide enough detail so that an independent entity familiar with the industry could draft a standard based on this description.)

[Required Field – Provide: 1) Necessary information to assist the drafting team (which is to include relevant study results and documentation), to the extent feasible, to allow them to draft the standard, 2) Any existing known cross references to NPCC or NERC documents and 3) Technical background for the RSAR to properly address the need for the standard.]

Related Standards [Required Field, to extent known] Standard No. Explanation

Related SARs or RSARs [Required Field, to extent known] SAR ID Explanation

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 B1 Approved by the NPCC Board xxxx xx, 2013

APPENDIX B: SELECTION OF DRAFTING TEAM MEMBERS A regional standard drafting team shall be comprised of Subject Matter Experts (SMEs) from NPCC Task Forces and Working Groups as determined by the RCC, and from industry. The guidelines provided herein primarily address overall team requirements and more specifically those of a SME.

Formal membership on a drafting team should be reserved only for those individuals who intend to work consistently, diligently, and professionally on what is required to be done for a regional standard. drafting Drafting team members are expected to contribute meaningfully to the ongoing development of the standard.

Drafting Tteam members must be:

• Committed to participating in scheduled drafting team meetings, teleconferences, as well as industry outreach (e.g., workshops and webinars)

• Willing to lead teams / sub-teams, as necessary

• Champions for standard development and promoters of the approval of the standard

• Open to consider the comments of others and provide constructive feedback

Subject Matter Experts should possess the necessary expertise and knowledge regarding the topic of the standard. The SMEs should represent a cross section of the registered entities applicable to the standard under development as well as geographical areas within the NPCC footprint.

Industry stakeholders may nominate themselves for consideration by the NPCC Regional Standards Committee (RSC) for the specific drafting team vacancies by completing the following drafting team Self Nomination form and submitting it to NPCC Manager of Reliability Standards, at npccstandard@npcc.org.

Nomination Form for NPCC [Name of drafting team] Drafting Team Please return this form as soon as possible. If you have any questions, please contact the NPCC Standards Staff at npccstandard@npcc.org.

By submitting the following information you are indicating your willingness and agreement to actively participate in the drafting team meetings if appointed to the drafting team by the NPCC Regional Standards Committee (RSC). This means that if you are appointed to the DT you are expected to attend all (or at least the vast majority) of the face-to-face DT meetings as well as participate in all the DT meetings held via conference calls. Failure to do so shall result in your removal from the DT.

Name:

Organization:

Address:

Telephone:

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 B2 Approved by the NPCC Board xxxx xx, 2013

E-mail:

Please briefly describe your experience and qualifications to serve on the requested drafting team.

If you are currently a member of any NERC or Regional drafting teams, please list each team here. Not currently on any active SAR or standard drafting team. Currently a member of the following SAR or standard drafting team(s):

If you previously worked on any drafting team please identify the team(s). No prior NERC or Regional SAR or standard drafting team experience. Prior experience on the following team(s):

Select each NERC Region that you represent: Select each Industry Segment that you represent:

ERCOT FRCC MRO NPCC RFC SERC SPP WECC NA – Not Applicable

1 — Transmission Owners

2 — RTOs, ISOs

3 — Load-serving Entities

4 — Transmission-dependent Utilities

5 — Electric Generators

6 — Electricity Brokers, Aggregators, and Marketers

7 — Large Electricity End Users

8 — Small Electricity End Users

9 — Federal, State, and Provincial Regulatory or other Government Entities

10 — Regional Reliability Organizations and Regional Entities

NA – Not Applicable

Select each Function20 in which you have current or prior expertise:

Balancing Authority Compliance Enforcement Authority Distribution Provider Generator Operator Generator Owner Interchange Authority Load-serving Entity Market Operator Planning Coordinator

Transmission Operator Transmission Owner Transmission Planner Transmission Service Provider Purchasing-selling Entity Reliability Coordinator Reliability Assurer Resource Planner

20 These functions are defined in the NERC Functional Model, which is downloadable from the NERC website.

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 B3 Approved by the NPCC Board xxxx xx, 2013

Provide the names and contact information for two references who could attest to your technical qualifications and your ability to work well in a group.

Name: Telephone:

Organization: E-mail:

Name: Telephone:

Organization: E-mail:

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 C1 Approved by the NPCC Board xxxx xx, 2013

APPENDIX C: MAINTENANCE OF REGIONAL STANDARDS AND PROCESS NPCC regional standards and the Regional Standards Process ManualRegional Standard Processes Manual are living documents that will be updated periodically to remain current and viable (e.g., respond to changing conditions, as well as to incorporate lessons learned and process improvements).

MAINTENANCE OF REGIONAL STANDARDS

NPCC regional standards will be posted for open process review by the RSC for possible revision at least once every five (5) years21 after the first regulatory approval and follow the same process as in the case of a new standard. If no changes are warranted, the Regional Standards Committee (RSC) shall recommend to the NPCC Board that the standard be reaffirmed. If the review indicates a need to revise or retire a regional standard, a Regional Standard Authorization Request shall be prepared by the RSC and submitted in accordance with the NPCC regional standards process. The existing, approved standard subject to revision will remain in effect until such time as the revised version has received FERC or applicable Provincial Governmental Authorities approvals, as appropriate, at which time it will be retired in accordance with any applicable implementation plan associated with the newly approved regional standard.

MAINTENANCE OF THE REGIONAL STANDARDS PROCESS

This NPCC Regional Standards Process will be reviewed for possible revision at least once every five (5) years, or more frequently if needed, and subject to the same procedure as applies to the development of a Regional Standard. All such revisions shall be subject to approval by the NPCC Board of Directors, NERC Board of Trustees, FERC, and may be subject to approval, if required, by Applicable Governmental Authorities in Canada.

21 More frequent reviews of NPCC regional standards may be required to promptly evaluate new or revised NERC reliability standards to ensure NPCC regional standards remain consistent and more stringent than continent-wide reliability standards.

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 D1 Approved by the NPCC Board xxxx xx, 2013

APPENDIX D: NPCC CLARIFICATION REQUEST

Note: A valid clarification request is one that requests additional clarity about one or more requirements in approved NPCC regional standards, but does not request approval as to how to comply with one or more requirements.

Request for an Clarification of a Regional Standard

Date submitted:

Contact information for person requesting the clarification:

Name:

Organization:

Telephone: E-mail:

Identify the standard that needs clarification:

Standard Number (include version number, e.g. PRC-006-NPCC-1 ):

Standard Title:

Identify specifically what requirement needs clarification:

Requirement Number and Text of Requirement:

Identify the nature of clarification that is requested: (Check as many as applicable)

Clarify the required performance

Clarify the conditions under which the performance is required

Clarify which functional entity is responsible for performing an action in a requirement

Clarify the reliability outcome the requirement is intended to produce

Please explain the clarification needed:

Identify the material impact associated with this clarification:

When completed, email this form to: npccstandard@npcc.org For questions about this form or for assistance in completing the form, call Lee Pedowicz at 212-840-1070.

Formatted: Font:

NPCC Regional Standards Process Manual (RSPM) - Appendices

RSPM Version 1 D2 Approved by the NPCC Board xxxx xx, 2013

Identify the material impact to your organization or others, if known, caused by the lack of clarity or an incorrect clarification of this standard.

DOCUMENT REVIEW FORM Document Name: Regional Standard Processes Manual (RSPM) Document Revision: 2nd Draft Document Date: 08/13/2013

Reviewer: RSC Phone Extension: Date Reviewed: 9/5 – 10/20/13

Page 1 of 6

Comment No.

Section/Page No. Comment Disposition of Comment

1 Section I “Of” should not be capitalized. Creating three new appendices: 1) Appendix A: Regional Standard Authorization Request (RSAR) Completion Guidelines and Form; 2) Appendix B: Selection Of drafting team Members and Nomination Form; and 3) Appendix C: Maintenance Of Regional Standards and Process

Comment incorporated

2 Section IV

Please see Non-NPCC Members section. An “s” can be removed from Members in the following sentence: Any entity or person that is neither a General nor Full Members of NPCC is not eligible to participate in the ballot body voting on a regional standard.

Comment incorporated

3 Page 14 Step section 2.3. – an RSAR can be changed to: a RSAR. Any proposed changes to definitions in existing regional standards should be sent to the appropriate Task Force (TF) for consideration of the impact to the standard. If necessary, the TF can produce an RSAR.

Comment incorporated (entire document checked and corrected for consistency)

4 Page 19 Request for clarification section – Step 3.1 Following item can be removed (it is not a process): “NERC had agreed with NPCC that upon receipt of a NERC RFI for a requirement of a NPCC regional standard,” “NERC had agreed with NPCC that upon receipt of a NERC RFI for a requirement of a NPCC regional standard, NERC Reliability Standards Staff will refer the RFI to NPCC and delegate its resolution to NPCC. NPCC will process the NERC delegation pursuant with the NPCC Request for Clarification process described herein.

Comment incorporated

DOCUMENT REVIEW FORM Document Name: Regional Standard Processes Manual (RSPM) Document Revision: 2nd Draft Document Date: 08/13/2013

Reviewer: RSC Phone Extension: Date Reviewed: 9/5 – 10/20/13

Page 2 of 6

5 Page 19 Reviewer does not agree with the proposed revision replacing “interpretation” with “clarification” as this introduces inconsistency with the NERC Rules of Procedure and fails to attain approval of the Applicable Governmental Authorities.

Comment not incorporated – The comment was considered but not incorporated due to a number of factors which include but are not limited to: • NPCC is working with NERC to overhaul its

interpretation process • Existing NERC Interpretation process is very

cumbersome and at the end, results in potential remands or even NERC refusing to file after BOT approval of the interpretation

• FERC staff has indicated that they are very supportive of accepting a changed process, as long as it is open and inclusive

• An Interpretation policy is mandated by ANSI but there are no specific requirements. NERC went too far with balloting, BOT approvals and also FERC filings.

• Within NPCC, remands can be particularly troublesome due to the International nature of the Region.

6 Page 4, Section II

Purpose – The first sentence states in part “formally interpreted.” Reviewer suggests deleting the word “formally” as it is not necessary in this context and implies there is some other interpretation process outside of the RSPM.

Comment incorporated

DOCUMENT REVIEW FORM Document Name: Regional Standard Processes Manual (RSPM) Document Revision: 2nd Draft Document Date: 08/13/2013

Reviewer: RSC Phone Extension: Date Reviewed: 9/5 – 10/20/13

Page 3 of 6

7 Page 4, Section II

Purpose – The second paragraph states that NPCC regional standards will, in all cases, not be inconsistent with the…continent-wide Reliability Standards.” Given that NPCC regional standards have been developed in advance of continent-wide Reliability Standards and the refinement of continent-wide Reliability Standards, it is possible that NPCC regional standards will be found inconsistent with the continent-wide Reliability Standards, therefore violating this statement in the Standards Process Manual. Reviewer suggests adding a sentence to cover this situation, such as, “NPCC will promptly evaluate new or revised NERC Reliability Standards to ensure NPCC regional standards remain consistent.”

Comment intent incorporated – Appendix C, Maintenance of regional standards and Process, was annotated to indicate that: “More frequent reviews of NPCC regional standards may be required to promptly evaluate new or revised NERC Reliability Standards to ensure NPCC regional standards remain consistent and more stringent than continent-wide reliability standards.”

8 Page 4, Section II

Purpose – The 3rd bullet states in part, “Provides a level of Bulk Electric System reliability that is adequate to protect public health, safety, and national security…” While these are lofty principles, Reviewer believes this language is overreaching and inconsistent with the ERO’s authority established in Section 215 to “develop and enforce…reliability standards that provide for an adequate level of reliability of the bulk-power system…” Reviewer suggests revising this bullet to state “Provides an adequate level of reliability for the Bulk Electric System.”

Comment not incorporated – this language is taken directly from the National Electricity Reliability Act and has been used in recent NERC filings e.g., Petition for Approval of BAL-001-TRE-01, filed September 18, 2013

9 Page 6 The 1st bullet states in part, “…provides a level of Bulk Electric System reliability that is necessary and adequate to protect public health, safety, welfare and North American security…” Reviewer suggests revising this bullet to state “…provides an adequate level of reliability for the Bulk Electric System.”

