talk with texas re protocol compliance department february 21, 2013
TRANSCRIPT
Talk With Texas RE
Protocol Compliance DepartmentFebruary 21, 2013
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Protocol Compliance Staff
● Director of Protocol Compliance - Paula Mueller Paula joined Texas RE in March, 2011, as Manager of Protocol Compliance.
Prior to joining Texas RE, Paula worked for 23 years at the Public Utility Commission of Texas (PUCT), where she served in various positions including Assistant General Counsel, Director of Legal Administration, Chief of the Office of Regulatory Affairs, and Deputy Executive Director. Paula received her law degree from the University of Texas Law School and has been a licensed attorney since 1981. She has B.A. and M.A. degrees in Botany from the University of South Florida.
● Senior Protocol Compliance Engineer – Jim Clawson Prior to joining Texas RE, Jim was employed by the Lower Colorado River
Authority (LCRA). During his 30 year career at LCRA, Jim worked as an engineer and project manager on power generation projects. Jim implemented project management processes across LCRA and he has served in various supervisory and managerial roles. Since 2007, Jim worked in the NERC Compliance office for LCRA Generation. Before employment at LCRA, Jim worked as a Turbine Generator Field Engineer for General Electric for 10 years. Jim is a licensed professional engineer in the State of Texas and also holds a Project Management Professional certificate from the Project Management Institute.
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Protocol Compliance Staff, cont.
● Senior Protocol Compliance Analyst – Greg Graham Prior to joining Texas RE, Greg was employed by the Lower Colorado River
Authority (LCRA). During his 17 year career at LCRA, Greg worked in various positions including Manager Fuel and Power Supply, Manager - Asset Management, Manager of QSE Operations, GenDesk Manager, Real Time Energy Trader, Project Manager, Project Controls Analyst, and Planner Scheduler. Before employment at LCRA, Greg worked for Jacobs Engineers and Constructors with a primary focus on the design and construction of Power Plants and Pulp and Paper Mills. Greg has a Bachelor of Business Administration degree from the University of Houston.
● Protocol Compliance Analyst 3 – Doug Whitworth Doug holds a Bachelor’s degree from Southwestern University and a Master's
degree in Public Administration from the University of Texas at Austin. Doug has worked in the electric utility industry as a non-destructive testing engineer, graduate student researcher, and auditor for the past 10 years after serving 5 years as a team leader in the U.S. Army. He joined Texas RE after working at the Public Utility Commission of Texas, ERCOT, and the City of Austin (Austin Energy) as a Senior Internal Auditor. Doug maintains the following auditor credentials: Certified Internal Auditor, Certified Government Auditing Professional, and Certified Internal Controls Auditor.
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Find us on the Web
● http://www.texasre.org/compliance/protocolcompliance/Pages/Default.aspx
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Authority to Perform Protocol Compliance Work
● Texas RE has been authorized by the Public Utility Commission of Texas (PUCT) and is permitted by NERC to investigate compliance with Texas reliability-related laws.
● Texas RE performs Protocol Compliance activities pursuant to a written agreement between the PUCT, Texas RE and ERCOT. Texas RE acts as the PUCT’s reliability monitor for the
ERCOT region. PUCT performs all enforcement activities. ERCOT performs real-time system monitoring and
reports possible non-compliance to Texas RE and the PUCT.
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Reliability Monitor Functions
● Monitor compliance with the reliability-related provisions of the Public Utility Regulatory Act, ERCOT Protocols, and ERCOT Operating Guides by ERCOT and ERCOT Market Entities.
● Initiate investigations based on monitoring activities, complaints and self-reported violations.
● Analyze specific ERCOT reliability-related events and prepare reports.
● Coordinate with the PUCT to review and evaluate proposed changes to ERCOT Protocols and Operating Guides to identify potential reliability impacts and inefficiencies.
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Investigations Completed 2011-2012
Talk with Texas REFebruary 21, 2013
Summary of Texas RE Investigations 2011 and 2012
2011Q1
2011Q2
2011Q3
2011Q4
2011Total
2012Q1
2012Q2
2012Q3
2012Q4
2012 Total
Investigations Initiated
Self Reports 2 1 3 4 10 1 0 0 1 2
ERCOT Complaints
0 1 4 5 10 0 1 0 0 1
Market Participant Complaints
0 1 0 0 1 0 0 0 0 0
Texas RE Initiated
0 0 13 0 13 0 0 5 12 17
Other 1 2 0 0 3 0 0 0 0 0
Total 3 5 20 9 37 1 1 5 13 20
Investigations Concluded
8 3 12 21 44 2 6 3 9 20
Pending Investigationsat End of Quarter
16 18 26 14 13 8 10 14
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Enforcement
● Enforcement actions arising out of Protocol Compliance audits or investigations are handled by the PUCT. PUCT staff decides whether to pursue a Notice of Violation and any penalty amount that will be recommended.
● When Texas RE has completed its initial investigation, information is transmitted to the PUCT. The market entity will be notified when this step occurs.
● PUCT will contact the market entity.
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Question submitted through Texas RE Website
● Is there an ERCOT requirement for a Generation Owner to Calibrate Under Frequency relays every 2 years at a minimum? If so, where is that specified in the guides/protocols.
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Protocol Compliance Audit Program
● Scope● Annual Audit Schedule● Audit Notification● Questionnaires● Audit Submittal ● Scope Period● Findings● Conclusion
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Self-Certifications
Question:Will there be an annual self-certification activity similar to what we have for NERC reliability standards?
Answer:Texas RE does not currently plan to use comprehensive annual self-certifications in the protocol compliance program.
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Self-Reports
● Self-reporting Protocol possible violations is encouraged, not required.
● Texas RE Protocol Compliance staff will review information submitted, may ask clarifying questions.
● Information will be forwarded to the PUCT.● If the Protocol self-report discloses a concurrent filing
of a NERC standard self-report, that information will be conveyed to the PUCT. Otherwise, information about a NERC standard self-report will
be treated as confidential information, and it will be up to the market entity to bring information about any NERC compliance activities related to Protocol possible violations to the PUCT’s attention.
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Question
● There are multiple working groups established around NERC Reliability Standards. Is there a working group forum for Protocol & Guides that entities can participate in?
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Contact Us
● http://www.texasre.org/about/contact/Pages/Default.aspx
● [email protected]; 512-583-4938● [email protected]; 512-583-4917● [email protected]; 512-583-4946● [email protected]; 512-583-4918
Talk with Texas REFebruary 21, 2013