nerc entity registration and certification in the ercot region

November 2, 2007

NERC Compliance Workshop

TEXAS REGIONAL ENTITY

AN INDEPENDENT DIVISION OF ERCOT

NERC Entity Registration and Certification in the ERCOT Region

S. A. “Tony” Shiekhi, PE

NERC Compliance WorkshopNovember 2, 2007

2



Objectives

● Current Registration in ERCOT ● Identify and register entities who qualify● Correlate NERC functional model to ERCOT market

participants● State the obligation that comes with registration● Appeals● Describe which entities must obtain NERC organizational

certification ● Register entities as Joint Registration Organizations

(JRO) ● Get familiar with various forms (Registration, JRO)


3



Compliance Registry

● NERC shall establish and maintain a compliance registry of the bulk power system owners, operators, and users that are subject to approved reliability standards (Energy Policy Act).

● Texas RE has been delegated the task of organization registration and certification by NERC.

● Texas RE will perform the registration and certification activities in accordance to NERC organization registration and certification procedures, which are incorporated into the Rules of Procedure as Appendix 5.

See NERC Rules of Procedure – Section 500:

http://www.nerc.com/~filez/rules_of_procedure.html


4



Who Must Comply?

● Any entity responsible for any part of bulk power system reliability Historically defined as control areas and reliability coordinators

● Functional entities Aligns reliability requirements with functional unbundling

● Entities that fall under the FERC Rule All entities subject to the Commission’s reliability jurisdiction…

(users, owners, and operators of the Bulk Power System) shall comply with applicable Reliability Standards …


5



Registration Process

For all geographical or electrical areas of the bulk power system, the registration process shall ensure that

(1) No areas are lacking any entities to perform the duties and tasks identified in and required by the reliability standards to the fullest extent practical (no gaps in the registration), and

(2) There is no duplication of such coverage or of required oversight of such coverage (no overlaps in the coverage).


6



Who Is Registered in the ERCOT Region?

In ERCOT region, there are 166 entities with 222 functional responsibilities.*

● 94 Generator Owners (GO)● 47 Generator Operators (GOP)● 30 Transmission Owners (TO)● 26 Transmission Planners (TP)● 25 Distribution Providers (DP)*● There will be at least 33 Purchasing Selling Entities (PSE)*● There is ONLY one Balancing Authority (BA), Transmission

Operators (TOP), one Reliability Coordinator (RC), Planning Authority (PA), Resource Planner (RP), and Transmission Service Provider (TSP)

*The number of entities will increase.

Refer to NERC Compliance Entity Registration List document on NERC Entity Registration page of ERCOT.com:

http://www.ercot.com/mktrules/compliance/tre/nercreg/index.html


7



NERC Entity Registration Steps

The following organization registration activities shall be performed by the Texas RE (NERC Rules of Procedure, Appendix 5).

● Entities seeking registration shall contact the Texas RE to become registered and, if necessary, certified. However, Texas RE can register the entities by filling out the NERC Registration Form.

● Texas RE will review the submitted form by the entity.● Texas RE will contact the entity to get clarification or needed

information, if needed.

● After the final review, Texas RE will submit the entity information to NERC.

● NERC will send a notification through a registered mail to the registered entity.

Refer to NERC Registration Form – New Entity form on

NERC Entity Registration page of ERCOT.com:



8



Any Changes?

● Each entity identified in the registry shall notify Texas RE of any changes in ownership, corporate structure, or similar matters that affect the entity’s responsibilities with respect to the reliability standards.

● Failure to notify will not relieve the entity from any responsibility to comply with the reliability standards or shield it from any penalties or sanctions associated with failing to comply with such standards.

● Please send any changes for your entity by end of each month

See the NERC Registration Form – Revisions to Entity’s Current Registration form on the

NERC Entity Registration page of ERCOT.com:



9



Typical ERCOT Entity Registrations

NERC Function ERCOT Entity Type _____________________ ____________________________

Generator Owner (GO) Resource Entity with Generators

Generator Operator (GOP) QSE level 3 and 4

Transmission Owner (TO) TDSP

Transmission Owner (TP) TDSP

Distribution Provider (DP) TDSP

Purchasing Selling Entity (PSE) QSE level 1 and 2 with TSIN #

Load Serving Entity (LSE) UNDER REVIEW (QSE level 1 & 2)

These are typical, not absolute!


10



NERC GO/GOP Registration Criteria

Generator Owner/Operator (GO/GOP):● Individual generating unit > 20 MVA and directly

connected to the bulk power system● Generating plant/facility > 75 MVA ● A black start unit● Any generator that is material to the reliability of the bulk

power system


11



GO/GOP Exclusions

● A generator owner/operator will not be registered based on these criteria if responsibilities for compliance have been transferred by written agreement to another entity (ROP section 500).

● As a general matter, entity may be excluded as a candidate for registration based on these criteria if (i) the net capacity provided to the bulk power system

does not exceed the criteria above or the Texas RE determines the generator is not material to the bulk power system;

(ii) standby, back-up and maintenance power services are provided to the generator (under approval of Texas RE or FERC).