Comment intent incorporated – revised to read: “A NPCC regional standard provides an Adequate Level of Reliability as defined by NERC.”

DOCUMENT REVIEW FORM Document Name: Regional Standard Processes Manual (RSPM) Document Revision: 2nd Draft Document Date: 08/13/2013

Reviewer: RSC Phone Extension: Date Reviewed: 9/5 – 10/20/13

Page 4 of 6

10 Page 6 Justifiable Difference – NPCC proposes to adopt the meaning of the phrase “physical difference” consistent with FERC’s Order, issued September 22, 2004, Granting Request for Clarification regarding Docket No. PL04-5-000, Policy Statement on Matters Related to Bulk Power System Reliability. The FERC Order pre-dates Subtitle A of the Electricity Modernization Act of 2005 adding Section 215 to the Federal Power Act (16 U.S.C. § 824n) (hereafter “the Act”), which, among other things, provides for the establishment of an electric reliability organization (“ERO”) to develop and enforce Reliability Standards applicable to all owners, operators, and users of the Bulk-Power System. Therefore, Reviewer believes usage of the phrase “physical difference” should be consistent with the Act, ERO Regulations, and the NERC Rules of Procedure.

Comment not incorporated – while the reviewer is correct that the cited FERC Order pre-dates the Act, ERO Regulations, and the NERC Rules of Procedure, the cited FERC Order clarifies that in addition to physical differences in the bulk power system there are other factors, such as population density and reliance on mass transit that uses electric power, may also justify more stringent regional reliability standards.

11 Page 6 Types of Reliability Requirements – Reviewer suggests that the first sentence related to the Drafting Team would be better positioned in the document on Page 9 under Drafting Team.

Comment incorporated

12 Page 6 #6 footnote, the link no longer works as a result of NERC web changes.

Comment incorporated – new link provided

DOCUMENT REVIEW FORM Document Name: Regional Standard Processes Manual (RSPM) Document Revision: 2nd Draft Document Date: 08/13/2013

Reviewer: RSC Phone Extension: Date Reviewed: 9/5 – 10/20/13

Page 5 of 6

13 Page 10 NON-NPCC MEMBERS – The first sentence states that “any entity or person that is neither a General nor Full Members of NPCC is not eligible to participate in the ballot body voting on a regional standard.” This statement is inconsistent with Criterion 3 (Exhibit B) of the Amended and Restated Delegation Agreement…(FERC approved effective January 1, 2012, which states in part, “[i]f the Regional Entity has members, the Regional Entity has established rules that assure that its membership is open…and that membership is not a condition for participating in the development of or voting on proposed Regional Reliability Standards. Reviewer seeks clarification in this regard.

Clarification provided herein: Exhibit B specifies the FERC approved criteria authorizing the ERO to delegate certain authority to a Regional Entity. NPCC’s Bylaws have been vetted against these criteria and found acceptable. As noted in Docket No. RR07-3-000, dated April 19, 2007: • ¶294 - “Membership (Criterion 3): NPCC represents

that it has established rules that assure that its membership is open, that it charges no more than a nominal membership fee and agrees to waive the fee for good cause shown, and that membership is not a condition for participating in the development of or voting on proposed reliability standards.”

• ¶297 - “We [Commission] find that the NPCC bylaws and the representations made in Exhibit B of the NPCC Delegation Agreement satisfy the governance requirements of FPA section 215 and the pro forma Exhibit B Governance Criteria.”

14 Page 11 Step 2.1 – In the second paragraph, suggest deleting the word “formal” from the phrase “formal Request for Clarification.”

Comment incorporated

15 Page 12 Step 2.1B – In the 1st paragraph, suggest the phrase “….the Requester will be contacted to decide on how to proceed.” be changed to read “….the Requester will be contacted to determine how to proceed.”

Comment incorporated

16 Page 12 Step 2.1B– Beginning with this step, the NPCC Cost Effectiveness Analysis Procedure (CEAP) is integrated in the RSPM either by direct text or indirectly by notes. Since the CEAP is being used in the development of Regional Reliability Standards, it should be fully integrated in the RSPM, or at the very least, attain the same level of regulatory approval.

Comment not incorporated – the NPCC Cost Effectiveness Analysis Procedure (CEAP) was approved by the RSC on 10/26/11 as a tool to be used in the development of Regional Standards. The CEAP document is posted on the NPCC “Standards - Regional Standards General” webpage

DOCUMENT REVIEW FORM Document Name: Regional Standard Processes Manual (RSPM) Document Revision: 2nd Draft Document Date: 08/13/2013

Reviewer: RSC Phone Extension: Date Reviewed: 9/5 – 10/20/13

Page 6 of 6

17 Page 16 Step 2.5 – The first paragraph, the implementation plan is not identified as “supporting documents” yet the implementation plan is identified as such by the example in the last paragraph. Further, Footnote 15 states that supporting documents are included in the ballot posting for information only and is not balloted. Reviewer requests clarification that the implementation plan is included with the Regional Reliability Standard ballot.

The implementation plan is posted during the comment period but is not posted for balloting. The intent is to include the implementation plan with the supporting material posted during the ballot period for information.

18 Page 19 Step 2.8 – The first sentence states in part, “…all users, owners, planners, and operators of the Bulk Electric System.” Suggest striking “planners” to be consistent with the statutory language.

Comment incorporated

19 Page 22 Reviewer suggests that the draft flowchart be included in subsequent distributions of the draft RSPM document.

Comment incorporated - document updated to include flowcharts

20 Page 23 Step 4 – Suggest replacing “Curtailment” with Discontinuance.”

Comment incorporated

21 Page 23 Step 7 – the last sentence starts with “in addition,” and is not completed. Suggest finishing sentence or deleting.

Comment incorporated – “In addition” deleted

22 Page B2 Page B2, the link in footnote 18 needs to be updated. Comment incorporated – new link provided

RSC December 2013 Meeting Item 6.1 RSC Meeting #13-6, Agenda Item 6.1: NERC Currently Posted Projects

Page 1 of 3

Item Name of Project Details 6.1.a Project 2009-03 -

Five-Year Review of Emergency Operations EOP-001, EOP-002, EOP-003, and IRO-001

Summary: The Emergency Operations Five-Year Review Team has reviewed EOP-001-2.1b,

EOP-002-3 and EOP-003-2 and has posted three draft recommendations for a 45-day industry comment period. Summary of FYRT’s recommendations: o EOP-001-2.1b: The EOP FYRT recommends retiring Requirements R3.1,

R6.1 and R6.3 under Criterion B7 of Paragraph 81; Requirement R3.2 under Criterion B7 and Criterion A of Paragraph 81; Requirement R3.4 under Criterion B1 and Criterion A of Paragraph 81; Requirement R6.2 under Criterion B6 of Paragraph 81; and Requirement R6.4 under Criterion A of Paragraph 81.

o The EOP FYRT further recommends revising and merging EOP-001-2.b and EOP-002-3.1 into one standard; revising Requirements R1, R2 and R5. A review of Attachment 1 was also recommended by this team.

o EOP-002-3.1: The EOP FYRT recommends retiring Requirements R1 and R6 under Criterion B7 of Paragraph 81; and Requirement R9 under Criterion A of Paragraph 81.

o The EOP FYRT further recommends that EOP-001-2b and EOP-002-3.1 be revised and merged into one standard and revisions are recommended for Requirement R8 and Attachment 1.

o EOP-003-2: The EOP FYRT recommends retiring Requirements R5 and R6 under Criterion B7 of Paragraph 81. Requirements R2, R4 and R7 are recommended to be moved to PRC-010-0.

Posted Documents: Standard Authorization Request Supporting Documents

o Unofficial Comment Form o EOP-001-3, Emergency Operations Planning o EOP-002-4, Capacity and Energy Emergencies o EOP-003-3, Load Shedding Plans

Key Issues: Key Dates: SAR Informal 30-day Comment period open through 8:00 p.m. ET on

December 5, 2013

RSC December 2013 Meeting Item 6.1 RSC Meeting #13-6, Agenda Item 6.1: NERC Currently Posted Projects

Page 2 of 3

Item Name of Project Details 6.1.b Project 2010-14.1

- Phase 1 of Balancing Authority Reliability-based Controls: Reserves - BAL-002-2

Summary: This project will review the standard related to Control Performance and

Disturbance control, and propose modifications or new standards as necessary. This project includes the testing and analysis of the new Balancing Authority ACE Limit (BAAL) metric, as well as the development of a continent-wide reserve policy to support BAL-01, BAL-002, and BAL-003.

Posted Documents: BAL-002-2, Disturbance Control Performance - Contingency Reserve for

Recovery from a Balancing Contingency Event Implementation Plan Supporting Materials:

o Unofficial Comment Form (Word) o Background Document o Mapping Document o CR Form 1

Key Issues: Key Dates: Additional Ballot window open through 8:00 p.m. ET on December 11, 2013 Formal 45-day Comment period open through 8:00 p.m. ET on December 11,

2013 6.1.c Project 2007-11 -

Disturbance Monitoring PRC-002-2

Summary: The drafting team to focus the project on a results-based approach to the capture

of data, instead of prescriptive requirements on equipment necessary to capture the data. The drafting team believed that it was best to describe the performance requirements (using a risk-based approach) rather than prescribing necessary equipment. Also, the Reliability Coordinator and Planning Coordinator were added as applicable entities to ensure that the responsibility for specifying and collecting needed disturbance data can be appropriately assigned.

Posted Documents: PRC-002-2, Disturbance Monitoring and Reporting Requirements Median Method Excel Workbook Implementation Plan Supporting Materials:

o PRC-002-2 Unofficial comment form (Word) o PRC-002-1 o PRC-018-1 o Issues and Directives o Mapping Document o VRF/VSL Justification

Additional Documents for Comment: Cost Effective Analysis Process (CEAP) CEAP Supporting Materials:

o Unofficial Comment Form (Word) Key Dates: Initial Ballot window open through 8:00 p.m. ET on December 16, 2013 Formal 45-day Comment period open through 8:00 p.m. ET on December 16,

2013 30-day Comment period for CEAP was open through 8:00 p.m. ET on

December 2, 2013

RSC December 2013 Meeting Item 6.1 RSC Meeting #13-6, Agenda Item 6.1: NERC Currently Posted Projects

Page 3 of 3

Item Name of Project Details 6.1.d Project 2007-06 -

System Protection Coordination - PRC-027-1

Summary: The System Protection Coordination Standard Drafting Team (SPC SDT) created

a new results-based standard, PRC-027-1,with the stated purpose ‘to coordinate Protection Systems for Interconnected Elements, such that Protection System components operate in the desired sequence during Faults. This standard incorporates and clarifies the coordination aspects of Requirements R2 and R3 from PRC-001-2 (formerly R3 and R4 of PRC-001-1).

Posted Documents: PRC-027-1 — Protection System Coordination for Performance During Faults Implementation Plan Supporting Materials:

o Unofficial Comment Form (Word) o Mapping Document o VRF/VSL Justification o PRC-001-2

Key Issues: Key Dates: Additional Ballot window open through 8:00 p.m. ET on December 18, 2013 Formal 45-day Comment period open through 8:00 p.m. ET on December 18,

2013 6.1.e Project 2014-01 -

Standards Applicability for Dispersed Generation Resources

Summary: The Standards Authorization Request (SAR) asks that the applicability section of

certain Reliability Standards that apply to a Generator Owner (GO)/Generator Operator (GOP) or the requirements of certain GO/GOP Reliability Standards be reviewed, and where appropriate revised to recognize the unique technical and reliability aspects of dispersed generation in order to ensure the applicability of the standards is consistent with the reliable operation of the Bulk Electric System (BES). Dispersed generation resources are those resources that are small-scale power generation technologies using a system designed primarily for aggregating capacity providing an alternative to, or an enhancement of, the traditional electric power system.

