1 / 10

FFT Presentation

FFT Presentation. Constance White, Vice President of Compliance May 14, 2011 WECC Compliance Committee. WECC’s violation processing before the FERC Order (Dec 2011 – March 2012). FFT (Find, Fix, Track) 31 Violations, 18.5% Expedited Settlement Agreement 73 Violations, 43.5%

miette
Télécharger la présentation

FFT Presentation

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. FFT Presentation Constance White, Vice President of Compliance May 14, 2011 WECC Compliance Committee

  2. WECC’s violation processing before the FERC Order (Dec 2011 – March 2012) • FFT (Find, Fix, Track) 31 Violations, 18.5% • Expedited Settlement Agreement 73 Violations, 43.5% • NOP (Notice of Alleged Violation) 64 Violations, 38.1%

  3. Criteria – FERC Order Criteria from the FERC order Minimal Risk • “No adverse impact” not a reason in itself that the violation posed a minimal risk • Risk must be based on facts, not assumptions and on facts at the time of the violation • No minimal risk if there are serious shortcomings in an entity’s reliability-related processes • If an entity has a programmatic failure a violation cannot pose a minimal risk • Aggregate risk of multiple violations may not pose a minimal risk (Red shows where WECC’s practices before the order were consistent with criteria in the order)

  4. Criteria – FERC Order-cont’d Mitigation • Violation must be mitigated • Affidavit signed by an officer of the company must be submitted Self reporting is a factor (Red shows where WECC’s practices before the order were consistent with criteria in the order)

  5. Impact of the FERC Order on WECC One criterion in FERC’s order is slightly more liberal than WECC’s FFT screening practices before the order: Violations can pose slightly more risk to the BES, although still must be minimal (Red shows where FERC order is different from WECC’s criteria pre-order)

  6. Impact of the FERC Order-cont’d One new requirement added: • FERC requires an affidavit, signed by an officer, attesting to mitigation, and describing preventive measures • Order was silent on requirement for formal Mitigation Plan • Affidavit is required whether or not there is a formal MP • NERC filed for rehearing/clarification on the affidavit issue

  7. FFT Candidates: Additional Considerations Additional considerations WECC uses, but were not explicitly discussed in the FERC FFT Order • Repeat violations (we are following existing guidance from FERC) • Compliance history (existing guidance from numerous FERC orders addressing the topic)

  8. Standards and Requirements to date • 68% of WECC’s FFTs are from 6 standards: • CIP-002 (Critical Cyber Asset Identification) • CIP-004 (Personnel and Training) • CIP-005 (Electronic Security Perimeter(s)) • CIP-007 (Systems Security Management) • VAR-002 (Reactive and Voltage Control) • VAR-501-WECC (Power Systems Stabilizer) • 62% of WECC’s FFTs involve CIP standards

  9. Standards and Requirements • FERC invited NERC to make specific proposals identifying the standards or requirements which should be revised or removed and setting forth technical basis • FERC invited NERC, Regional Entities and other interested entities to propose appropriate mechanisms to identify and remove unnecessary or redundant requirements • FERC: These three groups are asked to “coordinate to submit their respective comments concurrently”

  10. Questions? Constance White Vice President of Compliance Western Electricity Coordinating Council cwhite@wecc.biz 801-883-6855

More Related