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WHAT YOU NEED TO KNOW ABOUT NERC ERO COMPLIANCE

WHAT YOU NEED TO KNOW ABOUT NERC ERO COMPLIANCE. Louise McCarren Chief Executive Officer – WECC APPA National Conference June 16, 2009 Salt Lake City, Utah. WECC Compliance Goals. Improve Reliability for the Western Interconnection Transparency Consistency Professionalism Communications.

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WHAT YOU NEED TO KNOW ABOUT NERC ERO COMPLIANCE

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  1. WHAT YOU NEED TO KNOW ABOUTNERC ERO COMPLIANCE Louise McCarren Chief Executive Officer – WECC APPA National Conference June 16, 2009 Salt Lake City, Utah

  2. WECC Compliance Goals • Improve Reliability for the Western Interconnection • Transparency • Consistency • Professionalism • Communications

  3. CMEP Roles • Registration • Compliance Monitoring • Mitigation Tracking • Enforcement

  4. Compliance Monitoring • Work with registered entities to resolve violations once identified through one of the eight doors into Compliance Self Reports Self Certifications Exception Reporting On-site Audit Off-site Audit Spot Checks CVIs Complaints

  5. 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

  6. Violation Resolution Processes • Which process best suits circumstances • NAVAPS (NOAV) • NOCV • Settlement • Hearing

  7. 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

  8. 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

  9. 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

  10. 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

  11. Hearing • Process spelled out in CMEP • If parties cannot reach settlement, entities can request hearing • Formal adjudicative proceeding before hearing officer

  12. 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

  13. In Summary • Complex process • Many moving parts • Analogy to concurrent engineer/build • Changes/improvements as we learn • Commitment to keeping interested stakeholders informed

  14. WECC ComplianceContinued Outreach Taud 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

  15. WECC Compliance Update Questions Louise McCarren Chief Executive Officer Western Electricity Coordinating Council615 Arapeen Drive, Suite 210 Salt Lake City, Utah 84108-1262 16

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