Lee County Electric Cooperative, Inc. BUILDING A Compliance Program
Background A Not-For-Profit Florida Corporation Providing electric service in Southwest Florida since 1940 Five Counties (Lee, Collier, Hendry, Glades, Charlotte) One of the largest electric cooperatives in the US Governed by a Board of 10 Trustees Purchase power (no generation) Seminole Electric Cooperative, Inc. (SECI) Florida Power and Light 2
Company Facts 199,000 Members 8,076 miles of energized line 3,495 GWH Annual Sales All-Time System Peaks 798 MW Summer (August 2007) 1,112 MW Winter(February 2010) 3
Service Territory 4
GUIDING PRINCIPLES VISION Delivering the power that energizes our communities. MISSION We provide efficient, reliable, cost-competitive electric service, emerging energy solutions and excellent service to our customers. CORE VALUES Safety as everyone s responsibility Quality external and internal customer service Integrity, diversity and respect Employees working together to make success happen Accountability for results Responsibility to energize the community 5
NERC Registration Distribution Provider DP Load Serving Entity LSE Transmission Operator TOP Transmission Owner TO Transmission Planner TP 6
Challenges Define the Role of the Compliance Department Develop the Organizational Structure Develop interactive procedures & protocol for inter-departmental cooperation Develop Internal Compliance Program 7
Challenges The Role of the Compliance Department All Compliance Activities will be directed by the Compliance Department All correspondence with FERC/NERC/FRCC Audits Self Certification Spot Check All Reliability Standards document review schedule Assign Managers /SME to appropriate standard Set Mock Audit Schedule All Audit activities 8
Challenges The Role of the Compliance Department Other Activities directed by the Compliance Department NERC Alerts NERC/FRCC RBBS DADS Reporting Monitor TADS data Supporting documentation data entry into ROG 9
Organizational Structure Executive Steering Committee Board of Trustees Dennie Hamilton Executive Vice President & Chief Executive Officer Frank Cain Dir, Regulatory/Govt. Relations, Chief Risk/Compliance Officer Denise Vidal Director, Finance & Accounting Rick Fuson Director, Electric Operations Kathy Irwin Director, Human Resources Frederic Kunzi Director, Information Technology & Chief Information Officer Joe Padgett Director, Customer Information Services Compliance Department John Chin David Hadzima 10
Rick Fuson Director, Electric Operations Organizational Structure Compliance Department Clark Hawkins SME Manager, Design & Engineering Bob Grover SME Manager, System Operations Ed Nagy SME Head of IT Infrastructure Bob Tomlin SME Manager, Technical Services Allan Ruth SME Manager, Construction & Maintenance Kathy Irwin SME Director, Human Resources Compliance Team Compliance Team Compliance Team Compliance Team Compliance Team Compliance Team Compliance Department John Chin and David Hadzima Frank Cain Dir, Regulatory & Governmental Relations, Chief Risk/Compliance Officer Audits Standards Review/Interpretation Notification Record Keeping 11
Challenges Develop interactive procedures & protocol for inter-departmental cooperation Create a central repository for all Reliability Standards Documents Assign Keeper of the Keys for control of all Reliability Standards documents Create a revision control procedure for all Reliability Standards documents Create a procedure for document preparation for Reliability Standards documents Create a Mock Audit procedure and schedule Create a GAP Analysis Spreadsheet for Mock Audit results 12
Central Repository (Secured-limited access shared file OATI on Fs) This Shared File contains all documents regarding Compliance Audit 2012 Compliance Gap Analysis Planning Authority Standards If it isn t documented it didn t Happen 13
Standards Section of OATI on Fs (This Section of the Shared file Contains the Standards) The Standards Shared File contains the LCEC policy document (MS Word document), the RSAW folder, Archive folder and the Supporting Documentation folder. The following is the convention used for all the standards folders: Archive Folder RSAW Folder Supporting Document Living Document COM-001-1.1 If it isn t documented it didn t happen 14
NERC Reference Number: COM-001-1.1 Living Document Lee County Electric Cooperative, Inc. Operating Policies Telecommunications Purpose: Each Reliability Coordinator, Transmission Operator and Balancing Authority needs adequate and reliable telecommunications facilities internally and with others for the exchange of Interconnection and operating information necessary to maintain reliability. Scope: LCEC assures reliable and continuous operation of the Bulk Electric System with redundant, diversely routed voice and data facilities to communicate with LCEC operating personnel and Bulk Electric Operating entities including Balancing Authorities, Generator Operators, and Reliability Coordinators. SO-SOP 230 Sec. 3.0 Requirements: R1. Each Reliability Coordinator, Transmission Operator and Balancing Authority shall provide adequate and reliable telecommunications facilities for the exchange of Interconnection and operating