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WECC COMPLIANCE 101 Webinar. Thursday, October 17, 2013 2:00 pm MDT. Agenda. Introductions L. Scholl Overview of WECC and Regulatory Structure C. White Audit – What to Expect P. O’Donnell and C. Bakk Enforcement R. Ferrin, B. Christensen, E. Brereton

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wecc compliance 101 webinar


Thursday, October 17, 2013

2:00 pm MDT

  • Introductions L. Scholl
  • Overview of WECC and Regulatory Structure C. White
  • Audit – What to Expect P. O’Donnell and C. Bakk
  • Enforcement R. Ferrin, B. Christensen, E. Brereton

- Self-Disclosed Violations

- Mitigation Plans

- Case Processing

  • webCDMS Overview M. Dalebout, T. Allred, K. Israelsson


Module One

wecc profile
WECC Profile

The Western Electricity Coordinating Council (WECC) is a non-profit corporation that exists to assure a reliable bulk electric system in the geographic area of the Western Interconnection. This area includes all or parts of the 14 western United States, two Canadian provinces, and the northern portion of Baja California, Mexico.

wecc history
WECC History
  • Incorporated in 2002
  • Predecessor, WSCC formed in 1967
  • Largest geographic area of the eight Regional Entities
    • Entire Western Interconnection (1.8 million square miles) - includes all or part of 14 U.S. states, 2 Canadian provinces and a portion of Baja California Norte, Mexico
  • Non-Governmental
  • Industry participants join together to promote system reliability
  • Member-driven (401 members divided into 7 membership classes)
wecc coverage service area
WECC Coverage Service Area

1.8 million square miles

126,285 miles of transmission

Population of 78 million

wecc organization
WECC Organization
  • Members
    • 401
      • Grid owners, operators, users
      • Stakeholders
      • State and Provincial
  • Board of Directors
    • 32 members
    • Committees
      • Board
      • Member
wecc services
WECC Services
  • Reliability coordination
    • Operate two Reliability Coordination Offices (Vancouver Wa. and Loveland Co.) that provide situational awareness and real-time supervision of the entire Western Interconnection
wecc services1
  • Transmission expansion planning
    • Management of a comprehensive planning database
    • Provide coordination of sub-regional planning processes
    • Analyses and modeling
  • Studies
    • Model the system and perform studies under a variety of scenarios to set operating policies and limits
  • Market-operations interface
    • Ensure that competitive power markets do not negatively impact reliability
wecc services2
WECC Services
  • Loads and Resources Assessments
    • Perform annual assessment of 10-year loads and resources
    • Maintain 10-year coordinated plan of system growth
    • Provide information to NERC for summer and winter assessments of the reliability and adequacy of the bulk-power system
  • Operator training
    • Provide training sessions for operators, schedulers and dispatchers
    • Hosts the Western Renewable Energy Generation Information System, which creates and tracks renewable energy certificates
wecc services3
WECC Services
  • Delegation Agreement
    • Perform functions delegated to WECC as a Regional Entity under Delegation Agreement with NERC, including regulating entities subject to mandatory Reliability Standards
mandatory reliability regulation
Mandatory Reliability Regulation
  • Northeast Blackout of 2003
    • 10 Million people in Ontario, Canada
    • 45 million people in eight U.S. states
task force report
Task Force Report
  • Final report of the U.S.-Canada Power System Outage Task Force on the 2003 blackout concluded:

the single most important recommendation for preventing future blackouts, and reducing the scope of those that occur, is for the U.S. government to make reliability standards mandatory and enforceable.

congressional action
Congressional Action
  • Energy Policy Act of 2005
  • On August 8, 2005, the Energy Policy Act of 2005 (EPAct 2005) was signed into law.
  • “Section 215”
  • Section 215 of the EPAct 2005 directed FERC to certify an Electric Reliability Organization (ERO) and develop procedures for establishing, approving and enforcing electric reliability standards.
authority for compliance monitoring
Authority for Compliance Monitoring

●FERC Order 672 (Implementing Rule 18 CFR 39)

