1. Seattle City Light Reliability Standards Compliance Program Presented To the APPA January 10 th, 2007 By Chris Turner

2. Compliance Program Compliance ranges across multiple departments in the company. Compliance ranges across multiple departments in the company. Sufficient authority needed by the compliance director to get results Sufficient authority needed by the compliance director to get results A SCL NERC Reliability Compliance Steering Committee was established. A SCL NERC Reliability Compliance Steering Committee was established. –Composed of executive sponsorship and all necessary department directors

3. Compliance Program The Director of System Operations was given responsibility for overseeing compliance and heading effort The Director of System Operations was given responsibility for overseeing compliance and heading effort Protocols and processes to manage the flow of information were developed – these will evolve Protocols and processes to manage the flow of information were developed – these will evolve A compliance matrix (spreadsheet) was developed A compliance matrix (spreadsheet) was developed

4. Issues and Structure How to communicate/process/implement How to communicate/process/implement –New standards –Changes to existing standards –Regional standards Where will records and documentation required by standards reside Where will records and documentation required by standards reside Who will assign standards and requirements Who will assign standards and requirements

5. Issues and Structure Standards were broken down by requirement – over 1,400 requirements Standards were broken down by requirement – over 1,400 requirements Each requirement was assigned to a department director Each requirement was assigned to a department director Each director assigns a person to be responsible for that requirement Each director assigns a person to be responsible for that requirement Creates a clear communication stream and accountability for compliance Creates a clear communication stream and accountability for compliance

6. Issues and Structure If we are in compliance and level of non- compliance tracked If we are in compliance and level of non- compliance tracked Action plan to become compliant tracked Action plan to become compliant tracked Departments encourage to list when they are non-compliant Departments encourage to list when they are non-compliant One FTE added to assist with compliance One FTE added to assist with compliance New regional standards will add to the load New regional standards will add to the load

7. Issues and Structure Support for compliance comes from the top – superintendent and officers Support for compliance comes from the top – superintendent and officers Budget needs being addressed per department in the budget process Budget needs being addressed per department in the budget process Enhanced focus on now mandatory standard compliance is changing some processes in the company – somewhat a culture change Enhanced focus on now mandatory standard compliance is changing some processes in the company – somewhat a culture change

8. Issues and Structure Compliance program will continue to evolve as more experience is gained and lessons learned exchanged Compliance program will continue to evolve as more experience is gained and lessons learned exchanged