texas regional entity compliance report tac july 9, 2009

Texas Regional Entity Compliance Report

TACJuly 9, 2009

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Overview

NERC Organization Registration update Load Serving Entity (LSE) Registration JRO update NERC Standards Self-Certification Schedule NERC Audit & Enforcement Highlights Critical Infrastructure Protection - Spot Check Critical Performance Metrics and Criteria for the ERCOT Nodal

Market Zonal PRR and OGRR progress

TEXAS RE REPORT JULY 9, 2009

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NERC Organization Registration Update

● Texas RE and other ERCOT Stakeholders submitted comments on the proposed changes to NERC Rules of Procedures (section 500); These changes can modify: The rules dealing with organization registration and certification Appendix 5, the Organization Registration and Certification Manual

● Comments to changes are posted on the NERC website: http://www.nerc.com/page.php?cid=1|8|169

● Texas RE also provided comments on NERC’s technical feasibility exemptions (TFEs) procedure (CIP)


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NERC LSE Registration Update

● Stakeholders from the Load Serving Entity Registration Working Group (LSERWG) made additional comments for Texas RE staff to incorporate into the NERC LSE JRO Matrix and proposed Agreement

● Texas RE met with Transmission Owners (TOs) on July 1st to further streamline the proposed agreement and matrix content

● Texas RE made changes to the proposed agreement and matrix content, based on stakeholders comments and sent out for final review


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NERC Standards Self-Certification Schedule

Self-Certification Activity by NERC Function Start Due

Critical Infrastructure Protection (CIP) Standards, July 1 August 3

CIP-002-009 for Generator Owner (GO),

Generator Operator (GOP) and Transmission Owner (TO)

Distribution Provider (DP), Purchasing-Selling Entity (PSE), August 3 Sept 3

Transmission Planner (TP) and TO (non CIP Standards)

● All submissions will be via the Texas RE Portal● 100% of NERC GO/GOP self-certification submissions for non CIP

Standards in June, were received by Texas RE● All GO, GOP and TO registrants are required to complete the CIP Self

Certification even if they are being audited this year.

TEXAS RE REPORT

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NERC Audit & Enforcement Highlights

● Seven (7) NERC standards Audits; One (1) Protocol Audit conducted in June, as scheduled

● NERC observers attended five (5) NERC standards Audits and provided favorable comments on the conduct of the audit team

● Texas RE and the other seven (7) regions are continuing efforts to coordinate compliance activities for multi-region registered entities, with particular focus currently on PSEs (Purchasing Selling Entities)

● Focus in June has been to prepare for spot checks of NERC CIP standards

● Texas RE will conduct one spot-check in July for thirteen (13) requirements


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Public Notice of Penalties (NOP) Filed at FERC

● Violations and Settlements that have reached FERC are published at: http://www.nerc.com/filez/enforcement/index.html


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Critical Infrastructure Protection - Spot Check

● First spot check of CIP-002, Critical Cyber Asset identification was initiated in June, 2009

● One market participant, who has not reached auditably compliant stage, volunteered to provide their methodology for review as part of this spot check

● This effort will enable Texas RE to better understand the work load associated with CIP-002 standard auditing and enforcement

● Initial review of the methodology found it to be very good● Concern exists regarding how methodologies will be

coordinated between Registered Entities

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Critical Performance Metric and Criteria for the ERCOT Nodal Market

● Preliminary measures and criteria were published on June 3rd at http://www.puc.state.tx.us (under Hot Topic Briefs – ERCOT Nodal Metrics Project 37052)

● Workshops were conducted to collect stakeholder comments● Workshop was held on: Friday, June 12th at the PUCT, and

was well attended ● Second workshop was held on July 13th at the Met Center,

room 206● A new NPRR was submitted on July 2nd, jointly authored by

the PUCT, ERCOT ISO, and Texas RE to enhance existing nodal protocols with additional language, metrics, and pass/fail criteria

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ERCOT Protocol and Operating Guides Violation Monitoring

● Monthly monitored protocols using reports supported by ERCOT Resource Plan Metrics, SCPS2

● All other protocols and operating guides rely on events or incidents to trigger reporting by ERCOT

● Violations may be uncovered alternatively by Texas RE via compliance audits (3 year and 6 year cycles)


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ERCOT Protocol and Operating Guide Violation Policy Change

● Recommend that all Protocols and Operating Guides include: Definitions of metrics to be monitored by Texas RE Definition of explicit pass/fail criteria Monitoring methodology to be used Responsible entity for developing and maintaining any reporting

applications Availability of resources to develop system applications for

monitoring and identifying possible violations

Texas RE Report July 9, 2009

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PRR – Removing Access to Restricted Systems and Facilities

● Texas RE authored a PRR covering the requirement for market participants to manage access to restricted systems and facilities (per Board direction)

● Reporting criterion was included requiring market participants to adequately restrict access and report failures to Texas RE

● Flexibility is provided to allow market participants to address the need for security within their own framework

● Requested as urgent (per Board direction)


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PRR 787 – SCPS2 Metric & Outage Definitions

PRR 787: Defines enforcement methodology and adds exemptions to the SCPS2 scoring calculation

● PRS approved on June 18● Revised CEO Impact Analysis reflects no change to Outage Scheduler

Budget request:● Texas RE will require an additional 0.75 FTE to monitor and process the

new exemptions● This estimate is based on:

The recent exemptions requests from stakeholders, 300 to 400 exemptions per stakeholder (approximately 2 per month)

Texas RE is not able to independently verify the new exemptions These exemptions could impact ERCOT settlements process due to Texas

RE’s time consuming manual review and approval process of exemptions


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PRR 811 – Real Time Production Potential

PRR 811: Establishes a requirement for Wind

Generation Resources to telemeter a real time signal indicating

the real time production potential which will be a function of

wind and turbine availability

● Was addressed at July 7 QMWG meeting to address data requirements and to prepare comments for PRS

● Texas RE supports PRR 811 with modification to support compliance

Concerns: A metric and criteria that define passing and failing are

required as well as the method for monitoring the metric (e.g.

exception report, ISO complaint)● If approved, Texas RE will coordinate with ERCOT ISO to develop Spot-

Check performance query capability


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PRR 812 – Wind Generator Forecasting for Scheduling Metric

PRR 812: This PRR adds a requirement for wind-powered generation

resources to update resource plans and schedules every hour using

the ERCOT provided most likely short-term wind power forecast as

the standard for accuracy

● PRS approved on June 18

● Texas RE supports this protocol with modification to support compliance

Concerns: A metric and criteria that define passing and failing are

required as well as the method for monitoring the metric (e.g. exception

report, ISO complaint)

● Texas RE is coordinating with ERCOT ISO to develop Texas RE’s capability to

conduct Spot Check queries of Resource Plan performances


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OGRR 224 - Special Protection System (SPS) Operations Under No Contingency

OGRR 224: Places an obligation on Resource owners who have an

SPS to monitor the flows monitored by the SPS in the base case and

reduce output as needed before the arming point of the SPS is

Reached

● Texas RE supports the OGRR as written


texas regional entity compliance report tac july 9, 2009

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