  • Responsibility and oversight assigned to FERC
  • FERC designated NERC as Electric Reliability Organization
  • NERC has delegation agreement with WECC and seven other regions
order 693 order 706 standards
Order 693 & Order 706 Standards
  • Order 693 (Operations and Planning) includes:
    • Resource and Demand Balancing (BAL)
    • Emergency Preparedness & Operations (EOP)
    • Facilities Design, Connection & Mtnce. (FAC)
    • Protection and Control (PRC)
  • Order 706 (CIP) includes:
    • Critical Cyber Asset Identification
    • Personnel & Training
    • Electronic Security Perimeters
wecc compliance
WECC Compliance
  • Registers Entities
    • Register users, owners, operators according to function
  • Monitors Compliancewith Standards
    • Monitor compliance by users, owners and operators of the bulk power system in the United States
  • Enforces Compliance
    • Violation mitigation and settlement negotiation
    • Representation of WECC in any hearing or appeal process
  • Administration
    • Audit coordination
    • Reporting systems
  • Registered Functions determine applicable standards
compliance monitoring activities
Compliance Monitoring Activities
  • Onsite Audit
  • Offsite Audit
  • Self Reports
  • Self Certifications
  • Spot Checks
  • Compliance Violation Investigations
  • Complaints

Enforcement Activities

  • If a violation is identified, due process includes
    • Notice of Alleged Violation and Penalty or Sanction
    • Registered Entity Response
    • Request for Settlement or Hearing
    • NERC Approval
    • FERC Approval

Enforcement Activities

  • Mitigation of Violations
    • Prompt mitigation of violations and of risk to BES is important
    • Mitigation is not an “admission of guilt”
    • WECC reviews mitigation plans and accepts, rejects or requests revisions
    • WECC reviews completion of mitigation activities
  • Compliance User Groups/ Critical Infrastructure Compliance User Groups
  • Open WebEX - Monthly
  • Targeted Training
    • CIP 101
    • WebCDMS and EFT
    • E-learning Modules
    • Compliance 101
reference documents
Reference Documents
  • Compliance Monitoring and Enforcement Program (CMEP) & WECC’s annual plan
  • Delegation Agreement
  • Rules of Procedure
  • NERC Standards and WECC Regional Standards
  • NERC Guidance, Bulletins, Directives and Compliance Application Notices (CANs)
  • FERC Orders
Constance B. White

Vice President of Compliance



cathy bakk supervisor compliance program coordinators

Cathy BakkSupervisor, Compliance Program Coordinators

Notice of Audit

October 17, 2013

Compliance 101 Webinar

notice of compliance audit packet
Notice of Compliance Audit Packet
  • Notice of Audit Letter
  • Compliance Monitoring Authority Letter
  • Audit Team Biographies
  • Confidentiality Agreements
notice of compliance audit packet1
Notice of Compliance Audit Packet
  • Certification Letter
  • Pre-Audit Data Requests
  • Pre-Audit Survey
notice of compliance audit letter
Notice of Compliance Audit Letter
  • 90-Day Notice of Audit Letter
    • Details of your specific Audit
      • Dates of Audit
      • Audit Scope
      • Due Dates
      • Audit Team Composition, observers (if applicable)

Observers can include FERC/NERC

      • Date/time of proposed Pre-Audit Conference Call
      • Opening Presentation Suggestions
notice of compliance audit letter1
Notice of Compliance Audit Letter
  • Audit Team Composition
    • Primary Audit Team
      • Individuals expected to participate in the Audit
    • Alternate Audit Team
      • Individuals available to act as backup or replacements for Primary Team members
attachments a b c
Attachments A, B, & C
  • Attachment A
    • Informational; Explanation of Compliance Monitoring Authority
  • Attachment B
    • Short Biographies of the WECC Audit Staff
  • Attachment C
    • Signed Confidentiality Agreements of the WECC Audit Staff
attachments d e
Attachments D & E
  • Attachment D
    • RSAWs (Reliability Standard Audit Worksheets)
      • Customized for your Entity and your audit

Based on your Registered Functions and AML

  • Attachment E
    • Certification Letter
      • Must be printed on your company letterhead and signed by an Authorized Officer
      • Certifies that the information being provided for the Audit is accurate
attachment f
Attachment F
  • Attachment F
    • Pre-Audit Survey
      • Verify contact information
      • Audit Logistics
      • List any delegation agreements
      • Signed by Authorized Officer
      • Please complete all applicable fields
attachment g
Attachment G
  • Attachment G
    • Pre-Audit Data Requests
      • Why are we doing this to you?!?

