GC Meeting Book - Agenda 2020 GC Meeting Material… · GC Meeting Book - Agenda 1. GC Meeting Agenda—June 16, 2020 2 December 8, 2020 ... annual training session for the Board

Governance Committee

Meeting Agenda

Webinar

Webinar Link, Password: WECC | Dial-in Number: 1-415-655-0003, Access Code: 284 541 092

June 16, 2020, 11:00 to 11:45 a.m.

1. Welcome, Call to Order—Gary Leidich

2. Review WECC Antitrust Policy—Kwin Peterson

WECC Antitrust Policy.

Please contact WECC legal counsel if you have any questions.

3. Approve Agenda

4. Review and Approve Previous Meeting Minutes

Approval Item: March 10, 2020, minutes

5. Review of Previous Action Items—Kwin Peterson

6. Review of Board-Approved Documents—Kwin Peterson

7. Update on Information Sharing and Reporting Policies—Chris Albrecht

Approval Item: Revisions to the Information Sharing Policy

Approval Item: Revisions to the Information Reporting Policy

8. Director Training and Continuing Education—Joe McArthur

9. Responsibility and Accountability Matrix—Kwin Peterson

10. Public Comment

11. Review of New Action Items

12. Review Upcoming Meetings

September 10, 2020 ...................................................................................Henderson, NV

GC Meeting Book - Agenda

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https://wecc.webex.com/wecc/j.php?MTID=mc17fa69178e7383ef4bf685c1bfd3e81

https://www.wecc.biz/_layouts/15/WopiFrame.aspx?sourcedoc=/Corporate/Antitrust%20Policy.pdf&action=default&DefaultItemOpen=1

GC Meeting Agenda—June 16, 2020

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December 8, 2020 ......................................................................................Salt Lake City, UT

March 16, 2021...........................................................................................Salt Lake City, UT

13. Adjourn

GC Meeting Book - Agenda

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DRAFT Meeting Minutes

March 10, 2020

Salt Lake City, Utah

1. Welcome, Call to Order, Introductions

Gary Leidich, Governance Committee (GC) Chair, called the meeting to order at 10:15 a.m. on March 10, 2020. All members were in attendance. A list of attendees is attached as Exhibit A.

2. Review WECC Antitrust Policy

Kwin Peterson read aloud the WECC Antitrust Policy statement. The meeting agenda included a link to the posted policy.

3. Approve Agenda

Mr. Leidich introduced the proposed meeting agenda.

On a motion by Joe McArthur, the GC approved the agenda.

4. Review and Approve Previous Meeting Minutes

Mr. Leidich introduced the minutes from the December 3, 2019, meeting and noted that there was an error in the recorded time of adjournment. No other corrections were raised.

On a motion by Mr. McArthur, the GC approved the minutes from December 3, 2019.

5. Review of Previous Action Items

Mr. Peterson referred to the document on the status of action items and invited any questions or discussion. All items are closed.

6. Governance Committee Charter

Ian McKay reviewed his concerns about the language on closed sessions, which is addressed in the version before the committee. He also spoke in favor of the proposed language that would allow a quorum of the committee, rather than the chair, to waive the meeting notice requirement.

On a motion by Mr. McKay, the GC approved the revised GC Charter as posted and reviewed.

Mr. Leidich noted that this charter revision was being made as part of the annual review and improvement process and not in response to any issues.

GC Meeting Book - March Meeting Minutes

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GC Meeting Minutes—March 10, 2020

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7. Board Survey Follow-up

Ric Campbell reviewed the background of this issue. He reported that the Stakeholder Engagement Work Group had considered the question as suggested by the GC and recommended that Question 8 of the Annual Survey be reviewed by the Member Advisory Committee.

8. Information Sharing and Reporting Policy Updates

Chris Albrecht, WECC staff, reviewed the posting, comments, and responses to the Information Sharing and Information Reporting Policies. He reviewed the changes that were made in response to the comments.

In response to a question by Mr. Leidich, Mr. Albrecht reported he has not received additional responses or comments. Mr. Leidich asked that WECC exhaust opportunities for comment and make sure that the GC be made aware of substantive issues.

In response to a question by Mr. McKay, Mr. Albrecht clarified the differences between the approvals needed for various types of information.

9. Director Education and Professional Development

Mr. McArthur divided the subject into categories of training: individual Board member training, individual committee training, training for the Board as a group, and training on industry issues and environment. He reviewed resources he has used in the past and led a discussion of this matter.

Mr. Leidich noted that much training material for boards is aimed at for-profit, university, and charity boards. The committee discussed resources that are available in Diligent and those from each Director’s network resources. An accountability tool might be helpful for Directors, and anannual training session for the Board as a whole may be valuable.

10. Public Comment

Mr. Leidich opened the meeting to public comment. No comments were offered.

11. Review of New Action Items

∑ Ensure that the Information Reporting Policy is clear about Board responsibilities.o Assigned To: Chris Albrechto Due Date: May 15, 2020

∑ Draft a short paper on Director training and continuing education.o Assigned To: Joe McArthur and Kwin Petersono Due Date: May 22, 2020


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GC Meeting Minutes—March 10, 2020

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12. Upcoming Meetings

June 16, 2020..............................................................................................Salt Lake City, UT

September 10, 2020 ...................................................................................Lake Las Vegas, NV

December 8, 2020 ......................................................................................Salt Lake City, UT

13. Adjourn

Mr. Leidich adjourned the meeting without objection at 10:48 a.m.

Exhibit A: Attendance List

Members in Attendance

Ric Campbell ............................................................................................................................................... Director

Gary Leidich................................................................................................................................................ Director

Joe McArthur............................................................................................................................................... Director

Ian McKay.................................................................................................................................................... Director

Others in Attendance and Participating

Chris Albrecht ................................................................................................................................................WECC

Shelley Longmuir ....................................................................................................................................... Director

Kwin Peterson................................................................................................................................................WECC

Richard Woodward.................................................................................................................................... Director


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Status of GC Action Items

June 16, 2020

155 North 400 West | Suite 200 | Salt Lake City, Utah 84103www.wecc.org

The March 10, 2020 meeting produced two action items:

∑ Ensure that the Information Reporting Policy is clear about Board responsibilities. o Assigned To: Chris Albrechto Due Date: May 15, 2020

Status: This will be covered during the approval of the policy during this meeting.

∑ Draft a short paper on Director training and continuing education.o Assigned To: Joe McArthur and Kwin Petersono Due Date: May 22, 2020

Status: The paper was drafted and is included on this meeting’s agenda.

GC Meeting Book - Action Items

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6/1/2020 Refresh the current date by clicking in cell C1 and hitting Ctrl + ;

Document Name Last ReviewReview Cycle

(Months) Next ReviewDate of current

revision Document OwnerSubject Matter

ExpertAntitrust Jun 2019 24 Jun 2021 Jun 2017 Corporate Secretary Chris AlbrechtPrinciples of Corporate Governance Jun 2019 24 Jun 2021 Jun 2019 GC Kwin PetersonClosed Sessions and UDSA Sessions Jun 2019 24 Jun 2021 Jun 2017 Corporate Secretary Chris AlbrechtConfidentiality Aug 2018 24 Aug 2020 Sep 2018 Corporate Secretary Chris AlbrechtContact Information Jun 2018 24 Jun 2020 Sep 2018 Corporate Secretary Chris AlbrechtEnterprise Risk Management Jun 2019 24 Jun 2021 Jun 2019 Risk Management Jillian LessnerData Request Process Jun 2019 24 Jun 2021 Jun 2014 Corporate Secretary Chris AlbrechtDocument Categorization Aug 2018 24 Aug 2020 Sep 2018 Corporate Secretary Chris AlbrechtGenerating Unit Model Validation Mar 2012 24 Mar 2014 Mar 2012 MVWG Enoch DaviesInformation Reporting Jun 2020 24 Jun 2022 Dec 2016 Corporate Secretary Chris AlbrechtInformation Sharing Jun 2020 24 Jun 2022 Sep 2018 Corporate Secretary Chris AlbrechtInvestment Policy Dec 2018 24 Dec 2020 Jun 2017 FAC Jillian LessnerMeeting Nov 2018 24 Nov 2020 Dec 2018 Corporate Secretary Sandy MooyMonitoring Adherence to Regional Criterion Aug 2018 24 Aug 2020 Sep 2018 Corporate Secretary Steve RueckertObtaining Exemption from Regional Criterion Aug 2018 24 Aug 2020 Sep 2018 Corporate Secretary Steve RueckertRecords Retention Jun 2019 24 Jun 2021 Jun 2019 Corporate Secretary Kwin PetersonWhistleblower Aug 2018 24 Aug 2020 Sep 2018 Corporate Secretary Chris AlbrechtFAC Charter Jun 2020 12 Jun 2021 Jun 2019 FAC Jillian LessnerGC Charter Mar 2020 12 Mar 2021 Mar 2020 GC Kwin PetersonHRCC Charter Dec 2018 12 Dec 2019 Dec 2017 HRCC Jeanine WilsonJGC Charter Dec 2019 12 Dec 2020 Dec 2019 JGC Shelli NylandMAC Charter Dec 2019 12 Dec 2020 Dec 2019 MAC Kwin PetersonMIC Charter Sep 2019 12 Sep 2020 Sep 2019 MIC Layne BrownNC Charter May 2020 12 May 2021 Sep 2018 NC Jeanine WilsonOC Charter May 2020 12 May 2021 Mar 2020 OC Steve AshbakerRAC Charter May 2020 12 May 2021 Sep 2018 RAC Byron WoertzWSC Charter Dec 2019 12 Dec 2020 Dec 2019 WSC Steve Rueckert

Convenience copies are stored on the WECC website

GC Meeting Book - Board-Approved Documents

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Meetings Sponsored by WECC


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1 Introduction ....................................................................................................................................................3

1.1 Purpose .....................................................................................................................................................3

1.2 Document Owner ....................................................................................................................................3

1.3 Scope..........................................................................................................................................................3

1.4 Responsibilities ........................................................................................................................................3

2 Policy................................................................................................................................................................4

2.1 WECC Meetings.......................................................................................................................................4

2.2 Meeting Location .....................................................................................................................................4

2.3 Criteria for an Exception.........................................................................................................................5

3 Approval..........................................................................................................................................................6


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1 Introduction

All WECC-sponsored meetings should be scheduled in the most efficient and cost-effective manner possible. The WECC Board of Directors (Board) has encouraged staff to make full use of the Salt Lake City corporate office meeting space for WECC-sponsored meetings.

1.1 Purpose

The purpose of this policy is to facilitate effective and professional meetings while reducing the overall costs associated with meetings.

1.2 Document Owner

The owner of this document is the Managing Director, Organizational Development and OutreachChief Financial and Administrative Officer.

The document owner is responsible for:

∑ Performing or directing initial review and approvalrevision of the policy and its revisions in accordance with its review cycle, which is every two years from date of approval.

∑ Directing review and revision of the policy to be accurate and compliant with applicable regulatory, legal, and business requirements; and in accordance with the policy’s review cycle.

∑ Submitting the policy and its revisions to the Board for approval.

∑ Distributing the approved policy as appropriate.

1.3 Scope

This policy applies to all meetings sponsored by WECC or where official WECC business will transpire.

Exceptions to this policy:

∑ The Annual Meeting may be held in any location within the Western Interconnection, other than Salt Lake City, every year.

1.4 Responsibilities

1.4.1 Staff Liaisons

∑ Ensure that committee chairs are familiar with and adhere to the policy.


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∑ Work with the meetings department to address questions or concerns regarding implementation of the policy.

1.4.2 Supervisors

∑ Ensure that direct reports are familiar with and adhere to the policy.

1.4.3 Meetings Department

∑ Assist staff liaisons in creating, submitting, and managing meeting requests and logistics.

∑ DetermineFacilitate disposition of requested exceptions.

∑ Work with supervisors, staff liaisons, and senior management to address questions or concerns regarding policy implementation.

2 Policy

2.1 WECC Meetings

WECC-sponsored meetings1 are announced and organized by WECC staff.

2.2 Meeting Location

2.2.1 Salt Lake City Meeting Space

∑ Meetings should be scheduled in the Salt Lake City meeting space.

∑ Meetings should be scheduled as far in advance as possible and have flexibility in potential meeting dates.

∑ Meetings will include food and beverage service.

∑ Meetings will include audio-visual (A/V) services.

2.2.2 Hosted Meeting Location

∑ Meetings require prior approval by the Chief Financial and Administrative OfficerManaging Director, Organizational Development and Outreach.

1 Meetings are defined in Section 3.14 of the WECC Bylaws as approved in June 2018.


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∑ Meeting space shall be within the WECC footprint.

∑ WECC will pay for food and beverage service, provided the expenses are reasonable.

∑ Additional meeting fees such as facility fees, A/V fees, and receptions are not permitted without prior approval from the Chief Financial and Administrative OfficerManaging Director, Organizational Development and Outreach.

2.2.3 Commercial Meeting Facility

∑ Meetings held at a commercial meeting facility such as a hotel or convention center require prior approval by the Chief Financial and Administrative OfficerManaging Director, Organizational Development and Outreach.

∑ Meeting space shall be within the WECC footprint.

∑ Meetings will be held in a location and facility selected or approved by the Chief Financial and Administrative Officer Managing Director, Organizational Development and Outreach to ensure cost effectiveness for WECC and meeting attendees.

∑ WECC will pay for food and beverage service, provided the expenses are reasonable.

∑ Additional meeting fees such as facility fees, A/V fees, and receptions are not permitted without prior approval from the Chief Financial and Administrative OfficerManaging Director, Organizational Development and Outreach.

2.3 Criteria for an Exception

The following criteria will be used by the Chief Financial and Administrative Officer Managing Director, Organizational Development and Outreach when considering whether or not to grant an exception to the meeting policy location hierarchy:

∑ There is no available space in the Salt Lake City meeting space for the requested days.

