Joint CCC/SC Meeting. Wednesday, December 7, Meeting Time: 1:00 p.m. 5:00 p.m. EST Lunch: 12 1:00 p.m.

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1 Joint CCC/SC Meeting Wednesday, December 7, 2011 Meeting Time: 1:00 p.m. 5:00 p.m. EST Lunch: 12 1:00 p.m. Dial-In: Passocde: Security Code: Introductions and Chair s Remarks NERC Antitrust Compliance Guidelines and Public Announcement Agenda 1. Communication Between Standards & Compliance a. Overview of CCC roles and how they interface with NERC (Terry Bilke) b. Overview of SC roles and how they interface with NERC * (Ben Li) c. Compliance information available for Standard Drafting Teams 2. Joint Activities a. Status of VRF & VSL proposals * (Andy Rodruiqez) b. RSAW development and opportunity for drafting team input * (Linda Campbell) c. Participation in quality reviews * (Patrick Brown) d. CANs Process and SC/CCC involvement (Valerie Agnew) e. Staying up to date with Standards for Certifications (Jim Hughes) f. Status of Adequate Level of Reliability Task Force * (Allen Mosher) 3. Future Activities 4. Adjourn

2 Antitrust Compliance Guidelines I. General It is NERC s policy and practice to obey the antitrust laws and to avoid all conduct that unreasonably restrains competition. This policy requires the avoidance of any conduct that violates, or that might appear to violate, the antitrust laws. Among other things, the antitrust laws forbid any agreement between or among competitors regarding prices, availability of service, product design, terms of sale, division of markets, allocation of customers or any other activity that unreasonably restrains competition. It is the responsibility of every NERC participant and employee who may in any way affect NERC s compliance with the antitrust laws to carry out this commitment. Antitrust laws are complex and subject to court interpretation that can vary over time and from one court to another. The purpose of these guidelines is to alert NERC participants and employees to potential antitrust problems and to set forth policies to be followed with respect to activities that may involve antitrust considerations. In some instances, the NERC policy contained in these guidelines is stricter than the applicable antitrust laws. Any NERC participant or employee who is uncertain about the legal ramifications of a particular course of conduct or who has doubts or concerns about whether NERC s antitrust compliance policy is implicated in any situation should consult NERC s General Counsel immediately. II. Prohibited Activities Participants in NERC activities (including those of its committees and subgroups) should refrain from the following when acting in their capacity as participants in NERC activities (e.g., at NERC meetings, conference calls and in informal discussions): Discussions involving pricing information, especially margin (profit) and internal cost information and participants expectations as to their future prices or internal costs. Discussions of a participant s marketing strategies. Discussions regarding how customers and geographical areas are to be divided among competitors. Discussions concerning the exclusion of competitors from markets. Discussions concerning boycotting or group refusals to deal with competitors, vendors or suppliers.

3 Any other matters that do not clearly fall within these guidelines should be reviewed with NERC s General Counsel before being discussed. III. Activities That Are Permitted From time to time decisions or actions of NERC (including those of its committees and subgroups) may have a negative impact on particular entities and thus in that sense adversely impact competition. Decisions and actions by NERC (including its committees and subgroups) should only be undertaken for the purpose of promoting and maintaining the reliability and adequacy of the bulk power system. If you do not have a legitimate purpose consistent with this objective for discussing a matter, please refrain from discussing the matter during NERC meetings and in other NERC-related communications. You should also ensure that NERC procedures, including those set forth in NERC s Certificate of Incorporation, Bylaws, and Rules of Procedure are followed in conducting NERC business. In addition, all discussions in NERC meetings and other NERC-related communications should be within the scope of the mandate for or assignment to the particular NERC committee or subgroup, as well as within the scope of the published agenda for the meeting. No decisions should be made nor any actions taken in NERC activities for the purpose of giving an industry participant or group of participants a competitive advantage over other participants. In particular, decisions with respect to setting, revising, or assessing compliance with NERC reliability standards should not be influenced by anti-competitive motivations. Subject to the foregoing restrictions, participants in NERC activities may discuss: Reliability matters relating to the bulk power system, including operation and planning matters such as establishing or revising reliability standards, special operating procedures, operating transfer capabilities, and plans for new facilities. Matters relating to the impact of reliability standards for the bulk power system on electricity markets, and the impact of electricity market operations on the reliability of the bulk power system. Proposed filings or other communications with state or federal regulatory authorities or other governmental entities. Matters relating to the internal governance, management and operation of NERC, such as nominations for vacant committee positions, budgeting and assessments, and employment matters; and procedural matters such as planning and scheduling meetings. NERC Antitrust Compliance Guidelines 2