Clarifications for data submittals

Specifying types of evidence to remove some of the guesswork

att g operations planning o p data
Att G – Operations & Planning (O&P) Data
  • Some evidence may apply to more than one Standard
    • One copy is sufficient, but document inventories or “roadmaps” are appreciated
  • Single Line Diagram
    • Requested for the majority of Audits
att g cyber security cip data
Att G – Cyber Security (CIP) Data
  • CIP-004 – CIP-009 may not be applicable base upon the Critical Asset/Critical Cyber Asset determination
    • Determined by CIP-002-3 Requirements 2 & 3
    • Complete RSAWs indicating absence of CA/CCA identification
audit periods defined
Audit Periods Defined
  • Audit Periods, for O&P and CIP, are defined in Attachment G
    • O&P
      • Date of Registration – last day of Audit OR
      • Day after previous Audit Closing – date of Notice
    • CIP (Version 3)
      • October 1, 2010 – last day of Audit OR
      • Day after previous Audit Closing – date of Notice
audit frequency
Audit Frequency
  • 3 year cycle
    • Entities registered as a Balancing Authority (BA) or Transmission Operator (TOP)
  • All others – 6 year cycle
  • Know the Reliability Standards
  • Use the RSAWs as guides
  • Ask questions
  • Participate in Outreach (CUG/CIPUG)
  • We are here for you…
    • Questions
    • Comments
    • Concerns
phil o donnell manager operations and planning audit team

Phil O’DonnellManager, Operations and Planning Audit Team

Audit Approach and Best Evidence

October 17, 2013

Compliance 101 Webinar

compliance audit on site vs off site
Compliance Audit (on-site vs. off-site)
  • Primary difference is:
    • Location of audit conduct
  • Scope is typically smaller for off site.
  • On Site – Required for BA, TOP functions
      • Per NERC Rules of Procedure 403.11.2
compliance audit on site vs off site1
Compliance Audit (on-site vs. off-site)
  • On-Site
    • Documentation sent to WECC before audit for preliminary review
    • The audit team reviews evidence during off-site week or the first week of the audit and completes its review during the second week or on-site week
    • Data Requests or DRs
    • In-person interviews for clarification
  • Off-Site
    • Documentation sent to WECC before audit for preliminary review
    • Data Requests or DRs
    • Entity may be present at audit if desired
    • Telephone interviews for clarification
audit approaches
Audit Approaches
  • We audit to the Requirements of the Standards.
  • General Approaches included in RSAW
  • RSAW may ask specific questions
  • Always includes the section:

“Describe, in narrative form, how you meet compliance with this requirement.”

audit approaches1
Audit Approaches

“Describe, in narrative form, how you meet compliance with this requirement.”

  • Describe here how your company knows it is compliant with this requirement and how you know you have been compliant for the entire period of the audit.
  • Your place to describe your internal controls
  • Your evidence should support your narrative.
audit approaches2
Audit Approaches
  • List the evidence provided in the RSAW.
    • This road map is important
  • Compliance Assessment Approach in RSAW is used as a checklist.
    • Data Request (DR) for gaps or samples
  • Document & record review is primary
  • Interviews and observations are usually for Corroborating
sufficient audit evidence
Sufficient Audit Evidence

Sufficiency of Evidence

  • The measure of the quantity of evidence
  • Quantity of evidence is dependent on the scope of the audit
  • Extra Quantity does not make up for poor Quality
  • Ensure you provide enough evidence to demonstrate compliance for the entire audit period.
sufficient audit evidence1
Sufficient Audit Evidence

Sampling is used to limit the amount of detailed evidence provided.

  • Normally used in conjunction with summary of a full set of data.
  • Sampling used to assess details.
  • Reduces the burden on the Audit Team but not really on the Entity
  • Audit Team must select the samples
appropriate audit evidence
Appropriate Audit Evidence


The measure of the quality of evidence

  • Relevance
  • Validity
  • Reliability
appropriate audit evidence1
Appropriate Audit Evidence

Quality of Evidence

  • Good Internal Controls point to reliable evidence
  • Direct observation is more reliable than indirect observation.
  • Examination of original documents is more reliable than examination of copies.
  • Testimonial evidence from system experts is more reliable than from personnel with indirect or partial knowledge.
types of evidence
Types of Evidence
  • Physical Evidence
  • Documentary Evidence
  • Testimonial Evidence

