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WECC COMPLIANCE 101 Webinar. Thursday, October 9, 2014. Agenda. Overview of WECC and Regulatory Structure. Constance White Vice President of Compliance and Acting Regional Manager. COMPLIANCE 101 Overview of WECC And Regulatory Structure.

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wecc compliance 101 webinar


Thursday, October 9, 2014

overview of wecc and regulatory structure

Overview of WECC and Regulatory Structure

Constance White

Vice President of Compliance and

Acting Regional Manager



Overview of WECC

And Regulatory Structure

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 Profile
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


Industry participants join together to promote system reliability

Bifurcation in February 2014 changed functions

WECC History
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
  • Independent Board of Directors
    • 9 members
    • Committees
  • Members Advisory Committee
  • Members
      • Grid owners, operators, users
      • Stakeholders
      • State and Provincial
Peak Reliability assumed responsibility for

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 services
Transmission expansion planning

Management of a comprehensive planning database

Provide coordination of sub-regional planning processes

Analyses and modeling


Model the system and perform studies under a variety of scenarios to set operating policies and limits

wecc services1
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 Services
wecc services2
Delegation Agreement

Perform functions delegated to WECC as a Regional Entity under Delegation Agreement with NERC, including regulating entities subject to mandatory Reliability Standards

WECC Services
mandatory reliability regulation

Northeast Blackout of 2003

    • 10 Million people in Ontario, Canada
    • 45 million people in eight U.S. states
Mandatory Reliability Regulation
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.

Task Force Report
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

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
Authority for Compliance Monitoring
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
Order 693 & Order 706 Standards
wecc compliance
Recommends Registrations for Entities

Register users, owners, operators according to function

Monitors Compliance with 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


Audit coordination

Reporting systems

webCDMS and EFT

WECC Compliance


Reliability Standards

Delegation Agreement

Federal Power Act 2005






Self Certifications


Self Reports




Mitigation Actions




Due Process

Risk Assessments


education outreach






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

Reference Documents
notice of audit

Notice of Audit

Stacia Ellis

Compliance Program Coordinator

notice of compliance audit packet

Notice of Audit Letter

Compliance Monitoring Authority Letter

Audit Team Biographies

Confidentiality Agreements

Notice of Compliance Audit Packet
notice of compliance audit packet1

Certification Letter

Pre-Audit Data Requests

Pre-Audit Survey

Audit Scope and WECC RSAWs

Notice of Compliance Audit Packet
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 Letter
notice of compliance audit letter1

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
Notice of Compliance Audit Letter
attachments a b and 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 A, B and C
attachments d and e

Attachment D

    • Audit Scope
    • RSAWs (Reliability Standard Audit Worksheets)
      • Customized for your Entity and your audit
        • Based on your Registered Functions and Audit Scope
  • 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
Attachments D and E
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 F
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
Attachment G
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 – Operations & Planning (O&P) Data
att g cyber security cip data

CIP-004 – CIP-009 may not be applicable based upon the Critical Asset/Critical Cyber Asset determination

    • Determined by CIP-002-3 Requirements 2 & 3
    • Complete RSAWs indicating absence of CA/CCA identification
    • 2015 CIP audits will include CIP v5 outreach

If you have any questions please contact Brent Castagnetto at bcastagnetto@wecc.bizor 801-819-7627

Att G – Cyber Security (CIP) Data
attachment h

Attachment H

    • Audit Feedback
    • Now sending with initial package
      • Feedback is encouraged for all phases of audit.
Attachment H
audit periods defined

Audit Periods, for O&P and CIP, are clearly defined in Attachment G for both:

  • Operations and Planning (O&P)
  • Cyber Security (CIP)
Audit Periods Defined
audit frequency

3 year cycle

Entities registered as a:

    • Balancing Authority (BA)
    • Transmission Operator (TOP) or
    • Reliability Coordinator (RC)
  • All others
    • Generally a 6 year cycle. Subject to flexibility in the future as part of NERC’s Reliability Assurance Initiative (RAI).
Audit Frequency

“Howdy Call”

    • A few days after Notice of Audit Packet is uploaded to the EFT Server.