∑ The number of attendees is too large for the Salt Lake City meeting space.

∑ Limitation of hotel rooms or significant increase in price for hotel rooms in Salt Lake City.


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∑ There is a compelling business reason to meet in another location, e.g., more cost effective.

3 Approval

Approving Committee, Entity, or Person Date

WECC Board

This policy supersedes and revokes all past policies and practices, oral and written representations, or statements regardingterms and conditions of employment concerning the subject matter covered herein. WECC reserves the right to add to, delete, change, or revoke this policy at any time, with or without notice. This policy does not create a contract between WECC and any employee or contractor, nor does it create any entitlement to employment or any benefit provided by WECC to its employees or contractors.

Caution!—This document may be out of date if printed.


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Whistleblower Policy

September 12, 2018


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Whistleblower Policy Title

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1 Introduction ....................................................................................................................................................3

1.1 Purpose .....................................................................................................................................................3

1.2 Document Owner ....................................................................................................................................3

1.3 Scope..........................................................................................................................................................3

1.4 Responsibilities ........................................................................................................................................3

2 Policy................................................................................................................................................................4

2.1 Expectations and Responsibilities.........................................................................................................4

2.2 Reporting ..................................................................................................................................................5

2.3 Handling Reports ....................................................................................................................................5

2.4 No Retaliation ..........................................................................................................................................6

2.5 Reference Documents..............................................................................................................................6

2.6 Policy Assessment ...................................................................................................................................6

3 Approval..........................................................................................................................................................6


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1 Introduction

Western Electricity Coordinating Council (WECC) plays a critical role in assuring the reliability of the Western Interconnection. Ethical conduct and behavior in all matters is crucial to maintaining the credibility necessary to carry out this complex responsibility. Appendices A and B of the WECC Bylaws contain Standards of Conduct for the WECC Board of Directors (Directors) and officers and employees, and consultants or contractors (contractors) of WECC. In addition, WECC is bound by its delegation agreement with the North American Electric Reliability Corporation, laws regarding workplace conditions and behavior, and antitrust statutes and policies. Any WECC Director, officer, employee orcontractor who is aware of actions known or suspected to be in violation of a policy, regulation, or law must immediately report the actions to the appropriate person as described herein.

1.1 Purpose

The purpose of this document is to set forth WECC’s Whistleblower Policy, which includes reporting procedures and ensures that no Director, officer, employee, or contractor who in good faith reports an inappropriate or illegal action, behavior, or situation shall suffer harassment, retaliation, or adverse employment consequence.

1.2 Document Owner

The owner of this document is the General Counsel. The document owner, or designee, is responsible for:

∑ Reviewing the policy within the review cycle

∑ Making any needed revisions to the policy

∑ Obtaining Board approval of any revisions

∑ Ensuring the policy is appropriately distributed, posted and communicated

1.3 Scope

This policy applies to WECC Directors, officers, employees, and contractors.

1.4 Responsibilities

Chief Financial and Administrative Officer Managing Director, Organizational Development

∑ Receive reports from the WECC Conflict of Interest and Ethical Issues Reporting Hotline (WECC Hotline).

∑ Investigate reports of alleged violations of this policy, (with assistance from the General Counsel, as necessary,).


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∑ Communicate this policy to all Directors, officers, and employees.

∑ Resolve reports regarding alleged violations of this policy (and communicate such resolutions to the General Counsel).

General Counsel

∑ Receive reports from the WECC Hotline.

∑ Provide legal advice as needed.

∑ Assist the Chief Financial and Administrative Officer Managing Director, Organizational Development in investigating and resolving reports of violations.

2 Policy

2.1 Expectations and Responsibilities

2.1.1 WECC Directors, officers, employees, and contractors are expected to adhere to high standards of ethical conduct.

2.1.2 It is the responsibility of all Directors, officers, employees, and contractors to comply with the Standards of Conduct and other applicable laws and regulations and to report actual or suspected misconduct in accordance with this Whistleblower Policy. Under this policy, disciplinary action may be taken against an officer or employee who learns of misconduct and fails to appropriately report it. Appropriate action may likewise be taken against a contractor in accordance with the applicable agreement or contract. Matters involving Directors will be referred to the Board Chair, CEO, and General Counsel for appropriate action.

2.1.3 The type of misconduct that must be reported includes, but is not limited to, the following:

∑ Fraudulent or negligent accounting∑ False financial reporting∑ Violations of the WECC Delegation Agreement∑ Conflicts of interest or other violations of the Standards of Conduct∑ Breaches of confidentiality∑ Violations of antitrust laws∑ Gifts or gratuities prohibited by WECC policy∑ Bribes or kickbacks∑ Harassment or discrimination


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∑ Safety or security hazards∑ Violations of WECC Policies

2.2 Reporting

Reports of actual or suspected misconduct must be made as specified below.

2.2.1 WECC officers, employees, and contractors must report actual or suspected misconductto their supervisor or a member of the WECC management team, and the General Counsel. Directors must report actual or suspected misconduct to the Board Chair, and General Counsel.

2.2.2 Reports involving misconduct by employees must also be made to the Chief Financial and Administrative OfficerManaging Director, Organizational Development.

2.2.3 Anonymous reports may be made by calling the WECC Hotline by phone or online. While anonymous reports are accepted, individuals making such reports mustunderstand that anonymity cannot be guaranteed and may hinder any subsequent investigation. All reports made to the WECC Hotline will be communicated to the General Counsel and the Chief Financial and Administrative OfficerManaging Director, Organizational Development.

2.2.4 Anyone filing a report concerning actual or suspected misconduct must be acting in good faith and have reasonable grounds to believe the information disclosed indicates actual or suspected misconduct. Anyone who makes unfounded allegations that are proven to have been made recklessly, maliciously, or with the foreknowledge that the allegations are false is subject to disciplinary action.

2.2.5 Crimes against persons or property must immediately be reported to law enforcement.

2.3 Handling Reports

2.3.1 Reports made as described herein will be kept confidential to the extent appropriate.

2.3.2 The General Counsel and Chief Financial and Administrative Officer Managing Director, Organizational Development will promptly act to investigate and/or resolve reported misconduct.

2.3.3 If the report involves the CEO, General Counsel or Chief Financial and Administrative Officer Managing Director, Organizational Development the matter will be referred to the Board Chair who will determine how to proceed. If the report involves the General


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Counsel, outside legal counsel may be used to advise the Board Chair and to assist in any investigation.

2.4 No Retaliation

2.4.1 No Director, officer, employee, or contractor who in good faith reports actual or suspected misconduct shall suffer harassment, retaliation, or adverse employment consequence. An officer, employee or contractor who retaliates against someone who has reported actual or suspected misconduct in good faith is subject to discipline up to and including termination of employment. A Director who engages in such conduct is subject to action in accordance with the WECC Bylaws.

2.5 Reference Documents

WECC Bylaws

2.6 Policy Assessment

Following every Whistleblower event, this policy will be assessed to determine what, if any, changes are necessary.

3 Approval


Board of Directors September 12, 2018

This policy supersedes and revokes all past policies and practices, oral and written representations, or statements regarding terms and conditions of employment concerning the subject matter covered herein. WECC reserves the right to add to, delete, change, or revoke this policy at any time, with or without notice. This policy does not create a contract between WECC and any employee or contractor, nor does it create any entitlement to employment or any benefit provided by WECC to its employees or contractors.



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Contact Information Policy

June 20, 2018


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1 Introduction ....................................................................................................................................................3

1.1 Document Owner ....................................................................................................................................3

1.2 Scope..........................................................................................................................................................3

1.3 Review Cycle............................................................................................................................................3

1.4 Definitions ................................................................................................................................................3

2 Policy................................................................................................................................................................4

2.1 WECC Website.........................................................................................................................................4

2.2 Board Contact Information.....................................................................................................................4

2.3 Member Contact Information ................................................................................................................4

2.4 Compliance Contact Information..........................................................................................................5

2.5 Limitations on Use...................................................................................................................................5

3 Approval ..........................................................................................................................................................6


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1 Introduction

Increased profile of WECC has led to increased interest in Member Contact Information and Compliance Contact Information for solicitation purposes. Additionally, some Members and Registered Entities may want to coordinate outside of WECC and have expressed an interest in obtaining this Contact Information.

The Utah Revised Nonprofit Corporations Act restricts the use of membership lists. A membership list may not be used for any purpose unrelated to a member’s interest as a member. In addition, a membership list may not be used to solicit money or property, used for any commercial purpose, or sold.1

1.1 Document Owner

The owner of this document is the General Counsel.

1.2 Scope

This policy applies to employees, Bboard of Ddirectors, and Mmembers.

1.3 Review Cycle

This policy will be reviewed every two years or as needed.

1.4 Definitions

Term or Acronym DefinitionContact Information May include, but is not limited to, mailing address,

physical address, telephone number, email address and fax number.

Member Contact Information Includes any and all Contact Information provided by Members, including, but not limited to, Contact

1 Utah Revised Nonprofit Corporations Act – Section 16-6a-1605 – Limitations on use of membership list:(1) Without consent of the board of directors, a membership list or any part of a membership list may not be

obtained or used by any person for any purpose unrelated to a member’s interest as a member.(2) Without limiting the generality of Subsection (1), without the consent of the board of directors, a membership

list or any part of a membership list may not be:(a) Used to solicit money or property unless the money or property will be used solely to solicit the votes of

members in an election to be help by the nonprofit corporation;(b) Used for any commercial purpose; or(c) Sold to or purchased by any person.


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Information for: (1) Member Representatives, (2) committee, subcommittee, work group and task force members, (3) voting representatives, and (4) other mMember-designated participants.

Member Representative A Mmember’s designated primary representative.Compliance Contact Information Includes any and all Contact Information provided

by rRegistered eEntities, including, but not limited to, Contact Information for primary compliance contacts.

2 Policy

Any requests for Contact Information not specifically permitted under Utah law, the WECC bBylaws, and this policy, shall be denied.

2.1 WECC Website

Member Contact Information and Compliance Contact Information shall not be made publicly available on the WECC website.

The names, but not contact information, for committee, subcommittee, work group and task force members will be listed publicly on the website. Contact information for WECC staff supporting committees, subcommittees, work groups, and task forces will be made publicly available on the website.

Non-confidential meeting materials containing Contact Information (e.g. PowerPoint presentations) may be posted publicly on the website.

The email address, but not other Contact Information, of (1) Member Representatives, (2) members of committees, subcommittees, task forces and work groups, and (3) members of drafting teams, will be available to all mMember personnel on restricted portions of the website.

2.2 Board Contact Information

Contact Information for bBoard dDirectors is generally publicly available as a corporate document at the Utah Division of Corporations website. Member Representatives will also have access to Contact Information for board directors.

2.3 Member Contact Information

Member Contact Information shall not be made available except as provided in this policy.

Committee, subcommittee, work group and task force cChairs may distribute a group member contact list to the group members.


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Member Representative Contact Information will be available to other Member Representatives and aAlternate Member Representatives. Member Representatives will also have access to Contact Information for bBoard dDirectors.

Member Advisory Committee (MAC) members/class representatives may receive Member Representative Contact Information for their class.

Member Contact Information may be made available to mMember personnel upon request and a determination by the cCorporate sSecretary that the request is appropriate and permitted under Utah law, the WECC bBylaws, and this policy.

Any person on the slate of candidates for election as a Bboard dDirector will be provided a current list of all Member Representatives Contact Information.

WECC shall not provide any mMember Contact Information in response to third-party requests for information, except as required by law.

Board dDirectors will have access to all mMember Contact Information.

2.4 Compliance Contact Information

Compliance Contact Information is confidential and shall not be publicly available. Compliance Contact Information will be restricted to staff and Bboard Ddirectors. WECC may make Compliance Contact Information available to other rRegistered Eentity compliance contacts to enhance coordination in compliance with reliability requirements and in response to FERC or NERC directives or requests. However, WECC may require the execution of an agreement to maintain the confidentiality of Compliance Contact Information made available to Rregistered Eentity compliance contacts. WECC will not provide any Compliance Contact Information in response to third-party requests for such information, except as required by law.

2.5 Limitations on Use

Member Contact Information and Compliance Contact Information may not be used by any person, including staff, Bboard Ddirectors, and Mmembers, for purposes other than those related to membership, and may not be:

∑ Used to solicit money or property unless the money or property will be used solely to solicit the votes of the members in an election to be held by the nonprofit corporation;

∑ Used for any commercial purpose; or∑ Sold to or purchased by any person for commercial purposes.

Commented [AC1]: This is about Board contact information, so I moved it to that section.

Commented [AC2]: The list of member reps without contact information is on the website and this policy is about contact information so I think this is what we want to say.


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3 Approval


Board of Directors September 20, 2018

This policy supersedes and revokes all past policies and practices, oral and written representations, or statements regardingterms and conditions of employment concerning the subject matter covered herein. WECC reserves the right to add to, delete, change, or revoke this policy at any time, with or without notice. This policy does not create a contract between WECC and any employee or contractor, nor does it create any entitlement to employment or any benefit provided by WECC to its employees or contractors.



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IRP and ISP Changes

12/17/2019

155 North 400 West | Suite 200 | Salt Lake City, Utah 84103 www.wecc.org

Information Reporting Policy

Collection Process

WECC is proposing changes to the Information Reporting Policy (IRP) that simplify the policy and collection process by providing more discretion to staff and removing unnecessary provisions, while explicitly preserving in the policy notice to applicable Members, the opportunity for them to comment, and the ability to appeal to the Board, all prior to staff’s implementation of the change(s).

Specific Data

WECC is proposing changes to Exhibit A – Loads and Resources Data to update the data collected by WECC and to change sharing categorizations. WECC is proposing to begin collecting “transfer limits” and that the following data be shared as public:

• Actual historic hourly wind, solar and hydro generation (aggregated at the BA level); • Transfer limits; and • Actual year hourly demand data.

