Agenda Standards Committee Process Subcommittee December 09, :00 a.m. 12:00 p.m. Eastern

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1 Agenda Standards Committee Process Subcommittee December 09, :00 a.m. 12:00 p.m. Eastern NERC Headquarters 3353 Peachtree Road NE Suite 600, North Tower Atlanta, GA Process Subcommittee Joint Meeting Meeting Dial-in Information for 8:00 a.m. 9:00 a.m. Eastern: Phone: Meeting Code: Security Code: Process Subcommittee Meeting Dial-in Information for 9:00 a.m. 12:00 a.m. Eastern: Phone: Meeting Code: Security Code: Click here for: Webinar Access Link Administrative 1. Introductions and Chair s Remarks 2. NERC Antitrust Compliance Guidelines and Public Announcement* 3. Approval of Meeting Notes from October 28, 2014* 4. Review of Agenda and Objectives Agenda Items 1. Joint Discussion with Process Subcommittee on Consensus Building and SAR Development* B. Li 2. SCPS Activities* (Those Listed Below Will be Discussed) a. Consolidate SC Resource Documents* M. Benson b. SCPS Work Plan* L. Lee i. Project Assignments ii. Conceptual Projects c. Modifications to Quality Review (QR) Process L. Lee d. CEAP L. Lee e. Improve Standards Development Processes and Procedures L. Lee

2 3. Communication with Industry L. Lee 4. Items Slated for Presentation at Next Standards Committee Meeting L. Lee and K. Street 5. Review of Actions/Assignments K. Street 6. Discussion of planned meeting dates for Adjourn *Background materials are included. Meeting Agenda SCPS December 09,

3 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.

4 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

5 Public Announcements 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.

6 Standards Development Process Participant Conduct Policy I. General To ensure that the standards development process is conducted in a responsible, timely and efficient manner, it is essential to maintain a professional and constructive work environment for all participants. Participants include, but are not limited to, members of the standard drafting team and observers. Consistent with the NERC Rules of Procedure and the NERC Standard Processes Manual, participation in NERC s Reliability Standards development balloting and approval processes is open to all entities materially affected by NERC s Reliability Standards. In order to ensure the standards development process remains open and to facilitate the development of reliability standards in a timely manner, NERC has adopted the following Participant Conduct Policy for all participants in the standards development process. II. Participant Conduct Policy All participants in the standards development process must conduct themselves in a professional manner at all times. This policy includes in-person conduct and any communication, electronic or otherwise, made as a participant in the standards development process. Examples of unprofessional conduct include, but are not limited to, verbal altercations, use of abusive language, personal attacks or derogatory statements made against or directed at another participant, and frequent or patterned interruptions that disrupt the efficient conduct of a meeting or teleconference. III. Reasonable Restrictions in Participation If a participant does not comply with the Participant Conduct Policy, certain reasonable restrictions on participation in the standards development process may be imposed as described below. If a NERC Standards Developer determines, by his or her own observation or by complaint of another participant, that a participant s behavior is disruptive to the orderly conduct of a meeting in progress, the NERC Standards Developer may remove the participant from a meeting. Removal by the NERC Standards Developer is limited solely to the meeting in progress and does not extend to any future meeting. Before a participant may be asked to leave the meeting, the NERC Standards Developer must first remind the participant of the obligation to conduct himself or herself in a professional manner and provide an opportunity for the participant to comply. If a participant is requested to leave a meeting by a NERC Standards Developer, the participant must cooperate fully with the request. Similarly, if a NERC Standards Developer determines, by his or her own observation or by complaint of another participant, that a participant s behavior is disruptive to the orderly conduct of a

7 teleconference in progress, the NERC Standards Developer may request the participant to leave the teleconference. Removal by the NERC Standards Developer is limited solely to the teleconference in progress and does not extend to any future teleconference. Before a participant may be asked to leave the teleconference, the NERC Standards Developer must first remind the participant of the obligation to conduct himself or herself in a professional manner and provide an opportunity for the participant to comply. If a participant is requested to leave a teleconference by a NERC Standards Developer, the participant must cooperate fully with the request. Alternatively, the NERC Standards Developer may choose to terminate the teleconference. At any time, the NERC Director of Standards, or a designee, may impose a restriction on a participant from one or more future meetings or teleconferences, a restriction on the use of any NERCadministered list server or other communication list, or such other restriction as may be reasonably necessary to maintain the orderly conduct of the standards development process. Restrictions imposed by the Director of Standards, or a designee, must be approved by the NERC General Counsel, or a designee, prior to implementation to ensure that the restriction is not unreasonable. Once approved, the restriction is binding on the participant. A restricted participant may request removal of the restriction by submitting a request in writing to the Director of Standards. The restriction will be removed at the reasonable discretion of the Director of Standards or a designee. Any participant who has concerns about NERC s Participant Conduct Policy may contact NERC s General Counsel. Standards Development Process Participant Conduct Policy 2