Know the Reliability Standards

  • Use the RSAWs as guides
  • Ask questions
  • Participate in Outreach (CUG/CIPUG)
  • We are here for you…
    • Questions
    • Comments
    • Concerns
audit approach and best evidence

Audit Approach and Best Evidence

William Fletcher

Senior Compliance Auditor,

Operations and Planning

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 RC, BA, TOP functions
      • Per NERC Rules of Procedure 403.11.2
Compliance Audit (on-site vs. off-site)
compliance audit on site vs off site1


    • 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
Compliance Audit (on-site vs. off-site)
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
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 Evidence
sufficient audit evidence1
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

Sufficient Audit Evidence
appropriate audit evidence

The measure of the quality of evidence




Appropriate Audit Evidence
appropriate audit evidence1
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.

Appropriate Audit 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.

Types of Evidence
testimonial evidence
Attestations of Compliance or Statements of Compliance are generally not accepted as the only available evidence.

Attestations may be used to explain minor gaps in documentation or to state if no conditions occurred which are subject to a requirement.

Attestor must be knowledgable and qualified.

Testimonial Evidence
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 Procedural Documents
non applicable requirements
Three instances are acceptable for use of term “Not Applicable”

Entity is not registered for the applicable function. (only TOP responsible for TOP requirements)

Entity does not own, operate or maintain the equipment addressed by the requirement. (UVLS, UFLS, SPS etc.)

Entity does not use the program or process specified by the requirement. (and is not required to… ATC, CBM, etc)

Non Applicable Requirements
evidence for tasks performed
When the standard calls for a task to be performed it must be documented.




Work Orders

Phone recordings

Transcripts of phone recordings

Shift Schedules

Dates & Times are critical

Evidence for Tasks Performed
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 “Coordination” with other entities
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

Evidence of “Distribution” of information
enforcement 101 october 9 2014

Enforcement 101October 9, 2014

Rachael Ferrin

Richard Shiflett

Haley Sousa

Joelle Bohlender


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?

what is a violation

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

  • Possible Violation (PV)
    • 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).
What is a violation?
how does wecc know about a possible violation

Compliance Monitoring

  • Self-Reports
  • Self-Certifications
    • New possible violation
    • Change in scope
  • Compliance Audits
  • Spot Checks
  • Compliance Investigations
  • Periodic Data Submittals
  • Complaints
How does WECC know about a possible violation?
self report self certification content checklist

Is the version of the standard (in effect at the time of the violation) identified?

  • Are all multiple subrequirements in scope identified?
  • Has this violation been previously reported?
  • Does the violation description include:
    • All devices/facilities/personnel in scope?
    • Names/IDs of devices/facilities/personnel?
    • Where are these devices located?
    • What are these devices used for?
    • What type of access do the personnel have?
    • Any additional information to assess the VSL?
  • Is the start date and end date identified?
  • Are the compensating measures identified?
Self-Report/Self-Certification Content Checklist
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
Possible Violation Review
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
Entity’s next step after reporting a Possible Violation

Every violation goes through the same process.

mitigation plan submittal

Submit via webCDMS

    • One violation per plan
  • Eight Steps to Prevention and Mitigation
  • Mitigation Plan Content Checklist
Mitigation Plan Submittal
mitigation and prevention checklist


Root Cause

Corrective Actions

Preventive Actions

Detective Actions

Assign tasks

Timeline and milestones

Interim Risk

Mitigation and Prevention Checklist
mitigation plan content checklist

Has the scope of the violation being mitigated changed?

