what you need to know about nerc ero compliance louise mccarren chief executive officer – wecc...
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3 WECC Compliance Goals ● Improve Reliability for the Western Interconnection ● Transparency ● Consistency ● Professionalism ● CommunicationsTRANSCRIPT
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WHAT YOU NEED TO KNOW ABOUTNERC ERO COMPLIANCE
Louise McCarrenChief Executive Officer – WECC
APPA National ConferenceJune 16, 2009
Salt Lake City, Utah
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WECC Compliance Goals
●Improve Reliability for the Western Interconnection
●Transparency●Consistency●Professionalism●Communications
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CMEP Roles
●Registration●Compliance Monitoring●Mitigation Tracking●Enforcement
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Compliance Monitoring● Work with registered entities to resolve
violations once identified through one of the eight doors into Compliance
Self ReportsSelf Certifications
Exception ReportingOn-site AuditOff-site AuditSpot Checks
CVIsComplaints
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WECC Compliance Update Audits and Spot-Checks● On-Site Audits
Balancing Authorities and Transmission Operators Three-year cycle
● Off-Site Audits All other entities Six-year cycle
● CIP Spot Checks (beginning July 2009) Depending on region, may double audit work load
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Violation Resolution Processes
● Which process best suits circumstances NAVAPS (NOAV) NOCV Settlement Hearing
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Notice of Alleged Violation and Penalty or Sanction (NAVAPS)● Formerly referred to as a Notice of Alleged
Violation (NOAV)● Letter that contains:
Violations facts Recitation of the record Determination of penalties/sanctions Justification for penalties Notice to registered entity of its options
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Notice of Confirmed Violation (NOCV)● Can be used rather than a NAVAPS if
entity doesn’t contest violation or penalty; or
● May supplement a NAVAPS with any updates to the record
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Notice of Confirmed Violation (continued)
● Contains same level of factual data as NAVAPS Violation facts Recitation of the record Determination of penalties/sanctions Justification for penalties/sanctions PLUS – the statement that entity is not
contesting the violations
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Settlement
● Can be requested at anytime● Going directly to settlement (skipping NAVAPS
and/or NOAV) has proven to be most expeditious route
● End result – a settlement agreement that contains the factual history and the terms of the settlement
● NERC and FERC approval required
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Hearing
● Process spelled out in CMEP● If parties cannot reach settlement, entities
can request hearing● Formal adjudicative proceeding before
hearing officer
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Penalty Determination
●Determine fair and consistent penalties and/or sanctions Risk Factor Severity Level Impact of violation on BES Mitigating/aggravating factors Penalties assessed in similar cases Unique circumstances
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In Summary
● Complex process● Many moving parts● Analogy to concurrent engineer/build● Changes/improvements as we learn● Commitment to keeping interested
stakeholders informed
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WECC ComplianceContinued OutreachTaud Olsen, WECC Director of Stakeholder
Relations and Outreach● Compliance User Group (CUG)● CIP User Group (CIPUG)● Open Mic – Monthly● Compliance Questions Inbox
http://compliance.wecc.biz
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WECC Compliance Update Questions
Louise McCarrenChief Executive OfficerWestern Electricity Coordinating Council615 Arapeen Drive, Suite 210Salt Lake City, Utah 84108-1262