NERC and ERCOT Rules: How They Are Made and How YOU Can Change Them

1. NERC and ERCOT Rules: How They Are Made and How YOU Can Change Them Kevin Thundiyil Associate Reliability Analyst March 23, 2005

2. Objectives • What’s happening to NERC’s good old planning and operating standards? • How are NERC standards created? • What’s the connection between NERC policies and ERCOT’s Guides/Protocols? • How are ERCOT Guides/Protocols created?

3. What is Version 0? • Replacement to the current implementation of NERC Operating and Planning Standards • Part of NERC’s Functional Model concept • Effective April 1, 2005

4. How does Version 0 compare to current standards? • Same standards as before, just given a new name • Example: • CPS1 (P1T1 BAL-001-0) • UFLS System Maintenance (III.D.S1.M3  PRC-008-0) • Divided into fourteen categories • Given a three letter abbreviation

5. 14 Categories • Resource and Demand Balancing (BAL) • Critical Infrastructure Protection (CIP) – Robinson • Communications (COM) • Emergency Preparedness and Operations (EOP) • Facilities Design, Connections and Maintenance (FAC) • Interchange Scheduling and Coordination (INT) • Interconnection Reliability Operations and Coordination (IRO) • Modeling, Data and Analysis (MOD) • Organization Certification (ORG) • Personnel Performance, Training, and Qualifications (PER) • Protection and Control (PRC) • Transmission Operations (TOP) • Transmission Planning (TPL) • Voltage and Reactive (VAR)

6. NERC Standards Making Processes • 11-step process • Comments are received at each major step • ANSI-certified, ensures a fair process • Accelerated process exists as well, “Urgent Action” • Cyber Security • Brief introduction…

9. Steps 1 through 4: SAR Development • A SAR or Standard Authorization Request is submitted to the Standard Process Manager • Submit public comments on SAR • Gather ballot pool and draft team members (important later on in the process) • Obtain authorization to draft a new standard

12. Steps 5 through 8: Standard Development • Standard Drafting Team will work with Requester to develop SAR into a standard • Public comments on draft – usually several rounds • Testing – optional • Analyze comments and test results, submit for a ballot

15. Steps 9 through 11: Standard Approval and Implementation • Standard submitted to Ballot Pool • If the ballot fails (requires a 2/3 majority), the process must start fresh with a new SAR • Standard forwarded to NERC Board for adoption • The NERC Compliance Enforcement Program will oversee its implementation and assess the effectiveness of the Reliability Standard

16. Examples • Cyber Security 1300 draft standard completed second round of public comments • Revised vegetation management draft standard just completed first round of comments, more expected – needs work

17. Adventures through the NERC Website • View standards under development: https://www.nerc.net/standards/ReliabilityStandards.aspx?tabindex=2&tabid=14 • Register* yourself or your organization (submit SARs, comments, draft team, ballot pools): https://www.nerc.net/standards/ReliabilityStandards.aspx?tabindex=6&tabid=27 *Not registration as an entity in the NERC Functional Model

18. NERC Standards and their Relationship to YOU • NERC passes a new standard • ERCOT or Market Participant creates OGRR or PRR based on NERC standard • Protocols and/or Operating Guides updated to agree with the new NERC standard • Examples: • Vegetation Management, ERCOT Guides 3.1.5.3.1 • Operator Training, ERCOT Guides 1.8.2

19. ERCOT Guides and Protocols Revision Process

22. ERCOT –Operating Guide Revision Request • Completed Operating Guide Revision Request (OGRR) form is sent to ogrevreq@ercot.com • Request posted to the Market Information System (MIS) • Comments regarding OGRR sent to ogrevreq@ercot.com • Operations Working Group (OWG) and Reliability Operations Subcommittee (ROS) review the OGRR and recommend action • ROS reviews comments and submits recommendation to Technical Advisory Committee (TAC) • PRS reviews consistency with ERCOT Protocols • TAC approves OGRR • TAC action reported to ERCOT Board

25. ERCOT – Protocol Revision Request • Protocol Revision Request (PRR) form sent to ProtRevReq@ercot.com • PRR posted to MIS • Comments submitted • Submitted to PRS (Protocol Revisions Subcommittee) twice • PRS Recommendation Report • Comments submitted • Protocol Impact Analysis (PIA) • Comments submitted • TAC recommendation and approval • ERCOT Board approval • Urgent Timeline exists as well: PRR reviewed by PRS, sent to TAC then to the ERCOT Board

26. Protocol Revision Timeline ERCOT Posts PRR 25-Day IA Period ERCOT Posts TAC Rec ERCOT Posts BOD Decision ERCOT Posts PRS Rec ERCOT Updates PRS Rec 30-Day IA Period X X X X X X X 21 Day Comment Period 21 Day Comment Period Dec 1 July 23 August 26 PRS Consideration 1st Consideration October 7 TAC Consideration November 16 BOD Consideration September 25 PRS Consideration 2nd Consideration Similar process applies to System Change Requests

27. Wrap-up • Version 0, the new face of NERC’s Operating and Planning Standards • NERC and ERCOT Standards process – driven by public comments, stakeholders • New NERC standards eventually filter down to ERCOT Guides/Protocols • Conclusion: NERC and ERCOT need your knowledge and experience to improve!!!