Posted Documents: SAR Supporting Materials:

o Unofficial Comment Form (Word) Key Issues: Key Dates: SAR Formal 30-day Comment period open through 8:00 p.m. ET on

December 19, 2013

RSC December 2013 Meeting Item 6.2 NERC Ballot History (since last RSC Meeting)

Page 1 of 1

Line Project

Link to Ballot Resultshttps://standards.nerc.net/Ballot.aspx

(clicking in the column to the right of “Ballot Periods” column links to the Ballot Results)

Ballot Type Start DateEnd Date

(SortedOldest to Newest)

Ballot Results Recommendation/Date Comments

424 Project 2012-INT-04 Project 2012-INT-04 - Interpretation of CIP-007-3 for ITC Final Ballot 9/11/2013 9/20/2013 Quorum: 91.64%Approval: 98.61%

Support3/14/13

425 Project 2012-INT-06 Project 2012-INT-06 - Interpretation of CIP-003-3 for Consumers Energy

Final Ballot 9/11/2013 9/20/2013 Quorum: 90.98%Approval: 98.92%

Support3/14/13

427 Project 2013-03 Project 2013-03 Geomagnetic Disturbance Mitigation - EOP-010-1

Additional Ballot 10/9/2013 10/21/2013 Quorum: 77.58%Approval: 88.75%

Support10/16/13

428 Project 2013-03 Project 2013-03 Geomagnetic Disturbance Mitigation - EOP-010-1

Non-binding Poll 10/9/2013 10/21/2013 Quorum: 75.89%Approval: 90.04%

429 Project 2007-17.2 Project 2007-17.2 - Protection System Maintenance and Testing - Phase 2 (Reclosing Relays) - PRC-005-3

Final Ballot 10/16/2013 10/25/2013 Quorum: 85.71%Approval: 85.38%

430 Project 2010-17Project 2010-17 - Definition of Bulk Electric System (Phase 2)

Additional Ballot 10/18/2013 10/29/2013 Quorum: 75.83%Approval: 72.55%

Support10/21/13

431 Project 2013-03 Project 2013-03 Geomagnetic Disturbance Mitigation - EOP-010-1

Final Ballot 10/25/2013 11/4/2013 Quorum: 86.90%Approval: 91.95%

432 Project 2007-02 Project 2007-02 - Operating Personnel Communications Protocols - COM-002-4

Additional Ballot 10/25/2013 11/7/2013 Quorum: 76.67%Approval: 58.24%

433 Project 2010-01 Project 2010-01 - Training - PER-005-2 Additional Ballot 11/1/2013 11/12/2013 Quorum: 76.23%Approval: 56.48%

434 Project 2008-12Project 2008-12 - Coordinate Interchange Standards - Various INT standards - INT-004-3

Initial Ballot 11/4/2013 11/13/2013 Quorum: 76.12%Approval: 67.35%

Support11/5/13

435 Project 2008-12Project 2008-12 - Coordinate Interchange Standards - Various INT standards - INT-006-4

Initial Ballot 11/4/2013 11/13/2013 Quorum: 75.82%Approval: 75.58%

Support11/5/13

436 Project 2008-12Project 2008-12 - Coordinate Interchange Standards - Various INT standards - INT-009-2

Initial Ballot 11/4/2013 11/13/2013 Quorum: 75.82%Approval: 68.40%

Support11/5/13

437 Project 2008-12Project 2008-12 - Coordinate Interchange Standards - Various INT standards - INT-010-2

Initial Ballot 11/4/2013 11/13/2013 Quorum: 75.82%Approval: 58.03%

Support11/5/13

438 Project 2008-12Project 2008-12 - Coordinate Interchange Standards - Various INT standards - INT-011-1

Initial Ballot 11/4/2013 11/13/2013 Quorum: 75.52%Approval: 71.35%

Support11/5/13

439 Project 2008-12Project 2008-12 - Coordinate Interchange Standards - Various INT standards - Definition

Initial Ballot 11/4/2013 11/15/2013 Quorum: 76.42%Approval: 77.82%

Support11/5/13

440 Project 2010-17Project 2010-17 - Definition of Bulk Electric System (Phase 2)

Final Ballot 11/8/2013 11/18/2013 Quorum: 81.68%Approval: 74.34%

Support10/21/13

441 Project 2012-05 Project 2012-05 ATC Revisions (MOD A) - MOD-001-2 Additional Ballot 11/8/2013 11/20/2013 Quorum: 81.69%Approval: 82.97%

No Consensus8/26/13

442 Project 2010-03Project 2010-03 - Modeling Data (MOD B) - MOD-032-1, MOD-033-1

Additional Ballot 11/8/2013 11/20/2013 Quorum: %Approval: %

443 Project 2010-04Project 2010-04 - Demand Data (MOD C) - MOD-031-1

Additional Ballot 11/13/2013 11/22/2013 Quorum: %Approval: %

444 Project 2013-04Project 2013-04 Voltage and Reactive Control - VAR-001-4, VAR-002-3

Additional Ballot 11/15/2013 11/25/2013 Quorum: %Approval: %

445 Quorum: %Approval: %

446 Quorum: %Approval: %

RSC December 2013 Meeting Item 6.3 RSC Meeting #13-6, Agenda Item 6.3: Comment History

(Since last RSC Meeting)

Page 1 of 2

Line Project# Description Document Comment

Type Start Date End Date NPCC

Submitted

178 Project 2008-02

Project 2008-02 Undervoltage Load Shedding

Revised SAR Informal 9/10/13 10/9/13 Yes 10/9/13

179 Project 2013-03

Project 2013-03 Geomagnetic Disturbance Mitigation

EOP-010-1 Formal 9/4/13 10/18/13 Yes 10/18/13

180 Project 2010-17

Project 2010-17 - Definition of Bulk Electric System

BES Definition Formal 9/27/13 10/28/13 Yes 10/28/13

181 Project 2007-02

Project 2007-02 Operating Personnel Communications Protocols

COM-002-4 Formal 10/21/13 11/7/13 Yes 11/4/13

182 Project 2010-01

Project 2010-01 Training PER-005-2 Formal 9/27/13 11/12/13 Yes

11/12/13

183 Project 2008-12

Project 2008-12 Coordinate Interchange Standards

Various INT Standards Formal 9/30/13 11/13/13 Yes

11/13/13

184 Project 2012-05

Project 2012-05 ATC Revisions (MOD A)

MOD-001-2 Formal 10/4/13 11/20/13 Yes

11/18/13

185 Project 2010-03

Project 2010-03 Modeling Data (MOD B)

MOD-032-1, MOD-033-1 Formal 10/07/13 11/20/13

186 Project 2010-04

Project 2010-04 Demand Data (MOD C)

MOD-031-1 Formal 10/09/13 11/22/13 Yes 11/22/13

187 Project 2013-04

Project 2013-04 Voltage and Reactive Control

VAR-001-4, VAR-002-3 Formal 10/11/13 11/25/13

188 Project 2009-03

Project 2009-03 Emergency Operations

SAR Informal 11/06/13 12/05/13

189 Project 2010-14.1

Project 2010-14.1 - Phase 1 of Balancing Authority Reliability-based Controls: Reserves

BAL-002-2 Formal 10/28/13 12/11/13

190 Project 2007-11

Project 2007-11 - Disturbance Monitoring

PRC-002-2 Formal 11/01/13 12/16/13

191 Project 2007-06

Project 2007-06 - System Protection Coordination

PRC-027 Formal 11/04/13 12/18/13

RSC December 2013 Meeting Item 6.3 RSC Meeting #13-6, Agenda Item 6.3: Comment History

(Since last RSC Meeting)

Page 2 of 2

Line Project# Description Document Comment

Type Start Date End Date NPCC

Submitted

192 Project 2014-01

Project 2014-01 - Standards Applicability for Dispersed Generation Resources

SAR Formal 11/20/13 12/19/13

Note: RSC past comment forms are being posted on the NPCC Website under “Standards - Regional Standards Comments.”

RSC December 2013 Meeting Item 8.0

RSC Meeting #13-6, Agenda Item 8.0: Current Activities: Regional Standards

Page 1 of 1

8.1 Current Activities: Regional Standards Item Standard Details 8.1.a PRC-002-NPCC-2 Review PRC-002-NPCC-1 as necessary with due consideration to the revised BES

definition as filed with FERC and revise PRC-002-NPCC-1 accordingly to ensure that sufficient DM equipment is installed to measure and record disturbances on the BES. In addition all NPCC BOD approved interpretations as applicable to the standard will be incorporated into the revised standard. Consideration to all applicable NPCC Compliance Guidance Statements regarding applicability will be reflected in the revision as well as review and potential revision to the Implementation Plan. Status: Regional Standard Authorization Request (RSAR) has been submitted and

approved Drafting Team Nomination period ended March 25, 2013 Draft Team kick-off conference call was Monday April 8, 2013 Project is ongoing

8.2 Current Activities: Regional Standard Interpretations Item Standard Details

RSC December 2013 Meeting Item 9.0 RSC Meeting #13-6, Agenda Item 9.0: NPCC Non-Standards

Page 1 of 1

9.1 Directories In Development Item Directory Details 9.1.a Directory#1 Design

and Operation of the BPS

Status: CP11 and CO7 collaborative review of the Directory #1 Planning and Operating Criteria as directed by the TFCP and TFCO. CO7/CP11 returned draft of Directory#1 to the Task Forces in October for TF review of proposed revisions. Task Forces directed CO7/CP11 to complete the document review, including all Appendices. CO7/CP11 anticipates returning completed document to the TFCO and TFCP for Open Process posting in mid-December.

9.1.b Directory#3 Maintenance Criteria for Bulk Power System Protection

Status: TFSP to identify differences/gaps between Directory #3 and the NERC BOT approved PRC-005-2. Pending completion of the TFSP review of Directory#4.

9.1.c Directory#4 NPCC Bulk Power System Protection Criteria

Status: TFSP currently performing triennial review; review ongoing.

9.2 Directory Interpretations Item Directory Details 9.2.a

9.3 Criteria (A) / Guides (B) / Procedures (C) Documents Item Document Details 9.3.a A-15 - Disturbance

Monitoring Equipment Criteria

TFSP Document Review Tracking - Consideration for retiring this document is pending full implementation and regulatory approval of PRC-002-NPCC-01.

9.3.b B-25 Guide to Time Synchronization of Substation Equipment

TFSP Document Review Tracking - Consider submitting to RCC draft revised B-25 developed in 2010 Open Process Review – Pending approvals of PRC-002-NPCC-01 in Canadian provinces

9.3.c B-26 Guide for Application of Disturbance Recording Equipment

TFSP Document Review Tracking - Consider submitting to RCC draft revised B-26 developed in 2010 Open Process Review – Pending approvals of PRC-002-NPCC-01 in Canadian provinces

9.3.d C-29 Procedure for System Modeling: Data Requirements and Facility Ratings.

TFSS has requested a review of C-29 to consider the impact of the NERC MOD B project and to insure that the document can continue to be referenced in NPCC compliance assessments. Pending SS37 review.

9.3.e C-42 Procedure for Reporting and Reviewing System Disturbances

TFCO to review to insure that the document can continue to be referenced in NPCC compliance assessments. Pending TFCO review.

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 1 of 27

Latest Changes: Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage

Project: 2010-11 TPL Table 1 Order Approve: • TPL-001-4

Retire: • TPL-001-0.1 • TPL-002-0b • TPL-003-0a • TPL-004-0

Withdrawal: • TPL-001-1 /2 • TPL-002-2b • TPL-003-2a / 2b • TPL-004-2 / 2a • TPL-005-0 • TPL-006-0.1

Docket #: RM12-1-000 & RM13-9-000 / Date: 10/17/2013 Title: Order on Reliability Standard TPL-001-4 (Transmission System Planning Performance Requirements) Summary: FERC issues a final rule approving NERC's proposed Transmission Planning Reliability Standard TPL-001-4.