8 NERC List Policy NERC provides lists, or listservs, to NERC committees, groups, and teams to facilitate sharing information about NERC activities; including balloting, committee, working group, and drafting team work, with interested parties. All s sent to NERC listserv addresses must be limited to topics that are directly relevant to the listserv group s assigned scope of work. NERC reserves the right to apply administrative restrictions to any listserv or its participants, without advance notice, to ensure that the resource is used in accordance with this and other NERC policies. Prohibited activities include using NERC provided listservs for any price fixing, division of markets, and/or other anti competitive behavior. 1 Recipients and participants on NERC listservs may not utilize NERC listservs for their own private purposes. This may include announcements of a personal nature, sharing of files or attachments not directly relevant to the listserv group s scope of responsibilities, and/or communication of personal views or opinions, unless those views are provided to advance the work of the listserv s group. Use of NERC s listservs is further subject to NERC s Participant Conduct Policy for the Standards Development Process. Updated April Please see NERC s Antitrust Compliance Guidelines for more information about prohibited antitrust and anti competitive behavior or practices. This policy is available at

9 Draft Meeting Notes Standards Committee Process Subcommittee October 28, :00 4:00 p.m. Eastern Conference Call with ReadyTalk Web Access Administrative 1. Introductions and Chair s Remarks L. Lee brought the meeting to order on October 28, 2014 at 1:02 p.m. ET. L. Lee welcomed the attendees and indicated that G. Zito is resigning from the Standards Committee Process Subcommittee (SCPS) at the completion of his term, which expires year-end L. Lee stated that she wanted to express her appreciation for G. Zito s hard work. Laura stated that leadership for the projects for which G. Zito had responsibility would be reassigned. 2. NERC Antitrust Compliance Guidelines and Public Announcement M. Benson reviewed the NERC Antitrust Compliance Guidelines and announced that the meeting was public. 3. Approval of October 1, 2014 Meeting Notes S. Rueckert had previously provided corrections for the meeting notes from the October 1, 2014 meeting. The meeting notes were approved with a slight modification. 4. Review of Agenda and Objectives L. Lee informed the group that V. Agnew would be joining the meeting at 2:45 after attending a meeting with FERC. Agenda Items 1. Update on SCPS Activities* a. Consolidate SC Resource Documents* M. Benson M. Benson provided an update. Four SC endorsed documents were reviewed for updates needed. B. Li and L. Lee agreed to reference NERC staff in documents going forward instead of updating job titles periodically. L. Lee suggested that the NERC Glossary of Terms Used in Reliability Standards Development Procedure document should be updated to remove duplicative information. M. Benson indicated that she will update the documents based on the feedback received. The Roles and Responsibilities: Standards Drafting Team Activities document will be submitted to the Standards Committee with a request to retire the document since the Drafting Team Reference Manual is currently posted in its place.