12



NERC DP Registration Criteria

Distribution Provider (DP):● System serving >25 MW of peak load that is directly

connected to the bulk power system● Registered entity that owns, controls, or operates

facilities that are part of any of the following protection systems or programs designed, installed, and operated for the protection of the bulk power system: a required under-frequency load-shedding (UFLS)

program a required under-voltage load-shedding (UVLS)

program a required special protection system a required transmission protection system


13



NERC TO Registration Criteria

Transmission Owner (TO):● Owns an integrated transmission element associated

with the bulk power system 100 kV and above

OR● Owns a transmission element below 100 kV associated

with a facility that is included on a critical facilities list that is defined by the ERCOT ISO


14



NERC LSE Registration Criteria

Load-Serving Entity (LSE):

● Peak load at >25 MW

● Connected to the bulk power (>100 kV) system

OR

● Required for UFLS program

● Required for UVLS program


15



NERC PSE Registration Criteria

Purchasing-Selling Entity (PSE):● 113 entities in the OATI (Open Access Technology

International, Inc.) list● This list trimmed to 33 entities● OATI active DC tie Scheduling QSE list with the TSIN

name (Transmission Service Information Network)● Operates as a QSE in the ERCOT market


16



ERCOT ISO NERC Registration

The ERCOT ISO is registered for the following NERC functions:

● Reliability Coordinator (RC)

● Transmission Operator (TOP)

● Balancing Authority (BA)

● Planning Authority (PA)

● Transmission Service Provider (TSP)

● Resource Planner (RP)

Some of the Standards Requirements for the above functions may be delegated by the ERCOT ISO to other ERCOT entities such as TOs.


17



NERC Entity Registration Appeal Process

● Texas RE or the entity will register the entity for a NERC function.

● NERC shall notify each organization of its registration through registered mail.

● Any organization receiving such a notice may challenge the decision to include it on the compliance registry; it shall contact Texas RE and file its written objection with NERC’s director of compliance within 21 days stating the reasons it believes it should not be considered a bulk power system owner, operator, or user.


18



NERC Entity Registration Appeal Process (cont.)

● Texas RE will work with the entity to resolve the issue. If no agreement is reached, Texas RE will respond to NERC with its response.

● NERC will place the Texas RE’s response on the agenda for review.

● The Compliance Committee of the Board of Trustees will promptly issue a written decision on the challenge, including the reasons for the decision.

● The decision of the Compliance Committee shall be final unless, within 21 days, the organization appeals the decision to the applicable governmental authority (FERC).


19



Current Appeals

Texas RE has three appeals from entities under review and has to respond to NERC.

● Two are from GOPs.● One is from a GO.


20



NERC Entity Certification in ERCOT Region

● NERC/Texas RE shall provide for certification of all entities with primary reliability responsibilities requiring certification as established in the NERC reliability standards.

● Entities expected to be certified include reliability coordinators, transmission operators, and balancing authorities. Other entities may be added as required by approved reliability standards.

● The NERC program shall: Evaluate and certify the competency of entities performing

reliability functions. Certify each entity’s ability to meet the minimum requirements

established by the NERC reliability standards for each function. Maintain process documentation. Maintain records of currently certified entities.


21



Joint Registration Organizations

● The Joint Registration Organization (JRO) registers as the entity responsible for all functions that a JRO performs itself, and on the behalf of one or more of its members or related entities for one or more functions (GO, GOP, DP, etc.).

● JRO agrees to perform any or all requirements identified in the reliability standards that would otherwise be the responsibility of one or more of its members or related entities.

● Joint registration is pursuant to a written agreement. The JRO and its members or related entities agree (in a written

agreement that clearly specifies their respective responsibilities) to register and divide the responsibility among themselves to a particular function, for one or more requirements within particular NERC reliability standard/s.


22



Joint Registration Organizations (cont.)

● Texas RE or NERC may request clarification of any list submitted or additional information on the joint registration.

● Texas RE shall notify NERC of each joint registration that it accepts.● NERC shall maintain and post on its website a JRO registry listing

of all joint registrations that have been accepted by NERC or Texas RE with the listing of the reliability standards and its requirement associated to each entity.

● Annually, following submission of a joint registration, the JRO shall submit a form (specified by Texas RE) with a list to Texas RE: Any changes from prior year (i.e., the contact information) The functions for which the entities have registered


23



Joint Registration Organizations (cont.) – NERC Standards Violations

● In the event of a violation, the JRO or its member or related entity identified in the JRO registry as responsible for such reliability standard or requirement shall be identified in the notice of alleged violation and shall be assessed the sanction or penalty for the violation.

● Texas RE will follow the NERC Sanctions Guidelines for a violation that is attributable to a member or related entity that is registered under the joint registration.


24



Joint Registration Organizations (cont.) – Individual Member Registration

● Nothing in Section 507 shall preclude a member of a JRO, a related entity, or any other entity, from registering on its own behalf and undertaking full compliance responsibility, including reporting requirements, for the reliability standards applicable to the function(s) for which the member or other entity is registering.

● A JRO member or related entity that registers as responsible for any reliability standard or requirement of a reliability standards shall inform the JRO of its registration.


25



Where to Find NERC Entity Registration Info



26



Important Links

● Texas RE landing page on ERCOT.comhttp://www.ercot.com/mktrules/compliance/tre/index.html

● NERC Entity Registration page on ERCOT.comhttp://www.ercot.com/mktrules/compliance/tre/nercreg/index.html NERC Entity Registration Forms NERC Entity Registration List for ERCOT Region

● Reliability Standards page on ERCOT.comhttp://www.ercot.com/mktrules/compliance/tre/standards/index.html FERC-Approved Mandatory NERC Standards by Function with Violation Risk

Factors

● NERC website BOT Approved Reliability Standards

http://www.nerc.com/~filez/standards/Reliability_Standards.html NERC Statement of Registry Criteria Rev3-1

(found on Organization Registration and Certification, http://www.nerc.com/~org/) NERC Functional Model Version 3

(found in Reliability Standards, http://www.nerc.com/~filez/functionalmodel.html)


27



Registration

Questions?

nerc entity registration and certification in the ercot region

Documents

nerc organization registration

nerc registration form

registration process

objectivescurrent registration

pe nerc compliance workshop

various forms registration

nerc functional model

number of entities