Vol. 78, No. 205 – Date: Wednesday, October 23, 2013 RULES Transmission Planning Reliability Standards Key Dates: This rule will become effective December 23, 2013

Subject to Future Enforcement Last Action: 10/23/13 – FERC Order Published in Federal Register TPL-001-4 Enforceable: January 1, 2015 (R1 & R7) / January 1, 2016 (R2 thru R6 & R8)

Project: 2013-03, Geomagnetic Disturbance Mitigation

11/14/2013 - Petition of NERC for Approval of Proposed Reliability Standard EOP-010-1 Geomagnetic Disturbance Operations NERC submits a petition for approval of proposed Reliability Standard EOP-010-1 Geomagnetic Disturbance Operations. Docket No. RM12-22-000

Filed and Pending Regulatory Approval Last Action: 11/14/13 - NERC Petition Filed

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 2 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: WECC-0068 Approve: • BAL-004-WECC-2 • BAL-001-1 • NERC Glossary: o Area control

Error (ACE) o Automatic Time

Error Correction (ATEC)

Retire: • BAL-004-WECC-1 • BAL-001-0.1a • Appendix 1

Interpretation of Requirement R3 in Reliability Standard BAL-003-0.1b – Frequency Response and Bias

Docket #: RD13-11-000 / Date: 10/16/2013 Title: Letter Order Approving Regional Reliability Standard BAL-004-WECC-01 and Reliability Standard BAL-001-1 Summary: FERC issues a letter approving NERC's proposed regional Reliability Standard BAL-004-WECC-01 and Reliability Standard BAL-001-1. Enforceable: BAL-001-1 will be enforceable on April 1, 2014

Subject to Future Enforcement Last Action: 10/16/13 – FERC Order Issued BAL-001-1 Enforceable: April 1, 2014

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 3 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: 2006-06, Reliability Coordination Approve: • IRO-001-3 • IRO-002-3 • IRO-005-4 • IRO-014-2 Retire: • IRO-001-1.1 • IRO-002-2 • IRO-005-3a • IRO-014-1 • IRO-015-1 • IRO-016-1

Docket #: RM13-12-000, RM13-14-000, RM13-15-000 / Date: 11/21/2013 Title: NOPR to Remand NERC's Proposed Revisions to TOP and IRO Reliability Standards Summary: FERC issues a Notice of Proposed Rulemaking (NOPR) proposing to remand NERC’s proposed revisions to the Transmission Operations (TOP) and Interconnection Reliability Operations and Coordination (IRO) Reliability Standards. The NOPR indicates that, because NERC’s proposed revisions would no longer require entities to plan to operate within all system operating limits, a remand is appropriate. The NOPR raises other questions regarding NERC’s proposed revisions and indicates that, depending on the explanations provided in NOPR commenters, further modifications on remand may be directed. The NOPR also proposes to approve NERC’s proposed revision to Reliability Standard TOP-006-3.

Filed and Pending Regulatory Approval Last Action: 11/21/13 – FERC issues a NOPR

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 4 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: 2007-03, Real-time Transmission Operations Approve: • TOP-001-2 • TOP-002-3 • TOP-003-2 • TOP-006-3 • PRC-001-2 Retire: • TOP-001-1a • TOP-002-2.1b • TOP-003-1 • TOP-004-2 • TOP-005-2a • TOP-006-2 • TOP-007-0 • TOP-008-1 • PER-001-0.2 • PRC-001-1, R2,

R5, and R6

Docket #: RM13-12-000, RM13-14-000, RM13-15-000 / Date: 11/21/2013 Title: NOPR to Remand NERC's Proposed Revisions to TOP and IRO Reliability Standards Summary: FERC issues a Notice of Proposed Rulemaking (NOPR) proposing to remand NERC’s proposed revisions to the Transmission Operations (TOP) and Interconnection Reliability Operations and Coordination (IRO) Reliability Standards. The NOPR indicates that, because NERC’s proposed revisions would no longer require entities to plan to operate within all system operating limits, a remand is appropriate. The NOPR raises other questions regarding NERC’s proposed revisions and indicates that, depending on the explanations provided in NOPR commenters, further modifications on remand may be directed. The NOPR also proposes to approve NERC’s proposed revision to Reliability Standard TOP-006-3.

Filed and Pending Regulatory Approval Last Action: 11/21/13 – FERC issues a NOPR

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 5 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: 2010-INT-01 Rapid Revision of TOP-006-2 for FMPP Approve: • TOP-006-3

Docket #: RM13-12-000, RM13-14-000, RM13-15-000 / Date: 11/21/2013 Title: NOPR to Remand NERC's Proposed Revisions to TOP and IRO Reliability Standards Summary: FERC issues a Notice of Proposed Rulemaking (NOPR) proposing to remand NERC’s proposed revisions to the Transmission Operations (TOP) and Interconnection Reliability Operations and Coordination (IRO) Reliability Standards. The NOPR indicates that, because NERC’s proposed revisions would no longer require entities to plan to operate within all system operating limits, a remand is appropriate. The NOPR raises other questions regarding NERC’s proposed revisions and indicates that, depending on the explanations provided in NOPR commenters, further modifications on remand may be directed. The NOPR also proposes to approve NERC’s proposed revision to Reliability Standard TOP-006-3.

Filed and Pending Regulatory Approval Last Action: 11/21/13 – FERC issues a NOPR

Project: 2013-02, Paragraph 81 NOPR proposing to: • Retire 34

requirements within 19 Reliability Standards

• Withdraw 41 outstanding Commission directives

Docket #: RM13-8-000 / Date: 11/21/2013 Title: Order No. 788 Approving Electric Reliability Organization Proposal to Retire Requirements in Reliability Standards Summary: FERC issues a final rule approving NERC's proposed retirement of 34 requirements within 19 Reliability Standards in response to the Commission’s proposal in paragraph 81 of the March 15, 2012 order in Docket No. RC11-6-000. The final rule approves the retirement of the 34 requirements that either provide little protection for Bulk-Power System reliability or are redundant with other aspects of the Reliability Standards. In addition, the final rule withdraws 41 outstanding Commission directives that NERC make modifications to Reliability Standards that have been addressed in some other manner, are redundant with another directive, or provide general guidance as opposed to a specific directive.

Subject to Future Enforcement Last Action: 11/21/13 – FERC Order Issued

Project: 2008-06, Docket #: RM13-5-000 / Date: 4/18/2013 Subject to

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 6 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Cyber Security Order 706 Version 5 CIP Standards Approve: • CIP Version 5

Retire: • CIP Version 3 • CIP Version 4

Docket #: RM13-5-000 / Date: 11/22/2013 Title: Order Approving Version 5 CIP Reliability Standards Summary: FERC issues a final rule approving the Version 5 Critical Infrastructure Protection (CIP) Reliability Standards, CIP-002-5 through CIP-011-1. The final rule also approves 19 new or revised definitions associated with the CIP Version 5 Reliability Standards for inclusion in the NERC Glossary of Terms. The final rule further directs NERC to develop modifications to the CIP Version 5 Reliability Standards, and submit informational filings.

Future Enforcement Last Action: 11/22/13 – FERC Order Issued

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 7 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: 2006-06, Reliability Coordination Approve: • IRO-001-3 • IRO-002-3 • IRO-005-4 • IRO-014-2 Retire: • IRO-001-1.1 • IRO-002-2 • IRO-005-3a • IRO-014-1 • IRO-015-1 • IRO-016-1

4/16/2013 - Petition of the North American Electric Reliability Corporation for Approval of Proposed Reliability Standards IRO-001-3, IRO-002-3, IRO-005-4, and IRO-014-2 NERC submits a Petition for Approval of Proposed Reliability Standards IRO-001-3, IRO-002-3, IRO-005-4, and IRO-014-2. Docket No. RM13-_-000

Docket #: RM13-12-000, RM13-14-000, RM13-15-000 / Date: 11/21/2013 Title: NOPR to Remand NERC's Proposed Revisions to TOP and IRO Reliability Standards Summary: FERC issues a Notice of Proposed Rulemaking (NOPR) proposing to remand NERC’s proposed revisions to the Transmission Operations (TOP) and Interconnection Reliability Operations and Coordination (IRO) Reliability Standards. The NOPR indicates that, because NERC’s proposed revisions would no longer require entities to plan to operate within all system operating limits, a remand is appropriate. The NOPR raises other questions regarding NERC’s proposed revisions and indicates that, depending on the explanations provided in NOPR commenters, further modifications on remand may be directed. The NOPR also proposes to approve NERC’s proposed revision to Reliability Standard TOP-006-3.

Filed and Pending Regulatory Approval Last Action: 11/21/13 – FERC issues a NOPR

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 8 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: 2007-03, Real-time Transmission Operations Approve: • TOP-001-2 • TOP-002-3 • TOP-003-2 • TOP-006-3 • PRC-001-2 Retire: • TOP-001-1a • TOP-002-2.1b • TOP-003-1 • TOP-004-2 • TOP-005-2a • TOP-006-2 • TOP-007-0 • TOP-008-1 • PER-001-0.2 • PRC-001-1, R2,

R5, and R6

4/16/2013 - Petition for Approval of Three Transmission Operation Standards, One Protection and Control Reliability Standard, and Retirement of Nine Existing Reliability Standards and One Requirement from an Existing Reliability Standard NERC submits a Petition for Approval of Three Transmission Operation Standards (TOP-001-2—Transmission Operations, TOP-002-3—Operations Planning, TOP-003-2—Operational Reliability Data) One Protection and Control Reliability Standard (PRC-001-2—System Protection Coordination), and Retirement of Nine Existing Reliability Standards and One Requirement from an Existing Reliability Standard. Docket No. RM13-_-000

Docket #: RM13-12-000, RM13-14-000, RM13-15-000 / Date: 11/21/2013 Title: NOPR to Remand NERC's Proposed Revisions to TOP and IRO Reliability Standards Summary: FERC issues a Notice of Proposed Rulemaking (NOPR) proposing to remand NERC’s proposed revisions to the Transmission Operations (TOP) and Interconnection Reliability Operations and Coordination (IRO) Reliability Standards. The NOPR indicates that, because NERC’s proposed revisions would no longer require entities to plan to operate within all system operating limits, a remand is appropriate. The NOPR raises other questions regarding NERC’s proposed revisions and indicates that, depending on the explanations provided in NOPR commenters, further modifications on remand may be directed. The NOPR also proposes to approve NERC’s proposed revision to Reliability Standard TOP-006-3.

Filed and Pending Regulatory Approval Last Action: 11/21/13 – FERC issues a NOPR

Project: 2007-07 Transmission Vegetation Management Approve: • FAC-003-2 Retire: • FAC-003-1

12/21/2011 – Petition for Approval of Proposed Reliability Standard FAC-003-2 - Transmission Vegetation Management NERC files a Petition for Approval of Proposed Reliability Standard FAC-003-2 — Transmission Vegetation Management. Docket No. RM_-__-___ 4/24/2012 - Errata to Petition for Approval of FAC-003-2 NERC submits errata to the Petition for Approval of Proposed Reliability Standard FAC-003-2—Transmission Vegetation Management correcting a typo in the Compliance section of the standard. Docket No. RM12-4-000

Docket #: RM12-4-000 / Date: 4/23/2012 Title: Notice Inviting Comments on Report Prepared by PNNL on "Applicability of the 'Gallet Equation' to the Vegetation Clearances of NERC Reliability Standard FAC-003-2" Summary: FERC posts and invites comment upon a report prepared by the Pacific Northwest National Laboratory (PNNL) on “Applicability of the ‘Gallet Equation’ to the Vegetation Clearances of NERC Reliability Standard FAC-003-2” (PNNL Report). Docket No. RM12-4-000 Docket #: RM12-4-000 / Date: 5/4/2012 Title: Data Request in Response to the NERC Petition for Approval of Proposed Reliability Standard FAC-

Vol. 78, No. 60 – Date: Thursday, March 28, 2013 RULES Revisions to Reliability Standard for Transmission Vegetation Management Key Dates: This rule became effective May 28, 2013 Enforceable: FAC-003-2 will be enforceable on July 1, 2014 Vol. 78, No. 74 – Date: Wednesday, April 17, 2013 RULES Revisions to Reliability Standard for Transmission Vegetation Management; Correction Key Dates:

Subject to Future Enforcement Last Action: 9/4/13 – FERC Approved NERC Compliance Filing FAC-003-2 Enforceable: July 1, 2014

