2013 Implementation Plan. for Monitoring Compliance with Mexico Reliability Standards

Transcription

1 2013 Implementation Plan for Monitoring Compliance with Mexico Reliability Standards October 26, 2012

2 Table of Contents 1. Introduction Compliance Monitor (WECC) Organization WECC Operating Area Compliance Monitor (WECC) Organization Chart Program Implementation Monitoring Compliance Audits Self-Certifications Spot-Checks Compliance (Violation) Investigations Self-Reports Periodic Data Submittals Mitigation Plans Reliability Standards Subject to the 2013 Implementation Plan Actively Monitored Reliability Standards Notice of Alleged Violation Contents of Notice of Alleged Violation Compliance Outreach Compliance User Group (CUG) Critical Infrastructure Protection User Group (CIPUG) Compliance webcdms and EFT Server Training Open Webinars Questions and Answers by Subject Matter Experts Compliance Questions and Answers Appendices Appendix A Actively Monitored Standards List Appendix B Audit Schedule 2

3 1. Introduction The Comisión Federal de Electricidad (CFE) has entered into a Membership and Operating Agreement (MOA) with the Western Electricity Coordinating Council. The MOA provides for WECC to assist the Centro Nacional de Control de Energía (CENACE) and the Area de Control Baja California (ACBC) in monitoring compliance with Reliability Standards approved by CENACE for Baja California, Mexico. Pursuant to the MOA; CENACE, ACBC, and WECC have agreed to the processes, roles, and responsibilities in the Compliance Monitoring Program (CMP). The WECC Compliance Department worked with ACBC staff to develop this annual Implementation Plan, which is required by the CMP. This Implementation Plan specifies the Reliability Standards that are subject to reporting by the Designated Entities to WECC to verify compliance, and identifies the appropriate monitoring procedures and for each such Reliability Standard for Capitalized terms used in the Implementation Plan have the meanings set forth in the MOA or the CMP or as defined in this Implementation Plan. If there is any conflict, the MOA will prevail. This Implementation Plan includes references to the WECC Web Compliance Data Management System (webcdms) and the Enhanced File Transfer (EFT) Server expected to be used in Baja California, Mexico for electronic submittal and distribution of documents in The webcdms is WECC s primary compliance data system used for compliance monitoring processes. The EFT Server is used as a file upload solution for Audits and Spot-Checks, as well as ad hoc requests. For convenient reference, webcdms and EFT Server usage details are available on the WECC website at: 3

4 2. Compliance Monitor (WECC) Organization 2.1 WECC Operating Area 4

5 2.2 Compliance Monitor (WECC) Organization Chart Chief Executive Officer Vice President, Compliance Vice President, Communications and External Affairs Managing Director, Compliance Manager, Compliance Program Administration Coordinator, International Compliance Managing Director, Stakeholder Outreach Manager, Compliance Registration Manager, Operations and Planning Audit Team Manager, Cyber Security Audit Team Director, Compliance Enforcement 5

6 Program Implementation Monitoring Each Designated Entity has the responsibility to comply with all applicable Reliability Standards adopted by CENACE, and to follow all requirements of the CMP and this Implementation Plan. The CMP includes processes to be followed in the event of alleged non-compliance or non-submittal of data and information as required. Reliability Standards adopted by CENACE can be found using the following link: As new Reliability Standards are adopted by CENACE, WECC will include them for monitoring by the various methods specified in this Implementation Plan. The period for which WECC will monitor compliance with the Reliability Standards will be from January 1, 2013 for the standards included specifically in this Implementation Plan. WECC will monitor compliance with Reliability Standards adopted by CENACE to be effective by January 1, 2013 or from a later date specified by CENACE. 3.1 Compliance Audits WECC will conduct a Compliance Audit of the Designated Entity registered as either or both a Balancing Authority (BA) and Transmission Operator (TOP) every three years. The Compliance Audit conducted in 2013 may have on- and off-site components. All other Designated Entities will be subject to off-site Compliance Audits every six years. Compliance Audits scheduled for 2013 are listed below. In addition, WECC anticipates scheduling audits for Designated Entities after 2013 as follows: 2013 On-site audit of ACBC as Balancing Authority, Transmission Operator, Transmission Service Provider, and Purchasing-Selling Entity 2014 Off-site audit of Gerencia Regional de Transmisión Baja California as Transmission Owner and Distribution Provider Off-site audit of Subgerencia Regional de Generación Baja California as Generator Operator and Generator Owner Off-site audit of Independent Power Producer functions (currently applicable to Ciclo Combinado Mexicali, also known as La Rosita Power Plant) related to Generator Operator and Generator Owner that are interconnected to the CFE Grid 2015 Off-site audit of División de Distribución Baja California as Distribution Provider, Distribution Owner, and Load-Serving Entity Off-site audit of Subdirección de Programación as Generation and Transmission Planner (Resource Planner and Planning Coordinator) and Planning Authority 6

