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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Thursday, October 9, 2014
Vice President of Compliance and
Acting Regional Manager
Overview of WECC
And Regulatory Structure
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 functionsWECC History
1.8 million square miles
126,285 miles of transmission
Population of 78 million
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
Provide training sessions for operators, schedulers and dispatchers
Hosts the Western Renewable Energy Generation Information System, which creates and tracks renewable energy certificatesWECC Services
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
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
Violation mitigation and settlement negotiation
Representation of WECC in any hearing or appeal process
webCDMS and EFTWECC Compliance
Federal Power Act 2005
Compliance Monitoring and Enforcement Program (CMEP) & WECC’s annual plan
Rules of Procedure
NERC Standards and WECC Regional Standards
NERC Guidance, Bulletins, Directives and Compliance Application Notices (CANs)
FERC OrdersReference Documents
Compliance Program Coordinator
CIP-004 – CIP-009 may not be applicable based upon the Critical Asset/Critical Cyber Asset determination
If you have any questions please contact Brent Castagnetto at firstname.lastname@example.org 801-819-7627Att G – Cyber Security (CIP) Data
Audit Periods, for O&P and CIP, are clearly defined in Attachment G for both:
Senior Compliance Auditor,
Operations and Planning
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 samplesSufficient Audit 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
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
Definition or Purpose
Authorizing signaturesEvidence for Procedural Documents
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
Transcripts of phone recordings
Dates & Times are criticalEvidence for Tasks Performed
“…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
Attendance ListsEvidence of “Coordination” with other entities
“…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 acknowledgementEvidence of “Distribution” of information
A violation is a failure to demonstrate compliance pursuant to applicable NERC Reliability Standard Requirement
Self Report/Self Certification Content ChecklistPossible Violation Submittal
Is the version of the standard (in effect at the time of the violation) identified?
Every violation goes through the same process.
CMP Content ChecklistCMP Submittal
Disposition method used when the Case Manager determines the possible violation is not enforceable
Case Manager will issue a “Notice of Dismissal and Completion of Enforcement Action”
May identify errors that should be corrected in the “Notice of Confirmed Violation” (“NOCV”)
Submit a Mitigation PlanNOAV 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 will be submitted to Enforcement using the EFT Server within thirty (30) calendar days of receiving the NOAV.
NOAV Response must be submitted to Enforcement using the EFT Server within thirty (30) calendar days of receiving the NOAV.
The Penalty will be due thirty (30) days from the date the Notice is issued
Public NOP filings can be found on the NERC websitePayment & Closure of Enforcement Action
WECC EFT Server
Compliance Standards Index
Types of calls for WECC
email@example.comReminder: Help Desk