Update on Fill-In-The-Blank Standards

1. SPP Compliance Workshop February 2007 Update on Fill-In-The-Blank Standards

2. Background • FERC has referred those standards that establish an obligation on bulk power system owner, operator or user to meet one or more “specific RRO criteria or procedure” as fill-in-the-blank” standards. • Many of the these FIB standards were developed when NERC translated its planning standards into the Version 0 standards. • Per Section 215 of the U.S. Federal Power Act these FIB standards can’t be enforced by ERO.

3. Vision for Regional Standards NERC Reliability Standards Today • ERO Vision: • NERC & regional • standards are • Consistent • Congruent • Complete • Excellent C Region A F B E D H NERC Reliability Standards G Regional Reliability Standards A C H E D G B F Regional Criteria and Procedures

4. Regional Reliability Standards Working Group (RRSWG) • NERC has formed RRSWG to evaluate and provide solution each potential FIB standards • RRSWG has one representative from each of the eight regions • The RRSWG set November 1, 2006 as the target to submit their work plan to NERC BOT • URL: http://www.nerc.com/committees/rrswg.html

5. RRSWG – FIB Work Plan • RRSWG has started with approximately 43 potential FIB standards. Four additional standards were added at a later date. • RRSWG worked together and assigned these standards to one of the four categories • Develop uniform North American standard to replace FIB • Requesting regions to develop a Regional Reliability Standard for the adoption by ERO and other authorities • Removing the references to the regional criteria from FIB • Seeking other appropriate courses of action • RRSWG’s FIB work plan was filed as a part of NERC’s Standards Plan on December 1, 2006 (Volume III)

6. FIB Work Plan : Summary • RRSWG has come with a recommendation to have four Regional Reliability Standards • BAL-002 (Disturbance Control Performance) • PRC-002 (Define and Document DME Requirements) • PRC-006 (Development and Documentation of Regional UFLS program) • PRC-012 (Special Protection System Review Procedure) • For other potential FIB standards, RRSWG has recommended to develop 15 Standard Authorization requests (SARs)* to either make these as continent wide standards or remove it as enforceable reliability standards. * Several FIB standards have been grouped and addressed by a single SAR

7. FIB Work Plan : Time Line and Next Steps • NERC’s 3 year plan (2007 through 2010) has listed specific projects to address various issues by grouping similar standards. • New Proposed Regional Reliability Standards are included as follows: • 2007-01 (UFLS) : PRC-006 to PRC-009 • 2007-05 (Balancing Authority) : BAL-002, 004 & 006 • 2007-11 (Disturbance Monitoring) : PRC-002 & PRC-018 • 2008-04 (Protection Systems) : PRC-003 to PRC-005 • PRC-012, PRC-014, PRC-016 • and PRC-017

8. FIB Work Plan : SPP’s Role & Time-Line • February 07 : FERC ruling expected to adopt SPP as a Regional Entity These priorities may change as we move foreword.

9. 2007-01 (UFLS project) Gantt Chart SPP Process Starts Here

10. Summary • Significant work needs to be done in a fairly quick time to develop Regional Reliability Standards • SPP needs a head start (6 months) in order to align resources since we don’t have a standards approval process in place. • Active participation from the working group is encouraged (SPCWG, ORWG etc.) on Standard Drafting Team. SPP staff will represent on Standards Authorization Request (SAR) • SPP staff needs to dedicate more time developing and coordinating these standards with the members • SPP has to follow “Regional Reliability Standards Evaluation Procedure” to suggest any changes in the regional standards or propose a new regional standard

11. Mak NagleManager of Engineering501-614-3564mnagle@spp.org