Information Sharing Policy

Categorization Process

WECC is proposing changes to the Information Sharing Policy (ISP) that allow staff to change the categorization of data (as public, confidential, etc.) without Board approval, while explicitly preserving in the policy notice to Submitting Entities, the opportunity for them to comment, and the ability to appeal to the Board, all prior to staff’s implementation of the change(s).

Specific Data

In addition to the Loads and Resources changes described above, WECC is also proposing the following changes to sharing categorizations:

• Geomagnetic Induced Current and Remedial Action Scheme models – Confidential (CEII) o Removing restriction that they be shared only with NERC Registered Entities

• Short circuit models – Confidential (CEII) • Universal Data Sharing Agreement (UDSA) changed to Western Interconnection Data Sharing

Agreement (WIDSA)

GC Meeting Book - Information Sharing and Reporting Policies

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IRP/ISP Changes

February 19, 2020

Chris AlbrechtSenior Legal Counsel


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ß Two-Year Review ß Simplify Policy

• Remove unnecessary provisions• Changes without Board approval• Notice, comment, appeal

ß Transfer Limits/Capabilityß Categorize as “Public”

• Historic hourly renewable (BA level)• Historic hourly demand• Transfer Limits/Capability

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ß Simplify Policy• Changes without Board approval• Notice, comment, appeal

ß Categorizations from IRPß GIC and RAS models (CEII)• Remove Registered Entity only restriction• Requested by DS/RAC

ß Short Circuit Models (CEII)

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ß Posted for comment Dec. 17th – Jan. 17th

ß Comments from 11 entitiesß Additional Changes• Removed some GIS data from ISP• Appeals similar to NERC ROP Section 1503.5• All categorization/sharing terms moved to ISP• Notice of changes to GC and SCs• Other miscellaneous changes

ß Response to comments posted

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Comments


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ß Presentations to MIC, OC, RAC• Process suggestions

ß Next Steps• Comments still accepted• GC/Board approval in June

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Post-Comments


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Contact:Chris AlbrechtSenior Legal [email protected]

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IRP/ISP Comments

05/06/2020

155 North 400 West | Suite 200 | Salt Lake City, Utah 84103 www.wecc.org

WECC’s General Response to Comments

WECC appreciates the time entities have taken to comment on the Information Reporting Policy (IRP) and the Information Sharing Policy (ISP), both on the specific changes being proposed and on the revision process. WECC is providing commenters the information they requested and has made many changes to the policies in response to comments, including to the processes WECC will use to make future changes.

WECC has also:

• Removed all terms associated with data categorization and sharing from the IRP and included them in the ISP, which is more appropriate for the scopes of these two policies; and

• Removed “generation and substation GIS data” and “common case transmission assumption GIS data” from the ISP because WECC no longer shares this information.

WECC will continue to accept comments until the policies are posted for the approval of the Governance Committee and Board of Directors in June.

BC Hydro

General Comment on Changes to the Policies

At this time, BC Hydro does not support the revisions put forth because BC Hydro does not believe that adequate information on the rationale and reasons for these changes was presented to WECC Members with respect to the reasons for removing certain provisions and the changes in what data will be collected as well as the changes made to sharing categorizations from non-public to public. BC Hydro notes that WECC has only provided a summary of the proposed changes to the policies, which provide a high-level description of changes, but does not provide adequate reasons and rationale for WECC members. Accordingly, BC Hydro requests that presentations be made in this regard by WECC staff to the Member Advisory Committee at its January 29 meeting, and to the Standing Committee meetings from February 19-21, and that the time period for comments by members be extended until after this engagement has been completed.

The IRP was due for its two-year review and is an old policy that has changed little over the years, so WECC took a fresh look at the policy to see how it could better meet the needs of WECC and its Members. WECC proposed revisions to simplify the policy and collections process, to recognize that


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WECC began collecting transfer limits, and to recategorize as “public” certain information that WECC does not believe is market sensitive.

The changes to the ISP were due to WECC’s changes to the IRP, a recommendation on GIG and RAS models from the Data Subcommittee under the Reliability Assessment Committee, and the need to categorize short-circuit models.

Additional rationale supporting these changes is provided throughout this response to comments. WECC will provide presentations to committees as they request them and will accept comments on the policies until they are posted for Board approval.

In addition, below are some additional specific comments on the policies as follows:

Information Reporting Policy (IRP)

“2. Determining Information Reporting Requirements”

BC Hydro notes that WECC has removed some provisions from the IRP, including section 4.2 ”Avoiding Conflict with Existing Regulatory/Contractual Obligations”. BC Hydro suggests that the IRP be revised to include that WECC staff will consider these factors in the development of the reporting requirement Exhibits. BC Hydro suggests that in Section 2 – after the new “taking into consideration the burden of Members,” the following be added, “and making reasonable efforts to avoid imposing obligations under this policy that conflict with Members’ existing regulatory or contractual obligations,”.

WECC has added the requested language.

In addition, BC Hydro recommends some commentary to members on the Board governance role in approving the IRP and its Exhibits consistent with section 4.6.11 of the By-Laws, as the proposed changes to the IRP provide that changes to the Exhibits are developed by WECC staff and will be effective when approved by the WECC CEO – without Board approval. BC Hydro believes that further rationale and explanation is required for WECC membership regarding this change.

These changes provide a more efficient policy revision process that only requires the Board’s time and attention when necessary. The Board will continue to govern the IRP and its Exhibits by continuing to approve changes to the IRP and considering appeals of Exhibits.

“4. Protection and Sharing “

WECC staff is making the determination of the applicable Information Access Category (ie public – non public), and any disputes will also be resolved by WECC staff. There is no guidance provided in the policy for the procedure WECC staff will follow to make its determination with respect to disputes about applicable Information Access Categories. BC Hydro suggests that the WECC staff process for resolving disputes about Information Access Categories be included in section 4 of the IRP.


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As with the ISP, WECC has added language to the IRP stating that appeals will follow a process similar to Section 1503.5 of the NERC Rules of Procedure.

New data collected and changes in categorization – Exhibit A

WECC is proposing changes to Exhibit A – Loads and Resources Data to update the data collected by WECC and to change sharing categorizations, however, BC Hydro does not believe that the WECC membership, Standing Committees or Member Advisory Committee were provided with a presentation with respect to the rationale for the proposed categorizations changes from non-public to public and where this information will be contained at WECC. BC Hydro believes this stakeholder engagement should be completed before comments are solicited.

WECC is already collecting transfer limits and is simply updating the Exhibit accordingly. The rationale for the proposed changes to categorization is that WECC does not believe this data is market sensitive. WECC will provide presentations to committees as they request them and will accept comments on the policy until they are posted for Board approval.

In addition BC Hydro would like a clear understanding of the specific data that is included in the proposed collection of “transfer limits” that WECC is proposing to begin collecting and make public in order to adequately assess this provision. WECC should provide an appropriate definition of “Transfer Limits” and it should be developed with and agreed upon by WECC membership.

As stated above, WECC is already collecting transfer limits and is simply updating the Exhibit accordingly. WECC has revised the term in the proposed changes from “transfer limits” to “Transfer Capability,” which is defined in the WECC 2020 Loads and Resources Data Collection Manual.

Once the rationale has been provided for the proposed changes in categorizations for the data collected, BC Hydro will be in a better position to assess whether it has any comments with respect to whether the data below should be public.

• Actual historic hourly wind, solar and hydro generation (aggregated at the BA level);

• Transfer limits; and

• Actual year hourly demand data.

As stated above, WECC is proposing to recategorize this data as “public” because WECC does not believe it is market sensitive.

Information Sharing Policy (ISP)

WECC is proposing changes that allow staff to change the categorization of data (as public, confidential, etc.) without Board approval, while explicitly preserving in the policy notice to Submitting Entities, the opportunity for them to comment, and the ability to appeal to the Board, all


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prior to staff’s implementation of the change(s). BC Hydro believes that further rationale and explanation is required for WECC membership regarding this change.

This change provides a more efficient policy revision process that only requires the Board’s time and attention when necessary (i.e., upon appeal).

In addition to the Loads and Resources changes described above, WECC is also proposing the following changes to sharing categorizations:

• Geomagnetic Induced Current and Remedial Action Scheme models – Confidential (CEII) - Removing restriction that they be shared only with NERC Registered Entities

• Short circuit models – Confidential (CEII)

• Universal Data Sharing Agreement (UDSA) changed to Western Interconnection Data Sharing Agreement (WIDSA)

BC Hydro’s comments to the IRP information sharing and categorization above are also applicable to the ISP with respect to BC Hydro’s ability to assess the changes in sharing categorizations made to sections 2.1.2, 2.2.2, and 2.3.1.

The change to how WECC shares GIC and RAS models was requested by the Data Subcommittee under the Reliability Assessment Committee (RAC) to simplify the model-sharing process. This change was discussed by the RAC on multiple occasions. The Data Subcommittee and WECC staff believe the protections put in place to protect CEII are adequate and do not believe that GIC and RAS models need extra protection.

WECC recently began collecting short-circuit models and added them to the ISP as CEII. This approach is consistent with discussions held at multiple committee meetings (the Modeling Subcommittee under the Reliability Assessment Committee and the Short Circuit Modeling Working Group and at the Relay Work Group under the Operating Committee).

“2.4 Western Interconnection Data Sharing Agreement (WIDSA)

Please add to the start of this section ”Notwithstanding anything to the contrary contained in this policy” - so that section 3.3 does not inadvertently override the WIDSA terms.

WECC has added the requested language.

”2.5. Information Not Shared”

Information that will not be shared outside of the ERO enterprise (NERC and regional entities). BC Hydro notes that the WECC CEO can approve exceptions allowing the sharing of this data unless otherwise prohibited. BC Hydro expects that the sharing of any British Columbia (Non-US) entity compliance information with third parties without consent would be prohibited. Given that section 2.5 Information Not Shared categorization may contain BC registered entity compliance data, BC Hydro


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suggests that ISP be revised to provide that the WECC CEO must have the consent from the [non-US entity] or [entity or member] that provided the information prior to sharing this information.

The sharing of non-U.S. entity information in violation of its agreements with those entities would be prohibited. WECC has added the requested language.

3.11 - Categorization Changes

BC Hydro notes that the changes to the ISP provide that WECC staff may categorize or change the categorization without Board approval, and that WECC staff determine any disputes. No process is set out for how the dispute resolution process will be conducted. BC Hydro suggests that the WECC staff process for resolving disputes be included in section 3.11 of the ISP.

WECC has changed the policy so that disputes regarding the categorization of information will be addressed under Section 4 – Dispute Resolution and will follow a process similar to Section 1503.5 of the NERC Rules of Procedure.

Housekeeping edits

Section 1.4 – Review Cycle - Is the second paragraph in section 1.4 an internal drafting note?

Yes, thank you.

Section 3.1 – In the fourth line – “UDSA” – should be changed to “WIDSA.”

Yes, thank you.

BC Ministry of Energy

WECC has requested comments on the proposed changes to its information sharing and information reporting policies. British Columbia has concerns around the process that WECC has followed to bring these changes forward and the level of detail it has provided to its members in advance of giving feedback. Our concern is that WECC has not offered a clear rationale for why the existing policies need to be altered. In addition, the scope and impact of the changes are unclear (for example, the additional data requirement that WECC is proposing to collect, “transfer limits”, is not defined). As a result of not having sufficient information to make an informed decision, BC is not supportive of the recommended changes. WECC must to provide more detailed information to the MAC and its standing committees on what information is being requested and why it is needed and provide additional time for comment.

WECC followed the policy revision process set forth in the policy. WECC is providing the reasons and rationale for the changes in this response to comments. WECC has replaced the term “transfer limits” in the proposed changes with “Transfer Capability,” which is defined in the WECC 2020 Loads and Resources Data Collection Manual. WECC will provide presentations to committees as they request


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them and will continue to accept comments on the proposed changes until they are posted for Board approval.

Colorado Springs Utilities

UDSA should be WIDSA in Section 3.1 of the Information Sharing Policy

WECC has made this change.

An inconsistency (compare redlines in 1.3 of the Information Reporting Policy to the lack of matching redlines in 1.3 of the Information Sharing Policy

WECC has made these changes.

El Paso Electric Company

EPE opposes expanded sharing of models proposed within the Information Sharing Policy (to include, for example, RAS and short circuit models), because the expansion of model sharing is not accompanied by any strengthening to the "legitimate need" threshold used by WECC for permitting access to such information. Category (ii) of the legitimate need threshold in Section 3.7 requires the requester to simply represent that it wants the models for "analysis." On its face, an individual seeking access to models for the purpose of analyzing them in order to harm operators and users of the regional or interconnection-wide electric grid would qualify under the "legitimate need" test, even though the models, themselves, qualify for designation as CUI/CEII under FERC's rules.

Further, it is EPE's understanding that the substantial majority of requests for data access are granted by WECC, such that the result is that access is widely permitted. Since the legitimate need threshold is not being proposed for strengthening, EPE strongly opposes any expansion of the sharing of models that could be used to do harm to the electric grid. If Category (ii) of the legitimate need threshold in Section 3.7 had been proposed for elimination in the draft, EPE may have been more open to considering an expanded scope of model sharing. Any expansion of sharing should be accompanied by strengthening in the legitimate need test and greater rigor of evaluation of need.

The definition of “Legitimate Need” in the policy was taken from the definition of “Permitted Purposes” in the UDSA/WIDSA, to which EPE and all RCs, BAs, and TOPs in the Western Interconnection are signatories. WECC collects information from all requesters to evaluate who they are and their proposed need to prevent information from being used for malicious purposes.