Compliance Audits may use all three types but Documentary Evidence is by far the most frequent type of evidence assessed and relied on.

evidence for procedural documents
Evidence for Procedural Documents

The characteristics of a valid procedural or policy document include:

  • Document title
  • Definition or Purpose
  • Revision level
  • Effective dates
  • Authorizing signatures
evidence for tasks performed
Evidence for Tasks Performed
  • When the standard calls for a task to be performed it must be documented.
    • Records
    • Logs
    • Reports
    • Work Orders
    • Phone recordings
    • Transcripts of phone recordings
    • Shift Schedules
  • Dates & Times are critical
evidence of coordination with other entities
Evidence of “Coordination” with other entities
  • Typical evidence provided initially is a single email.

“…If you have any comments please contact ______”

This alone is neither sufficient or appropriate to demonstrate coordination between two or more parties.

  • If emails or correspondence are used
    • Two way communications are needed
  • Better are:
    • Meeting Agendas
    • Meeting Minutes
    • Attendance Lists
evidence of distribution of information
Evidence of “Distribution” of information
  • Typical evidence provided initially is a single email with a large distribution list.

“…please see attached”

This alone is typically neither sufficient or appropriate to demonstrate distribution to others.

  • If emails or correspondence are used
    • Need clear identification of the personnel on the distribution list.
  • Even Better is corroboration by receipt acknowledgement
lifecycle of a violation
Lifecycle of a Violation

Every violation goes through the same process

  • What is a violation?
  • How does WECC know about a violation?
  • What is the submittal and review process for possible violations?
  • What is the submittal and review process for Mitigation Plans?
the team
The Team
  • Ben Christensen – CIP Enforcement Analyst
  • Tyson Jarrett – CIP Enforcement Analyst
  • Jenifer Vallace – Associate CIP Enforcement Analyst
  • Ruchi Ankleshwaria – Associate Compliance Engineer – Enforcement
  • Brent Read - Compliance Engineer – Enforcement
  • Duane Cooke – Compliance Process Analyst
  • Rachael Ferrin – Associate Enforcement Process Analyst
what is a violation
What is a violation?

A violation is a failure to demonstrate compliance pursuant to applicable NERC Reliability Standard Requirement

  • Possible Violation
    • The identification by the Compliance Enforcement Authority of a possible failure by a registered Entity to comply with a Reliability Standard that is applicable to the Registered Entity. NERC Rules of Procedure, Appendix 2 (January 31, 2012).
how does wecc know about a violation
How does WECC know about a violation?

Compliance Monitoring

  • Self-Reports
  • Self-Certifications

New possible violation

Change in scope

  • Compliance Audits
  • Spot Checks
  • Compliance Investigations
  • Periodic Data Submittals
  • Complaints
possible violation submittal
Possible Violation Submittal
  • Submit Self-Reports and Self-Certifications via webCDMS
  • Self Report/Self Certification Content Checklist
why use the checklist
Why use the checklist?
  • Here’s a sample of questions I ask:
  • Why do you believe there is a violation of CIP 00X RX
  • Has a review been done to confirm the scope?
    • What is the status of the review?
  • Give a high-level walk-through of documented process for ensuring CIP 00X RX.
  • What devices are in scope?
    • Total number of devices?
    • How are the devices classified? CCA/ACM/PAC/Non-CCA?
    • What do the devices do? (Servers, workstations, networking, etc.)
    • Where are they located?
      • ESP?
      • PSP?
  • What controls were in place to reduce any risk associated with this violation?
  • What is the start date?
    • What happened on this date?
possible violation review
Possible Violation Review
  • WECC Subject Matter Experts (SME) reviews the possible violation
  • Analyze facts and circumstances
  • Data Requests/conference call if necessary
  • Technical assessment
    • Facts and Timelines
    • Risk Assessment
  • Recommendation of Dismissal or Acceptance to Case Managers
what is the entity s next step after reporting a possible violation
What is the Entity’s next step after reporting a possible violation?
  • Submit Mitigation Plan
    • Notice of Alleged Violation triggers Mitigation Plan due date
    • Timely Mitigation is encouraged
    • Not admission of violation