10 L. Lee indicated that, once the field test is revised the SCPS would consider this project closed. S. Miller stated that the field test would be complete by year end, and the plan is to submit to the Standards Committee during the first part of M. Benson took an action item to S. Miller and copy L. Oelker to see where project is. L. Lee stated that a scope for the next phase is needed to define review frequency and responsibility, as well as to determine if additional consolidation of resource documents is required. b. SCPS Work Plan* L. Lee L. Lee provided an update on the Work plan, and indicated that assignments that have been completed should be removed from the Work Plan document after the communication step has been completed and the status has been listed as complete for at least one Standards Committee meeting. She also stated that the projects for which G. Zito maintained responsibility need new lead SCPS members. L. Lee asked S. Rueckert to get with P. Heidrich and A. Pusztai to see who can lead the CEAP project and notify Laura, Katherine and Monica of the new lead. SCPS Scope has been approved by the Standards Committee. Outreach is the next step plan is for M. Benson to reach out to M. Huggins on how to communicate to industry. Items will not be indicated as complete until communicated out to the industry. M. Benson is the lead on the Training program for Drafting Team members. The modules will be provided to the SCPS for feedback. M. Benson will seek solicitation for members that are interested in volunteering. K. Porterfield will work with M. Benson to develop scope. Interpretation process P. Heidrich will discuss with Stacey to determine if the ANSI requires an interpretation process and if the interpretations are required to be filed with FERC. The answer from Stacey will determine next steps. c. Consensus Building for SAR Development B. Li B. Li provided an overview progress report. L. Lee noted that she had a brief discussion with V. Agnew the day prior, and understood that K. Street had provided V. Agnew with documents associated with the project from the last SCPS meeting to review. L. Lee indicated that she would like to get feedback from V. Agnew prior to presenting to the Standards Committee, and B. Li agreed that such input was needed. B. Li noted that at the last SC meeting he asked P. Heidrich if he wanted to talk with V. Agnew, and that P. Heidrich indicated he talked with her in an earlier stage of development in reference to a document that was developed. L. Oelker inquired as to where the responsibility for oversight of consensus building lies. B. Li indicated that, during a planned pilot stage, responsibility would reside with the SCPS, but that the SC would have ultimate oversight. B. Li indicated that he is formalizing consensus building efforts that occurred in the previous year, and that V. Agnew was concerned with creating efficiencies when informal development was initiated, and that obtaining input prior to ballots was merely intended to Standards Committee Process Subcommittee Meeting Notes December 1,

11 determine if the drafting team received the information, but that the process creates inefficiencies. She does support the additional transparency, however, adding process creates additional obligations and lengthens process time. P. Heidrich took an action item to develop updated presentation and, along with other SCPS members, meet with V. Agnew to discuss. d. Charter Revisions (Scope)* L. Lee L. Lee noted that the SCPS Scope was approved at the last SC meeting and is now finalized. The PMOS may make a conforming change to their Scope to align more closely with the language in the SCPS scope that states Standards Committee members may participate. M. Benson will reach out to M. Huggins to include in weekly bulletin. e. Modifications to Quality Review (QR) Process L. Lee L. Lee discussed the proposed QR process with V. Agnew, who indicated that she is planning a management staff meeting in November to discuss, and that she will reconvene with the SCPS to communicate the new process and what NERC is planning to report to the SC. L. Lee requested a meeting with V. Agnew in conjunction with the SCPS December meeting to discuss. K. Porterfield to communicate an offer of assistance to V. Agnew, and L. Lee to notify K. Porterfield of scheduled meetings with V. Agnew to discuss this issue. f. SCPS Membership L. Lee L. Lee noted that R. Rhodes retiring, and G. Zito will not seek to renew his membership after his term expires at the end of She stated that she will approach the SC to determine if any of the members of the SC wish to join, or if membership should be sought outside of the SC. 2. Communication with Industry L. Lee 3. Items Slated for Presentation at Next Standards Committee Meeting L. Lee and K. Street SC Nov 19 get work plan updated and on SC agenda. Consensus bldg. Dec meeting Endorsement of updates to resource documents and retirement of Roles and Responsibilities document 4. Review of Actions/Assignments* K. Street 5. Future Meetings a. Meetings in Coordination with Standards Committee: December 9, 2014 (8:00 a.m. 12:00 p.m.) Atlanta L. Lee indicated that the SCPS agreed to reschedule their December meeting to December 9 th, 2014 from 8:00 a.m. 12:00 p.m. at NERC s offices in Atlanta, and requested that Monica provided notification to the SCPS_plus@nerc.com listserv of the change. Standards Committee Process Subcommittee Meeting Notes December 1,

12 L. Lee noted that K. Street that the SCPS and PMOS adopt an alternating schedule between PMOS and SCPS before SC meetings for scheduled in-person meetings in b. Interim Meetings TBD 6. Adjourn L. Lee thanked members for their participation and adjourned the meeting at 2:40 p.m. Eastern. Standards Committee Process Subcommittee Meeting Notes December 1,

13 A Proposed Concept on Consensus Building and SAR Development Objective: Put some structure around consensus building, outreach and informal development of standard projects Enhance transparency of informal outreach Develop a clearer demarcation from informal development to formal launch of a standard project Staff has provided inputs to the proposed concept A couple of areas need some discussion with the SC SCPS is presenting this concept to SC for its feedback and endorsement If endorsed, SCPS will proceed to develop and present detailed documents to the SC for approval at March 2015 meeting

