Download - FRCC Registration and Compliance Overview
FRCCFRCCRegistration and Compliance Registration and Compliance
OverviewOverview
Linda CampbellFRCC Director of Reliability and
Compliance
FRCCFRCCEntity RegistrationEntity Registration
OverviewOverview
Registered FunctionsRegistered Functions
• BA, Balancing Authority• DP, Distribution Provider• GOP, Generator
Operator• GO, Generator Owner• LSE, Load Serving
Entity• PA, Planning Authority• PSE, Purchasing-Selling
Entity• RC, Reliability
Coordinator
• RSG, Reserve Sharing Group
• RP, Resource Planner• TO, Transmission
Owner• TOP, Transmission
Operator• TP, Transmission
Planner• TSP, Transmission
Service Provider
Registration CriteriaRegistration Criteria
• Load Serving Entities (LSE)
Peak Load > 25 MW or,Responsible for UFLS facilities or,Responsible for UVLS facilities
Registration CriteriaRegistration Criteria
• Distribution Provider (DP)
System serving > 25 MW or,Responsible for UFLS facilities or,Responsible for UVLS facilities or,Responsible for required SPS
Registration CriteriaRegistration Criteria
• Generator Owner/Operator
(GO or GOP)Individual Generating Unit > 20 MVAGenerating Plant/Facility > 75 MVAAny blackstart unit that is part of
entities restoration planAny generator, regardless of size that
is material to reliability
Registration CriteriaRegistration Criteria
• Transmission Owner/Operator
(TO or TOP)Owns or operates transmission
element 100 KV or above, or lower voltage defined by FRCC as necessary for reliable operation of the grid, or that is included on a critical facilities list defined by FRCC.
Registration CriteriaRegistration Criteria
• Joint Action Agency or Similar OrganizationMay register on behalf of one or more
of its membersMust accept compliance reporting
responsibility for all standards applicable to the members
Shall provide FRCC with an annual “Agency Member Registry”
Registration TimelineRegistration Timeline
• December 14, 2006 – NERC implements Revision 2 to Registry Criteria
• December 20, 2006 – FRCC submitted update of “non-binding” compliance registry
• January 10, 2007 – Review of “non-binding” registry by NERC and Regional Compliance Managers
Registration Timeline Registration Timeline (con’t)(con’t)
• Late January, 2007 FRCC initiate final update of Compliance Registry
• March 2, 2007 – FRCC to submit to NERC a final Compliance Registry
• March 12, 2007 – Final review of Compliance Registry by NERC and Regional Compliance Managers
FRCCFRCCCompliance ProgramCompliance Program
OverviewOverview
What is Compliance What is Compliance Monitoring?Monitoring?
• Process by which a Registered Entity’s performance is measured against:– NERC Reliability Standards– FRCC Regional Reliability Standards
• Does not review anything that is not included in the standards
Who does Compliance Who does Compliance Monitoring?Monitoring?
• FRCC will be a Regional Entity with delegated responsibility and authority from NERC and FERC
• FRCC monitors registered entities in our region
• NERC provides oversight of FRCC compliance program
• FERC provides oversight of both NERC and FRCC
What are Violations?What are Violations?
• Violations occur when a Registered Entity does not comply with a requirement of a Reliability Standard that is applicable to that entity
• Alleged violations are required to be reported to NERC and FERC
• Confidentiality of the entity will be maintained until the alleged violation is confirmed
Sources of ViolationsSources of Violations
• On-site Compliance Audits • Annual Self Certification• Spot Audits• Compliance Violation Investigations• Complaints• Self-Reporting• Periodic Data Submittal• Exception Reporting
Processing Alleged Processing Alleged ViolationsViolations
• Entity provided with written notice of alleged violation
• Entity can accept or object to the alleged violation– Accept : Reported to NERC, Mitigation
Plan prepared by entity– Contest : Entity request FRCC
Hearing Process be initiated
What are Sanctions and What are Sanctions and Penalties?Penalties?
• FERC has identified June 2007 as the time period for which compliance with Reliability Standards will be mandatory and enforceable
Sanctions (Non-Monetary)
– Letters to company officers
– Require actions to be taken
– Placement on “watch list” Penalties (Monetary Fines)
– Calculated by FRCC Compliance Staff• Base penalty adjusted by mitigating or aggravating
factors
How are Sanctions and Penalties How are Sanctions and Penalties determined?determined?
• Example in current standard
BASE PENALTY TABLEBASE PENALTY TABLE
• Future
Low High Low High Low High Low HighLower $1,000 $3,000 $2,000 $7,500 $3,000 $15,000 $5,000 $25,000
Medium $2,000 $30,000 $4,000 $100,000 $6,000 $200,000 $10,000 $335,000
High $4,000 $125,000 $8,000 $300,000 $12,000 $625,000 $20,000 $1,000,000
ViolationRisk
Factor
High Severe
Violation Severity Level
Range Limits Range Limits Range Limits Range LimitsLower Moderate
On-Site Compliance AuditsOn-Site Compliance Audits
• Audits are performed by the FRCC• Based on “pro-forma” program developed
by NERC• Performed every three years for RC, BA
and TOP, others to be on a schedule determined by NERC
• Will include all standards applicable to entity that were monitored in the annual implementation plans since last audit
Audit ReportAudit Report
• A Final Report of the audit will be prepared by the audit team– Audited entity will review and provide
factual or technical corrections
• Submit to the FRCC Compliance Committee for review
• Final Report will be posted on the FRCC website
Mitigation PlansMitigation Plans
• Mitigation Plans are required for every confirmed violation
• Must identify how the entity plans to come into compliance with the requirement
• Will be approved by the FRCC Compliance Committee
• Must include milestones if longer than 3 months to correct.
FRCC Hearing ProcessFRCC Hearing Process
• Registered Entity must contest or respond to notice of violation within 30 days.– If no response, violation is considered to be
accepted• If objection not resolved with 40 days of
entity response, must request hearing• Hearing Body is the FRCC Board
Compliance Committee• If Registered Entity does not agree with
outcome of FRCC Hearing, may appeal at NERC.
Questions?