Every violation goes through the same process

mitigation plan submittal
Mitigation Plan Submittal
  • Submit via webCDMS
    • One violation per plan
  • Eight Steps to Prevention and Mitigation
  • Mitigation Plan Content Checklist
mitigation and prevention checklist
Mitigation and Prevention Checklist
  • Symptom
  • Root Cause
  • Corrective Actions
  • Preventive Actions
  • Detective Actions
  • Assign tasks
  • Timeline and milestones
  • Interim Risk
mitigation plan review
Mitigation Plan Review
  • WECC Subject Matter Experts (SME) conduct reviews
  • Review the mitigation plan
    • Actions (Corrective, Detective and Preventive)
    • Duration
  • Data Requests/conference call if necessary
  • Notice of Acceptance or Rejection via auto notification or EFT server
mitigation plan extensions
Mitigation Plan Extensions
  • Extension Requests
    • Accepted Mitigation Plan completion date = date Completion Certification and evidence submitted to WECC
    • Five business days prior to completion date
    • Submit via webCDMS
      • Include reasons for request
      • Don’t forget milestones!
    • Usual WECC review process
cmp submittal
CMP Submittal
  • Submit Completion Certification and evidence via webCDMS
  • CMP Content Checklist
mitigation plan completion review
Mitigation Plan Completion Review
  • WECC Subject Matter Experts (SME) conduct reviews
  • Analyze Evidence
    • Were all actions outlined in the plan completed?
    • Has both procedural and implementation evidence been submitted?
  • Data Requests/conference call if necessary
  • Notice of Acceptance or Rejection via auto notification or EFT Server
  • Violation life cycle
    • Submitting violations and mitigation plans
    • WECC’s review of violations and mitigation plans
  • Resources
    • http://www.wecc.biz/compliance/outreach/Lists/101Links/AllItems.aspx
wecc enforcement case managers
WECC Enforcement Case Managers

Primary Role: Determining Violation Disposition (disposition analysis)

  • Case analysis
  • Violation Disposition
  • Policy analysis
  • Assess penalties
  • Conduct settlements
  • Build relationships
disposition analysis
Disposition Analysis
  • Dismissal
  • Find, Fix and Track (“FFT”)
  • Notice of Alleged Violation (“NOAV”)
  • Expedited Settlement Agreement (“ESA”)
  • Disposition method used when the Case Manager determines the possible violation is not enforceable

For Example…

    • Standard Requirement does not apply to Entity
    • Facts and circumstances warrant a violation of a different Standard Requirement
    • Entity produced additional evidence demonstrating compliance
what does a dismissal look like
What does a dismissal look like?
  • Case Manager will issue a “Notice of Dismissal and Completion of Enforcement Action”
  • WECC:
    • Withdraws the Possible Violation from Entity’s compliance record
    • Any data retention directives relating to the possible violation are released
  • Entity:
    • Does not need to respond to notice
    • Questions/concerns contact Case Manager
not a dismissal now what
Not a Dismissal, Now what?
  • Dismissal
  • Find, Fix and Track (“FFT”)
  • Notice of Alleged Violation (“NOAV”)
  • Expedited Settlement Agreement (“ESA”)
pvs for fft review
PVs for FFT Review

All PVs undergo a FFT Scrub

“Strong” FFT Candidates:

  • Are not Repeat PVs
  • PV does not reveal programmatic or systematic shortcomings
what does an fft look like
What does an FFT look like?
  • WECC Enforcement will issue a “Notice of Find, Fix and Track”
    • PV becomes a “remediated issue”
    • Remediation Required
      • Entities must submit an affidavit confirming completed remediation
    • No Penalty or sanction
    • FFT is filed with NERC but does not become a “confirmed violation”
  • FFT will become part of an Entity’s compliance history
what to do with an fft
What to do with an FFT?
  • Within five (5) days of receiving an FFT Notice an Entity
  • Must submit to WECC an affidavit, signed by an officer with knowledge of remediation,