7 Compliance Audits may include a review of all Reliability Standards applicable to the Designated Entity. Compliance Audits will review, at a minimum, all applicable Reliability Standards identified in Appendix A under the column marked Compliance Audit. In addition, at least 90 days prior to the commencement of a scheduled Compliance Audit, WECC will: 1) notify the Designated Entity of the Compliance Audit; 2) identify the Compliance Audit Committee members and their recent employment history; and 3) request information. Reliability Standards Audit Worksheets (RSAW) for those Reliability Standards selected for audit in 2013 will be provided to the Designated Entities with the Notice of Compliance Audit. Subject to possible adjustments, the WECC Compliance Audit Schedule for Designated Entities scheduled for on- or off-site Compliance Audits during the program year can be identified in Appendix B. WECC will provide an Audit Report to the Designated Entity, CENACE, and ACBC on completion of the audit in accordance with Section of the CMP. The final Audit Report is considered to be accepted by CENACE 30 days after WECC provides it unless the CENACE directs otherwise. Section 3.1 of the CMP provides information about Compliance Audits requirements. 3.2 Self-Certifications Designated Entities are required to self-certify compliance with all of the applicable Reliability Standards identified in Appendix A under the column Self-Certification. Designated Entities will be required to submit Self-Certifications during the submittal period of October 1 20, WECC will provide Designated Entities with a notice of required Self-Certifications at least 30 days prior to the submittal period. WECC will post Self-Certification forms on webcdms at least 30 days prior to the submittal period. WECC will accept Self-Certification data only during the submittal period. Designated Entities will have access to edit and save their data, but will not have the ability to submit data until the submittal period has begun. Section 3.2 of the CMP provides information about Self-Certification requirements. Section 6 of the webcdms Regional Entity Quick Start Guide provides additional information concerning the Self-Certification submittal process. 7

8 3.3 Spot-Checks In accordance with the CMP, WECC may perform Spot-Checks at any time with notice to the Designated Entity, CENACE, and ACBC. Spot-Checking may be random or may be initiated in response to system events, operating problems and/or to verify or confirm Self-Certifications, Self-Reporting, and Periodic Data Submittals. Section 3.3 of the CMP provides information about Spot-Check requirements. 3.4 Compliance (Violation) Investigations In accordance with the CMP, WECC may initiate a Compliance (Violation) Investigation at any time with notice to the Designated Entity, CENACE, and ACBC. Section 3.4 of the CMP provides information about Compliance (Violation) Investigation requirements. 3.5 Self-Reports Designated Entities are encouraged to file Self-Reports via webcdms when they become aware of a possible violation of a Reliability Standard, or upon a change in the scope of a previously-reported violation. Section 3.5 of the CMP provides information about Self-Report requirements. Section 8 of the webcdms Regional Entity Quick Start Guide provides additional information concerning the Self-Report submittal process. 3.6 Periodic Data Submittals Some Reliability Standards require the periodic submittal of information to demonstrate compliance with the requirements of the Standard. Designated Entities are required to provide Periodic Data Submittals to WECC for all applicable Reliability Standards identified in Appendix A under the column marked Periodic Data Submittal. If additional Reliability Standards containing Periodic Data Submittal reporting requirements become effective for the Designated Entities during 2013, Periodic Data Submittals may be required at that time. The reporting intervals and timing are contained within the applicable Reliability Standards. WECC will issue a request to the applicable Designated Entity for a Periodic Data Submittal at least 20 days prior to the required submittal date. Section 3.6 of the CMP provides information about Periodic Data Submittal requirements. Section 8 of the webcdms Regional Entity Quick Start Guide provides additional information concerning the Periodic Data Submittal process. 8