4 Public Announcements REMINDER FOR USE AT BEGINNING OF MEETINGS AND CONFERENCE CALLS THAT HAVE BEEN PUBLICLY NOTICED AND ARE OPEN TO THE PUBLIC Conference call version: Participants are reminded that this conference call is public. The access number was posted on the NERC website and widely distributed. Speakers on the call should keep in mind that the listening audience may include members of the press and representatives of various governmental authorities, in addition to the expected participation by industry stakeholders. Face-to-face meeting version: Participants are reminded that this meeting is public. Notice of the meeting was posted on the NERC website and widely distributed. Participants should keep in mind that the audience may include members of the press and representatives of various governmental authorities, in addition to the expected participation by industry stakeholders. For face-to-face meeting, with dial-in capability: Participants are reminded that this meeting is public. Notice of the meeting was posted on the NERC website and widely distributed. The notice included the number for dial-in participation. Participants should keep in mind that the audience may include members of the press and representatives of various governmental authorities, in addition to the expected participation by industry stakeholders. August 10, 2010

5 SC & NERC Staff Points of Interface December 7, 2011

6 SC Responsibilities 1. Manage Standards Development 2. Manage Standards Process 3. Review Effectiveness of Balloting Process 4. Coordinate with Compliance 5. Coordinate with NAESB 6. Coordinate with Board of Trustees, Regulators and Industry Groups, and Stakeholders 2 RELIABILITY ACCOUNTABILITY

7 Manage Standard Development Authorize posting (SARs) Approve development of new/revised standards based on SARs Determine whether to field test a proposed standard Facilitate industry discussion of proposed standards Provide guidance to drafting teams Appoint standard drafting teams Monitor & manages progress/prioritization of standards projects 3 RELIABILITY ACCOUNTABILITY

8 Manage Standards Process Ensure integrity of the standards process Ensure standards meet quality attributes Monitor effectiveness of standard process & implement improvements Ensure standard process maintains ANSI accreditation Develop & maintain annual & long-term plans consistent with ERO s strategic plans Manage update of reference documents 4 RELIABILITY ACCOUNTABILITY

9 Review Balloting Review registered ballot body membership for balance Review balloting results for balance Monitor participation in the balloting process 5 RELIABILITY ACCOUNTABILITY

10 Coordinate with Compliance Work with CCC through activities such as Quality Reviews Ensure drafting teams are coordinating with/receiving support from the compliance program Ensure applicability section of standards is clear and meets needs of compliance program Ensure implementation plans meet the needs of compliance program 6 RELIABILITY ACCOUNTABILITY

11 Coordinate with NAESB Executive Committee assists Director of Standards in implementing the NERC/NAESB Joint Coordination Procedure Executive Committee develops annual work plan for joint activities with NAESB 7 RELIABILITY ACCOUNTABILITY

12 Coordinate with Others Coordinate with NERC Board of Trustees, Regulators and Industry Groups, and Stakeholders Interface with NERC & industry groups regarding standards Actively seek inputs from the BOT, regulators, Regions, compliance program, readiness audit program, technical committees, & stakeholders on standards issues Sponsor standards conferences to communicate with stakeholders Review standards work plans & key projects with regulators 8 RELIABILITY ACCOUNTABILITY

13 Questions? 9 RELIABILITY ACCOUNTABILITY

14 VRF Guidelines VRF Definitions and Tool Goal Increase clarity of NERC s VRF definitions VRF Tool o Encountered hurdles to providing improved clarity Guideline definitions can not be written to reflect the tool Current definitions are 2 dimensional (Consequence & Severity) Issue is 3 dimensional (Consequence, Severity & Probability ) o Need more diverse input from industry (buy-in) Goal Standardize the assessment process for SDTs o Encountered hurdles to making a valid assessment Mixes a qualitative problem with a quantitative method 2 dimensional, not 3 dimensional (Contingency & Probability) o Better to have sound definitions and build the tool, not vice-versa 1 RELIABILITY ACCOUNTABILITY

15 VRF Next Steps Need to hold in-person development meetings January & February 2012 SME Focus areas (CIP, Planning, Operations, & Protection) Treat effort like a SDT for transparency Options for SC action Suggest participants to work in definition development, or Endorse NERC to seek volunteers Post for industry comment March 2012 Revise based on comments and prepare report SC meeting April 2012 Consider next steps 2 RELIABILITY ACCOUNTABILITY

16 VSL Pro Forma Goal Simplify VSL development Reduce development time Eliminate flaws and errors Proposal Introduces the use of a Standard s Purpose statement to assist in determining compliance o Need to work out issues regarding Purpose statements o Conformity with FERC directives Needs o Need more diverse input from industry (buy-in) 3 RELIABILITY ACCOUNTABILITY

17 VSL Next Steps Need to hold in-person development meetings January & February 2012 Utilize the VRF team (emphasis on a compliance member) Treat effort like a SDT for transparency Options for SC action Suggest participants to work in Pro Forma development, or Endorse NERC to seek volunteers Post for industry comment March 2012 Revise based on comments and prepare report SC meeting April 2012 Consider next steps 4 RELIABILITY ACCOUNTABILITY