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 9 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage 5/3/2012 - Request for Information of NERC on the Notice Inviting Comments on the PNNL Report Concerning the Applicability of the Gallet Equation to the Vegetation Clearances of NERC Transmission Vegetation Management Reliability Standard FAC-003-2 NERC submits a request for information on the Notice Inviting Comments regarding related documents. Docket No. RM12-4-000 5/24/2012 - Comments of NERC in Response to PNNL Report on the Use of the Gallet Equation in FAC-003-2 NERC files comments in response to the report prepared by the Pacific Northwest National Laboratory (“PNNL”) on “Applicability of the ‘Gallet Equation’ to the Vegetation Clearances of NERC Reliability Standard FAC-003-2." Docket No. RM12-4-000 5/25/2012 - Response of NERC to FERC Office of Reliability's May 4, 2012 Data Request regarding FAC-003-2 NERC files its response to the FERC Office of Electric Reliability’s May 4, 2012 Data Request regarding FAC-003-2. Docket No. RM12-4-000 12/21/2012 - Comments of NERC in response to NOPR on Transmission Vegetation Management Standard FAC-003-2 NERC submits comments in response to the October 18, 2012 Notice of Proposed Rulemaking proposing to approve Reliability Standard FAC-003-2. Docket No. RM12-4-000 2/5/2013 - Reply Comments of NERC in Response to Comments Submitting on NOPR on Transmission Vegetation Management Standard FAC-003-2

003-2 - Transmission Vegetation Management Summary: FERC issues a data request in response to NERC's Petition for Approval of Proposed Reliability Standard FAC- 003-2 – Transmission Vegetation Management order to better understand NERC’s petition. Docket No. RM12-4-000 Docket #: RM12-4-000 / Date: 10/18/2012 Title: NOPR on Revisions to Reliability Standards for Transmission Vegetation Management Summary: FERC issues a NOPR in which it proposes to approve Reliability Standard FAC-003-2 (Transmission Vegetation Management, the three definitions in the petition, the implementation plan and the Violation Severity Levels associated with the proposed Reliability Standard. The Commission proposes to direct that NERC revise the Violation Risk Factor for Requirement R2, and approve the remainder of the Violation Risk Factors. Docket No. RM12-4-000 Docket #: RM12-4-000 / Date: 3/21/2013 Title: Order No. 777 - Final Rule Approving FAC-003-2 - Transmission Vegetation Management Summary: FERC issues a final rule approving Reliability Standard FAC-003-2 - Transmission Vegetation Management, and three new definitions in the NERC Glossary of Terms – “Right-of-Way,” “Vegetation Inspection,” and “Minimum Vegetation Clearance Distance.” FAC-003-2 also incorporates a new minimum annual inspection requirement, and incorporates new minimum vegetation clearance distances into the text of the standard. Docket No. RM12-4-000 Docket #: RM12-4-001 / Date: 9/4/2013 Title: NERC Compliance Filing in Response to Order No. 777 Summary: FERC issues a letter order accepting NERC’s

N/A - the following corrections are made: 1. On page 18826, in the third column, in paragraph

73, correct ‘‘45 days’’ to read ‘‘60 days’’ 2. On page 18827, in the first column, in paragraph

77, correct ‘‘45 days’’ to read ‘‘60 days’’

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 10 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage NERC submits reply comments to comments submitted on the NOPR on Revisions to Reliability Standards for Transmission Vegetation Management. Docket No. RM12-4-000 7/12/2013 - Compliance Filing of NERC FAC-003-2 NERC submits a compliance filing to: (1) provide a detailed description of NERC's plan to conduct testing to develop empirical data regarding the flashover distances between conductors and vegetation; (2) modify the Violation Rick Factor ("VRF") for Requirement R2; and (3) confirm NERC has posted guidance materials for NERC Reliability Standard FAC-003-2. Docket No. RM12-4-000

compliance filing without modification submitted in response to Order No. 777, which approved NERC’s proposed Reliability Standard FAC-003-2 (Transmission Vegetation Management). In that order, the Commission directed NERC to (1) provide a description of NERC’s plan to conduct testing to develop empirical data regarding the flashover distances between conductors and vegetation; (2) modify the Violation Risk Factor for Requirement R2 from Medium to High; and (3) confirm that NERC has posted guidance materials for NERC Reliability Standard FAC-003-2 to its website. Enforceable: FAC-003-2 enforceable on July 1, 2014

Project: 2007-09 ― Generator Verification Approve: • MOD-025-2 • MOD-026-1 • MOD-027-1 • PRC-019-1 • PRC-024-1 Retire: • MOD-024-1

(pending regulatory approval)

• MOD-025-1 (pending regulatory approval)

5/30/2013 - Petition of NERC for Approval of Five Proposed Reliability Standards MOD-025-2, MOD-026-1, MOD-027-1, PRC-019-1 and PRC-024-1 Attachments to the Filing NERC submits a petition for five new Generator Verification Standards and their accompanying VRFs and VSLs. Docket No. RM_-_-000

Docket #: RM13-16-000 / Date: 9/19/2013 Title: Notice of Proposed Rulemaking to Approve Reliability Standards MOD-025-2, MOD-026-1, MOD-027-1, PRC-019-1 and PRC-024-1 Summary: FERC issues a Notice of Proposed Rulemaking (NOPR) proposing to approve the proposed Reliability Standards. The Commission notes in the NOPR that, collectively, the proposed Reliability Standards improve the accuracy of model verifications needed to support reliability and enhance the coordination of generator protection systems and voltage regulating system controls. The Commission goes on to state that such improvements should help reduce the risk of generator trips and provide more accurate models for Transmission Planners and Planning Coordinators to develop system models and simulations.

Vol. 78, No. 185 – Date: Tuesday, September 24, 2013 PROPOSED RULES Generator Verification Reliability Standards Key Dates: Comments due 11/25/2013

Filed and Pending Regulatory Approval Last Action: 9/24/13 – NOPR published in Federal Register. Comments due November 25, 2013 Comments Due: 11/25/13

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 11 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: 2007-12 ― Frequency Response and Frequency Bias Setting Approve: • BAL-003-1 Retire: • BAL-003-0.1b

3/29/2013 - Petition for Approval of Proposed Reliability Standard BAL-003-1 - Frequency Response and Frequency Bias Setting NERC submits a Petition of the North American Electric Reliability Corporation for Approval of Proposed Reliability Standard BAL-003-1 – Frequency Response and Frequency Bias Setting. The proposed standard ensures that each of the Interconnections have sufficient Frequency Response to guard against underfrequency load shedding (“UFLS”) due to an event in that Interconnection. Docket No. RM13-11-000 9/27/13 – NERC Comments on NOPR on Frequency Response NERC submits comments in response to the Notice of Proposed Rulemaking (NOPR) regarding proposed Reliability Standard BAL-003-1 (Frequency Response and Frequency Bias Setting)

Docket #: RM13-11-000 / Date: 7/18/2013 Title: Notice of Proposed Rulemaking (NOPR) on Reliability Standard BAL-003-1 Summary: The Commission proposes to approve Reliability Standard BAL-003-1 (Frequency Response and Frequency Bias Setting), submitted by the North American Electric Reliability Corporation, the Commission-certified Electric Reliability Organization. The proposed Reliability Standard defines the necessary amount of frequency response needed for reliable operations for each Balancing Authority within an Interconnection.

Vol. 78, No. 145 – Date: Monday, July 29, 2013 PROPOSED RULES Frequency Response and Frequency Bias Setting Reliability Standard Key Dates: Comments due 9/27/2013

Filed and Pending Regulatory Approval Last Action: 9/27/13 NERC Comments on NOPR on Frequency Response

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 12 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: 2007-17 ― Protection System Maintenance and Testing Approve: • PRC-005-2 Retire: • PRC-005-1.1b • PRC-008-0 • PRC-011-0 • PRC-017-0

2/26/2013 - Petition for Approval of Proposed Reliability Standard PRC-005-2 - Protection System Maintenance NERC submits proposed Reliability Standard PRC-005-2 which consolidates Reliability Standards PRC-005-1.1b, PRC-008-0, PRC-011-0, and PRC-017-0 into a single proposed Reliability Standard. Proposed PRC-005-2 also addresses the directives related to those Reliability Standards issued by the Commission in Order No. 693. Docket No. RM13-7-000 9/9/13 - Informational Filing of NERC Regarding Definition of Protection System NERC submits an Informational Filing Regarding the implementation of the modification to the definition of "Protection System" on the Glossary Terms in NERC. Docket No. RD11-13-000 9/23/13 – Comments of NERC in Response to Notice of Proposed Rulemaking on PRC-005-2 (Protection System Maintenance) NERC submits comments on the Notice of Proposed Rulemaking (NOPR) regarding proposed Reliability Standard PRC-005-2. Docket No. RM13-7-000

Docket #: RM13-7-000 / Date: 7/18/2013 Title: Notice of Proposed Rulemaking to Approve PRC-005-2 Summary: FERC issues a Notice of Proposed Rulemaking (NOPR) to approve Reliability Standard PRC-005-02-Protection System Maintenance.

Vol. 78, No. 142 – Date: Wednesday, July 24, 2013 PROPOSED RULES Protection System Maintenance Reliability Standard Key Dates: Comments due 9/23/2013

Filed and Pending Regulatory Approval Last Action: 9/23/13 - NERC submits comments on the NOPR regarding proposed Reliability Standard PRC-005-2

Project: 2008-06, Cyber Security Order 706 Version 5 CIP Standards Approve: • CIP Version 5

Retire: • CIP Version 3 • CIP Version 4

1/31/2013 - Petition of NERC for Approval of CIP Version 5 Reliability Standards NERC submits a Petition for approval of Critical Infrastructure Protection Reliability Standards Version 5. Docket No. RM13-5-000 6/24/2013 - Comments of NERC on the Notice of Proposed Rulemaking for Version 5 Critical Infrastructure Protection Reliability Standards NERC submits comments on the Notice of Proposed Rulemaking (NOPR) regarding NERC's proposed Version 5 Critical Infrastructure Protection (CIP Version5) Reliability Standards issued by FERC on April 18, 2013.

Docket #: RM13-5-000 / Date: 4/18/2013 Title: NOPR on Version 5 Critical Infrastructure Protection Reliability Standards Summary: FERC issues a Notice of Proposed Rulemaking proposing to approve the Version 5 CIP Standards. The proposed Reliability Standards, which pertain to the cyber security of the bulk electric system, represent an improvement over the current Commission-approved CIP Reliability Standards as they adopt new cyber security controls and extend the scope of the systems that are protected by the CIP Reliability Standards. Docket #: RM13-5-000 / Date: 5/3/2013

Vol. 78, No. 79 – Date: Wednesday, April 24, 2013 PROPOSED RULES Version 5 Critical Infrastructure Protection Reliability Standards Key Dates: Comments were due 6/24/2013 Vol. 78, No. 90 – Date: Thursday, May 9, 2013 PROPOSED RULES Version 5 Critical Infrastructure Protection Reliability Standards - Errata Key Dates: N/A

Subject to Future Enforcement Last Action: 11/22/13 – FERC Order Issued

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 13 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage 9/30/2013 - Errata to Petition for Approval of CIP Version 5 NERC submits Errata to Petition of NERC for Approval of Critical Infrastructure Protection Reliability Standards (CIP Version 5). Docket No. RM13-5-000 10/1/2013 - Errata to Petition for Approval of CIP Version 5 On September 30, 2013, NERC submitted errata to the proposed defined terms and Violation Severity Levels associated with version 5 of the Critical Infrastructure Protection Reliability Standards (“CIP Version 5”) pending before the Commission. NERC submits a replacement Attachment 2 that contains corrected clean and redline version of proposed CIP-002-5.1. Docket No. RM13-5-000

Title: Errata to FERC's Order on Version 5 CIP Reliability Standards Summary: FERC issues errata correcting minor typographical errors in the Order on Version 5 Critical Infrastructure Protection Reliability Standards. Docket #: RM11-11-000 (V4) & RM13-5-000 (V5) / Date: 8/12/2013 Title: Order Granting Extension of Time CIP Version 4 and 5 Summary: FERC issues an order granting extension of time on Version 4 of the Critical Infrastructure Protection (CIP) Reliability Standards. The Commission approved the Version 4 CIP Reliability Standards in Order 761. This order extends the effective date from April 1, 2014 to October 1, 2014. [Six-month extension is consistent with the NOPR proposal regarding implementation of the proposed V5 Standards (i.e., transition from V3 CIP directly to V5 CIP.] Docket #: RM13-5-000 / Date: 11/22/2013 Title: Order Approving Version 5 CIP Reliability Standards Summary: FERC issues a final rule approving the Version 5 Critical Infrastructure Protection (CIP) Reliability Standards, CIP-002-5 through CIP-011-1. The final rule also approves 19 new or revised definitions associated with the CIP Version 5 Reliability Standards for inclusion in the NERC Glossary of Terms. The final rule further directs NERC to develop modifications to the CIP Version 5 Reliability Standards, and submit informational filings.

