1. 1 FRCC Compliance Organization and Entity Registration 2008 FRCC Compliance Workshop

2. 2 FRCC Compliance Organization FRCC is a Regional Entity with delegated responsibility and authority from NERC and FERC to monitor, assess, and enforce compliance with Reliability Standards NERC provides oversight of the FRCC compliance program FERC provides oversight of the NERC and FRCC compliance programs

3. 3 FRCC Compliance Organization Organization Basics  FRCC Compliance Staff  FRCC Compliance Committee  FRCC Board of Directors  FRCC Board Compliance Committee  FRCC Compliance Advisory Panel

4. 4 FRCC Compliance Staff Linda Campbell – Vice President and Executive Director of Standards & Compliance Barry Pagel – Manager of Compliance Jim Dodge – Compliance Auditor Richard Gilbert – Compliance Auditor Madelin Alba – Compliance Program Administrator Currently have 3 vacant positions

5. 5 Entity Registration September 3, 2006 - Federal Energy Regulatory Commission, (FERC) issued Order 672. The order directs owners, operators and users of the bulk power system to be registered with the Electric Reliability Organization (NERC). FERC recognized the functional model as the best method for determining who must comply with the Reliability Standards.

6. 6 Entity Registration FRCC maintains a proactive registration process  The owners, operators and users of the bulk electric system maintain the responsibility to become a registered entity.  Organizations shall register for any functional designation applicable to them as soon as it becomes aware of its responsibility to register.  Changes to a registered entity’s status are to be submitted to the FRCC within 30 days of becoming known.

7. 7 FRCC Registration Summary The FRCC currently has 79 Registered Entities covering 250 functions 1 1116 1381 RCs BAsTOPs PAsTSPsRSGs 141225 RPsTPsTOs 26 DPs 413826 GOsGOPsPSEs 18 LSEs

8. 8 Entity Registration NERC Current Registry Criteria is Revision 4.0 Latest version includes the function type – Interchange Authority, approved by FERC 2/5/08 No other changes from Revision 3.1 Registry Criteria promotes: Consistency between regions and across the continent, and; Requires that any entity reasonably deemed material to the reliability of the bulk power system will be registered, irrespective of other considerations.

9. 9 Entity Registration Criteria Load Serving Entities  Peak Load > 25MW or,  Responsible for UFLS facilities or,  Responsible for UVLS facilities Distribution Provider  System serving > 25 MW or,  Responsible for UFLS facilities or,  Responsible for UVLS facilities or,  Responsible for required SPS

10. 10 Entity Registration Criteria Generator Owner/Operator  Individual Unit > 20 MVA or,  Generating Plant/Facility >75 MVA or,  Black-start unit part of restoration plan or,  Any generator material to reliability Transmission Owner/Operator  Transmission element 100 KV or above, or lower voltage defined by FRCC as necessary for reliable operation of the grid, or that is included on a critical facilities list defined by FRCC.

11. 11 Entity Registration Criteria Joint Registration Organization  May register on behalf of one or more of its members  Must accept compliance reporting responsibility for all standards applicable to the members that it registered on behalf of  Shall provide FRCC with an annual “Agency Member Registry”  Must identify primary compliance contact

12. 12 Entity Registration Criteria Joint Registration  May agree on division of compliance responsibility for one or more applicable reliability standards applicable to that functions  Must have written agreement to clearly specify respective responsibilities  Both entities register for the applicable function  Must provide FRCC detailed description of division of responsibilities

13. 13 Disputed Registrations Entities may be in disagreement with the FRCC regarding the appropriate functions for their company.  The FRCC and the entity will attempt to resolve the difference.  FRCC will submit to NERC the registration it believes is best supported by the registration criteria.  Entity may appeal the registration at NERC

14. 14 Changes to Registration The FRCC has a form to use if a Registered Entity needs to change its functional registration The form can be found on the FRCC Compliance Website In certain cases, the FRCC may require copies of agreements between entities if there is a transfer of responsibility

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