9 3.7 Mitigation Plans Designated Entities are strongly encouraged to thoroughly and swiftly mitigate any suspected non-compliance as soon as that non-compliance has been discovered. Proposed Mitigation Plans, progress updates, and certification of completion; as well as any requests from the Designated Entity to revise the Mitigation Plan or extend the Mitigation Plan completion date; are to be submitted by the Designated Entity using webcdms. WECC will review and will make recommendations to CENACE, with a copy to the Designated Entity and ACBC, for acceptance or rejection of Mitigation Plans or completion, revision, or extension of Mitigation Plans. If WECC recommends rejection, it will provide detailed reasons in a notice to CENACE, the Designated Entity, and ACBC. Section 6 of the CMP provides information about Mitigation Plan requirements. Section 7 of the webcdms Regional Entity Quick Start Guide provides additional information concerning the Mitigation Plan process. 4. Reliability Standards Subject to the 2013 Implementation Plan Each Designated Entity is responsible for compliance with all applicable Reliability Standards adopted by CENACE. However, a subset of those Reliability Standards may specifically be actively monitored as set forth in this Implementation Plan for These Standards have been selected based on North American industry perspectives on risk to reliability. 4.1 Actively Monitored Reliability Standards For 2013, WECC will actively monitor, at a minimum, the Reliability Standards identified in Appendix A using the monitoring processes specified in Appendix A. As revisions and additions to Reliability Standards are approved by CENACE, the revised and additional Standards may be added to the Actively Monitored Standards List for the appropriate time period for monitoring in the same manner as any standards and requirements they are replacing. Designated Entities are responsible for compliance with all CENACEapproved Reliability Standards and requirements in effect for their applicable function(s) at all times; regardless of what is specified in Appendix A. 9

10 5. Notice of Alleged Violation If WECC concludes, based on the facts and circumstances, that evidence exists to indicate a Designated Entity has violated a Reliability Standard, WECC shall issue a Notice of Alleged Violation to the Designated Entity with a copy to CENACE and ACBC. A Notice of Alleged Violation will be treated as confidential by WECC. 5.1 Contents of Notice of Alleged Violation The Notice of Alleged Violation will contain, at a minimum: the Reliability Standard and requirement(s) thereof the Designated Entity has allegedly violated; the date(s) the Alleged Violation occurred (or is occurring); the facts WECC determines demonstrate or constitute the Alleged Violation; a notice that the Designated Entity shall, within 30 days, elect one of the following options or WECC will deem the Designated Entity to have accepted the assessment of violation: o agree with the assessment of Alleged Violation, agree to submit and implement a Mitigation Plan to correct the violation and its underlying causes, and provide a response in accordance with Section 5.3; or o contest the Alleged Violation. a notice that the Designated Entity may elect to submit a Mitigation Plan while contesting the Alleged Violation, and that submission of a Mitigation Plan will not waive the Designated Entity s right to contest the Alleged Violation; and required procedures to submit the Designated Entity s Mitigation Plan. Section 5 of the CMP provides information about Notice of Alleged Violation requirements. 6. Compliance Outreach WECC values the relationship it has with every member and entity in the Western Interconnection. WECC is working to strengthen stakeholder relations, improve communications, and promote meaningful training and education opportunities while providing appropriate assistance with compliance. WECC s Outreach program includes: Compliance User Group (CUG) meetings Critical Infrastructure Protection User Group (CIPUG) meetings Compliance webcdms and Enhanced File Transfer (EFT) Server Training Open Webinar Sessions Questions and Answers by Subject Matter Experts Compliance Questions and Answers 10