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 14 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: 2009-01, Disturbance and Sabotage Reporting Approve: • EOP-004-2

Retire: • EOP-004-1 • CIP-001-2a

12/31/2012 - Petition for Approval of Proposed Reliability Standard EOP-004-2 - Event Reporting NERC submits a petition for approval of standard EOP-004-2 - Event Reporting. The proposed Reliability Standard provides a comprehensive approach to reporting disturbances and events that have the potential to impact the reliability of the Bulk Electric System in accordance with several Commission directives. Docket No. RD13-3-000 1/4/2013 - Errata to Petition for Approval of Proposed Reliability Standard EOP-004-2 - Event Reporting NERC submits errata making a minor correction to Exhibit B - Reliability Standard EOP-004-2. Docket No. RD13-3-000

Docket #: RD13-3-000 / Date: 6/20/2013 Title: Order Granting Approval for EOP-004-2 Summary: FERC issues an order approving EOP-004-2, which would replace two existing Reliability Standards, EOP-004-1- Disturbance Reporting and CIP-001-2a - Sabotage Reporting. EOP-004-2 is a Result Based Standards that merges EOP-004-1- and CIP-001-2a into a single event reporting standard. Enforceable: EOP-004-2 enforceable on January 1, 2014

N/A - Order is effective immediately (6/20/2013) Vol. 78, No. 135 – Date: Monday, July 15, 2013 ORDER APPROVING RELIABILITY STANDARDS Order Approving Reliability Standards: North American Electric Reliability Corp. [EOP-004-2] Key Dates: N/A

Subject to Future Enforcement Last Action: 7/15/13 – FERC Order Published in Federal Register EOP-004-2 Enforceable: January 1, 2014

Project: 2009-19, Interpretation of BAL-002-0 R4 and R5 by NWPP Reserve Sharing Group Approve: • BAL-002-1a

Retire: • BAL-002-1

2/12/2013 - Petition for Approval of Interpretation to BAL-002-1 - Disturbance Control Performance NERC submits a petition for approval of proposed interpretation BAL-002-1a, which includes an interpretation to Requirements R4 and R5 of BAL-002-1. Docket No. RD13-_-000 7/8/2013 - NERC Comments on Proposed Remand of BAL-002 NERC submits comments in response to the May 16, 2013 Notice of Proposed Rulemaking (NOPR) proposing to remand the proposed interpretation of Reliability Standard BAL-002-1. Docket No. RM13-6-000

Docket #: RM13-6-000 / Date: 5/16/2013 Title: NOPR Proposing to Remand Interpretation to BAL-002-1 - Disturbance Control Performance Summary: FERC issues a NOPR in which it proposes to remand a proposed interpretation to BAL-002-1, Requirements R4 and R5.

Vol. 78, No. 99 – Date: Wednesday, May 22, 2013 PROPOSED RULES Electric Reliability Organization Interpretation of Specific Requirements of the Disturbance Control Performance Standard Key Dates: Comments were due 7/8/2013

Filed and Pending Regulatory Approval Last Action: 7/8/13 – NERC Submits Comments [NERC urges FERC to accept the proposed interpretation as submitted]

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 15 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: 2010-07, Generator Requirements at the Transmission Interface Approve: • FAC-001-1 • FAC-003-3 • PRC-004-2.1a • PRC-005-1.1b

Retire: • FAC-001-0 • FAC-003-1 / 2 • PRC-004-2a • PRC-005-1b

7/30/2012 - Petition for Approval of FAC-001-1, FAC-003-3, PRC-004-2.1a, and PRC-005-1.1b NERC submits a petition for approval of proposed Reliability Standards FAC-001-1 – Facility Connection Requirements, FAC-003-3 – Transmission Vegetation Management, PRC-004-2.1a – Analysis and Mitigation of Transmission and Generation Protection System Misoperations and PRC-005-1.1b - Transmission and Generation Protection System Maintenance and Testing. Docket No. RD12-16-000 6/24/2013 - Comments of the North American Electric Reliability Corporation on Generator Requirements at the Transmission Interface NOPR NERC submits comments in response to FERC's April 18, 2013 NOPR regarding modifications to four existing Reliability Standards, FAC -001-1 (Facility Connection Requirements), FAC -003-3 (Transmission Vegetation Management), PRC -004-2.1a (Analysis and Mitigation of Transmission and Generation Protection System Misoperations), and PRC -005-1.1b (Transmission and Generation Protection System Maintenance and Testing). Docket No. RM12-16-000 7/9/2013 - Reply Comments of NERC in Response to GOTO NOPR Comments NERC submits reply comments in response to the comments submitted on June 24, 2013 on the FERC April 18, 2013, Notice of Proposed Rulemaking (NOPR) regarding modifications to four existing Reliability Standards. Docket No. RM12-16-000

Docket #: RM12-16-000 / Date: 4/18/2013 Title: NOPR Proposing to Approve Generator Requirements at the Transmission Interface (GOTO) Summary: FERC issues at NOPR in which it proposes to approve Reliability Standards FAC-001-1 (Facility Connection Requirements), FAC-003-3 (Transmission Vegetation Management), PRC-004-2.1 (Analysis and Mitigation of Transmission and Generation Protection System Misoperations), and PRC-005-1.1b (Transmission and Generation Protection System Maintenance and Testing). The proposed modifications improve reliability either by extending their applicability to certain generator interconnection facilities, or by clarifying that the existing Reliability Standard is and remains applicable to generator interconnection facilities. Docket #: RM12-16-000 / Date: 9/19/2013 Title: Order on Final Rule Generator Requirements at the Transmission Interface Summary: FERC issues a Final Rule approving revisions to four Reliability Standards that extend or clarify that applicability of those standards to Generator Owners and Generator Operators and/or to their generator interconnection Facilities. In the final rule, the Commission also states that, while additional Reliability Standards or individual requirements may need to be applied on a case-by-case basis to generator interconnection Facilities in certain circumstances, for the majority of Generator Owners and Operators, NERC will not pursue registration of Generator Owners and Operators as Transmission Owners or Transmission Operators due solely to their ownership or operation of generator interconnection Facilities.

Vol. 78, No. 79 – Date: Wednesday, April 24, 2013 PROPOSED RULES Generator Requirements at the Transmission Interface Key Dates: Comments were due 6/24/2013 Vol. 78, No. 185 – Date: Tuesday, September 24, 2013 RULES Generator Requirements at the Transmission Interface Key Dates: Rule effective 11/25/13

Subject to Future Enforcement Last Action: 9/24/13 - NERC Final Rule published in Federal Register PRC-004-2.1a and PRC-005-1.1b Enforceable: November 25, 2013 FAC-001-1 and requirement R3 of FAC-003-3 Enforceable: April 1, 2015 Remaining requirements of FAC-003-3 Enforceable: April 1, 2016.

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 16 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: 2010-INT-01 Rapid Revision of TOP-006-2 for FMPP Approve: • TOP-006-3

Docket #: RM13-12-000, RM13-14-000, RM13-15-000 / Date: 11/21/2013 Title: NOPR to Remand NERC's Proposed Revisions to TOP and IRO Reliability Standards Summary: FERC issues a Notice of Proposed Rulemaking (NOPR) proposing to remand NERC’s proposed revisions to the Transmission Operations (TOP) and Interconnection Reliability Operations and Coordination (IRO) Reliability Standards. The NOPR indicates that, because NERC’s proposed revisions would no longer require entities to plan to operate within all system operating limits, a remand is appropriate. The NOPR raises other questions regarding NERC’s proposed revisions and indicates that, depending on the explanations provided in NOPR commenters, further modifications on remand may be directed. The NOPR also proposes to approve NERC’s proposed revision to Reliability Standard TOP-006-3.

Filed and Pending Regulatory Approval Last Action: 11/21/13 – FERC issues a NOPR

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 17 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: 2010-INT-05, CIP-002-1 Requirement R3 for Duke Energy Approve: • CIP-002-4a

Retire: • CIP-002-4

4/22/2013 - Request for Clarification of NERC on Order Remanding Interpretation to CIP-002-4 NERC submits a request for clarification to the March 21, 2013 Order on Interpretation of Reliability Standard remanding NERC's proposed interpretation to CIP-002-4, Requirement R2. NERC seeks clarification on two specific issues. Docket No. RD12-5-000

Docket #: RD12-5-000 / Date: 3/21/2013 Title: Order Remanding Interpretation to CIP-002-4 - Critical Cyber Asset Identification Summary: FERC issues an order in which it remands the proposed interpretation to Reliability Standard CIP-002-4, Requirement R3. Docket #: RD12-5-001 / Date: 5/20/2013 Title: Order Granting Rehearing for Further Consideration on CIP-002-4 Remand Summary: FERC issues an order granting rehearing for further consideration on the order remanding the proposed interpretation to CIP-002-4 issued on March 21, 2013. Docket #: RD12-5-001 / Date: 6/25/2013 Title: Order on Clarification on Proposed Interpretation of CIP 002 Summary: FERC issues an order for clarification of the March 21, 2013 Order on Interpretation of Reliability Standards, in which the Commission remanded NERC's proposed interpretation of Critical Infrastructure Protection (CIP) Reliability Standard CIP -002.

Interpretation Remanded Last Action: 6/25/13 – FERC Issues Order on Clarification

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 18 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: 2010-11 TPL Table 1 Order Approve: • TPL-001-4

Retire: • TPL-001-0.1 • TPL-002-0b • TPL-003-0a • TPL-004-0

Withdrawal: • TPL-001-1 /2 • TPL-002-2b • TPL-003-2a / 2b • TPL-004-2 / 2a • TPL-005-0 • TPL-006-0.1

2/28/2013 - Petition of NERC for Approval of Modified Transmission Planning Reliability Standards in the Case of System Performance Following Loss of a Single Bulk Electric System Element NERC submits a Petition for Approval of Modified Transmission Planning Reliability Standards that include changes to the requirements and processes for planned load shed in the event of a single Contingency that are identified in a revised footnote. NERC is also requesting Commission approval of revisions to the Standards that correspond to the Footnote revisions included in this Petition and other related documents. 6/24/2013 - Comments of the North American Electric Reliability Corporation in Response to Supplemental Notice of Proposed Rulemaking TPL -001-4 NERC submits comments in response to FERC's May 16, 2013 Supplemental Notice of Proposed Rulemaking (NOPR) regarding Reliability Standard TPL -001-4. The proposed modifications improve reliability and resolve issues and concerns with previous standards. The supplemental NOPR proposes to approve Reliability Standard TPL -001-4.

Docket #: RM12-1-000 & RM13-9-000 / Date: 5/16/2013 Title: Supplemental NOPR on Transmission Planning Reliability Standard TPL-001-2 Summary: FERC issues a NOPR in which it proposes to approve TPL-001-4, which supersedes TPL-001-2. Docket #: RM12-1-000 & RM13-9-000 / Date: 10/17/2013 Title: Order on Reliability Standard TPL-001-4 (Transmission System Planning Performance Requirements) Summary: FERC issues a final rule approving NERC's proposed Transmission Planning Reliability Standard TPL-001-4.

