Common use of Exhibit C: MRO Reliability Standards Development Clause in Contracts

Exhibit C: MRO Reliability Standards Development. 277. Exhibit C to the MRO Delegation Agreement consists of narrative responses addressing each of NERC’s 34 pro forma Common Attributes addressed above.157 In 155 See 18 C.F.R. §§ 39.1 and 39.10 (2006). See also Order No. 672, FERC Stats. & Regs. ¶ 31,204 at P 113. 156 116 FERC ¶ 61,062 at P 90. 157 See supra section IV(A). addition, NERC and MRO rely on an MRO draft manual, “The Midwest Reliability Organization Regional Reliability Standards Process Manual,” version 3.0 (MRO Standards Development Manual).158 The MRO Standards Development Manual is included in NERC’s filing as supplemental information and is cross-referenced in the narrative responses addressing NERC’s 34 pro forma Common Attributes. 278. NERC, in its transmittal letter, states that the MRO Standards Development Manual is consistent with the requirements set forth in NERC’s 34 pro forma Common Attributes. Specifically, NERC states that it has not identified any substantive differences between the MRO Standards Development Manual and NERC’s 34 Common Attributes. XXXX adds that it has worked closely with each of the Regional Entity candidates, including MRO, to attain a high level of consistency among the proposed Regional Entity standards development procedures. NERC further states that each reliability standard that will be proposed to NERC by MRO will have the same format as a NERC reliability standard, will contain the same elements as a NERC reliability standard, and will have been developed through a process meeting the common procedural elements. 279. The MRO Standards Development Manual also addresses voting procedures applicable to the adoption of a proposed reliability standard.159 Specifically, the MRO Standards Development Manual provides for the establishment of a registered ballot body comprised of all organizations and entities that: (i) qualify for one of seven designated voting segments;160 (ii) are registered with MRO as ballot participants in the voting on standards; and (iii) are current with any MRO designated fees associated with the Standards Development Process.161 The MRO Standards Development Manual states 158 The MRO Standards Development Manual has not been approved by the MRO board. 159 See MRO Standards Development Manual at app. C (registered ballot body registration procedures) and app. D. (balloting examples). 160 The segments are: (i) transmission owners; (ii) RTOs, regional transmission group, ISOs, reliability organizations, and reliability coordinators; (iii) load-serving entities; (iv) electric generators; (v) electricity brokers, aggregators, and marketers;