14 A Concept on Consensus Building and SAR Development Some basic understanding and assumptions Consensus building is a continuous process Objective: develop consensus to aid decisions on standard projects and standards approval SAR development usually has a finite period It is an important first step to identify the need and determine the scope of a standard development project SAR development and posting do not imply needing or starting a standard development project* SAR development may be regarded as an informal step i.e., all activities prior to SC accepting/approving the SAR* * A SAR may be accepted/approved, but standard drafting may be withheld to suit project schedules and resource allocation

15 A Concept on Consensus Building and SAR Development Standard Projects Initiation Reliability Standard Development Plan (RSDP): Usually does not have a SAR Reliability Issues Steering Committee (RISC) nominations That developing standard is the appropriate and preferred way to address a risk issue) May have a SAR Industry proposals May have a SAR Regulatory directives: RISC may be involved May or may not have a SAR Board of Trustees (BoT) requests: RISC may be involved May or may not have a SAR

16 A Concept on Consensus Building and SAR Development Proposed Concept at a Glance A structured approach* to consensus building Covers the informal development stage only A Consensus Building Team (CBT) to perform all tasks leading to SAR acceptance/approval* by SC CBT to be formed via an open and transparent nomination process CBT selection criteria should enable broad-based representation To better facilitate/support outreach including NERC staff Its size can be > SDT s CBT to process SAR posting and recommend approval of SARs to SC Hence removing the need to form a SAR DT) * Some discussion is needed on these topics. See slide in the end.

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18 A Concept on Consensus Building and SAR Development Scope and Tasks of Consensus Building During Informal Development (Tasks of CBT) Collect technical information to aid in: Assessing the need of a proposed project Recommending to SC the perceived need, and the continuation of, a proposed project to the SAR development stage Development of a SAR (with sufficient tech info.), or to refine submitted SARs prior to their posting Responding to comment on SARs, and revising and finalizing SARs Recommending to SC acceptance/approval of SARs, or otherwise

19 A Concept on Consensus Building and SAR Development Formation of a Consensus Building Team (CBT) Formation should require SC s approval CBT members to be solicited through an open and transparent process Membership appointed by SC At least one NERC staff to be included in the CBT No automatic, or expectation of, continuation to standard drafting team

20 A Concept on Consensus Building and SAR Development CBT Selection Criteria Subject matter experts For their background, experience and technical expertise Regional representation For supporting a wide coverage for outreach activities Functional entity representation For their experience as the anticipated functional entities potentially impacted by the proposed project At least one PMOS member For coordination with proposed and current standard projects Previous CBT or SDT participation For their experience in developing and/or refining SARs

21 A Concept on Consensus Building and SAR Development Outreach Activities - Targets Regions Trades ISOs/RTOs Standing Committees (and their sub-committees) Transmission/Generation Forum ERO Workshop/Seminar audience Others

22 A Concept on Consensus Building and SAR Development Outreach Activities - Mechanisms Regional Entity meetings Trades meetings ISOs/RTOs meetings Standing Committees (and subcommittee) meetings Transmission/Generation Forum meetings Workshops, conferences Postings Data surveys Others

23 A Concept on Consensus Building and SAR Development Some Q&As What s/where s RISC s involvement/interface? Can be at front end to nominate a project or provide inputs to RSDP Can be consulted when someone proposes a project (through a SAR or an issue statement) What if a proposal is made through a SAR submission? CBT can be formed and mobilized to start consensus building toward refining the SAR prior to posting (provided SC does not reject it) What if the BoT or a regulatory authority directs the initiation of a standard project? CBT can be formed and mobilized to start consensus building and develop a SAR to meet the directive Can or should CBT also draft standards? CBT may find it convenient and/or desirable to develop draft standards when SAR is being developed/posted/finalized. However, CBT should not be asked or expected to develop draft standards, nor should it be forbidden to do so.

24 A Concept on Consensus Building and SAR Development Discussion Needed: Is a structured approach appropriate for consensus building in the informal stage? Does the SC have the authority to approve SAR and decide on the start or cessation of a proposed standard development project? Questions, Inputs/Comments Endorsement?

