Document Categorization Policy

1. Document Categorization Policy Chris Albrecht, Legal Counsel Western Electricity Coordinating Council

2. FERC Audit of WECC • FERC Audit of WECC • Recommendation 14: Adopt written criteria for evaluating whether activities should be funded under Section 215 • Recommendation 15: Provide detail surrounding WECC’s Regional Business Practice activities sufficient to ensure the appropriateness of funding these activities under section 215 • WECC’s Implementation • Adopted a funding criteria based on and nearly identical to NERC’s funding criteria that was approved by FERC • Criteria V: The activity is required or specified by, or carries out, the provisions of NERC’s Rules of Procedure • NERC ROP refer to “Regional Criteria” not “Regional Business Practices” • The name “Regional Business Practices” is misleading Western Electricity Coordinating Council

3. Recategorization • Solution: recategorize “Regional Business Practices” as “Regional Criteria” • Required changes to Document Categorization Policy, Process for Monitoring Adherence of RBP, and Process for Seeking an Exemption to RBP • Other changes to simplify and streamline the documents • Changes to Document Categorization Policy • Retained existing treatment of all RC and RBP; both before and after recategorization: • Documents referenced in a standard – subject to CMEP • Documents not referenced in a standard – subject to WECC Process for Monitoring Adherence of RBP • Only terminology has changed • Prior to recategorization the terminology was RC and RBP • After recategorization the terminology is “RC referenced in a standard” and “RC not referenced in a standard” Western Electricity Coordinating Council

4. Approval and Aftermath • Board Approval • Documents posted for notice and comment as Board approval items • MAC notified and given opportunity to review and advise the Board • OC and MIC Meetings • Confusion regarding changes • Resolutions stating the MAC should ask Board to rescind changes • MAC • Formed a task force that did not see a need to ask Board to rescind changes, but suggested documents be posted for member comment • Comments • Board asked staff to post the documents for member comment • Comments submitted by FEUS and Powerex • WECC followed up with commenters Western Electricity Coordinating Council

5. Requested Changes • No commenter is requesting recategorization back to Regional Business Practices • Powerex has concerns with some of the other simplifying changes made to the documents and requests changes specifying: • Guidelines, Reports and White Papers be developed using a notice and comment process prior to notice and comment process required for approval • Concern this change will be overly burdensome on committee work • WECC Director of Standards consider the purpose and intent of a Regional Criterion during evaluation of adherence • Board be given notice of validated non-adherence • WSC consider adding to the Drafting Team (responsible for making a recommendation a proposed exemption) persons from neighboring or adjacent entities • Further review disclosed lack of clarity over applicability of policy—substance applies specifically to OC, PCC, MIC, and TEPPC. Western Electricity Coordinating Council