EPE's comments on the proposed changes to the WECC Information Reporting Policy:

EPE opposes the removal of Section 4.2 of the WECC Information Reporting Policy, because removal would eliminate the obligation of WECC to make reasonable efforts to avoid imposing obligations that conflict with existing regulatory obligations. WECC should be obligated to make reasonable efforts to


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avoid imposing obligations that conflict with FERC or other regulatory requirements. Members should expect at least that much from WECC, its staff and governing board.

WECC has added language to the policy to specify that WECC will make reasonable efforts to avoid imposing obligations under the policy that conflict with Members’ existing regulatory or contractual obligations.

In addition, EPE opposes the proposed sharing, as public, transfer limits, actual hourly demand, and actual historic hourly wind & solar generation data. Transfer limits are properly considered CEII, because access to transfer limits could aid in a bad actor's pursuit and implementation of harm to the grid. Should WECC make it publicly available, WECC would be acting contrary to the federal definition and treatment of such data, as non-public. This inconsistency also illustrates the problem with the proposed removal of Section 4.2, for the reasons identified above. Finally, with respect to the proposed changes to begin sharing, as public, hourly demand data and historic hourly wind and solar generation data, EPE opposes these changes, because they would not serve any reliability purpose. Further, there is no justification presented to support such a change.

WECC does not believe transfer limits are CEII. WECC has replaced the term “transfer limits” in the proposed changes with “Transfer Capability,” which is defined in the WECC 2020 Loads and Resources Data Collection Manual. WECC does not believe this Transfer Capability would be useful to someone planning an attack on critical infrastructure. EPE offers no support for its contention that this data could help a bad actor harm the grid.

WECC is proposing to share hourly demand and renewable data publicly because it does not believe this data is market sensitive. The public availability of this data serves a WECC reliability purpose of making this data available for public reliability assessments that WECC performs. The public availability of this data may also serve other reliability purposes for other entities.

PacifiCorp

Section 1.3 “Scope” of the Information Reporting Policy”, Not sure why “WECC” was removed before “employees” because it is unclear what employees are being referring to now.

“WECC” was removed from in front of employees, the Board of Directors, and Members because, given this is a “WECC” policy, it is implied that it applies, and it can only apply to, “WECC” employees, the “WECC” Board of Directors, and “WECC” Members, so it does not need to be explicitly stated. The edits were proposed to remove redundancy.

In 1.3, why does this policy no longer apply to WECC contractors? This must have been an intentional deletion, it should be explained.


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As with the corporate policies of any corporation, WECC corporate policies are not intended to apply to, nor are they in any way enforceable against, all WECC contractors. Contractors will be made subject to policies or specific terms from those policies as necessary through contracts.

Under Section 2 of the Information Reporting Policy”, WECC Staff will develop exhibits for reporting requirements which consider the burden to Members, but Section 4.1 regarding avoiding burdensome requirements on Members was removed.

Section 4.1 was deleted because such extensive terms are unnecessary and to simplify the policy. The simple requirement that WECC consider the burden to members was moved to Section 2 so it was not lost.

Section 2.1.2, bullet #3, suggest changing the “BA” reference to “BAA for example PAC would submit all of PacifiCorp as the BA (Balancing Authority) and not by the individual BAA (Balancing Authority Area) (PACE or PACW).

WECC has changed the language to specify it is “aggregated at the BA or BA-area level.”

Section 3.3 “Presumption” of the Information Reporting Policy”, presumption in favor of requests for information being reasonable when Petitions for Relief are presented was removed. This seems to increase the chances that Petitions for Relief will granted.

WECC deleted Section 3.3 because presumptions (used to create evidentiary hurdles) and precedents are a level of process not needed in this policy. WECC will consider all the circumstances, including the presumed need for information and reasonableness of the request, in deciding whether to grant a petition for relief.

In 3.11, WECC “may” treat public information as confidential during an appeal to the board. It would be better if WECC was required to treat that information as confidential until an appealing party has been heard. Further, what if information is already confidential, and WECC Staff has decided to reclassify it as public? It’s not clear that this language would apply if the classification change went that way.

WECC has revised the language to require that it treat as confidential any public information it proposes for recategorization as confidential during the recategorization process. This provision is not intended to apply, and on its face does not apply, to information that is already confidential. Information that is already confidential must continue to be treated as such until it is determined to no longer be so.

Portland General Electric

Portland General Electric Company (PGE) hereby submits comments to WECC concerning recent proposed changes to the WECC Information Reporting Policy and WECC Information Sharing Policy. PGE respectfully requests WECC to provide the justification for the requested information,


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specifically what the data will be used for, and how such information will be made available to the public. If WECC clearly demonstrates a need for such data, PGE suggests WECC utilize already publicly available data for: actual hourly wind, solar and hydro generation (aggregated at the BA level); actual year hourly demand and; transfer limits. The United States Energy Information Administration (EIA) already collects this data via Form EIA-930 and publishes the data on their public website.

Form EIA-930 data collection provides a centralized and comprehensive source for hourly operating data about the high-voltage bulk electric power grid in the lower 48 states. The data is collected from the Balancing Authority Areas (BAs) that operate the grid. PGE is one of the many BAs in WECC that submit data to the EIA via Form EIA-930.

The EIA-930 contains the following hourly data elements: https://www.eia.gov/beta/electricity/gridmonitor/about

• Demand • Demand by subregion • Demand forecast • Net Generation • Net generation by energy source • Total net interchange • Interchange with directly interconnected BAs

WECC utilizing already publicly available information mitigates the administrative burden of collecting and transmitting the same data to multiple entities, as well as ensures data consistency across multiple forums.

PGE appreciates WECC’s willingness to engage with its members about the proposed modification to the WECC Information Reporting Policy and WECC Information Sharing Policy. PGE appreciates the opportunity to submit these comments and looks forward to working with WECC on this issue.

WECC is not requesting any new data that it does not already collect, but is updating the IRP to reflect its current collection of transfer limits. WECC has replaced the term “transfer limits” in the proposed changes from to “Transfer Capability,” which is defined in the WECC 2020 Loads and Resources Data Collection Manual. WECC uses the Transfer Capability in its zonal model to limit or cap the amount of surplus supply that can be moved from one area to another to balance the system. WECC does and will continue to investigate using EIA data for its reliability assessments, including the specific suggestions made by Portland General Electric.


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Powerex

Powerex appreciates the opportunity to comment on the proposed changes to the Information Sharing Policy and Information Reporting Policy that were published on December 17th, 2019. At this time, Powerex does not support the revisions put forth, and agrees with the concerns that have been expressed by BC Hydro in their comments. Powerex believes that WECC staff should undertake further consultations and stakeholder engagement with WECC members through the Standing Committees and Member Advisory Committee. WECC staff should also provide reasons and rationale regarding the changes to the committees and subsequently open up another comment period after those consultations. The consultation with WECC Members and final comment period should be completed before this topic is presented to the WECC Board.

Please see WECC’s responses to BC Hydro’s comments. WECC is providing the reasons and rationale for the changes in this response to comments. WECC will provide presentations to committees as they request them and will continue to accept comments on the proposed changes until they are posted for Board approval.

Puget Sound Energy

PSE opposes several of the proposed changes. PSE is in opposition because the proposed changes differ from WECC’s otherwise stated intention of sharing protected information, negate utilities’ rights to protect their own CEII, unnecessarily escalates security risks, and overburdens the study process.

First, the body of the notice says that WECC’s proposal is to include RAS and GIC data in the base cases—this intent is not within the Sharing Policy’s redline. Currently, WECC stores RAS and GIC data within a separate database, which requires separate approval and an NDA for a third-party to access. Without being within the redline proposal, WECC’s proposed revisions are misleading. And action taken to put the information within base cases after the redlines are approved would be outside the policy’s scope since the policy implies that such sharing is to be determined on a case-by-case basis.

WECC’s Data Subcommittee under the Reliability Assessment Committee (RAC) requested this change. Changing the ISP categorization or treatment of GIC and RAS models does not require or necessarily mean that these models are included directly in base cases. While this may or may not happen, WECC believes the wording of the proposed revision is enough to notify stakeholders that base cases may “include” GIC and RAS models. These concerns should be shared and discussed at the Data Subcommittee.

Second, NERC Rule of Procedure Section 1503(3) requires WECC to give utilities notice and an opportunity to object anytime WECC receives a request for utility-owned CEII within its possession. WECC itself defines RAS and GIC data as CEII. By including RAS and GIC data within the base cases, WECC is negating utilities’ rights to notice and comment. At a minimum, WECC is creating a system where it and utilities will continuously need to be engaged in extraordinary CEII evaluations every


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time an entity makes a base case request, regardless of whether that entity even wants the RAS and GIC information.

WECC is applying Section 1503.3 of the NERC Rules of Procedure through the ISP and its approval processes. The policy and WECC’s communications to Submitting Entities during the approval process constitute the required notice to Submitting Entities. Submitting Entities are also given an opportunity to comment during the policy approval process.

Third, including RAS data in the WECC base cases is a security problem. The RAS data tells people where the system is weak and what causes those weaknesses. With the emphasis on how vulnerable the grid is to cyber (and other) attacks, sharing this information without a specific CEII request, evaluation, and NDA is not prudent.

The ISP categorizes base cases as CEII and all requests for base cases are treated as CEII requests, including evaluation by WECC and an NDA. However, changing the ISP categorization or treatment of RAS models does not require or necessarily mean that these models are included directly in base cases. These concerns should be shared and discussed at the Data Subcommittee.

Fourth, including GIC data as part of the base case review process could degrade the quality of the data. WECC is aware that utilities are already struggling to keep up with the case reviews, so it is not reasonable to add another item to the list of things to review for each base case. Although it is possible that the GIC data will not be given enough attention during the case review process, utilities are already short on time for these reviews, and the NERC quality metrics and overall quality of the base cases are not likely improve with this addition.

WECC is requesting updates to the GIC data on an annual basis, which is unlikely to change unless a need arises. While including the GIC data in base cases would be more data and added complexity, WECC expects that its inclusion in the base cases would decrease duplicated data and increase the accuracy of the GIC data for the annual update. Regardless, changing the ISP categorization or treatment of GIC models does not require or necessarily mean that these models are included directly in base cases. These concerns should be shared and discussed at the Data Subcommittee.

Fifth, changes to section 4, “Sharing and Protection”, removes the ability of WECC members to effectively address concerns with future changes to the policy. The policy should still require WECC staff to provide justification for changes, in addition to a comment period, and provide for a separate dispute resolution process that is not also governed by WECC staff. Allowing WECC staff to dictate changes and also to resolve disputes concerning those changes creates a conflict of interest.

WECC has removed all terms associated with data sharing and categorization from the IRP and included them in the ISP, which is more appropriate for the scopes of these two policies. WECC has revised the process in the ISP to include WECC’s posting of the reasons and rationale for the changes and to include additional committees to be notified.


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The policy, as revised, protects Members’ ability to address their concerns by posting of the proposed categorization change (including the reasons and rationale for the change), notice to applicable entities and committees, a comment period, and the ability to appeal, including to the Board of Directors.

Lastly, two of the changes to section 2.1 concerning hourly data could cause SOC concerns. The actual hourly renewable data has historically been considered market sensitive information and not to be shared with Marketing Function Employees (MFEs). Allowing actual hourly demand data to be made available to WECC entities only before being made publicly available may be construed as violations of the unfair treatment and no conduit rules.

Hourly renewable data—WECC does not believe this information is market sensitive. No commenter has given any explanation or justification for treating it as such.

Hourly demand data—This data would not be available only to WECC entities before being made publicly available by WECC. Instead, this information would be publicly available to any requester upon collection by WECC.

Puget Sound Energy has not provided any support for the contention that these changes may be a violation of the FERC Standards of Conduct, including the No Conduit Rule.

Short-Circuit Modeling Work Group (SCMWG)

At its meeting on April 29, 2020, the SCMWG reached consensus that short-circuit models should only be shared with NERC Registered Entities.

Given these models are not WECC work products and WECC is simply facilitating the exchange of these models for the benefit of the data submitters, WECC will defer to the data submitters on how they should be shared and has made corresponding changes to the policy.

Southern California Edison

The purpose of this email is to provide a response to the subject document regarding sharing Geomagnetic Induced Current data. SCE had previously expressed concern on providing this information in the base cases. The concern is that providing this information could result in identifying locations of SCE’s transmission facilities. As a result of identifying these locations, it could result in security risks of critical infrastructures.

WECC collects information from all requesters to evaluate who they are and their proposed need to prevent information from being used for malicious purposes.

Tri-State Generation and Transmission Association


Exhibit A – Loads and Resources Data; Section B. Identification of Data Collected


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Data Listed as required in this Exhibit will be identified more specifically, including additional generator and path specifications, in the “WECC Data Collection Manual” that is approved annually by WECC. Comment: Please include the responsible party at WECC for its approval.

The Data Collection Manual is not formally approved by any responsible party; it is reviewed, updated and provided annually by WECC staff. The language has been updated to remove the reference to “approval.”


2.1.4: Even though this information appears to have been included in a past policy and is not posted on the public portion of the WECC website, due to concerns with possible nefarious intentions by individuals / groups, Tri-State does not think principal transmission and planned facilities maps nor latitude, longitude and two-dimensional data should be posted with access by just having a UN and PW.

WECC does not share the principal transmission and planned facilities maps with all who have a username and password to the WECC website. WECC shares this information only with WECC Members or others who have been vetted and approved by WECC.

WECC only shares latitude, longitude, line, and two-dimensional data related to the principal transmission and planned facilities maps. As stated above, WECC does not share this information with all who have a username and password to the WECC website. WECC shares this information only with WECC Members or others who have been vetted and approved by WECC.

2.1.5: Even though this information appears to have been included in a past policy and is not posted on the public portion of the WECC website, due to concerns with possible nefarious intentions by individuals / groups, Tri-State does not think Production Cost Models and data not integrated with power flow, detailed transmission topology or other restricted information and Generation and substation Geographic Information System (GIS) data should be under Public Information. There is no reason to make life easy for bad actors.

