1. Compliance Program Update Lisa Milanes Manager of Compliance Administration

2. Compliance Program UpdateSelf-Certification What is a “Self-Certification”? • Stated in CMEP: REs are required to self-certify their compliance on an annual basis • Policy: Annual Self-Certification required, regardless if RE is scheduled for On-site or Off-site Audit during the year • Forms are posted to the WECC website • According to quarterly schedule

3. Compliance Program UpdateSelf-Certification Schedule

4. Compliance Program UpdateSelf-Certification Process • Current process: • Forms posted to Compliance Manuals webpage • REs notified of Self-Certification (30 days prior) • REs will sign in and fill out forms • Submit to Compliance Dept. within submittal period (10 days) • Future Process: • Forms will be posted electronically via web portal • REs notified of Self-Certification via web portal • REs will sign in and fill out forms electronically • Submit via web portal

5. Compliance Program UpdateSelf-Certification Results Q4 2007 (BA, TOP, TO, RC, and RSG): • Received 86 Self-Certification submittals • 5 “Notice of Non-Submittals” were sent • Received 4 in response to Non-Submittal Notices • Still waiting on 1 response • 16 new violations (total) • Response letters will be sent this week

6. Compliance Program UpdateSpot Check • What is a “Spot Check”? • Defined in CMEP: To verify or confirm Self-Certifications, Self Reporting, and Periodic Data Submittals. Spot Checks may also be random or may be initiated in response to events, as described in the Reliability Standards, or by operating problems, or system events. • Policy: If an RE has had an audit within 12 months prior, they will not be subject to a Spot Check. All other REs will be subject to a Spot Check. This process is used to validate Self-Certification submittals. • REs will know when the Spot-Check will occur, but will not know which standard(s) will be selected

7. Compliance Program UpdateSpot Check Process • Receive “Notice of Spot Check” approx. 15 days after Self-Certification period • RE made aware of which standards are Spot Checked within the “Notice of Spot Check” • 20 days to submit evidence

8. Compliance Program UpdateSpot Check Results Q1 2008 (BA, TOP, TO, RC, and RSG): • Currently reviewing Spot Check submittals • Should be completed by April 4th, 2008 • Response letters will be sent the following week

9. Compliance Program UpdateRSAW RSAW = Reliability Standard Audit Worksheet • Provide guidance to compliance auditors in assessing compliance with the reliability standards • Provide consistency across all regions • Used for any type of audit • Could be used by internal compliance programs

10. Compliance Program UpdateRSAW Development Process • Each regional entity provides input into the development of RSAWs • A member of the NERC standards committee also participates in review process • Thorough review by the NERC Standards department and NERC legal department to assure RSAWs do not exceed the boundaries of the Reliability Standard requirements

11. Compliance Program Update2008 RSAWs • Additional RSAWs added in 2008: BAL-004-0 BAL-005-0 BAL-006-1 BAL-STD-002-0 COM-002-2 EOP-002-2 EOP-004-1 FAC-013-1 INT-001-2 INT-003-2 INT-004-1 IRO-003-2 IRO-005-1 IRO-006-3 IRO-STD-006-0 TOP-002-2 TOP-004-1 VAR-002-1 • RSAW for all NERC Actively Monitored Standards

12. Compliance Program UpdateWhere to find the RSAWs • WECC Compliance Manuals webpage, Manual 4: http://www.wecc.biz/wrap.php?file=/wrap/Compliance/manuals.html • NERC website: http://www.nerc.com/~comply/auditor_resources.html

13. Compliance Program UpdateRSAW Feedback • Who to contact? • Contact your Regional Entity (WECC) • Region will consider the comments • If Region agrees, comments will be forwarded to NERC for review and approval • If NERC agrees, the suggested revisions will be incorporated into the RSAW

14. Questions? Lisa MilanesManager of Compliance Administration Western Electricity Coordinating Council615 Arapeen Drive, Suite 210 Salt Lake City, Utah 84108-1262 801.883.6867