25 Standards Committee Procedure NERC Glossary of Terms Used in Reliability Standards Definition Development Procedure Title: Purpose: Conditions: Definition: Requester NERC Glossary of Terms Used in Reliability Standards Definition Development Procedure The procedure establishes the process for development of, consensus for approval, revision, and withdrawal of the definitions associated with the terms contained in the NERC Glossary of Terms. The NERC Glossary of Terms establishes working definitions of terms used in the NERC and Regional Reliability Standards and various technical and informational documents associated with the reliability planning and reliable operation of the Bulk Electric System of North America. When a term used in a Reliability Standard, either approved or in the development process, technical or informational document is unclear, and the lack of clarity or an incorrect assessment could result in a material impact to the reliability of the Bulk Electric System. Any person or entity (organization, company, government agency, individual, standard drafting team, interpretation drafting team, etc.) directly or materially affected by an existing standard or standard under development, may request that a term be defined by completing a Request for Definition Development/Revision form. Note: The development of new definitions should be avoided unless absolutely necessary. Before a Definition Requester requests that a new term be defined, the requester should check the latest version of the NERC Glossary of Terms Used in Reliability Standards to determine if the same term, or a term with the same meaning, has already been defined. If a term is used in a standard and the term is defined in a collegiate dictionary, then there is no need to also include the term in the NERC Glossary of Terms Used in Reliability Standards, unless the Standard Drafting Team can provide a technical basis for adding clarity to or better defining the application of the commonly defined term. The addition of an adjective or a prefix to an already defined term should not result in a new defined term. If a simple phrase can be used in a standard to replace a new term, then the drafting team should consider using the phrase rather than trying to obtain stakeholder consensus on the new term.

26 Responsibility 1. Develop Request for Defined Term Activity Definition Requester Director, Standards ProcessNERC staff Definition Requester Complete the applicable sections of the Request for the Development/Revision of a Definition for a Term Used in Reliability Standards form and submit to the Director, Standards Process.NERC staff Within 10 calendar days, complete the following: Send the Requester an electronic confirmation of receipt of the request. Verify that all required information has been provided. Determine the extent of use of the identified term in the NERC Reliability Standards and Regional Reliability Standards (approved and in development). Document and provide identified issues and concerns to the Definition Requester for resolution. As soon as reasonably possible after receipt of the Director, Standards ProcessNERC staff identified issues and concerns regarding the request, if any, work with the Director, Standards ProcessNERC staff to resolve all issues and concerns to the satisfaction of the Definition Requester and the Director, Standards ProcessNERC staff and determine if the Definition Requester seeks to either move forward with or withdraw the request. Note: In the event that all of the identified issues or concerns are not resolved to the satisfaction of the Definition Requester or the Director, Standards ProcessNERC staff and the Definition Requester seeks to move forward with the request; all unresolved issues or concerns will be documented and presented with the request to the Standards Committee for resolution. 2. Approve or Reject Request for Defined Term Standards Committee The Standards Committee (SC) will determine if the identified term falls within the scope of: 1) One (1) Standard Development Project, 2) Multiple (>1) Standard Development Projects, or 3) Cannot be associated with a current Standard Development Project. Based on the review of existing Standard Development Projects, the SC will assign the definition development to the appropriate Standard Drafting Team (SDT) or will direct the Director, Standards ProcessNERC staff to establish a Definition Drafting Team (DDT) to initiate the project. NERC Glossary of Terms Used in Reliability Standards Definition Development Procedure 2

27 Note: The NERC Standards Committee has the authority to determine the appropriate path that the definition development should take. (See NERC Definition Development Process Diagram) 2.1. Standards Committee Assigns Definition Development to an Existing Standard Drafting Team Standard Drafting Team The SDT will revise the existing project SAR to reflect: 1) All Reliability Standards that require revision as a result of the newly defined/revised term, and 2) Development Develop or reviseof an Implementation Plan to include the term Standards Committee Assigns Definition Development to a Definition Drafting Team Director, Standards ProcessNERC staff Post a request allowing interested parties the opportunity to nominate individuals to the definition drafting team. Self-nominations shall be acceptable. Those individuals who are nominated shall be considered for appointment to the associated definition drafting team. The Director, Standards ProcessNERC staff shall recommend a list of candidates for appointment to the team and shall submit the list to the Standards Committee. Note: The Requester may serve as a member of the drafting team. The Director, Standards Process NERC staff shall conduct a review of active standard development projects to identify projects which may be impacted by the new or revised definition. The Director, Standards Process NERC staff will notify the NERC Standard Drafting Team (SDT) chairs from the previously identified active development projects, that a Request for Definition Development/Revision has been submitted and approved; and direct the SDT chairs to perform an assessment of the potential impact to the standard development project and provide the results to the Director, Standards ProcessNERC staff for dissemination to the definition drafting team. Note: To facilitate a coordinated effort in the development of the definition, current SDT members should be encouraged to participate in the development of the definition as a definition drafting team member. NERC Glossary of Terms Used in Reliability Standards Definition Development Procedure 3

