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Technical Feasibility Exceptions (TFEs) ReliabilityFirst CIP Webinar Thursday, September 30, 2010 Steve Garn, Sr. Engineer
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Discussion Topics TFE Part B Reviews TFE Reporting TFE Team Questions? 2 © ReliabilityFirst Corporation
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TFE Part B – Review Entity submits TFE Part B information via secure means RFC performs Substantive Review of TFE Part B Latest Part A Quantity of covered assets compared to Part A Verification from vendors of Entity assertions Evidence of Compensating Measures and Mitigation Measures Dates compared to Part A Signed by Senior Manager or Delegate RFC issues Approve or Disapprove decision on Part B Decision notice issued within one year of Part A submittal If Disapprove, include reasons why and set “Effective Date” 3 © ReliabilityFirst Corporation
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TFE Part B – Amendments Entity may “Request Amendment” when TFE is in the following states: “Disapproved” “Approved” Cannot have more than one “Amendment” pending at a time Normal reasons to amend: Quantity of covered assets goes up Dates changed Errors in original submittal 4 © ReliabilityFirst Corporation
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TFE Part B – Disapprovals Asset quantity exceeds that in Part A Missing verification from the vendors Vendor’s Operating Guide “Silence is Golden” is not true Impact assessment does not include the effect on the asset AND the BES if the compensating and mitigating measures fail No commitment to file Quarterly and/or Annual Reports 5 © ReliabilityFirst Corporation
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TFE – Miscellaneous For new TFE for new assets, must submit Part A before asset connected to the network and turned on 60 days ahead would be ideal Changes to asset quantities should be put in the TFE Summary Spreadsheets and submitted with the Quarterly Reports After Amending a Part A, submit the associated Part B 6 © ReliabilityFirst Corporation
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TFE Reporting by Entity Entity Reporting Requirements for Approved TFEs Quarterly Reports Annual Reports 30 days prior to Expiration Date All reports must be signed and dated by the Senior Manager or Delegate and include a statement that they have read and approved the report 7 © ReliabilityFirst Corporation
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TFE Quarterly Report Draft 1 8 © ReliabilityFirst Corporation
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TFE Quarterly Report Draft 1 – Col. 1-4 9 © ReliabilityFirst Corporation TFE Unique ID Approval Date Applicable Requirement of TFE Are there any changes to Device Count? If yes, please explain. Submit new TFE Summary Spreadsheet
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TFE Quarterly Report Draft 1 – Col. 5-6 10 © ReliabilityFirst Corporation Are all compensating and/or mitigating measures being implemented as described in the approved TFE? If not, please explain. Has the proposed time schedule for implementing the proposed compensating and/or mitigating measures in the approved TFE changed? If yes, please explain.
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TFE Quarterly Report Draft 1 – Col. 7-9 11 © ReliabilityFirst Corporation Has the proposed plan and/or time schedule for achieving strict compliance with the Applicable Requirement changed? If yes, please explain. Entity Primary Contact Entity Primary Contact Phone
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TFE Quarterly Report Draft 1 – Certification 12 © ReliabilityFirst Corporation
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TFE Quarterly Report Draft 2 – Top 13 © ReliabilityFirst Corporation
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TFE Quarterly Report Draft 2 – Middle 14 © ReliabilityFirst Corporation
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TFE Quarterly Report Draft 2 – Bottom 15 © ReliabilityFirst Corporation
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TFE Team Steve Garn (Lead) 330-247-3086 Karen Yoder330-247-3078 Mike Ketchens330-247-3079 Call any of us at any time 16 © ReliabilityFirst Corporation
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Questions Questions should be emailed to Karen Yoder (karen.yoder@rfirst.org) Subject: “CIP WEBINAR”karen.yoder@rfirst.org Questions will be considered in the order they are received Clarifying questions are welcome and we will do our best to answer during the question period Challenges to a position should be addressed to the presenter and will be taken offline
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