1. Overview of WECC and Regulatory Structure
Matthew Moore
Manager of Enforcement
Good afternoon, and welcome to the series of Compliance 101 videos. Our goal in producing these segments is, of course, for you to learn the basics of what we do at WECC, why we do it, and indeed what your role is and what you can expect from us. I will give you the high level overview of how we got to where we are, where our authority comes from, why we are doing this, and how WECC come to be.

2. WECC Profile
The Western Electricity Coordinating Council (WECC) is a 501(c)(4) social welfare organization 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.
WECC is anon-profit organization, specifically with the IRS status as a social welfare organization. WECC is the largest of the eight regional entities with delegated authority to monitor and enforce mandatory reliability standards, we cover 14 western states, two canadian provinces and a part of Baja California in Mexico. We exist in part to assure the reliability of the bulk electric system throughout this western interconnection.

3. 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
Bifurcation in February 2014 changed functions
To best understand where we are today, it is important to know our history. While WECC was incorporated in 2002, the predecessor organization, the Western States Coordinating Council formed in 1967; this organization did some similar functions that we still do today.
While we are a non-governmental organization, we do have powers that have been delegated to us by government. I mentioned we are a social welfare organizations, acting in the public interest, however, we have many partners in achieving our mission including industry and other stakeholder participation and partnerships.
For those who may be somewhat familiar to WECC but may not be keeping specifically up to the date, historically WECC was Reliability Coordinator, operating in Loveland Colorado and Vancouver Washington, as well as an Interchange Authority. In 2014, WECC spun off or bifurcated such that we no longer perform those functions.

4. WECC Coverage Service Area
1.8 million square miles
126,285 miles of transmission
Population of 78 million
WECC is the largest and most diverse of the eight regional entities, coving almost two million square miles and significant population with most densely populated areas and rural areas throughout the western US, Canada, and Mexico.

5. I have said a few times now that WCC is one of eight regional entities with authority delegated to them by NERC. This map shows all eight regional entities. WECC and Texas are the only regional entities that cover an entire interconnection with six organizations covering the eastern interconnection.

6. WECC Organization Independent Board of Directors 9 members Committees
Members Advisory Committee
Members
Grid owners, operators, users
Stakeholders
State and Provincial
With a recent reorganization, WECC’s 9-member board is made if of independent board members and is advised by a number of committees including a committee that represents membership’s interests.

7. 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
So, with that history and governance overview as context What does WECC do? What does it mean to perform as a social welfare organization? We provide services, including transmission expansion planning that benefits the industry as well as polocy makers

8. 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

9. WECC Services Delegation Agreement
Perform functions delegated to WECC as a Regional Entity under Delegation Agreement with NERC, including;
facilitating development of western interconnection reliability standards
conducting reliability assessments and event analysis
regulating entities subject to mandatory Reliability Standards

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

12. 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.

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

14. 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.

15. 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

16. 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

17. 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

18. WECC Compliance Recommends Registrations for Entities
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
webCDMS and EFT

19. Reliability Standards
Authority
CMEP
Reliability Standards
Delegation Agreement
Federal Power Act 2005

20. Registration Registration Authority
WECC recommends registration to NERC based on functions
New tool
Discussed by Brittany Power later
Authority

21. Monitoring Other Self Certifications Registration Self Reports Audits
Onsite Audit
Offsite Audit
Self Reports
Self Certifications
Spot Checks
Compliance Violation Investigations
Complaints
Authority

22. Enforcement Mitigation Actions Settlement Registration Monitoring
Risk Assessments
Mitigation Actions
Settlement
Due Process
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
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
Authority

23. Reference Documents
Compliance Monitoring and Enforcement Program (CMEP) & WECC’s annual implementation plan
Delegation Agreement
Rules of Procedure
NERC Reliability Standards
NERC Guidance, Bulletins, Directives and Compliance Application Notices (CANs)
FERC Orders