18 RSAWS as Measures Linda Campbell December 7, 2011

19 RSAW Development Involve drafting team in development of technical content of RSAWS Identify what acceptable performance looks like Identify what unacceptable performance looks like and why When to draft RSAWS? As part of standard development, or Following standard approval Should RSAWs replace Measures? 2 RELIABILITY ACCOUNTABILITY

20 Participation in QRs Patrick Brown December 7, 2011

21 QR Overview Conducted before each posting for formal comment/ballot Drafting team sends documents to standards staff Standards staff solicits 3 QR reviewers (compliance, legal, standards) QR members review documents in parallel, then have conference call to develop consensus document Results sent to Drafting Team Drafting Team s response sent to QRAWG for review QRAWG determines if standard is ready to post 2 RELIABILITY ACCOUNTABILITY

22 Current Status More than 50 people trained to conduct QRs, including 7 CCC members next session December 9 Training expanded to include auditors, Regional staff developing/reviewing standards, stakeholder lawyers working in standards/compliance Conducted 48 reviews from Jan 1-Nov (5 in progress) Some teams more receptive to feedback than others 3 RELIABILITY ACCOUNTABILITY

23 Ideas for QR Guidelines Limit focus on standard not other documents (mapping document, issues, VRF/VSL justification, implementation plan) Use same review team throughout project cycle Limit focus in successive reviews to just changed content Establish criteria for representing Compliance perspective and for representing Legal perspective 4 RELIABILITY ACCOUNTABILITY

24 ALR Task Force SC/CCC Joint Meeting December 7, 2011 Allen Mosher, ALRTF Chair

25 Outline Background Definition Reliability Objectives Supporting Technical Document Next Steps 2 RELIABILITY ACCOUNTABILITY

26 Background Adequate Level of Reliability Task Force (ALRTF) charged with: Reviewing current definition of ALRTF (filed for information with FERC in 2008) Determining if existing definition and characteristics need enhancement in coordination with the MRC s BES/ALR Policy Group Task Force includes representatives from each of the Standing Committees Has met monthly since June RELIABILITY ACCOUNTABILITY

27 Background, cont. Goal: Definition of ALR that encompasses NERC s responsibility to ensure reliability, and to define objectives and characteristics that are measurable Enable the ERO enterprise to focus on and align its activities with specific characteristics of ALR that have the greatest impact on bulk power system reliability Definition must be: Concise, yet self-contained Self-explanatory to BES planners and operators Meaningful to policymakers placing a premium on translation in the ALRTF Report 4 RELIABILITY ACCOUNTABILITY

28 Background, cont. Input from MRC s BES/ALR Policy Group directed group to consider: Cost/benefit Load loss distinctions Definition of cascading 5 RELIABILITY ACCOUNTABILITY

29 Draft Definition Seven Reliability Objectives Associated Performance Outcomes Addressed in four time frames Associated Disturbances/Initiating Events Collectively, the performance outcome and the associated disturbances/initiating events fully describe the characteristics of each reliability objective what it is and under what conditions we intend to achieve the reliability objective. 6 RELIABILITY ACCOUNTABILITY

30 Draft Reliability Objectives 1. Prevent the BES from instability, uncontrolled separation, cascading, and voltage collapse when subject to a set of predefined initiating events. 2. Maintain BES frequency within defined parameters under normal operating conditions and when subject to a set of predefined initiating events. 3. Maintain BES voltage within defined parameters during normal operating conditions and when subject to a set of predefined initiating events. 7 RELIABILITY ACCOUNTABILITY

31 Draft Reliability Objectives, cont. 4. Provide and maintain sufficient transfer capability of the BES transmission system to meet required BES demands during normal operating conditions and when subject to a set of predefined initiating events. 5. Provide and maintain sufficient resource capability on the BES to meet required BES demands during normal operating conditions and when subject to a set of predefined initiating events. 8 RELIABILITY ACCOUNTABILITY

32 Draft Reliability Objectives, cont. 6. Minimize adverse impact on the BES resulting from conditions beyond the scope of the set of predefined initiating events (e.g., multiple contingencies or unplanned, uncontrolled outages). 7. Recover from blackouts and widespread outages with the ability to restore BES Facilities in a controlled manner that rebuilds BES integrity and restores supply to load. 9 RELIABILITY ACCOUNTABILITY

33 Technical Document Introduction Overview of Reliability Objectives Performance Outcomes Disturbances that Impact Reliability/Initiating Events Means to Meet Reliability Objectives Associated Social Impacts Reliability Principles 10 RELIABILITY ACCOUNTABILITY

34 Next Steps Dec. 7, 2011: Present to SC/CCC Dec , 2011: Q&A (if necessary) during OC, PC, CIPC meetings Jan , 2012: Next ALRTF meeting End of Jan.: Complete robust draft definition and technical document Feb. 2012: Present draft documents to SCCG for review March 2012: Post for industry comment 11 RELIABILITY ACCOUNTABILITY

35 Questions? 12 RELIABILITY ACCOUNTABILITY