Vol. 78, No. 100 – Date: Thursday, May 23, 2013 PROPOSED RULES Transmission Planning Reliability Standards Key Dates: Comments were due 6/24/2013 Vol. 78, No. 205 – Date: Wednesday, October 23, 2013 RULES Transmission Planning Reliability Standards Key Dates: This rule will become effective December 23, 2013

Subject to Future Enforcement Last Action: 10/23/13 – FERC Order Published in Federal Register TPL-001-4 Enforceable: January 1, 2015 (R1 & R7) / January 1, 2016 (R2 thru R6 & R8)

Project: 2010-13 Relay Loadability Approve: • PRC-025-1

9/27/2013 - Petition of NERC for Approval of Proposed Reliability Standard PRC-025-1 NERC submits proposed Reliability Standard PRC-025-1- Generator Relay Loadability for approval. [According to NERC, the new standard is designed to reduce the risk of cascading outages by preventing generator tripping “when conditions do not pose a direct risk to the generator and associated equipment.” NERC requests that FERC delay approving the new generator relay loadability standard until after NERC submits an updated version of NERC’s Transmission Relay Loadability Standard, PRC-023-3, in order to maintain consistency between

Vol. 78, No. 175 - Tuesday, September 10, 2013 COMPLIANCE FILINGS: Transmission Relay Loadability Reliability Standard Compliance filing in response to Commission Order Nos. 733 and 759 directing NERC to file a test for Planning Coordinators to identify sub-200kV critical facilities Key Dates: Comments due September 20, 2013

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 19 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage the generator and transmission relay loadabilty standards.]

Project: 2010-17, BES Definition and BES Exception Procedure Approve: • New BES

Definition • BES Exception

Procedure (ROP) Retire: • Existing BES

Definition

1/25/2012 - Petition for Approval of a Revised Definition of "Bulk Electric System" in the NERC Glossary of Terms Used in Reliability Standards NERC submits a Petition for Approval of a Revised Definition of “Bulk Electric System” in the NERC Glossary of Terms Used in Reliability Standards. Docket No. RM12-6-000 4/4/2013 - Compliance Filing in Response to Order No. 773 - Approving Revisions to the ERO Definition of BES and Rules of Procedure NERC submits a filing in response to Order No. 773 Approving Revisions to the Electric Reliability Organization Definition of Bulk Electric System and Rules of Procedure. By this filing, NERC submits a schedule outlining how and when it will modify Exclusion E3 of the Bulk-Electric System definition to remove the 100 kV minimum operating voltage in the local network definition. Docket Nos. RM12-6-000 and RM12-7-000

Docket #: RM12-6-000 & RM12-7-000 / Date: 12/20/2012 Title: Order No 773 - Final Rule on the Revisions to the Electric Reliability Organization Definition of Bulk Electric System and Rules of Procedure Summary: FERC issues an order in which it approves modifications to the currently-effective definition of “bulk electric system” developed by NERC. Docket Nos. RM12-6-000 and RM12-7-000 Docket #: RM12-6-001 & RM12-7-001 / Date: 4/18/2013 Title: Order No. 773-A on Rehearing and Clarification of Order No. 773 - Revisions to the ERO Definition of BES and Rules of Procedure Summary: Order No. 773 approved modifications to the currently effective definition of “bulk electric system” and revisions to the NERC Rules of Procedure. Order No. 773-A denies rehearing in part, grants rehearing in part, and otherwise reaffirms FERC’s determinations in Order No. 773. Docket Nos. RM12-6-001 and RM12-7-001 Docket #: RM12-6-001 & RM12-7-001 / Date: 5/6/2013 Title: Errata to FERC Order on Revisions to ERO Definition of BES and Rules of Procedure Summary: FERC issues errata correcting minor typographical errors in the Order on the ERO Definition of Bulk Electric System (BES) and Rules of Procedure Docket #: RM12-6-000 & RM12-7-000 / Date: 6/13/2013 Title: Order Granting Extension of Time Summary: FERC issues an order granting an extension

Vol. 78, No. 3 – Date: Friday, January 4, 2013 RULES Revisions to Electric Reliability Organization Definition of Bulk Electric System and Rules of Procedure [Order No. 773] Key Dates: This Final Rule became effective March 5, 2013 Vol. 78, No. 96 – Date: Friday, May 17, 2013 RULES Revisions to Electric Reliability Organization Definition of Bulk Electric System and Rules of Procedure [Order No. 773-A]

Subject to Future Enforcement Last Action: 8/30/13 – Order Denying Request for Clarification and Rehearing Revised BES Definition Enforceable: July 1, 2014

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 20 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage of time on the Bulk Electric System definition effective date and the Rules of Procedure exception process, issued today by FERC in Docket NOS. RM126-6-000 and RM12-7-000. This order extends the effective date from July 1, 2013 to July 1, 2014. Docket #: RM12-6-002 & RM12-7-002 / Date: 8/30/2013 Title: Order Denying Request for Clarification and Rehearing Summary: FERC issues an order denying the requested clarification or in the alternative rehearing, by National Rural Electric Cooperative Association and the American Public Power Association, of the Commission's Order No. 773-A.. Enforceable: Revised BES Definition enforceable on July 1, 2014

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 21 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: 2011-INT-01, Interpretation of MOD-028, R3.1 for FPL Approve: • MOD-028-2

Retire: • MOD-028-1

8/24/2012 - Petition for Approval of MOD-028-2 - Area Interchange Methodology NERC submits a petition for approval of proposed Reliability Standard MOD-028-2 - Area Interchange Methodology. Docket No. RD_-_-___ 5/13/2013 - Comments in Response to NOPR Proposing to Approve MOD-028-2 NERC submits comments in response to FERC's March 21, 2013 Notice of Proposed Rulemaking proposing to approve MOD-028-2. Docket No. RM12-19-000

Docket #: RM12-19-000 / Date: 3/21/2013 Title: Notice of Proposed Ruling Proposing to Approve MOD-028-2 - Area Interchange Methodology Summary: FERC issues a NOPR in which it proposes to approve Reliability Standard MOD-028-1 - Area Interchange Methodology pertaining to the information a transmission service provider must include when calculating Total Transfer Capability using the area interchange methodology for the on-peak and off-peak intra-day and next day time periods. The Commission also proposes to approve NERC’s proposed implementation plan and retirement of the currently-effective standard. Docket #: RM12-19-000 / Date: 7/18/2013 Title: Order No. 782 - Final Rule Approving Revisions to Modeling, Data, and Analysis Reliability Standard MOD-028-2 Summary: In this Final Rule, pursuant to section 215 of the Federal Power Act, the Federal Energy Regulatory Commission (Commission) approves Modeling, Data, and Analysis (MOD) Reliability Standard MOD-028-2, submitted to the Commission for approval by the North American Electric Reliability Corporation (NERC), the Commission-certified Electric Reliability Organization. The Commission finds that the proposed Reliability Standard represents an improvement over the currently-effective standard, MOD-028-1 because the proposed Reliability Standard clarifies the timing and frequency of Total Transfer Capability calculations needed for Available Transfer Capability calculations. The Commission also approves NERC’s proposed implementation plan and retirement of the currently-effective standard. Enforceable: MOD-028-2 enforceable on October 1, 2013

Vol. 78, No. 61 – Date: Friday, March 29, 2013 PROPOSED RULES Revisions to Modeling, Data, and Analysis Reliability Standard Key Dates: Comments were due 5/13/2013 Vol. 78, No. 145 – Date: Monday, July 29, 2013 RULES Revisions to Modeling, Data, and Analysis Reliability Standard Key Dates: This rule will become effective September 27, 2013

Subject to Future Enforcement Last Action: 7/29/13 – FERC Order Published in Federal Register MOD-028-2 Enforceable: October 1, 2013

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 22 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: 2011-INT-02, (Rapid Revision) VAR-002-2b Approve: • VAR-002-2b

Retire: • VAR-002-1.1b

11/21/2012 - Petition for Approval of Proposed Reliability Standard VAR-002-2b NERC submits a petition for approval of VAR-002-2b— Generator Operation for Maintaining Network Voltage Schedules, approval of the proposed Reliability Standard, the associated implementation plan, Violation Risk Factors (“VRFs”) and Violation Severity Levels (“VSLs”), and retirement of the currently effective Reliability Standard VAR-002-1.1b. Docket No. RD13-2-000 1/23/2013 - Reply Comments of NERC on Petition for Approval of Reliability Standard VAR-002-2b NERC submits Reply Comments in response to comments submitted on NERC’s Petition for Approval of Proposed Reliability Standard VAR-002-2b concerning the Violation Severity Level for Requirement R2. Docket No. RD13-2-000

Docket #: RD13-2-000 / Date: 4/16/2013 Title: Order Approving Reliability Standard VAR-002-2b Summary: FERC issues an order in which it approves Reliability Standard VAR-002-2b - Generator Operation for Maintaining Network Voltage Schedules, the associated VSLs and VRFs, and an implementation plan for VAR-002-2b. The revised Reliability Standard VAR-002-2b ensures that generators provide reactive and voltage control necessary to ensure voltage levels, reactive flows, and reactive resources are maintained within applicable facility ratings to protect equipment and the reliable operation of the interconnection. Enforceable: VAR-002-2b enforceable on January 1, 2014

N/A - Order is effective immediately (4/16/2013) Subject to Future Enforcement Last Action: 4/16/13 – FERC Order Issued VAR-002-2 Enforceable: January 1, 2014

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 23 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: 2012-INT-02, Interpretation of TPL-003-0a and TPL-004-0 for SPCS Approve: • TPL-003-0b • TPL-004-0a Retire: • TPL-003-0a • TPL-004-0

4/12/2013 - Petition for Approval of an Interpretation to TPL-003-0a and TPL-004-0 NERC submits a Petition for Approval of an Interpretation to Reliability Standards TPL-003-0a and TPL-004-0. Docket No. RD13-8-000

Docket #: RD13-8-000 / Date: 6/20/2013 Title: Letter Order Granting Petition for Approval of the Interpretation to TPL-003-0a and TPL-004-0 Summary: FERC issues a letter order granting approval of the proposed interpretation to certain requirements for two Reliability Standards: TPL-003-0a (System Performance Following Loss of Two or More Bulk Electric System Elements (Category C)) and TPL-004-0 (System Performance Following Extreme Events Resulting in the Loss of Two or More Bulk Electric System Elements (Category D)). Interpretation Response: 1. Entity must evaluate both conditions presented in

Table 1 2. Entity is permitted to use “engineering judgment”

to select the protection system component failures for evaluation

Enforceable: TPL-003-0b and TPL-004-0a enforceable on June 20, 2013

N/A - Order is effective immediately (6/20/2013) Subject to Enforcement Last Action: 6/20/13 – FERC Order Issued TPL-003-0b & TPL-004-0a Enforceable: June 20, 2013

Project 2012-08.1 Phase 1 of Glossary Updates: Statutory Definitions • Bulk-Power

System • Reliable

Operation • Reliability

Standard

5/10/2013 - Petition for Approval of the NERC Glossary Terms "Bulk-Power System," "Reliable Operation" and "Reliability Standard" NERC submits a Petition for Approval of the NERC Glossary Terms "Bulk-Power System," "Reliable Operation" and "Reliability Standard." Docket No. RD13-10-000

Docket #: RD13-10-000 / Date: 7/9/2013 Title: Letter Order on Glossary Definitions RM13-10-000 Summary: FERC issues a letter order granting approval of the NERC Glossary Terms "Bulk-Power System," "Reliable Operation" and "Reliability Standard." Enforceable: Phase 1 of Glossary Updates: Statutory Definitions enforceable on July 9, 2013

N/A - Order is effective immediately (7/9/2013) Subject to Enforcement Last Action: 7/9/13 – FERC Order Issued

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 24 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: 2013-02, Paragraph 81 NOPR proposing to: • Retire 34

requirements within 19 Reliability Standards

• Withdraw 41 outstanding Commission directives

2/28/2013 - Petition of NERC for Approval of Retirement of Requirements in Reliability Standards NERC submits a petition requesting approval of the retirement of 34 requirements within 19 currently effective Reliability Standards that are redundant or otherwise unnecessary, and for which violations of these requirements (currently included in Reliability Standards) pose a lesser risk to the reliability of the Bulk-Power System. Docket No. RM13-8-000 8/27/2013 - NERC Comments on the P81 Notice of Proposed Rulemaking NERC submits comments in response to FERC June 20, 2013 Notice of Proposed Rulemaking (NOPR) proposing to approve NERC's petition to retire 34 Requirements within 19 Reliability Standards and proposing to withdraw 41 outstanding directives. Docket No. RM13-8-000

Docket #: RM13-8-000 / Date: 6/20/2013 Title: NOPR on Electric Reliability Organization Proposal to Retire Requirements in Reliability Standards Summary: FERC issues a Notice of Proposed Rulemaking (NOPR) proposing to retire 34 requirements within 19 Reliability Standards that are redundant or otherwise unnecessary, and where violations of these requirements pose a lesser risk to the reliability of the Bulk-Power System. In addition, the NOPR proposes to withdraw 41 outstanding Commission directives that NERC make modifications to Reliability Standards that have been addressed in some other manner, are redundant with another directive, or provide general guidance as opposed to a specific directive. Docket #: RM13-8-000 / Date: 11/21/2013 Title: Order No. 788 Approving Electric Reliability Organization Proposal to Retire Requirements in Reliability Standards Summary: FERC issues a final rule approving NERC's proposed retirement of 34 requirements within 19 Reliability Standards in response to the Commission’s proposal in paragraph 81 of the March 15, 2012 order in Docket No. RC11-6-000. The final rule approves the retirement of the 34 requirements that either provide little protection for Bulk-Power System reliability or are redundant with other aspects of the Reliability Standards. In addition, the final rule withdraws 41 outstanding Commission directives that NERC make modifications to Reliability Standards that have been addressed in some other manner, are redundant with another directive, or provide general guidance as opposed to a specific directive.

