Background
The Energy Policy Act of 2005 authorized the Federal Energy Regulatory Commission (FERC) to oversee the development and enforcement of mandatory reliability standards for the bulk power system. Violations of the standards could result in civil penalties as high as $1 million per violation per day.
FERC designated the North American Electric Reliability Corporation (NERC) as the Electric Reliability Organization (ERO). As the ERO, NERC has promulgated more than 100 continent-wide reliability standards that upon FERC approval are applicable to the users, owners and operators of the bulk power system. Applicability to each such entity is determined according to the functions that the entity performs in the course of its business operations.
NERC maintains a FERC-approved Compliance Monitoring and Enforcement Program (CMEP) and annually develops a CMEP Implementation Plan. NERC has designated the Western Electricity Coordinating Council (WECC) as the Regional Entity responsible for the Western Interconnection and has delegated ERO oversight authority to WECC for the region. NERC’s annual CMEP Implementation Plan typically includes an appendix that describes WECC’s current approach to monitoring and enforcing compliance with the continent-wide NERC standards and the regionally-specific WECC standards.
Purpose
TANC is the majority owner of the California-Oregon Transmission Project (COTP), a 500-kilvolt alternating current transmission line extending from the California-Oregon border to Central California. TANC is registered with NERC for the functions of Transmission Owner (TO), Transmission Service Provider (TSP) and Transmission Planner (TP). Based upon its functional registrations, TANC must comply or demonstrate non-applicability with all FERC-approved reliability standards requirements that are nominally applicable to the TO, TSP, and TP functions.
TANC maintains a culture of compliance. TANC’s Reliability Standards Compliance Program supports its culture of compliance with applicable regulatory obligations, particularly the bulk power system reliability standards that are applicable to TANC. The Compliance Program identifies responsibilities, resources, training activities, procedures and reporting obligations to effectively achieve and demonstrate compliance with all applicable reliability standards. Support for the Compliance Program comes from the highest levels of TANC’s organizational structure. The TANC Commission originally adopted the Compliance Program on May 30, 2007 and is briefed regularly regarding activities related to its implementation. Updates to the Compliance Program are considered by the TANC Commission generally bi-annually.
TANC has established a Reliability Standards Compliance Team, which is led by the Reliability Standards and Compliance Manager and under the direct oversight of the General Manager. TANC management, including the General Manager and Compliance Manager regulatory report compliance activities to the TANC Commission and various other committees.