WECC does not believe that production cost model information (that does not include power flow, detailed transmission topology, or other restricted information) is sensitive in any way or useful to a person planning an attack on critical infrastructure. Making this information publicly available promotes reliability by facilitating its use in a wider variety of forums and by increasing transparency.

WECC is removing “generation and substation GIS data” and “common case transmission assumption GIS data” from the ISP because WECC does not share this information.

2.5: Information not Shared introductory paragraph: Please add that a signed Non-Disclosure Agreement by the entity desiring the information would have to be in place and notice to the owners of the information would be provided prior to any information being provided.


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WECC has added these requirements.

3.1: UDSA in the fourth line down should be changed to WISDA.

WECC has made this change.

Western Interconnection Regional Advisory Body

WECC appreciates WIRAB’s supportive comments.

WECC should include a provision in the Information Sharing and Reporting Policies requiring that WECC staff inform the Governance Committee (GC) of any decisions to change the categorization of collected data. Updating the GC of such staff decisions provides an opportunity for oversight and review of the staff’s reclassification of information categorization determinations. This action by WECC staff and the GC will improve transparency when data categories are updated by ensuring that independent board members of the GC are fully aware that such changes have been made.

WECC has added to the ISP the identification of the Governance Committee as an entity to be notified of proposed data categorization changes.

WECC should work with stakeholders to develop specific criteria for categorizing data as Public Information, Market Sensitive Information, Confidential Information, and CEII. The Information Sharing and Reporting Policies provide an extensive list of data designated for inclusion under each data category. However, no explanation about why or what data should be included within each category is provided. WECC should work with stakeholders to develop criteria and a process for categorizing data, thereby improving transparency and providing substantial guidance to WECC staff in their efforts to review and change the categorization of collected data. This has been a longstanding WIRAB recommendation; one that WIRAB believes is an important aspect of a well-developed data sharing policy.

WECC is subject to and must follow Section 1500 of the NERC Rules of Procedure as the criteria for categorizing data as Confidential, CEII, and Market Sensitive. WECC does not believe an attempt to develop more specific criteria to implement the definitions in Section 1500 is appropriate or necessary, as such determinations come down to engineering judgment and discretion. The explanation as to why data is in each category is that WECC believes that data meets the corresponding definition in Section 1500. A transparent process for categorizing data, including opportunities to provide comments or guidance to WECC staff, is already provided for in the policy.


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September 12, 2018


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2

1 Introduction ....................................................................................................................................................3

1.1 Notice ........................................................................................................................................................3

1.2 Document Owner ....................................................................................................................................3

1.3 Scope ..........................................................................................................................................................3

1.4 Review Cycle ............................................................................................................................................3

2 Policy ................................................................................................................................................................3

2.1 Public Information ...................................................................................................................................4

2.2 Confidential Information ........................................................................................................................5

2.3 Market Sensitive Information ................................................................................................................6

2.4 Western Interconnection Data Sharing Agreement (WIDSA) ...........................................................7

2.5 Information Not Shared ..........................................................................................................................7

2.6 Other ..........................................................................................................................................................8

3 Administration ...............................................................................................................................................8

3.1 Applicable Laws, Agreements, and Policies or Processes .................................................................8

3.2 Unrestricted Information ........................................................................................................................9

3.3 Information from Multiple Sources ......................................................................................................9

3.4 Redacted or Aggregated Information ...................................................................................................9

3.5 Availability of Information Internally ..................................................................................................9

3.6 Availability of Information to NERC, FERC and Other Governmental Entities ............................9

3.7 Legitimate Need.....................................................................................................................................10

3.8 Requests for Information ......................................................................................................................10

3.9 Protection of Information .....................................................................................................................11

3.10 Information Not Addressed .................................................................................................................11

3.11 Categorization Changes ........................................................................................................................11

4 Dispute Resolution ......................................................................................................................................11

5 Approval ........................................................................................................................................................11


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3

1 Introduction

The purpose of this policy is to set forth Western Electricity Coordinating Council (WECC) policies for the sharing of certain data, reports, maps, or other types of information. This policy:

• Provides direction to WECC staff regarding the sharing of information; • Describes whether and how persons can obtain access to specific types of information; and • Makes clear to those who provide information to WECC the conditions under which the

information is made available to others.

1.1 Notice

This policy constitutes WECC’s notice to submitting entities under Section 1503.3 of the North American Electric Reliability Corporation (NERC) Rules of Procedure that WECC intends to share Confidential Information as set forth in this policy. This policy also constitutes WECC’s notice to submitting entities under Section 1505 of the NERC Rules of Procedure that WECC may share information with the Federal Energy Regulatory Commission (FERC) in accordance with the terms herein.

1.2 Document Owner

The owner of this document is the WECC General Counsel.

1.3 Scope

This policy applies to WECC employees, the WECC Board of Directors, and WECC Members.

Nothing in this policy is intended to apply to or restrict how WECC Members or other submitting entities receive their own information or share their own information directly with others.

1.4 Review Cycle


A broad responsibility statement may be included at the end of this section; usually no more than 1 to 3 sentences.

2 Policy

This policy categorizes information into the following different Information Access Categories which set forth how information may be shared.


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2.1 Public Information

The following types of information are not restricted and may be made publicly available.

2.1.1 General

• Charters, meeting agendas, open meeting materials and minutes

• Reliability Standards, Regional Criteria, Policies, and Guidelines

2.1.2 Loads and Resources

• Existing generation list

• Planned generation list

• Projected and actual demand reduction data

• Projected peak demand (years 4-10)

• Projected energy forecasts (years 4-10)

• Scheduled peak-hour generation outages (years 4-10)

• Actual year peak-hour generation outages

• Actual historic hourly wind, solar and hydro generation (aggregated at the BA or BA-area level)

• Actual year hourly demand data

• Transfer Capability

2.1.3 Event Analysis and Situational Awareness

• Major WECC Remedial Action Schemes (RAS) table

• Event analysis lessons learned (including brief event background)

2.1.4 System Stability Planning

• Major WECC Transfer Paths table

• Principal transmission and planned facilities maps

i. Will not be posted on public portions of WECC website

• Latitude, longitude, line and two-dimensional data



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2.1.5 System Adequacy Planning

• Production Cost Models and data not integrated with power flow, detailed transmission topology or other restricted information

• Long term planning tool data (not otherwise restricted by Section 2.6).

• Path descriptions, planned ratings, system conditions, allocation and interactions with other transfer paths from the WECC Path Rating Catalog

• Generation and substation Geographic Information System (GIS) data (from public sources)

2.2 Confidential Information

The following types of information will be treated as Confidential Information under Section 1500 of the NERC Rules of Procedure and may only be shared with persons who (1) at the discretion of WECC have demonstrated a legitimate need, and (2) have executed a non-disclosure agreement (NDA).


• Transmission and generation protection system misoperations reports (Critical Energy Infrastructure Information or CEII)

• Event analysis reports and brief reports (CEII)

• Resolved and unresolved disturbance logs (CEII)

• RAS database and RAS database summaries (Operating Procedures) (CEII)


• Base-case data (power flow and dynamics data) including Geomagnetic Induced Current (GIC) and Remedial Action Scheme (RAS) models (CEII)

i. Geomagnetic Induced Current (GIC) and Remedial Action Scheme (RAS) models will only be available on the WECC website to employees of NERC Registered Entities and non-U.S. entities in the Western Interconnection who perform similar functions, who have signed an NDA. Other persons may also receive GIC and RAS


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models upon request, a specific determination of legitimate need by WECC, and execution of an NDA.

• Under-Frequency Load Shedding (UFLS) data required to be provided by PRC Reliability Standards and Regional Criteria (CEII)

• Under-Voltage Load Shedding (UVLS) data required to be provided by PRC Reliability Standards (CEII)

• Comprehensive progress reports provided pursuant to the WECC Path Rating Process (CEII)

• WECC Path Rating Catalog (CEII)

• Generator model data validation test reports (CEII)

• Short circuit models (CEII)

i. These models will only be shared with NERC Registered Entities and non-U.S. entities in the Western Interconnection who perform similar functions.


• Common case transmission assumption GIS data

• Complete Production Cost Model cases that include power flow, detailed system topology or other restricted information (CEII)

2.3 Market Sensitive Information

The following types of information will be treated as Confidential Business and Market Information under Section 1500 of the NERC Rules of Procedure and may only be shared with persons who (1) are not (a) Market Function Employees as defined by FERC, nor (b) actively and personally engaged in day-to-day sales of electric power or other marketing functions, (2) at the discretion of WECC, have demonstrated a legitimate need, and (3) have executed an NDA.






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• Actual historic hourly wind, solar and hydro generation (aggregated at the Balancing Authority level)

2.4 Peak Reliability DataWestern Interconnection Data Sharing Agreement (WIDSA)

Information received by WECC from Peak Reliability will be shared as follows:

2.4.1 UDSA Covered Data

Information received by WECC from Peak Reliability that meets the definition of Covered Data under the Peak Reliability UniversalNotwithstanding anything to the contrary contained in this policy, information WECC receives that is subject to the Western Interconnection Data Sharing Agreement (UWIDSA) may only be shared in accordance with the terms therein.

2.4.2 WebSAS Data

• Information that WECC has access to through the webSAS tool may only be shared by WECC with signatories of the UDSA unless otherwise agreed to in writing by Peak Reliability.

2.5 Information Not Shared

Due to the nature of the following types of information and/or any applicable restrictions, this information may not be shared outside the Electric Reliability Organization (ERO) Enterprise (NERC and the Regional Entities). The WECC Chief Executive Officer (CEO) can approve exceptions allowing for the sharing of this data unless otherwise prohibited. Exceptions approved by the CEO require execution of an NDA by the requester, notice to submitting entities, and consent from any applicable non-U.S. entity, prior to sharing the information.

2.5.1 Compliance

• Control performance data (CPS1 and CPS2 scores) collected under BAL-001

• Disturbance control performance data collected under BAL-002

• Operating reserve data collected under BAL-STD-002/BAL-002-WECC

• Frequency response data provided to NERC under BAL-003

• Transmission vegetation outage data collected under FAC-003


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• Automatic voltage regulator data collected under VAR-002-WECC

• Power system stabilizer operating status data collected under VAR-051-WECC

• Compliance Monitoring and Enforcement Program (CMEP) information and documentation, such as, violation information, Self-Reports, Audit Reports, Notices of Alleged Violation, Settlement Agreements, etc.

2.5.2 General

• Closed session presentations and minutes

2.5.3 Loads and Resources:


i. WECC may make this information public when it has been made public by FERC.

2.5.42.5.3 System Stability Planning

• Transmission planning system performance assessments required to be provided by TPL Reliability Standards

2.6 Other

The following types of information are not treated in accordance with an Information Access Category set forth above and may be shared as specified.

• Proprietary vendor, contractor or consultant information may only be shared as permitted by the applicable request for proposals, contract or agreement.

• WECC reports and white papers will be shared in accordance with the Information Access Category pertaining to the information contained therein.

3 Administration

3.1 Applicable Laws, Agreements, and Policies or Processes

Nothing in this policy shall be read as authorizing the release or restriction of information in a manner contrary to (1) applicable law, such as the NERC Rules of Procedure, the FERC Standards of Conduct and Reliability Standards, (2) applicable agreements, such as the


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NERC/WECC Regional Delegation Agreement and the UWIDSA, or (3) rules in other applicable policies or process documents, such as the WECC Confidentiality Policy.

3.2 Unrestricted Information

Information in any Information Access Category may, at the discretion of WECC, be made publicly available by WECC if it has lawfully been made public by another source or the information was obtained by WECC from the owner of the information without restriction.

3.3 Information from Multiple Sources

Identical data sets received from multiple sources may be treated in accordance with the restrictions that allow the broadest sharing of the data.

3.4 Redacted or Aggregated Information

Information in any Information Access Category may, at the discretion of WECC, be made publicly available by WECC if it has been aggregated and/or redacted to eliminate the confidential or restricted nature of the information.

3.5 Availability of Information Internally

All information addressed herein may, subject to applicable restrictions above, be made available to the following persons for internal WECC purposes:

• WECC staff;

• Contractors doing work for WECC who have executed an NDA; and

• WECC member committees, subcommittees, task forces and working groups who at the discretion of WECC have demonstrated a legitimate need and upon execution of an NDA.

3.6 Availability of Information to NERC, FERC and Other Governmental Entities

WECC may share information in any Information Access Category, including non-U.S. entity data, with NERC, as the Electric Reliability Organization, pursuant to the confidentiality provisions in the NERC/WECC Regional Delegation Agreement approved by FERC, unless otherwise prohibited by applicable law or agreement.

A request from FERC for reliability information with respect to owners, operators, and users of the bulk power system within the United States is authorized by Section 215 of the Federal


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Power Act. Accordingly, WECC may share information in any Information Access Category from such entities with FERC.

When providing non-public information to FERC or other governmental authorities or entities, WECC will preserve any mark of confidentiality, inform the governmental authority or entity that the information is non-public, and consider the need for notice to submitting entities. WECC will also take precautions to protect the information from disclosure under applicable freedom of information or sunshine laws. Such precautions may include terms in an agreement and/or asserting exemptions to disclosure under applicable laws.

3.7 Legitimate Need

Persons in the Electric Line of Business, as defined in the WECC Bylaws, and persons doing work set forth in writing for such persons, may, at the discretion of WECC, be presumed as having a legitimate need for non-public information, subject to applicable restrictions above.

Other persons will be determined to have a legitimate need for information if their need for the information relates to: (i) directly maintaining and improving the operational performance and reliability of the Bulk Power System or reducing Bulk Power System operating costs; (ii) analysis for better theoretical or actual understanding of the operation and reliability of the Bulk Power System; or (iii) development of new technologies and applications to directly support the safe, reliable, and efficient operation of the Bulk Power System.