28 Standards Committee Director, Standards ProcessNERC staff Definition Drafting Team The Standards Committee may accept the recommendations of the Director, Standards ProcessNERC staff or may select other individuals to serve on the definition drafting team. This team shall consist of a group of people who collectively have relevant experience, the necessary technical expertise and the work process skills to perform an extensive review of the NERC Reliability Standards, the NERC Glossary of Terms and any regionally defined terms; and prepare a definition that supports the overall use of the term. The Standards Committee shall appoint the definition drafting team, including its officers. The Director, Standards NERC staff shall assign staff personnel as needed to assist in the drafting of the definition and development of the associated Standard Authorization Request (SAR). The SDT will develop a SAR which has a clearly defined scope that includes: 1) All Reliability Standards that require revision as a result of the newly defined/revised term, and 2) Development of an Implementation Plan Drafting Team Activities Proceed Note: From this point forward, based on the assignment made by the Standards Committee, either the Standard Drafting Team or the Definition Drafting Team will be responsible for the Drafting Team activities documented throughout the remainder of this procedure (See NERC Definition Development Process Diagram). Standards Committee Drafting Team Upon acceptance of the SAR, the Standards Committee will authorize NERC Standards staff to post the project s SAR in accordance with the following: For SARs that are limited to addressing regulatory directives, or revisions to definitions currently in the NERC Glossary of Terms, authorize posting the SAR for a 30-day informal comment period with no requirement to provide a formal response to the comments received. For SARs that address the development of new projects or definitions, authorize posting the SAR for a 30-day formal comment period. If the SAR is posted for a 30-day formal comment period, the Drafting Team shall review and respond to all comments provided by industry. If the comments indicate that there is not a consensus for the scope of the SAR, consider revising the SAR. NERC Glossary of Terms Used in Reliability Standards Definition Development Procedure 4

29 Draft a definition that does not modify the intent of what is in the reliability standards (approved or in the development process). Care should be taken to ensure that the draft definition can be consistently applied across all regions. Submit the draft definition and the revised SAR (including the revised (redline) versions of the approved NERC Reliability Standards that contain the term and the Implementation Plan) to the Director, Standards ProcessNERC staff for quality review. If agreement cannot be reached on the scope of the SAR, the draft definition the revisions to the applicable NERC Reliability Standards or the Implementation Plan, seek the guidance of the Standards Committee. Standards Committee If guidance is sought, the Standards Committee shall meet as soon as reasonably possible to consider the request for guidance. The Standards Committee shall provide guidance as requested, which may include one or more of the following: Provide assistance in drafting the definition Solicit assistance from industry and regulatory experts Direct the drafting team to move the drafted definition forward in the development process Director, Standards Process NERC staff Conduct quality review and recommend to the Standards Committee to post the definition for a parallel comment and ballot period, or remand to the drafting team for revision if the definition does not meet established Quality Review criteria. Manager of Standards Information NERC staff Post the Request for Definition Development/Revision, the SAR, (including the revised (redline) versions of the approved NERC Reliability Standards that contain the term and the Implementation Plan) and the proposed definition for a 45-day concurrent posting period. In conjunction with the 45-day comment period, the ballot pool will be established during the first 30-days of the posting period and the initial ballot will be conducted during the final 10-days of the posting period. The following questions should be addressed during the comment period: Does the definition alter the intent of the identified reliability standardsreliability Standards? NERC Glossary of Terms Used in Reliability Standards Definition Development Procedure 5