  • Must submit to WECC written notification opting out of the FFT processing
    • If an Entity opts out of the FFT disposition, then WECCs policy is to issue the violation through the traditional NOAV process.
4 disposition methods
4 Disposition Methods
  • Dismissal
  • Find, Fix and Track (“FFT”)
  • Notice of Alleged Violation (“NOAV”)
  • Expedited Settlement Agreement (“ESA”)
a word on penalties
A Word on Penalties
  • Attached to violations disposed of using the NOAV or ESA processes
  • Based on:
    • NERC Sanction Guidelines (January 31, 2012)
    • Penalty Range
      • Penalty range depends upon Violation Severity Level (“VSL”) and Violation Risk Factor (“VRF”)
  • Penalties are then adjusted for either Mitigating or Aggravating Factors
4 disposition methods1
4 Disposition Methods
  • Dismissal
  • Find, Fix and Track (“FFT”)
  • Notice of Alleged Violation (“NOAV”)
  • Expedited Settlement Agreement (“ESA”)
what does a noav look like cmep section 5 3
What does a NOAV Look like?CMEP Section 5.3
  • NERC Rules of Procedure, Appendix 4C §5.3 (“CMEP”)
  • Alleged Violation Facts
  • Mitigation Plan Summary (if applicable)
  • Enforcement Violation Determinations
    • BES Impact Statement
      • Minimal
      • Moderate
      • Severe
    • Violation Severity Level (“VSL”)
    • Violation Risk Factor (“VRF”)
  • Penalty
what to do with a noav
What to do with a NOAV?
  • Submit a NOAV Response within 30 days
  • The NOAV Response must conform to one of three options
  • Failure to submit a NOAV Response within 30 days will automatically result in confirmed violations with penalties
noav response option 1 does not contest
NOAV Response: “Option 1” Does not contest
  • Does not contest violation facts as alleged in the NOAV
  • May identify errors that should be corrected in the “Notice of Confirmed Violation” (“NOCV”)
  • Submit a Mitigation Plan

Enforcement will issue a Notice of Confirmed Violation within ten (10) days of receiving a NOAV Response that “agrees with or does not contest an alleged violation.”

noav response option 2 contests penalty
NOAV Response: “Option 2” Contests Penalty
  • NOAV Response will be submitted to Enforcementusing the EFT Server within thirty (30) calendar days of receiving the NOAV.
  • Submit a Mitigation Plan.
  • NOAV Response must explicitly contest penalty and request settlement.
    • NOAV Response must articulate basis for each penalty
    • NOAV Response should include a proposed penalty the entity believes to be reasonable including the basis for proposed penalty
noav response option 3 contests alleged violation penalties
NOAV Response: Option 3Contests Alleged Violation & Penalties
  • NOAV Response must be submitted to Enforcement using the EFT Server within thirty (30) calendar days of receiving the NOAV.
  • NOAV Response must explicitly contest each alleged violation and proposed penalty and request settlement.
  • Each Contention must be supported by:
    • An explanation of the Entity’s position
    • Basis for Contention
    • Additional Information or evidence
4 disposition methods2
4 Disposition Methods
  • Dismissal
  • Find, Fix and Track (“FFT”)
  • Notice of Alleged Violation (“NOAV”)
  • Expedited Settlement Agreement (“ESA”)
what does an esa look like
What does an ESA look like?
  • Expedites Formal Settlement Negotiations
  • The ESA will contain
    • Facts and circumstances of the violation
    • Risk Assessment Summary
    • Mitigation Plan Summary
    • VSL and VRF determinations
    • Penalty determination
what to do with an esa
What to do with an ESA?

1. Entity will have 15 days to review the ESA…

  • The Entity will contact Case Manager with questions or concerns.

2. If the Entity accepts the terms of the ESA…

  • The Entity must submit a signed copy of the ESA to WECC within 15 days of receipt of the ESA issuance.

3. If the Entity rejects the ESA or does not respond within 15 days…

  • WECC will issue a Notice of Alleged Violation and Proposed Penalty and Sanction.
payment closure of enforcement action
Payment & Closure of Enforcement Action
  • After NOP becomes effective,
  • WECC issues a “Payment Due Notice”
  • The Penalty will be due thirty (30) days from the date the Notice is issued.
  • Public NOP filings can be found on the NERC website


enforcement process summary
Enforcement Process Summary
  • Lifecycle of a Possible Violation
  • Best Compliance Practices
  • Possible Violation Disposition and Entity Responses
Presented by

Ben Christensen

Rachael Ferrin

Elizabeth M. Brereton


michael dalebout taylor allred

Michael DaleboutTaylor Allred

webCDMS Update

Thursday, October 17, 2013