3.8 Requests for Information

Public Information will generally be posted on the WECC website. Requests for Public Information not posted on the WECC website may be submitted to [email protected].

Requests for Confidential Information and Market Sensitive Information shall describe the requester’s legitimate need for the information and shall be sent to [email protected]. Persons whose requests are approved and who have executed an NDA shall be given access to the requested information, which may include a login and password to restricted portions of the WECC website which may contain similarly restricted information.

In responding to requests for non-public information, WECC will consider providing the least amount of non-public information needed, whether aggregated and/or redacted information should be provided in lieu of non-public information, and/or whether information can simply be shown, rather than transferred, to the requester.

Requests for UDSA Covered Data shall be sent and processed in accordance with Peak Reliability processes.


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mailto:[email protected]



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3.9 Protection of Information

Any person provided access to information under this policy shall take all reasonable precautions to preserve and protect the information from unauthorized disclosure.

3.10 Information Not Addressed

WECC may treat other types of information not specifically addressed herein pursuant to an Information Access Category listed above or in another manner as appropriate at the discretion of WECC.

Persons seeking to have information not listed herein included in and treated pursuant to an Information Access Category may submit a request to WECC at [email protected]. WECC may ask the requester to provide information justifying the request.

3.11 ClassificationCategorization Changes

WECC staff may categorize or change the categorization of information without Board approval. Prior to classifying,categorizing or changing the classificationcategorization of, any information, WECC shall (1) post the proposed classificationcategorization on the WECC website including reasons and rationale for the change, (2) notify submitting entities, the Governance Committee, and the WECC Member Advisory Committee, and all Standing Committees, and (3) provide an opportunity for comments. Posting and notification shall be done at least twenty-one (21) days prior to Board approval of the classificationthe change becoming effective. WECC may begin to treat information in accordance with the proposed classification prior to and during this outreach and pending Board consideration. WECC will treat as confidential any public information it proposes for recategorization as confidential during this outreach and any appeal.

4 Dispute Resolution

A person whose request for information under this policy is denied in whole or part may appeal that determinationDisputes regarding denied requests for information or the categorization of information may be appealed in writing to the WECC CEO within 30 days of the determination. The appeal will follow a process similar to the process described in Section 1503.5 of the NERC Rules of Procedure. The outcome of this appeal may be appealed in writing to the WECC Board of Directors within 30 days.

5 Approval


Board of Directors


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1 Introduction ....................................................................................................................................................3

1.1 Notice ........................................................................................................................................................3

1.2 Document Owner ....................................................................................................................................3

1.3 Scope ..........................................................................................................................................................3

1.4 Review Cycle ............................................................................................................................................3

2 Policy ................................................................................................................................................................3

2.1 Public Information ...................................................................................................................................3

2.2 Confidential Information ........................................................................................................................5

2.3 Market Sensitive Information ................................................................................................................6

2.4 Western Interconnection Data Sharing Agreement (WIDSA) ...........................................................6

2.5 Information Not Shared ..........................................................................................................................6

2.6 Other ..........................................................................................................................................................7

3 Administration ...............................................................................................................................................8

3.1 Applicable Laws, Agreements, and Policies or Processes .................................................................8

3.2 Unrestricted Information ........................................................................................................................8

3.3 Information from Multiple Sources ......................................................................................................8

3.4 Redacted or Aggregated Information ...................................................................................................8

3.5 Availability of Information Internally ..................................................................................................8

3.6 Availability of Information to NERC, FERC and Other Governmental Entities ............................9

3.7 Legitimate Need.......................................................................................................................................9

3.8 Requests for Information ........................................................................................................................9

3.9 Protection of Information .....................................................................................................................10

3.10 Information Not Addressed .................................................................................................................10

3.11 Categorization Changes ........................................................................................................................10

4 Dispute Resolution ......................................................................................................................................10

5 Approval ........................................................................................................................................................11


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1 Introduction

The purpose of this policy is to set forth Western Electricity Coordinating Council (WECC) policies for the sharing of certain data, reports, maps, or other types of information. This policy:

• Provides direction to WECC staff regarding the sharing of information; • Describes whether and how persons can obtain access to specific types of information; and • Makes clear to those who provide information to WECC the conditions under which the

information is made available to others.

1.1 Notice

This policy constitutes WECC’s notice to submitting entities under Section 1503.3 of the North American Electric Reliability Corporation (NERC) Rules of Procedure that WECC intends to share Confidential Information as set forth in this policy. This policy also constitutes WECC’s notice to submitting entities under Section 1505 of the NERC Rules of Procedure that WECC may share information with the Federal Energy Regulatory Commission (FERC) in accordance with the terms herein.

1.2 Document Owner

The owner of this document is the WECC General Counsel.

1.3 Scope

This policy applies to employees, the Board of Directors, and Members.

Nothing in this policy is intended to apply to or restrict how WECC Members or other submitting entities receive their own information or share their own information directly with others.

1.4 Review Cycle


2 Policy

This policy categorizes information into the following different Information Access Categories which set forth how information may be shared.

2.1 Public Information

The following types of information are not restricted and may be made publicly available.


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2.1.1 General

• Charters, meeting agendas, open meeting materials and minutes

• Reliability Standards, Regional Criteria, Policies, and Guidelines


• Existing generation list

• Planned generation list

• Projected and actual demand reduction data




• Actual year peak-hour generation outages

• Actual historic hourly wind, solar and hydro generation (aggregated at the BA or BA area level)


• Transfer Capability


• Major WECC Remedial Action Schemes (RAS) table

• Event analysis lessons learned (including brief event background)


• Major WECC Transfer Paths table

• Principal transmission and planned facilities maps


• Latitude, longitude, line and two-dimensional data




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• Production Cost Models and data not integrated with power flow, detailed transmission topology or other restricted information

• Long term planning tool data (not otherwise restricted by Section 2.6).

• Path descriptions, planned ratings, system conditions, allocation and interactions with other transfer paths from the WECC Path Rating Catalog

2.2 Confidential Information

The following types of information will be treated as Confidential Information under Section 1500 of the NERC Rules of Procedure and may only be shared with persons who (1) at the discretion of WECC have demonstrated a legitimate need, and (2) have executed a non-disclosure agreement (NDA).


• Transmission and generation protection system misoperations reports (Critical Energy Infrastructure Information or CEII)

• Event analysis reports and brief reports (CEII)

• Resolved and unresolved disturbance logs (CEII)

• RAS database and RAS database summaries (Operating Procedures) (CEII)


• Base-case data (power flow and dynamics data) including Geomagnetic Induced Current (GIC) and Remedial Action Scheme (RAS) models (CEII)

• Under-Frequency Load Shedding (UFLS) data required to be provided by PRC Reliability Standards and Regional Criteria (CEII)

• Under-Voltage Load Shedding (UVLS) data required to be provided by PRC Reliability Standards (CEII)

• Comprehensive progress reports provided pursuant to the WECC Path Rating Process (CEII)

• WECC Path Rating Catalog (CEII)

• Generator model data validation test reports (CEII)


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• Short circuit models (CEII)

i. These models will only be shared with NERC Registered Entities and non-U.S. entities in the Western Interconnection who perform similar functions.


• Complete Production Cost Model cases that include power flow, detailed system topology or other restricted information (CEII)

2.3 Market Sensitive Information

The following types of information will be treated as Confidential Business and Market Information under Section 1500 of the NERC Rules of Procedure and may only be shared with persons who (1) are not (a) Market Function Employees as defined by FERC, nor (b) actively and personally engaged in day-to-day sales of electric power or other marketing functions, (2) at the discretion of WECC, have demonstrated a legitimate need, and (3) have executed an NDA.





2.4 Western Interconnection Data Sharing Agreement (WIDSA)

Notwithstanding anything to the contrary contained in this policy, information WECC receives that is subject to the Western Interconnection Data Sharing Agreement (WIDSA) may only be shared in accordance with the terms therein.

2.5 Information Not Shared

Due to the nature of the following types of information and/or any applicable restrictions, this information may not be shared outside the Electric Reliability Organization (ERO) Enterprise (NERC and the Regional Entities). The WECC Chief Executive Officer (CEO) can approve exceptions allowing for the sharing of this data unless otherwise prohibited. Exceptions approved by the CEO require execution of an NDA by the requester, notice to submitting entities, and consent from any applicable non-U.S. entity, prior to sharing the information.

2.5.1 Compliance


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• Control performance data (CPS1 and CPS2 scores) collected under BAL-001

• Disturbance control performance data collected under BAL-002

• Operating reserve data collected under BAL-STD-002/BAL-002-WECC

• Frequency response data provided to NERC under BAL-003

• Transmission vegetation outage data collected under FAC-003

• Automatic voltage regulator data collected under VAR-002-WECC

• Power system stabilizer operating status data collected under VAR-051-WECC

• Compliance Monitoring and Enforcement Program (CMEP) information and documentation, such as, violation information, Self-Reports, Audit Reports, Notices of Alleged Violation, Settlement Agreements, etc.

2.5.2 General

• Closed session presentations and minutes


• Transmission planning system performance assessments required to be provided by TPL Reliability Standards

2.6 Other

The following types of information are not treated in accordance with an Information Access Category set forth above and may be shared as specified.

• Proprietary vendor, contractor or consultant information may only be shared as permitted by the applicable request for proposals, contract or agreement.

• WECC reports and white papers will be shared in accordance with the Information Access Category pertaining to the information contained therein.


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3 Administration

3.1 Applicable Laws, Agreements, and Policies or Processes

Nothing in this policy shall be read as authorizing the release or restriction of information in a manner contrary to (1) applicable law, such as the NERC Rules of Procedure, the FERC Standards of Conduct and Reliability Standards, (2) applicable agreements, such as the NERC/WECC Regional Delegation Agreement and the WIDSA, or (3) rules in other applicable policies or process documents, such as the WECC Confidentiality Policy.

3.2 Unrestricted Information

Information in any Information Access Category may, at the discretion of WECC, be made publicly available by WECC if it has lawfully been made public by another source or the information was obtained by WECC from the owner of the information without restriction.

3.3 Information from Multiple Sources

Identical data sets received from multiple sources may be treated in accordance with the restrictions that allow the broadest sharing of the data.

3.4 Redacted or Aggregated Information

Information in any Information Access Category may, at the discretion of WECC, be made publicly available by WECC if it has been aggregated and/or redacted to eliminate the confidential or restricted nature of the information.

3.5 Availability of Information Internally

All information addressed herein may, subject to applicable restrictions above, be made available to the following persons for internal WECC purposes:

• WECC staff;

• Contractors doing work for WECC who have executed an NDA; and

• WECC member committees, subcommittees, task forces and working groups who at the discretion of WECC have demonstrated a legitimate need and upon execution of an NDA.


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3.6 Availability of Information to NERC, FERC and Other Governmental Entities

WECC may share information in any Information Access Category, including non-U.S. entity data, with NERC, as the Electric Reliability Organization, pursuant to the confidentiality provisions in the NERC/WECC Regional Delegation Agreement approved by FERC, unless otherwise prohibited by applicable law or agreement.

A request from FERC for reliability information with respect to owners, operators, and users of the bulk power system within the United States is authorized by Section 215 of the Federal Power Act. Accordingly, WECC may share information in any Information Access Category from such entities with FERC.

When providing non-public information to FERC or other governmental authorities or entities, WECC will preserve any mark of confidentiality, inform the governmental authority or entity that the information is non-public, and consider the need for notice to submitting entities. WECC will also take precautions to protect the information from disclosure under applicable freedom of information or sunshine laws. Such precautions may include terms in an agreement and/or asserting exemptions to disclosure under applicable laws.

3.7 Legitimate Need

Persons in the Electric Line of Business, as defined in the WECC Bylaws, and persons doing work set forth in writing for such persons, may, at the discretion of WECC, be presumed as having a legitimate need for non-public information, subject to applicable restrictions above.

Other persons will be determined to have a legitimate need for information if their need for the information relates to: (i) directly maintaining and improving the operational performance and reliability of the Bulk Power System or reducing Bulk Power System operating costs; (ii) analysis for better theoretical or actual understanding of the operation and reliability of the Bulk Power System; or (iii) development of new technologies and applications to directly support the safe, reliable, and efficient operation of the Bulk Power System.

3.8 Requests for Information

Public Information will generally be posted on the WECC website. Requests for Public Information not posted on the WECC website may be submitted to [email protected].

Requests for Confidential Information and Market Sensitive Information shall describe the requester’s legitimate need for the information and shall be sent to [email protected]. Persons whose requests are approved and who have executed an NDA shall be given access to


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the requested information, which may include a login and password to restricted portions of the WECC website which may contain similarly restricted information.

In responding to requests for non-public information, WECC will consider providing the least amount of non-public information needed, whether aggregated and/or redacted information should be provided in lieu of non-public information, and/or whether information can simply be shown, rather than transferred, to the requester.

3.9 Protection of Information

Any person provided access to information under this policy shall take all reasonable precautions to preserve and protect the information from unauthorized disclosure.

3.10 Information Not Addressed

WECC may treat other types of information not specifically addressed herein pursuant to an Information Access Category listed above or in another manner as appropriate at the discretion of WECC.

Persons seeking to have information not listed herein included in and treated pursuant to an Information Access Category may submit a request to WECC at [email protected]. WECC may ask the requester to provide information justifying the request.

3.11 Categorization Changes

WECC staff may categorize or change the categorization of information without Board approval. Prior to categorizing or changing the categorization of any information, WECC shall (1) post the proposed categorization on the WECC website including reasons and rationale for the change, (2) notify submitting entities, the Governance Committee, the Member Advisory Committee, and all Standing Committees, and (3) provide an opportunity for comments. Posting and notification shall be done at least twenty-one (21) days prior to the change becoming effective. WECC will treat as confidential any public information it proposes for recategorization as confidential during this outreach and any appeal.