Vol. 78, No. 125 – Date: Friday, June 28, 2013 PROPOSED RULES Electric Reliability Organization Proposal to Retire Requirements in Reliability Standards Key Dates: Comments due 8/27/2013 Vol. 78, No. 132 – Date: Wednesday, July 10, 2013 PROPOSED RULES Electric Reliability Organization Proposal to Retire; Correction Key Dates: N/A – the following corrections are made to the proposed rule published in the Federal Register on Friday, June 28, 2013: 1. In ¶90, the estimate ‘‘$535,500’’ in the first

sentence is changed to ‘‘$518,220.’’ 2. In the table in ¶90, the ‘‘Estimated Total Annual

Reduction in Burden (in hours)’’ for FAC–013–2, R3 and INT–007–1, R1.2 is changed from ‘‘1,600’’ to ‘‘640’’ and from ‘‘448’’ to ‘‘1,120,’’ respectively, and the Total is changed from ‘‘8,925’’ to ‘‘8,637.’’

3. In the table in ¶90, the ‘‘Estimated Total Annual Reduction in Cost’’ for FAC–013–2, R3 and INT–007–1, R1.2 is changed from ‘‘$96,000’’ to ‘‘$38,400’’ and from ‘‘$26,880’’ to ‘‘$67,200,’’ respectively, and the Total is changed from ‘‘$535,500’’ to ‘‘$518,220.’’

Subject to Future Enforcement Last Action: 11/21/13 – FERC Order Issued

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 25 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: 2013-03, Geomagnetic Disturbance Mitigation

5/21/2012 - Comments of NERC Following the Technical Conference on Geomagnetic Disturbances to the Bulk-Power System NERC files comments following the FERC Technical Conference held on April 30, 2012 regarding Geomagnetic Disturbances to the Bulk Power System. Docket No. AD12-13-000 12/26/2012 - Comments of NERC in Response to NOPR Proposing NERC Develop Geomagnetic Disturbance Standards NERC submits comments in response to the October 18, 2012 Notice of Proposed Rulemaking proposing to direct NERC to file for approval with the Commission Reliability Standards that address the risks posed by geomagnetic disturbances (“GMDs”) to the reliable operation of the Bulk-Power System, in two stages. Docket No. RM12-22-000 1/10/2013 - Reply Comments of NERC in Response to Notice of Proposed Rulemaking on Reliability Standards for Geomagnetic Disturbances NERC submits comments in response to comments submitted in response to the Notice of Proposed Rulemaking on Reliability Standards for Geomagnetic Disturbances. Docket No. RM12-22-000 11/14/2013 - Petition of NERC for Approval of Proposed Reliability Standard EOP-010-1 Geomagnetic Disturbance Operations NERC submits a petition for approval of proposed Reliability Standard EOP-010-1 Geomagnetic Disturbance Operations. Docket No. RM12-22-000

Docket #: RM12-22-000 / Date: 10/18/2012 Title: NOPR Proposing to Direct NERC to Develop and Submit Geomagnetic Disturbance Reliability Standards Summary: FERC issues a NOPR in which it proposes to direct NERC to file for approval with the Commission Reliability Standards (GMD Reliability Standards) that address the risks posed by geomagnetic disturbances (GMD) to the reliable operation of the Bulk-Power System. Docket No. RM12-22-000 Docket #: RM12-22-000 / Date: 5/16/2013 Title: Order No. 779 - Final Rule on Reliability Standard for Geomagnetic Disturbances Summary: FERC issues Order No. 779, in which it directs NERC to submit to the Commission for approval proposed Reliability Standards that address the impact of GMD on the reliable operation of the Bulk-Power System. The Commission directs NERC to implement the directive in two stages.

Vol. 78, No. 100 – Date: May 23, 2013 RULES Reliability Standards for Geomagnetic Disturbances Key Dates: Order becomes effective on July 22, 2013

Filed and Pending Regulatory Approval Last Action: 11/14/13 - NERC Petition Filed

Definition of Adequate Level of Reliability

5/10/2013 - Informational Filing on the Definition of "Adequate Level of Reliability" NERC submits an Informational Filing on the definition of "Adequate Level of Reliability" and a supporting technical report. Docket No. RR06-1-000

N/A - informational filing the definition of “Adequate Level of Reliability” that the NERC Board of Trustees approved on May 9, 2013 and a supporting technical report. NERC is not requesting the Commission to take any action on this definition.

N/A - informational filing the definition of “Adequate Level of Reliability” that the NERC Board of Trustees approved on May 9, 2013 and a supporting technical report. NERC is not requesting the Commission to take any action on this definition.

Completed Last Action: 5/10/13 – Informal Filing

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 26 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Standards Processes Manual Revisions to Implement SPIG Recommendation

2/28/2013 - Petition of NERC for Approval of Revisions to the NERC Standard Processes Manual NERC files a petition for approval of revisions to the NERC Standards Process Manual (SPM). The SPM contains all of the procedures governing the Reliability Standards development process. The proposed revisions to the SPM enhance the Reliability Standards development process by providing additional clarity and streamlining the drafting, commenting and balloting processes. Docket Nos. RR12-3-000 and RR10-12-000 4/5/2013 - Reply Comments of NERC in Response to Comment on NERC Revisions to the Standard Processes Manual NERC submits comments in response to the comments of the City of Santa Clara made on NERC's Filing for Approval of Revisions to the NERC Standard Processes Manual. Docket No. RR13-2-000

Docket #: RR13-2-000 / Date: 6/26/2013 Title: Order Approving Revisions to Electric Reliability Organization's Standard Processes Manual Summary: FERC issues an order approving the proposed SPM modifications as reasonable, allowing for greater flexibility and efficiency in the Reliability Standards development process. FERC notes that the revised provisions recognize the need for highly qualified standards drafting teams that include technical writers, legal compliance, and rigorous and highly trained project management.

N/A - Order is effective immediately FERC Approved Last Action: 6/26/13 – FERC Order Issued New SPM (Appendix 3A of NERC RoP) effective June 26, 2013

TRE Regional Standard BAL-001-TRE-01

9/18/13: Joint Petition of NERC and TRE for Approval of BAL-001-TRE-01 submitted

Filed and Pending Regulatory Approval

WECC Regional Standard BAL-002-WECC-2

9/23/13: NERC and WECC submitted comments in response to the Notice of Proposed Rulemaking (NOPR) proposing to approve regional Reliability Standard BAL-002-WECC-2

Filed and Pending Regulatory Approval

RSC December 2013 Meeting Item 11.0 RSC Meeting #13-6, Agenda Item 11.0: Standards Activity Post NERC BOT Approval

Page 27 of 27

Project 11.1: NERC Filings to FERC 11.2: FERC Orders / Rules 11.3: Federal Register Stage Project: WECC-0046, Regional Variance Approve: • VAR-001-3

Retire: • VAR-001-2

2/25/2013 - Petition for Approval of Proposed Reliability Standard VAR-001-3 - Voltage and Reactive Control NERC submits a petition for approval of proposed Reliability Standard VAR-001-3 (Voltage and Reactive Control) developed by NERC and WECC that adds a regional variance developed by WECC as Section E of proposed VAR-001-3. Docket No. RD12-_-000

Docket #: RD13-6-000 / Date: 6/20/2013 Title: Letter Order Granting Approval of Proposed Reliability Standard VAR-001-3 Summary: FERC issues a letter order granting approval of proposed Reliability Standard VAR-001-3 (Voltage and Reactive Control), its associated implementation plan, Violation Risk Factors, Violation Severity Levels, and retirement of VAR-001-2. Scope: WECC Regional Variance for R3 and R4 Enforceable: VAR-001-3 will be enforceable on January 1, 2014

N/A - Order is effective immediately Subject to Future Enforcement Last Action: 6/20/13 – FERC Order Issued VAR-001-3 Enforceable: January 1, 2014

Project: WECC-0068 Approve: • BAL-004-WECC-2 • BAL-001-1 • NERC Glossary: o Area control

Error (ACE) o Automatic Time

Error Correction (ATEC)

Retire: • BAL-004-WECC-1 • BAL-001-0.1a • Appendix 1

Interpretation of Requirement R3 in Reliability Standard BAL-003-0.1b – Frequency Response and Bias

8/20/2013 - Joint Petition of NERC and WECC for Approval of BAL-004-WECC-02 and BAL-001-1 NERC submits a joint petition for approval of proposed regional Reliability Standard BAL-004-WECC-02 and proposed Reliability Standard BAL-001-1.

Docket #: RD13-11-000 / Date: 10/16/2013 Title: Letter Order Approving Regional Reliability Standard BAL-004-WECC-01 and Reliability Standard BAL-001-1 Summary: FERC issues a letter approving NERC's proposed regional Reliability Standard BAL-004-WECC-01 and Reliability Standard BAL-001-1. Enforceable: BAL-001-1 will be enforceable on April 1, 2014

Subject to Future Enforcement Last Action: 10/16/13 – FERC Order Issued BAL-001-1 Enforceable: April 1, 2014

RSC December 2013 Meeting Item 13.0 RSC Meeting #13-6, Agenda Item 13.0: NERC Compliance Tools

Page 1 of 1

13.1 Compliance Application Notices (CANs) http://www.nerc.com/pa/comp/Resources/Pages/Compliance-Application-Notices.aspx 13.1.1 There have not been any CANs posted or retired since the last RSC meeting

Note: NERC has indicated: “To further streamline compliance related communication tools, and support the efforts of the Reliability Assurance Initiative (RAI), the Compliance Application Notice (CAN) process will be phased out during 2013. All currently active CANs will remain in effect until they can be transitioned into either the Reliability Standard Auditor Worksheets (RSAWs) or other acceptable compliance communication tool, at which time the CAN will be retired.”

13.2 Compliance Analysis Reports (CARs) http://www.nerc.com/pa/comp/Pages/Compliance-Analysis-Reports.aspx 13.2.1 There have not been any CARs posted since the last RSC meeting

13.3 Reliability Standard Audit Worksheets (RSAWs) http://www.nerc.com/pa/comp/Pages/Reliability-Standard-Audit-Worksheets-(RSAWs).aspx 13.3.1 There were six RSAWs published on October 10, 2013:

13.3.1.1 MOD-028-2 Area Interchange Methodology 13.3.1.2 PRC-001-1 System Protection Coordination 13.3.1.3 PRC-023-2 Transmission Relay Loadability 13.3.1.4 TPL-003-0b System Performance Following Loss of Two or More

Bulk Electric System Elements (Category C) 13.3.1.5 TPL-004-0a System Performance Following Extreme Events Resulting

in the Loss of Two or More Bulk Electric System Elements (Category D)

13.3.1.6 VAR-002-2b Generator Operation for Maintaining Network Voltage Schedules

13.3.2 There were two RSAWs published on October 15, 2013: 13.3.2.1 EOP-004-2 Event Reporting 13.3.2.2 PER-005-1 System Personnel Training