11 WECC invites and encourages the participation of every member and entity in its outreach programs. WECC welcomes the opportunity to combine its efforts to promote and maintain a reliable electric power system in the Western Interconnection with those of its members and other entities in the Western Interconnection. As part of its outreach effort, WECC works with the Western Interconnection Compliance Forum (WICF) to further understand the needs of entities in the region. The WECC Managing Director of Stakeholder Outreach, reporting to the WECC Vice President of Communications and External Affairs, coordinates Compliance Outreach, training, and educational efforts. Questions concerning the WECC Outreach program should be directed to compliancesupport@wecc.biz. Additional information can be found on the WECC Outreach home page: Compliance User Group (CUG) The Compliance User Group (CUG) provides an open forum for the exchange of information regarding the WECC Compliance Program and the enforcement of mandatory Reliability Standards in the Western Interconnection. CENACE, ACBC, and the Designated Entities are encouraged to participate in the CUG. All CUG meetings are open to the public and anyone with an interest in compliance activities in the Western Interconnection may attend. The CUG generally meets in person three or four times per year in cities in the West. WECC continues to explore ways to increase participation. It has offered webinar access to several in-person meetings and may continue to expand this effort in Critical Infrastructure Protection User Group (CIPUG) This group focuses on the CIP-002 through CIP-009 Reliability Standards. CIPUG members include entities responsible for compliance, industry experts, and WECC who participate in semi-annual workshops for training and education on the demanding requirements and details of these critical Standards. Although at this time these CIP standards are not in effect in Baja California Mexico, CENACE, ACBC, and the Designated Entities are welcome to participate; particularly if or when such standards are adopted in Baja California, Mexico. 6.3 Compliance webcdms and EFT Server Training WECC provides periodic training for entities on using webcdms and the EFT Server. This training includes detailed instructions and demonstrations on submitting Self- Reports, Self-Certifications, Periodic Data Submittals, audit information, Mitigation Plans, and other pertinent data submittal. In addition to submitting data, users will be trained on how to track and monitor the status of their submittals. Questions concerning webcdms or EFT Server processes should be directed to compliancesupport@wecc.biz. 11

12 6.4 Open Webinars Monthly Open Webinars provide an opportunity for open discussion regarding predetermined standards and compliance topics. They are followed by an open Q&A period. All entities, including CENACE, ACBC and Designated Entities, are invited and encouraged to participate, along with WECC Compliance staff and subject matter experts. Typically, these calls do not provide a forum to address entity-specific questions and issues. Any entity with specific questions can contact WECC Compliance staff directly. WECC records the Open Webinars and provides access to these recordings on its website for a 30-day period following the calls. Open Webinars are currently scheduled for the third Thursday of every month at 2:00 p.m. Mountain time. More information can be found on the Compliance Outreach page by using the following link: Questions and Answers by Subject Matter Experts WECC Compliance Subject Matter Experts (SME), also known as Compliance Engineers or Compliance Auditors, exhibit the highest level of expertise in performing the Reliability Standards audit and investigation processes. Each SME has special, indepth knowledge of a Reliability Standard or area of discipline. This enhances the team s overall skill, knowledge, and competence. Each SME is available to address specific entity questions regarding compliance. Contact information can be found on the WECC Compliance website at: Compliance Questions and Answers The WECC Compliance Department appreciates the need for entities to pose compliance-related questions. WECC has set up the compliancesupport@wecc.biz address to provide an avenue for WECC to answer these questions. WECC logs every question and the appropriate WECC SME provides a response. If a telephone call is preferred to an , calls made to (801) are answered and forwarded to the appropriate Compliance staff member or SME. 12