  • Has the root cause been identified?
  • Does the mitigation plan include:
    • What is being fixed?
    • How it is being fixed?
    • When it is being fixed?
  • Do the mitigation actions:
    • Relate to the requirements in scope?
    • Identify preventative measures?
    • Identify detection measures?
Mitigation Plan Content Checklist
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 Review
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
Mitigation Plan Extensions
cmp content checklist

Has the scope changed since the Mitigation Plan was accepted?

    • Have you included a brief statement to confirm the scope?
  • Is the evidence uploaded with a description for each file?
  • Is there a mapping of actions to evidence?
  • Is there a completion date for each action?
CMP Content Checklist
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
Mitigation Plan Completion Review

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

Primary Role: Determining Violation Disposition (disposition analysis)

  • Case analysis
  • Violation Disposition
  • Policy analysis
  • Assess penalties
  • Conduct settlements
  • Build relationships
WECC Enforcement Case Managers
disposition analysis


Find, Fix and Track (“FFT”)

Notice of Alleged Violation (“NOAV”)

Expedited Settlement Agreement (“ESA”)

Disposition Analysis

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

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
What does a dismissal look like?
not a dismissal now what


Find, Fix and Track (“FFT”)

Notice of Alleged Violation (“NOAV”)

Expedited Settlement Agreement (“ESA”)

Not a Dismissal, Now what?
pvs for fft review

WECC Reviews All PVs for FFT Treatment

“Strong” FFT Candidates:

  • Are not Repeat PVs
  • PV does not reveal programmatic or systematic shortcomings
  • Found and Fixed by the Entity
  • Mitigation Plan has been submitted
PVs for FFT Review
what does an fft look like

WECC Enforcement will issue a “Notice of Find, Fix and Track”

    • Remediation Required
    • 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 does an FFT look like?
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,


  • 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.
What to do with an FFT?
4 disposition methods


Find, Fix and Track (“FFT”)

Notice of Alleged Violation (“NOAV”)

Expedited Settlement Agreement (“ESA”)

4 Disposition Methods
what does a noav l ook 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 does a NOAV look like?CMEP Section 5.3
what to do with a noav

Submit a NOAV Response within 30 days

  • The NOAV Response must conform to one of three options
    • Agree with the violation AND penalty
    • Agree with the violation, but contest penalty
    • Contest both the violation AND penalty
  • Failure to submit a NOAV Response within 30 days will automatically result in confirmed violations with penalties
What to do with a NOAV?
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

NOAV Response: “Option 1” Does not contest

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 will be submitted to Enforcement using 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 2” Contests Penalty
noav response option 3 contests 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
NOAV Response: “Option 3”Contests Alleged Violation & 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
A Word on Penalties
4 disposition methods1


Find, Fix and Track (“FFT”)

Notice of Alleged Violation (“NOAV”)

Expedited Settlement Agreement (“ESA”)

4 Disposition Methods
esa expedited settlement process
ESA: Expedited Settlement Process

Settlement Agreement


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 does an ESA look like?
what to do with an esa

Entity will have 15 days to review the ESA…

    • The Entity will contact Case Manager with questions or concerns.
  • 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.
  • 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.
What to do with an ESA?
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

Payment & Closure of Enforcement Action


enforcement process summary
Enforcement Process Summary
  • Lifecycle of a Possible Violation
  • Best Compliance Practices
    • http://www.wecc.biz/compliance/Pages/Best-Practices.aspx
  • Possible Violation Disposition and Entity Responses
compliance 101

Compliance 101

Brittany Power

Data Coordinator

webcdms regions
webCDMS Regions




Texas RE


eft server
EFT Server


compliance standards index
Compliance Standards Index

Compliance Standards Index

reminder help desk
Call @ 801-883-6879

Types of calls for WECC

EFT Questions

Registration Questions

Historical Questions

Standard Questions

Non-technical Questions


Reminder: Help Desk

WECC Support

OATI Support

  • Call @ 673-220-2020
  • Types of calls for OATI
    • Technical Problems
    • webCDMSLogin Problems
    • Certificate Problems
    • Access Problems