30 Does the definition correctly define the term? If not, why not? Does the scope of the project include all affected NERC Reliability Standards? * Notes: Assemble comments submitted during the comment period and the ballot period, tabulate the ballot results and distribute to the Drafting Team. 1. When the definition development has been assigned to an existing SDT, the draft definition and associated documents may be balloted at the same time as the original project. 2. If the number of NERC Reliability Standards requiring revisions to properly address the addition of the term into the NERC Glossary of Terms is substantial, the posting periods may be extended as necessary to provide adequate time for industry participation. 3. If the number of NERC Reliability Standards requiring revisions to properly address the addition of the term into the NERC Glossary of Terms is substantial, separate balloting may be conducted based on Reliability Standard categories to eliminate the potential of disagreement with a single revision resulting in the failure of the entire ballot. Drafting Team Review and respond to all comments. Responses may be in summary format versus individual responses to each comment. If the comments or the results of the ballot (i.e. negative votes with comments) do not indicate consensus for the definition or the associated documents, and either no changes or only minor changes are needed to improve consensus, either: As necessary, revise the definition, the applicable NERC Reliability Standards or the Implementation Plan and recommend posting for a 10- day final ballot. Standards Program If the comments or the results of the ballot (i.e. negative votes with comments) do not indicate consensus for the definition or the associated documents, and require substantive changes to improve consensus, either: Revise the definition, the applicable NERC Reliability Standards or the Implementation Plan and recommend posting for a 3045-day concurrent posting. In conjunction with the 30additional 45-day comment period, a 10-day additional ballot will be conducted during the final 10-days of the posting period, or Recommend that the request be withdrawn and the project terminated. NERC Glossary of Terms Used in Reliability Standards Definition Development Procedure 6

31 Administrator If the initial ballot results indicate consensus (i.e. no negative votes with comments and ballot requirements (quorum and 2/3 affirmative majority reached), submit the definition, the applicable NERC Reliability Standards and the Implementation Plan to the Director,Manager of Standards ProcessInformation.NERC staff. Post the Drafting Team s response to comments. If the comments or the results of the initial ballot (i.e. negative votes with comments) do not indicate a consensus for the definition, the applicable NERC Reliability Standards and the Implementation Plan and either no changes or only minor changes have been made to improve consensus, announce and conduct a final ballot for 10-days. If the comments or the results of the ballot (i.e. negative votes with comments) do not indicate consensus for the definition or the associated documents, and require substantive changes to improve consensus, announce and conduct a successivean additional ballot during the final 10- days of a 3045-day concurrent posting. Director of Standards DevelopmentNERC staff Board of Trustees Director of Standards DevelopmentNERC staff Standards Administrator Submit the definition, the applicable NERC Reliability Standards and the Implementation Plan to the board for its approval. The Board shall adopt or reject the definition, the applicable NERC Reliability Standards and the Implementation Plan, but may not modify the proposed definition, the applicable NERC Reliability Standards or the Implementation Plan. If the Board chooses not to adopt, it shall provide its reasons for not doing so. Submit the definition, the applicable NERC Reliability Standards and the Implementation Plan to the applicable government authorities for regulatory approvals. Incorporate the definition into the NERC Glossary of Terms, post the approved NERC Reliability Standards and the Implementation Plan and send notice of the approval to the Regional Entities and the standards list servers. NERC Glossary of Terms Used in Reliability Standards Definition Development Procedure 7

32 Version History Version Date Owner Change Tracking 1 July 13, 2011 NERC (Standards Committee Endorser) ApprovedEndorsed by Standards Committee 2 August 29, 2014 NERC (Standards Information StaffCommittee Endorser) 3 October 15, 2014 NERC (Standards Committee Endorser) Updated template Updated job titles and removed duplicate language from SPM NERC Glossary of Terms Used in Reliability Standards Definition Development Procedure 8

33 Roles and Responsibilities: Standards Drafting Team Activities (Approved by Standards Committee July, 2011) Standards are developed by industry stakeholders, facilitated by NERC staff, following the process (hereafter referred to as the standard development process ) outlined in the Standard Processes Manual ( SPM ) that is managed by the NERC Standards Committee. This standard development process is accredited by the American National Standards Institute (ANSI) as fair, balanced, open, inclusive, and conducted with due process. The standard development process requires consensus of industry stakeholders first on the need for a proposed standard and then on the standard itself. The SPM is approved by stakeholders and adopted by the NERC Board of Trustees, and is incorporated in Section 300 of the ERO Rules of Procedure by reference as Appendix 3A. This document supplements the SPM and provides additional clarity with respect to roles and responsibilities of drafting teams, team leaders, NERC staff, and the Standards Committee with the expectation that all participants in NERC s standard development process will adhere to the principles embodied herein. The document also provides guidance to the drafting teams regarding involvement from regulatory authority staff 1 in the standards development process 2. Roles and Responsibilities of the Standards Committee The Standards Committee manages the NERC standard development process for North American continent-wide reliability standards. The Standards Committee members are volunteers elected by stakeholders to protect the integrity and credibility of the standard development process. The Standards Committee meets at least monthly, and reports directly to the NERC Board of Trustees. The Standards Committee Charter directs the Standards Committee to: a. manage standards development; b. manage the standards process; c. review the effectiveness of the ballotting process; d. coordinate with the compliance program; e. coordinate with the North American Energy Standards Board (NAESB); and f. coordinate with the NERC Board of Trustees, regulators, industry groups, and stakeholders. 1 Please note that the references to regulatory authorities and their staffs are limited to those authorities that have direct oversight over NERC standards development activities. 2 Appendix 1 contains an expanded discussion of FERC s Role as articulated in the Energy Policy Act and Commission Order No. 693.

