1. Overview of Tampa Electric’s Compliance Program APPA Reliability Standards and Compliance Program January 10, 2007

2. 2 Key Elements of Reliability Compliance Framework Design of program will be in the context of Federal regulatory and legal precedent on compliance Design of program will be in the context of Federal regulatory and legal precedent on compliance Program framework will be consistent with other compliance programs Program framework will be consistent with other compliance programs Business unit has responsibility and accountability for managing program Business unit has responsibility and accountability for managing program Independent oversight of program by Regulatory Compliance Officer responsible for all compliance programs Independent oversight of program by Regulatory Compliance Officer responsible for all compliance programs

3. 3 FERC – Transitioning from Regulation of Services to Regulation of Behavior FERC has begun discharging their legal duties by setting rules of general application (behavior) FERC has begun discharging their legal duties by setting rules of general application (behavior) EPAct of 2005 and enabling FERC regulations EPAct of 2005 and enabling FERC regulations Expanded FERC’s Civil penalty to cover violations over any provision of Part II of the FPA Expanded FERC’s Civil penalty to cover violations over any provision of Part II of the FPA Increased civil penalty authority to $1M/day Increased civil penalty authority to $1M/day Policy Statement on Enforcement Policy Statement on Enforcement December 21, 2006 Administrative Policy December 21, 2006 Administrative Policy Expanded scope of criminal provisions of FPA, NGA and NGPA & increased maximum fines & imprisonment time Expanded scope of criminal provisions of FPA, NGA and NGPA & increased maximum fines & imprisonment time Clear message – enhancement & creation of compliance programs based on FERC Enforcement Policy & the Federal Sentencing Guidelines Clear message – enhancement & creation of compliance programs based on FERC Enforcement Policy & the Federal Sentencing Guidelines

4. 4 FERC Policy Statement on Enforcement Factors guiding the selection of enforcement remedies Factors guiding the selection of enforcement remedies Credit for internal compliance, self- reporting & cooperation Credit for internal compliance, self- reporting & cooperation Adopts or references enforcement policies of other agencies Adopts or references enforcement policies of other agencies DOJ Federal Sentencing Guidelines DOJ Federal Sentencing Guidelines Commodity Futures Trading Commission (CFTC) Commodity Futures Trading Commission (CFTC) Securities & Exchange Commission (SEC) Securities & Exchange Commission (SEC) Evolvement of FERC enforcement rules Evolvement of FERC enforcement rules A journey but FERC will use existing enforcement policies of the above agencies as a benchmark A journey but FERC will use existing enforcement policies of the above agencies as a benchmark

5. 5 Federal Sentencing Guidelines No established body of law interpreting FERC’s new policy No established body of law interpreting FERC’s new policy Guidelines represent critical history to benchmark FERC compliance programs Guidelines represent critical history to benchmark FERC compliance programs Incorporates U.S. Sentencing Commission premise that it would not be fair to impose harsh fines on organizations that had taken all reasonable steps to prevent criminal conduct Incorporates U.S. Sentencing Commission premise that it would not be fair to impose harsh fines on organizations that had taken all reasonable steps to prevent criminal conduct Guidelines establish criteria for an effective compliance program Guidelines establish criteria for an effective compliance program Guidelines are currently used in the industry as the basis for Corporate Compliance Programs Guidelines are currently used in the industry as the basis for Corporate Compliance Programs

6. 6 Federal Sentencing Guidelines – Compliance Program Criteria Periodic risk assessments Periodic risk assessments Standards & procedures to prevent/detect unlawful conduct Standards & procedures to prevent/detect unlawful conduct Directors’ program oversight responsibility Directors’ program oversight responsibility Senior officer(s) program responsibility Senior officer(s) program responsibility Specific individual delegated day-to-day operational responsibility Specific individual delegated day-to-day operational responsibility Background checks at hire & promotion Background checks at hire & promotion Communication of standards & procedures Communication of standards & procedures Auditing & monitoring, including internal reporting mechanisms Auditing & monitoring, including internal reporting mechanisms Periodic evaluation of the program Periodic evaluation of the program Promote and enforce the program consistently Promote and enforce the program consistently Respond appropriately to violations to prevent future occurences Respond appropriately to violations to prevent future occurences

7. 7 Compliance Programs Standards of Conduct (SOC) Standards of Conduct (SOC) Open Access transmission Tariff (OATT) Open Access transmission Tariff (OATT) Reliability Standards Reliability Standards FERC Anti-Manipulation Regulations (AMR) FERC Anti-Manipulation Regulations (AMR)

8. 8 Compliance Programs North American Energy Standards Board (NAESB) North American Energy Standards Board (NAESB) NERC cousin - business practices NERC cousin - business practices Tariff and Other Matters Tariff and Other Matters MBR & Cost Based Tariffs MBR & Cost Based Tariffs PUCHA Section 203 PUCHA Section 203 Interlocking Directorates Interlocking Directorates Periodic Reports & Filings Periodic Reports & Filings

9. Regulatory Compliance Framework Regulatory Compliance Officer Regulatory Compliance Administrator Specific Compliance Program Administrators & Support SOC OATT NAESB Reliability Transmission & Generation Standards Cyber-security Standards AMRCompliance Counsel Tariff & Other Matters

10. 10 Implementing the Regulatory Compliance Program Written delegation from Compliance Officer to specific program administrators (job descriptions) Written delegation from Compliance Officer to specific program administrators (job descriptions) Each Program Administrator will have primary responsibility and accountability for managing their compliance area Each Program Administrator will have primary responsibility and accountability for managing their compliance area Common template for each compliance area Common template for each compliance area Written procedures Written procedures Audit & Monitoring Audit & Monitoring Training Training Above items developed, revised and maintained by Program Administrators Above items developed, revised and maintained by Program Administrators

11. 11 Regulatory Compliance Program Process Quarterly reports developed for Regulatory Compliance Officer Quarterly reports developed for Regulatory Compliance Officer Coordination with TECO Energy Corporate Compliance Program Coordination with TECO Energy Corporate Compliance Program Administration of compliance programs overseen by Regulatory Compliance Administrator Administration of compliance programs overseen by Regulatory Compliance Administrator

12. 12 Reliability Program Next Steps – “Devil in the Detail” Integrate into existing company compliance structures as previously discussed Integrate into existing company compliance structures as previously discussed Outreach and education Outreach and education Make individual employees accountable for each requirement Make individual employees accountable for each requirement Determining what standards are applicable - NERC functional model registration Determining what standards are applicable - NERC functional model registration Identifying what constitutes compliance for each standard and requirement Identifying what constitutes compliance for each standard and requirement 118 standards, 1234 requirements! 118 standards, 1234 requirements!

13. 13 QUESTIONS? Greg Ramon gjramon@tecoenergy.com 813-228-4469