Disputes regarding denied requests for information or the categorization of information may be appealed in writing to the WECC CEO within 30 days of the determination. The appeal will follow a process similar to the process described in Section 1503.5 of the NERC Rules of Procedure. The outcome of this appeal may be appealed in writing to the WECC Board of Directors within 30 days.


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5 Approval

Approval Date

Board of Directors


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WECC Information Reporting Policy

December 7, 2016


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1 Introduction ....................................................................................................................................................3

1.1 Governing Authority ..............................................................................................................................3

1.2 Document Owner ....................................................................................................................................3

1.3 Scope ..........................................................................................................................................................3

1.4 Review Cycle ............................................................................................................................................3

2 Determining Information Reporting Requirements ...............................................................................3

3 Petition for Relief...........................................................................................................................................4

4 Protection and Sharing .................................................................................................................................6

5 Dispute Resolution ........................................................................................................................................6

6 Approval ..........................................................................................................................................................7


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1 Introduction

The purpose of this policy is to establish procedures associated with WECC Board of Director (“Board”) requests for information; submission of that information by WECC Members (“Members”); avoidance of undue burden on Members; and the treatment of the requested information.

1.1 Governing Authority

WECC Bylaws (“Bylaws”) Section 4.6.11 provides that, except as otherwise provided in the Bylaws or other applicable authority, Members have an obligation “to provide system data that the Board has determined is necessary for WECC functions and does not impose an undue burden on the Members; provided, however, that the Board shall adopt appropriate limitations on this obligation or procedures that protect, and avoid the unnecessary collection of, confidential, privileged, trade secret or critical energy infrastructure information or other information that the Board determines merits such protection consistent with applicable law.”

1.2 Document Owner

The document owner is the WECC General Counsel. The document owner, or designee, is responsible for:

• Reviewing the policy within the review cycle

• Making any needed revisions to the policy

• Obtaining Board approval of any revisions

• Ensuring the policy is appropriately distributed, posted and communicated

1.3 Scope

This policy applies to WECC employees and contractors, the WECC Board of Directors, and WECC Members.

1.4 Review Cycle


2 Determining Information Reporting Requirements

2.1 Exhibit Reporting Requirements

Reporting requirements are contained in Exhibits to this policy (“Exhibits”). Exhibits are developed by a Board Committee or Standing Committee or WECC staff, taking into consideration the burden to Members and making reasonable efforts to avoid imposing obligations under this policy that


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conflict with Members’ existing regulatory or contractual obligations, and shall identify at a minimum: (i) the following:

Tthe information to be supplied to WECC;, and (ii)

Tthe Members required to supply such information;

The proposed Information Access Category from the Information Sharing Policy.

Affected entities shall be provided an opportunity to comment on a proposed Exhibit. When a draft Exhibit is finalized, it will be forwarded to the Board for approval. The Exhibit will become effective only upon approval by the Board. Exhibits will be reviewed and updated by the Board Committee or Standing Committee, or by WECC staff as necessary. Any revisions or retirement will be submitted to the Board for approval.Exhibits will be reviewed and updated by WECC staff as necessary. WECC shall provide applicable Members notice of and an opportunity to comment on all new Exhibits and all revisions to existing Exhibits. Exhibits become effective upon approval by WECC. WECC’s approval of Exhibits may be appealed in accordance with Section 5.

2.2 Other Reporting Requirements

It is possible that WECC may require Members to provide information not set forth in an Exhibit or otherwise required. Such requests will comply with the requirements and limitations set forth in Section 4.6.11 of the Bylaws and, to the extent practicable, this policy. Such requests will as soon as practicable be incorporated into an Exhibit by Board approval.

3 Petition for Relief

3.1 Filing a Petition for Relief

Any Member seeking exemption from or modification of its obligation to provide information under this policy may submit a written Petition for Relief. All Petitions for Relief will be submitted to the Board Committee or Standing Committee responsible for the Exhibit or WECC staff as applicable. Petitions for Relief must be submitted to the WECC CEO within 30 days of the date of the applicable information request, with a copy to the WECC CEO and Chair of the Board. The Petition for Relief must state in detail the grounds for appeal contain a detailed description of the need for relief and specify any relief short of complete waiver that would satisfy the Member’s concerns while at the same time assuring that WECC’s purposes are servedmeeting the needs of WECC.


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3.2 Determination and Appeal Rights

The applicable Board Committee or Standing Committee or WECC staff will issue a written decision explaining why and to what extent the requested relief is granted or denied. This initial decision may be appealed in accordance with Section 5 to the Board within 30 days of being issued.

If a Member files a Petition for Relief under this Section 3, the Member shall be temporarily exempt from its obligation to provide the information subject to such Petition for Relief. Such temporary exemption will expire five (5) business days following final action on the Petition for Relief.

3.3 Presumption

For purposes of determining Petitions for Relief, there will be a presumption that requests for information in an Exhibit are reasonable and consistent with Section 4.6.11 of the Bylaws. The resolution of issues presented in Petitions for Relief will be on a case-by-case basis and will not be considered to establish a precedent for any other or future cases, except to the extent that the policy underlying such resolution is subsequently codified in this policy or another WECC policy.

4 Avoiding Undue Burden on Members

4.1 Avoiding Burdensome Requirements

4.1.1 Board Determination – The Board shall not approve any new or updated Exhibits under Section 2.1 of this policy if the Board determines that compliance with the Exhibit requirements will impose an “undue burden” on the affected Members. Likewise, WECC shall not impose additional information reporting obligations on Members under Section 2.2 of this policy if it determines that compliance will impose an “undue burden” on such Members.

4.1.2 Member Petition – Any Member subject to an obligation to provide information under this policy may, in a Petition for Relief under Section 3.1 above, present evidence in support of its argument that such obligation constitutes an “undue burden.”

4.2 Avoiding Conflict with Existing Regulatory/Contractual Obligations

The Board will make reasonable efforts to avoid imposing obligations under this policy that conflict with Members’ existing regulatory or contractual obligations. However, the existence of such conflict will not automatically exempt a Member from its obligation to provide needed information to WECC. In the event that a Member’s obligation to provide information under


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this policy conflicts with a regulatory or contractual obligation that existed before the date on which the obligation under this policy arose, the Member will, in the first instance, attempt to resolve such conflict through good faith negotiation with the regulatory agency or contracting party. Upon request, WECC will attempt to assist in such negotiation. In the event that such conflict cannot be resolved informally within 30 days, the affected Member may file a Petition for Relief pursuant to Section 3.1. In addition to the information required under Section 3.1, such Petition for Relief must include a copy of the existing rule, regulation, tariff, contract, etc., that allegedly conflicts with the Member’s obligation to provide information to WECC, with the relevant provisions clearly identified. In the event that a Member files a Petition for Relief under this Section 4.2, the Member shall be temporarily exempt from its obligation to provide the information subject to such Petition for Relief. Unless the Board instructs otherwise, such temporary exemption will expire five (5) business days following final Board action on the Petition for Relief.

54 Protection and Sharing

5.1 Protection

Any person provided access to iInformation collected under this policy shall comply at all times withshall be protected and shared by WECC in accordance with the WECC Confidentiality Policy and the WECC Information Sharing Policy.

Sharing

5.2.1 Determination – The determination of the applicable Information Access Category in the Information Sharing Policy will be made initially by the Board Committee or Standing Committee developing an Exhibit or WECC staff. Any determination that information will be treated as non-public shall be accompanied by supporting rationale.

5.2.2 Appeals – Any disputes regarding Information Access Categories will be resolved by the Board Committee or Standing Committee developing an Exhibit or WECC staff, subject to a Member’s right to appeal that determination in writing to the Board within 30 days.

5.2.3 Information Sharing Policy – The Information Sharing Policy shall be revised, if necessary, as soon as practicable thereafter to reflect the decision on the sharing of the information.


Disputes regarding Exhibits and Petitions for Relief may be appealed in writing to the WECC CEO within 30 days of the determination. The appeal will follow a process similar to the process described in Section 1503.5 of the NERC Rules of Procedure. The outcome of this appeal may be appealed in writing to the WECC Board of Directors within 30 days.


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6 Approval

Approving Committee, Entity, or PersonApproval Date

Board of Directors


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Exhibit A – Loads and Resources Data

A. Overview and Background

WECC oversees loads and resources data collection and related activities, including the annual Power Supply Assessment of resource adequacy in the Western Interconnection, and participates in loads and resources activities at NERC. WECC also disseminates loads and resources information to parties throughout the Western Interconnection. Loads and resources data collected by WECC may also be used in other WECC assessments, models and studies.

B. Identification of Data Collected

In accordance with the Information Reporting Policy, WECC Balancing Authorities (BA) are required to provide, and update as necessary, the data listed below:

• Actual year hourly demand data. • Existing generation; • Planned generation; • Projected and actual demand reduction data; • Projected peak demand • Projected energy forecasts • Scheduled peak hour generation outages • Actual year peak hour generation outages; • Actual historic hourly wind, solar and hydro generation (aggregated at the BA or BA-area level) • Transfer Capability • Other data collected in support of the annual WECC Power Supply Assessment, the NERC

Long Term Reliability Assessment, and the NERC Seasonal Assessments.

Data listed as required in this Exhibit will be identified more specifically, including additional generator and path specifications, in the “WECC Data Collection Manual” that is approvedprovided annually by WECC.

In addition, data to support the annual WECC Power Supply Assessment, the NERC Long Term Reliability Assessment, and the NERC Seasonal Assessments, shall also be provided upon request.

C. Sharing of Data Collected

The following information shall be Public Information under the WECC Information Sharing Policy:

Public Information

• Existing generation list; • Planned generation list; • Actual year hourly demand data • Projected and actual demand reduction data; • Projected peak demand (years 4-10)


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• Projected energy forecasts (years 4-10) • Scheduled peak hour generation outages (years 4-10) • Actual year peak hour generation outages; • Actual historic hourly wind, solar and hydro generation (aggregated at the BA or BA-area level) • Transfer Capability

The following information shall be non-public and shall be shared in accordance with the following categories in the WECC Information Sharing Policy:

Market Sensitive Information

• Projected peak demand (years 1-3) • Projected energy forecasts (years 1-3) • Scheduled peak hour generation outages (years 1-3) • Actual historic hourly wind, solar and hydro generation (aggregated at the BA level)

Information Not Shared Externally

• Actual year hourly demand data.


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WECC Information Reporting Policy


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1 Introduction ....................................................................................................................................................3

1.1 Governing Authority ..............................................................................................................................3

1.2 Document Owner ....................................................................................................................................3

1.3 Scope ..........................................................................................................................................................3

1.4 Review Cycle ............................................................................................................................................3

2 Determining Information Reporting Requirements ...............................................................................3

3 Petition for Relief...........................................................................................................................................4

4 Protection and Sharing .................................................................................................................................4

5 Dispute Resolution ........................................................................................................................................4

6 Approval ..........................................................................................................................................................4


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1 Introduction

The purpose of this policy is to establish procedures associated with WECC Board of Director (“Board”) requests for information; submission of that information by WECC Members (“Members”); avoidance of undue burden on Members; and the treatment of the requested information.

1.1 Governing Authority

WECC Bylaws (“Bylaws”) Section 4.6.11 provides that, except as otherwise provided in the Bylaws or other applicable authority, Members have an obligation “to provide system data that the Board has determined is necessary for WECC functions and does not impose an undue burden on the Members; provided, however, that the Board shall adopt appropriate limitations on this obligation or procedures that protect, and avoid the unnecessary collection of, confidential, privileged, trade secret or critical energy infrastructure information or other information that the Board determines merits such protection consistent with applicable law.”

1.2 Document Owner

The document owner is the WECC General Counsel. The document owner, or designee, is responsible for:

• Reviewing the policy within the review cycle

• Making any needed revisions to the policy

• Obtaining Board approval of any revisions

• Ensuring the policy is appropriately distributed, posted and communicated

1.3 Scope

This policy applies to employees, the Board of Directors, and Members.

1.4 Review Cycle


2 Determining Information Reporting Requirements

Reporting requirements are contained in Exhibits to this policy. Exhibits are developed by WECC staff, taking into consideration the burden to Members and making reasonable efforts to avoid imposing obligations under this policy that conflict with Members’ existing regulatory or contractual obligations, and shall identify at a minimum: (i) the information to be supplied to WECC, and (ii) the Members required to supply such information.


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Exhibits will be reviewed and updated by WECC staff as necessary. WECC shall provide applicable Members notice of and an opportunity to comment on all new Exhibits and all revisions to existing Exhibits. Exhibits become effective upon approval by WECC. WECC’s approval of Exhibits may be appealed in accordance with Section 5.

3 Petition for Relief

Any Member seeking exemption from or modification of its obligation to provide information under this policy may submit a written Petition for Relief. Petitions for Relief must be submitted to the WECC CEO within 30 days of the date of the applicable information request. The Petition for Relief must contain a detailed description of the need for relief and specify any relief short of complete waiver that would satisfy the Member’s concerns while at the same time meeting the needs of WECC.

WECC staff will issue a written decision explaining why and to what extent the requested relief is granted or denied. This decision may be appealed in accordance with Section 5.

If a Member files a Petition for Relief under this Section 3, the Member shall be temporarily exempt from its obligation to provide the information subject to such Petition for Relief. Such temporary exemption will expire five (5) business days following final action on the Petition for Relief.

4 Protection and Sharing

Information collected under this policy shall be protected and shared by WECC in accordance with the Confidentiality Policy and the Information Sharing Policy.


Disputes regarding Exhibits and Petitions for Relief may be appealed in writing to the WECC CEO within 30 days of the determination. The appeal will follow a process similar to the process described in Section 1503.5 of the NERC Rules of Procedure. The outcome of this appeal may be appealed in writing to the WECC Board of Directors within 30 days.