information: R1.1 Internally. R1.2 Between the Reliability Coordinator and its Transmission Operators and Balancing Authorities. R1.3 With other Reliability Coordinators, Transmission Operators, and Balancing Authorities as necessary to maintain reliability. R1.4 Where applicable, these facilities shall be redundant and diversely routed. LCEC takes several precautions to ensure primary communications are flexible and robust enough to recover from minor communication disruptions at the PCC. Communications from the PCC include analog and digital voice line communications, analog data communications, RC Hotline, mobile cellular phone communications, satellite phone communications, email, and multi-channel radio communications. These redundant diversely routed communication methods provide for adequate and reliable telecommunications for the exchange of interconnection and operating information internally and between LCEC, Transmission Operators, Reliability Coordinators, and Balancing Authority to maintain the reliability of the Bulk Electric System. If it isn t documented it didn t happen 15
OATI webcompliance Software (Keeper of the Keys-Compliance Department) If it isn t Documented it didn t Happen 16
OATI webcompliance Software (Keeper of the Keys-Compliance Department) If it isn t Documented it didn t Happen 17
Mock Audit Schedule-2012 Standard SME Audit Date Date Completed CIP-001-2a Manager /Sys Ops 6/12 7/12 CIP-002-3 FAC-001-0 FAC-003-2 PRC-005-1a Head/IT Infrastructure Manager/Design & Engineering Manager/Construct ion & Maintenance Manager/ Technical Services 6/12 7/12 9/12 10/12 7/12 8/12 7/12 8/12 18
GAP Analysis 19
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Internal Compliance Program Table of Contents Purpose of this document Who should use this document Introduction-About LCEC Compliance Program Objective Communications Compliance Team Structure Registered Entity Status Reliability Standards-Compliance Monitoring Documentation Database and Submittal Tools Monitoring Request Training Program Discipline Procedure Time Frame and Period Definitions Document Control 21
Training & Awareness Monthly Meetings with Department Managers Attend all NERC webinars- Managers, SMEs and Compliance Staff Attend all FRCC workshops Managers, SMEs and Compliance Staff RE Compliance Committee & Member Services Committee members All meetings and training require sign in sheets. Articles about Compliance are placed into the company magazine Connections ICP and FRCC workshop presentations are placed into Linus (LCEC intranet) for review by all employees. Compliance Metrics presentation is presented quarterly to CEO and ESC 22
Training & Awareness Metric Presentation 23
Sign-In Sheets 24
Connections Magazine NEWS from the World of Regulatory Compliance Hello and Season s Greetings from your Regulatory Compliance Department Recently NERC ( North American Electric Reliability Corporation) and the FRCC ( Florida Regional Reliability Council) released the 2012 CMEP ( Compliance Monitoring and Enforcement Program) on their respective websites for review by all the registered entities, of which LCEC is one. These documents contain the implementation plan for regulatory compliance for the entire Industry for the year 2012. Among the items listed in the CMEP are the registered entities that have been scheduled for an On-Site Compliance Audit as well as those entities that will provide Self-Certification documentation. LCEC will be participating in both the Self-Certification process in January 2012 and the On-Site Compliance Audit scheduled for the week on November 26 through November 30, 2012. Both these documents are available to LCEC employees on Linus under Employee Info/Compliance & Ethics: NERC 2012 CMEP Implementation Plan and FRCC 2012 CMEP Implementation Plan. If you have questions regarding these documents or regulatory compliance in general, please contact Bill Miller or John Delucca. 25
Appendix F Mock Audit Schedule 2012 Compliance Program Mock Audit Schedule STANDARD SME Audit Date Date Completed BAL-005-0.1b Bob Grover 7/12 CIP-001-2a Bob Grover 6/12 7/5/2012 CIP-002-3 Ed Nagy 6/12 Audited CIP-003-3 Ed Nagy 6/12 Audited COM-001-.1 Bob Grover 6/12 8/13/2012 COM-002-2 Bob Grover 3/12 3/22/2012 EOP-001-0b Bob Grover 3/12 3/7/2012 EOP-002-3 Bob Grover 5/12 4/16/2012 EOP-003-2 Bob Grover 3/12 3/23/2012 EOP-004-1 Bob Grover 4/12 3/7/2012 EOP-005-1 Bob Grover 612 7/9/2012 EOP-008-0 Bob Grover 6/12 7/10/2012 FAC-001-0 Clark Hawkins 9/12 8/13/2012 FAC-002-0 Clark Hawkins 9/12 8/22/2012 FAC-003-2 Allan Ruth 7/12 8/15/2012 FAC-008-1 Clark Hawkins 6/12 6/28/2012 FAC-009-1 Clark Hawkins 9/12 Audited FAC-014-2 Bob Grover 3/12 3/21/2012 INT-004-2 Bob Grover 3/12 3/7/2012 IRO-001-1.1 Bob Grover 5/12 6/11/2012 IRO-004-2 Bob Grover 5/12 5/32/2012 IRO-005-3a Bob Grover 12/12 8/29/2012 IRO-010-1a Bob Grover 10/12 10/1/2012 MOD-001-1a Clark Hawkins 11/12 MOD-004-1 Clark Hawkins 6/12 6/6/2012 MOD-008-1 Clark Hawkins 12/12 MOD-010-0 Clark Hawkins 11/12 11/20/2012 MOD-012-0 Clark Hawkins 11/12 11/12/30 MOD-017-0.1 Clark Hawkins 5/12 5/31/2012 MOD-018-0 Clark Hawkins 11/12 11/13/2012 MOD-019-0.1 Clark Hawkins 5/12 6/4/2012 26
QUESTIONS? 27