Compliance Program Update Lisa Milanes Manager of Compliance Administration

2 Compliance Program Update Self-Certification What is a “Self-Certification”? ● Stated in CMEP: REs are required to self-certify their compliance on an annual basis ● Policy: Annual Self-Certification required, regardless if RE is scheduled for On-site or Off-site Audit during the year ● Forms are posted to the WECC website  According to quarterly schedule

3 Compliance Program Update Self-Certification Schedule

4 Compliance Program Update Self-Certification Process ● Current process:  Forms posted to Compliance Manuals webpage  REs notified of Self-Certification (30 days prior)  REs will sign in and fill out forms  Submit to Compliance Dept. within submittal period (10 days) ● Future Process:  Forms will be posted electronically via web portal  REs notified of Self-Certification via web portal  REs will sign in and fill out forms electronically  Submit via web portal

5 Compliance Program Update Self-Certification Results Q (BA, TOP, TO, RC, and RSG): ● Received 86 Self-Certification submittals ● 5 “Notice of Non-Submittals” were sent  Received 4 in response to Non-Submittal Notices  Still waiting on 1 response ● 16 new violations (total) ● Response letters will be sent this week

6 Compliance Program Update Spot Check ● What is a “Spot Check”? ● Defined in CMEP: To verify or confirm Self-Certifications, Self Reporting, and Periodic Data Submittals. Spot Checks may also be random or may be initiated in response to events, as described in the Reliability Standards, or by operating problems, or system events. ● Policy: If an RE has had an audit within 12 months prior, they will not be subject to a Spot Check. All other REs will be subject to a Spot Check. This process is used to validate Self-Certification submittals. ● REs will know when the Spot-Check will occur, but will not know which standard(s) will be selected

7 Compliance Program Update Spot Check Process ● Receive “Notice of Spot Check” approx. 15 days after Self-Certification period ● RE made aware of which standards are Spot Checked within the “Notice of Spot Check” ● 20 days to submit evidence

8 Compliance Program Update Spot Check Results Q (BA, TOP, TO, RC, and RSG): ● Currently reviewing Spot Check submittals ● Should be completed by April 4 th, 2008 ● Response letters will be sent the following week

9 Compliance Program Update RSAW RSAW = Reliability Standard Audit Worksheet ● Provide guidance to compliance auditors in assessing compliance with the reliability standards ● Provide consistency across all regions ● Used for any type of audit ● Could be used by internal compliance programs

10 Compliance Program Update RSAW Development Process ● Each regional entity provides input into the development of RSAWs ● A member of the NERC standards committee also participates in review process ● Thorough review by the NERC Standards department and NERC legal department to assure RSAWs do not exceed the boundaries of the Reliability Standard requirements

11 Compliance Program Update 2008 RSAWs ● Additional RSAWs added in 2008: BAL-004-0BAL BAL-006-1BAL-STD COM-002-2EOP EOP-004-1FAC INT-001-2INT INT-004-1IRO IRO-005-1IRO IRO-STD-006-0TOP TOP-004-1VAR ● RSAW for all NERC Actively Monitored Standards

12 Compliance Program Update Where to find the RSAWs ● WECC Compliance Manuals webpage, Manual 4: anuals.html ● NERC website:

13 Compliance Program Update RSAW Feedback ● Who to contact?  Contact your Regional Entity (WECC)  Region will consider the comments  If Region agrees, comments will be forwarded to NERC for review and approval  If NERC agrees, the suggested revisions will be incorporated into the RSAW

14 Questions? Lisa Milanes Manager of Compliance Administration Western Electricity Coordinating Council 615 Arapeen Drive, Suite 210 Salt Lake City, Utah