34 Additionally, it is the responsibility of the Standards Committee and the standards drafting teams to assist NERC in implementing pending regulatory authority directives by including provisions that address those directives in the proposed standards that are processed through the industry ballot process. Roles and Responsibilities of Standard Drafting Team Members Standard drafting teams, following NERC s standard development process, have responsibility for developing new reliability standards and making revisions to existing reliability standards. The mission of each drafting team is to develop excellent, technically correct standards that provide for an adequate level of bulk power system reliability. Some drafting teams work to modify already approved standards, with modifications aimed to varying degrees at addressing specific regulatory authority directives or to address reliability issues not directed by regulatory authorities. Other drafting teams work to develop new standards that are not associated with any regulatory directives. In all cases, team members are selected from industry volunteers to provide the standard drafting team with sufficient technical expertise from diverse industry perspectives to ensure development of reliability standards that, when approved, demonstrate broad industry consensus. Standard drafting teams are selected by, and report to the Standards Committee. In developing reliability standards that achieve the objectives delineated in the Standards Authorization Request ( SAR ), each standard drafting team, working on behalf of all stakeholders, has primary responsibility to: a. draft new or revised standards that provide for an adequate level of reliability 3 ; b. propose reliability standards that address the full scope contained in the SAR; c. revise approved standards to address applicable regulatory authority directives; d. provide an initial set of violation risk factors and violation severity levels for new or modified reliability standards; e. ensure the proposed standards meet statutory and regulatory authority criteria for approval in each relevant jurisdiction 4 ; f. meet with regulatory authority staff, as requested, to present and discuss the standard drafting team s approach to meet a regulatory authority directive, including any alternate approaches; g. document the technical justification associated with each proposal for a new or modified requirement and for each proposal to retire a requirement; h. respect the integrity of the standard development process as outlined in NERC s Rules of Procedure, including: 3 NERC filed its definition for adequate level of reliability with the Commission on May 5, Refer to 4 In the U.S., FERC established its criteria for approving proposed reliability standards in Order No. 672 beginning at P320: 2

35 i. developing requirements that are clear and unambiguous from a compliance and implementation perspective; ii. considering and responding to all posted comments; iii. developing an implementation plan to support the proposed standards; iv. identifying the need for field testing proposed technical requirements and, where a field test is needed, reviewing, and analyzingthe associated data. i. recommend to the Standards Committee when a proposed standard is ready for balloting; j. respond to observations from a quality review of a proposed standard and associated implementation plan k. engage stakeholders during standards development to help build industry consensus; l. identify and consider variances to proposed standards; m. report progress to the Standards Committee; n. develop or support development of supporting documents to supplement reliability standards; and, o. provide technical input to NERC staff during preparation of regulatory documents, including: i. filing(s); ii. submitting the proposed standard(s) for approval; iii. responding to questions raised in a notice of proposed rule-making; iv. preparation of a request for clarification or rehearing following the issuance of the rule or order addressing a proposed standard filed for approval; v. preparing requests for extensions of time when a regulatory imposed deadline for standards development cannot be achieved. 5 The standard drafting team chair and vice-chair have additional responsibilities to: a. facilitate SDT discussions such that the team reaches consensus on proposed standard(s) that will achieve the SAR objectives and SDT responsibilities described above; b. represent the drafting team before the Standards Committee in reporting on team progress in implementing the scope of the SAR and in addressing regulatory directives; c. represent the drafting team in discussions with regulatory authority staff on how the proposed standards address the applicable regulatory directives; d. lead the drafting team in the effective dispatch of its standards development obligations; and e. assist the NERC standards staff coordinator to provide technical input into: i. draft regulatory filings for approval of the proposed standard(s); ii. responses to questions raised in a notice of proposed rule-making; 5 It is ultimately the decision of the NERC Board of Trustees to approve specific filings. 3