6 Approval

Approval Date

Board of Directors


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Exhibit A – Loads and Resources Data

A. Overview and Background

WECC oversees loads and resources data collection and related activities, including the annual Power Supply Assessment of resource adequacy in the Western Interconnection, and participates in loads and resources activities at NERC. WECC also disseminates loads and resources information to parties throughout the Western Interconnection. Loads and resources data collected by WECC may also be used in other WECC assessments, models and studies.

B. Identification of Data Collected

In accordance with the Information Reporting Policy, WECC Balancing Authorities (BA) are required to provide, and update as necessary, the data listed below:

• Actual year hourly demand data. • Existing generation; • Planned generation; • Projected and actual demand reduction data; • Projected peak demand • Projected energy forecasts • Scheduled peak hour generation outages • Actual year peak hour generation outages; • Actual historic hourly wind, solar and hydro generation (aggregated at the BA or BA area level) • Transfer Capability

Data listed as required in this Exhibit will be identified more specifically, including additional generator and path specifications, in the “WECC Data Collection Manual” that is provided annually by WECC.

C. Sharing of Data Collected

The following information shall be Public Information under the WECC Information Sharing Policy:

Public Information

• Existing generation list; • Planned generation list; • Actual year hourly demand data • Projected and actual demand reduction data; • Projected peak demand (years 4-10) • Projected energy forecasts (years 4-10) • Scheduled peak hour generation outages (years 4-10) • Actual year peak hour generation outages; • Actual historic hourly wind, solar and hydro generation (aggregated at the BA or BA area level) • Transfer Capability


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The following information shall be non-public and shall be shared in accordance with the following categories in the WECC Information Sharing Policy:

Market Sensitive Information

• Projected peak demand (years 1-3) • Projected energy forecasts (years 1-3) • Scheduled peak hour generation outages (years 1-3)


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Board Member Continuing Education


June 2020

155 North 400 West | Suite 200 | Salt Lake City, Utah 84103www.wecc.org

Please Note: this white paper only covers skill and team development of the Board as a whole.

1. WECC Board Training

Provide Board annual training for Board members that meets some of the following criteria:

∑ Routine∑ Covers changes to Board composition or committees∑ Best practices∑ Defined by Board members∑ Individualized when necessary

2. Issue Statement

Board members and senior WECC executives want to continue the training and development of the Board’s skills, awareness, and effectiveness. Defined by the individual Board members, feedback obtained from Board members and feedback provided by the Member Advisory Committee (MAC).

3. Problem Statement

We have not defined a process where Board members and senior executive staff have an organized approach to define training.

4. Objective/Purpose of Whitepaper

Develop a schedule and activities to define training.

5. Background

We have an experienced Board with backgrounds that cover essential functions of a well operating Board. We continue to monitor industry and Board practices that are used to define our practices. We have sustained feedback to the Board from Board members, membership, and continue to collect best practices from industry.

GC Meeting Book - Director Education

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Board Member Continuing Education

2

6. Analysis

Annual feedback is provided by the Board members and the MAC. The Board has had continuing education including new member orientation, self-assessment, training sessions, and continued improvement plan for the Board as a whole. The Board did join NACD and was quickly overwhelmed with information and publications which did not appear to meet the collective goals of the Board members. Finally, Board training continues to be routinely brought up by Board members seeking an organized plan.

7. Discussion/Options

∑ We could continue status quo. ∑ We could adopt a framework for training schedule with milestones. ∑ Training could be left on an individual basis.∑ Schools and classes are available through several associations and colleges.∑ Utilize a local Salt Lake consultant to advise and educate the Board.

8. Other Groups Impacted

Impacted groups are the Board, senior executives, MAC, Board members, and the WECC Human Resources Department.

9. Conclusions/Recommendations

Recommend we have one of the Board members take responsibility role for determining training content for the Board as a group. Individual training would continue to be the responsibility of individual Board members.

10. Next Steps

The following steps would be initiated this year with the goal of having defined a training plan:

∑ Assign a Board member to collect training ideas and query Board members, senior executives, WECC Human Resources and MAC Chair.

∑ Develop an interview and training ideas “form” to determine training ideas.∑ Complete the Board self-assessment and MAC Board assessment for 2020.∑ Present assessment results in December.∑ Assess training ideas by the lead Board member in January of each year.∑ Board develops a schedule and content for the year in March of each year.

GC Meeting Book - Director Education

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Attachment 1: Responsibility and Accountability Matrix I

GOVERNANCE Stakeholders Member Rep MACStanding

CommitteeJGC VP CEO

Board Committee

Board

Amend Bylaws C A C C R R

Strategy I I C C C R R A

Corporate & Officer Goals

C R R R (HRCC) A

IdentifyingIRAM Priorities

C C C C C R A C

Operating Plan I I C C C R A I

BP&B C C C C C R R R (FAC) A

Corporate Policy R A I

Director Election A R (NC)

Director Compensation A R (NC)

Board Effectiveness (MAC)

A I

Board Effectiveness (Board)

R (GC) A

Board Policy C C R C R R A

CEO Compensation C R (HRCC) A

Officer Compensation R R (HRCC) A

Develop Guidelines & Technical Papers

C C I R I C A I

Monitor Reliability/Operations/Security Practices

C C I R I R A I

GC Meeting Book - Responsibility and Accountability Matrix

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Attachment 1: Responsibility and Accountability Matrix II

GOVERNANCE Stakeholders Member Rep MACStanding

CommitteeJGC VP CEO

Board Committee

Board

Monitor Market/Commercial Practices

C C I R I R A I

Evaluate Generation/Load Balance

C C I R I R A I

Evaluate Adequacy of BES Infrastructure

C C I R I R A I

Monitor Performance to Op Plan and Strategy

C RA

I(FAC)

(HRCC)I

Resource Allocation R A

Day-to-Day Operations

R A

Standards Development C R R (WSC) A

Regional Criteria C R R (WSC) A

Special Reliability Assessments

C C C R A C

Training C R A

Risk Assessment-CMEP & RPPA

I I I C R A I


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Attachment 1: Responsibility and Accountability Matrix III

Stakeholders – Individuals and entities that have an interest in the business of WECC, but do not belong to one of the other participant categories (e.g., not a Member, MAC representative, Standing Committee representative). This group includes statutorily recognized bodies such as the Western Interconnection Regional Advisory Board (WIRAB), as well as members of the public who may desire to respond to public postings.

Member Representative (Member Rep) – The authorized, designated representative of each WECC Member. The Member Rep, or designated Alternate or Proxy, is the only person authorized to cast the Member’s vote with respect to Bylaws amendments, and Director and MAC Representative elections. Consultation and information activities are performed via public postings and emails to the Member Representative.

Member Advisory Committee (MAC) – As described in the WECC Bylaws, the MAC is responsible for providing policy advice to the WECC Board of Directors. The MAC executes its responsibilities/accountabilities through the formal, collective action of its Member Representatives in accordance with the WECC Bylaws. In providing policy advice to the Board, the MAC represents the views of the WECC Membership as a whole.

Standing Committee – Collectively, this refers to the three traditional, technical standing committees—the Operating Committee (OC), Planning Coordination Committee (PCC), and Market Interface Committee—and the WECC Standards Committee, as defined in the WECC Bylaws. Standing Committee responsibility/accountability for each listed activity is determined by the nature of theactivity with reference to each committee’s charter. Where the committee is responsible, appropriate action should be taken by the committee as a whole. For those activities for which a committee is consulted, communication will typically occur through thecommittee chair who is then responsible for appropriate dissemination of information. For instance, the OC may have no formal role in approval of a Board policy not related to the OC’s chartered responsibilities, but the Board Policy process recognizes a consultative role for the OC, so staff would communicate proposed revisions to the OC Chair for further dissemination and, as appropriate, the communication back to staff of OC member feedback.

Joint Guidance Committee (JGC) – A chartered committee created by the Board of Directors and charged, generally, with advising management and the Board in the development of corporate strategy and reviewing proposed Standing Committee work plans to ensure alignment with that strategy.


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Attachment 1: Responsibility and Accountability Matrix IV

Vice President (VP) – The Vice Presidents of WECC, as appointed by the WECC Board of Directors. The relevant VP for each activity listed is determined by the nature of the activity, as determined by the CEO. Alternatively, VP responsibility/accountability may refer collectively to all WECC VPs as members of the WECC executive management team.

Chief Executive Officer (CEO) – The WECC CEO, as appointed by the WECC Board of Directors.

Board Committee – A committee so identified in the WECC Bylaws or created and chartered by the WECC Board of Directors for a specified purpose.

Board of Directors (Board) – The WECC Board, taking formal action as a body in accordance with the WECC Bylaws.

A = ACCOUNTABLE/APPROVER

“The Buck Stops Here”

The accountable person is the individual who is ultimately answerable for the activity or decision. This includes “yes” or “no” authority and veto power. Only one “A” can be assigned to an action.

R = RESPONSIBLE/RECOMMEND

“The Doer”

The “doer” is the individual(s) who actually completes the task. The “doer” is responsible for action/implementation. Responsibility can be shared. The degree of responsibility is determined by the individual with the “A.”

C = CONSULT

“In the Loop”

The consult role is the individual(s) (typically subject matter experts) to be consulted prior to a final decision or action. This is a predetermined need for two-way communication. Consultation can be direct or by more widespread means such as public posting for comment. For example, consultation may be made with the OC Chair or with the entire OC membership, depending on the issue.Consultation implies “I’ll be informed and I’ll be heard.” Consultation does not imply control.

I = INFORM

“Keep in the Picture”


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Attachment 1: Responsibility and Accountability Matrix V

This is the individual(s) who needs to be informed after a decision or action is taken. They may be required to take action as a result of the outcome. It is a one-way communication.

Process Examples

1. Amend Bylaws—The WECC Bylaws vest the membership with ultimate authority for Bylaws amendments, either by requiring member approval in the first instance or by permitting Members to overturn a Board decision to amend the Bylaws. The amendment process will typically begin with a staff, Member, or Director request to amend. Staff, on behalf of the CEO, will draft the requested amendment and provide it to the MAC for consideration and comment. Staff will also provide the amendment to the Standing Committee chairs for dissemination or committee action, as they deem appropriate. Depending on the nature of the amendment, other stakeholder input may also be sought. In accordance with the Bylaws, the amendment will be posted in advance of Board and member approval.

2. Strategy—The Board is accountable for ensuring a reasonable strategy is developed and executed to achieve WECC’s reliability mission. The CEO and executive team develop this strategy in consultation with the MAC and Standing Committees who review and provide comment.

3. Corporate and Officer Goals—These goals are established by the CEO, working with the executive team and staff as appropriate, and approved by the Board on the recommendation of the Human Resources and Compensation Committee (HRCC). The CEO briefs the MAC regarding the draft corporate goals and incorporates MAC feedback prior to presenting them to the HRCC.

4. Director Compensation—The process for determining and setting Director compensation levels is described in WECC Bylaws section 6.4.5. The Bylaws make clear that the MAC is ultimately accountable for approving compensation levels for the coming year, based on the recommendation received from the Nominating Committee (NC). What is less clear is what role, if any, the broader Membership has in this process. The Bylaws provide the MAC a 30-day window to consider the NC recommendation and make an approval decision. What should the MAC do during this 30-day period? Actually, as with most things it does, the MAC is free to do whatever it wants during this time. What is absolutely clear is that the MAC is not required to do anything—MAC members can consult with their respective classes if they choose, but they do not have to; the MAC can post its proposed action for public comment, but it does not have to. Precisely what the MAC chooses to do may depend on the action the NC recommends—a recommendation for no change to current compensation levels may call for


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Attachment 1: Responsibility and Accountability Matrix VI

less member input than would a recommendation to dramatically overhaul the compensation structure or increase the compensation amount. Again, this would be a decision for the MAC alone to make since it need not consult or seek input from any stakeholders once it has received the NC’s recommendation.

5. Board Policy—A Board policy is any policy requiring Board approval. A Board policy may apply broadly to every individual/entity engaged in a WECC activity or process, or it may apply more discretely to, for example, WECC members or WECC staff. A proposed policy or revision to current policy may be proposed by any interested stakeholder listed in the tableabove. In accordance with that table, staff (under the direction of the CEO) is responsible for formatting, reviewing, and circulating the draft policy prior to presentation for Board approval. Staff would distribute the policy to the MAC, StandingCommittee chairs, membership, stakeholders, and applicable Board committee for review and comment. The Board committee responsible for the policy area in question, if any, will participate in the development of the policy and provide a recommendation to the Board. The MAC is responsible to review the final draft and comment/recommend to the Board asappropriate. The CEO will also provide a recommendation to the Board. If a Board committee is involved, that committee will present the policy for Board approval; if no Board committee is involved, staff will present the policy to the Board.

6. Monitor Reliability/Operations/Security Practices1—These activities relate broadly to the reliability of the Bulk Electric System such that they are a WECC Regional Entity responsibility for which the CEO is ultimately accountable. While the CEO isaccountable for outcomes that support WECC’s reliability mission, in practice, the CEO is not directly involved in these activities; instead, the CEO ensures through staff engagement at the committee level that the activities and recommendations of the technical Standing Committees appropriately represent and assist WECC in the achievement of its reliability goals. The monitoring activities are the joint responsibility of the WECC executive management team (specifically, the VP of Reliability Planning and Performance Analysis) and the Standing Committees. In addition to “day-to-day” work conducted by staff and the Standing Committee members, stakeholders and Members may be consulted with respect to specific issues, analyses and reports, with the MAC and Board being informed through staff or Standing Committee reporting as necessary.

1 This process description also applies to activities from the table above: Monitor Market/Commercial Practices, Evaluate Generation/Load Balance, and Evaluate Adequacy of BES Infrastructure.


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