1. COMPLIANCE 101
Module One

2. Module 1: WECC History & Roles
Review of Resources
Settlement Processes
Enforcement Processes
New Possible Violation
Compliance Processes
Implementation of CMEP
Development of CMEP
Regulatory Structure in U.S.
WECC History & Roles

3. 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.

4. 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
Non-Governmental
Industry participants join together to promote system reliability
Member-driven (401 members divided into 7 membership classes)

5. WECC Coverage Service Area
1.8 million square miles
126,285 miles of transmission
Population of 78 million

7. WECC Organization Members Board of Directors 401 32 members Committees
Grid owners, operators, users
Stakeholders
State and Provincial
Board of Directors
32 members
Committees
Board
Member

8. WECC Services 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

9. WECC Services Transmission expansion planning Studies
Management of a comprehensive planning database
Provide coordination of sub-regional planning processes
Analyses and modeling
Studies
Model the system and perform studies under a variety of scenarios to set operating policies and limits
Market-operations interface
Ensure that competitive power markets do not negatively impact reliability

10. WECC Services Loads and Resources Assessments Operator training WREGIS
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
WREGIS
Hosts the Western Renewable Energy Generation Information System, which creates and tracks renewable energy certificates

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

12. Mandatory Reliability Regulation
Northeast Blackout of 2003
10 Million people in Ontario, Canada
45 million people in eight U.S. states

15. 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.

16. Task Force Findings Inadequate System Understanding
Inadequate Situational Awareness
Inadequate Tree Trimming
Inadequate Reliability Center Diagnostic Support

17. Congressional Action Energy Policy Act of 2005 “Section 215”
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.

18. 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

19. Implementing Section 215 SECTION 215
Creates Electrical Reliability Organization (ERO)
FERC names NERC as ERO
Regional Entities
NERC selects 8 regional entities
WECC is selected for Western Interconnection
Delegation Agreement
NERC and WECC sign agreements
WECC oversight begins in Western Interconnection

20. Development of Mandatory Reliability Standards
Operations and Planning (O&P) Standards become mandatory and enforceable
June17, 2007 (FERC Order 693)
Critical Infrastructure Protection (CIP) standards become
mandatory and enforceable December 2009
(FERC Order 706)

21. 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

22. WECC Compliance Registers Entities Monitors Compliance with Standards
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
Administration
Audit coordination
Reporting systems

23. NERC Registration & Certification

24. Registration
Registered Functions determine applicable standards

25. Compliance Monitoring Activities
Onsite Audit
Offsite Audit
Self Reports
Self Certifications
Spot Checks
Compliance Violation Investigations
Complaints

26. Enforcement Activities
If a violation is identified, due process includes
Notice of Alleged Violation and Penalty or Sanction
Registered Entity Response
Request for Settlement or Hearing
NERC Approval
FERC Approval

27. Enforcement Activities
Mitigation of Violations
Prompt mitigation of violations and of risk to BES is important
Mitigation is not an “admission of guilt”
WECC reviews mitigation plans and accepts, rejects or requests revisions
WECC reviews completion of mitigation activities

28. Outreach
Compliance User Groups/ Critical Infrastructure Compliance User Groups
Open WebEX - Monthly
Targeted Training
CIP 101
WebCDMS and EFT
E-learning Modules
Compliance 101

29. 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

30. Questions?
Constance B. White
Vice President of Compliance