1 Compliance Report WECC Board of Directors Meeting December 7-8, 2006 Steve Rueckert Director, Standards and Compliance

2 Presentation Overview RMS Criteria 6th Amendment 2006 Compliance Enforcement Program Status Entity Registration 2007 Compliance Program

3 RMS 6 th Amendment Filed with FERC on October 31, 2006 WECC requested that the Sixth Amendment become effective on the day after filing (November 1, 2006) and the Amendment become effective on the date specified by the FERC. –This waves Section 13.4 that stipulates an amendment shall take effect 30 days after the date of an order issued by FERC accepting such amendment for filing. –FERC is not expected to rule on this request until at least mid December Monetary Sanctions for violations of the Operator Certification by Transmission Operators begin January 1, 2007

4 Sixth Amendment to RMS Criteria Revision to Control Area definition Added additional definitions RMS requirements cease upon approval of equivalent NERC Reliability Standard Operator Certification applicable to TOP Additional Excuse of Performance Provision for Field testing

Compliance Results to Date Total number of RMS violations is down 97 vs. 55 Third quarter 27 vs. 6 –Currently 2 TOP not meeting Operator Certification requirements Tagging violation resolved Biggest concern at this point is repeat violations.

Compliance Results to Date NERC Compliance results are being tabulated as we speak Readiness Audit Probable Violations included in 2006 NERC Penalty and Sanction Calculations Biggest concern is repeat violations

7 Entity Registration Registration information continues to come in Received Northwest registration package, as promised, on December 1 –Added 103 entities –Most were LSE and DP –Will be added to WECC Registry Will take WECC Registry to approximately 220 entities

8 Entity Registration NERC just posted a revised Statement of Compliance Registry –Includes Joint Action Agency Registration instructions Most current information to be provided to NERC on December 15

9 Entity Registration Begin Phase Two activities in January –Identify entities who have not voluntarily registered Information from other BA or TOP TSIN Registry –Notify entities that are added to the registry –Entities may challenge addition to registry Verification and validation process of registry due to NERC March 2, 2007

10 Responsible Entity Registration Organizations in compliance registry are subject to compliance and enforcement programs Registered organizations must comply with approved reliability standards

11 Responsible Entity Registration Organizations listed in the registry are responsible and will be monitored for complying with approved mandatory standards WECC will not monitor those not listed in the registry An organization not listed in compliance registry, but which should be, will be added by WECC but has the right to challenge

Compliance Program Develop 2007 WECC Compliance Enforcement Program Implementation Plan Roll-out Workshop in January-February time frame Additional Regional Compliance workshops to address Compliance Audits and compliance requirements –May also address Readiness Audits Working on 2007 Compliance Audit Schedule

13 Compliance Report WECC Board of Directors Meeting December 7-8, 2006 Questions?