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AGENDA ITEM NO.: 4.E.1
MEETING DATE: 05/18/2015
ADMINISTRATIVE REPORT NO.: 2015-59
To:
Honorable Public Utilities Board
From:
Cynthia Whitchurch
Interim AGM – Engineering & Operations
Submitted by: ______/s/___________
Cynthia Whitchurch
Interim AGM – Engineering & Operations
Approved by: _____/s/_____________
Glenn O. Steiger
General Manager
Subject: Alameda Municipal Power’s North American Electric Reliability Corporation Internal
Compliance Program Update – Information Only
RECOMMENDATION
For information only, no action is requested. The purpose of this report is to provide the Public
Utilities Board (Board) with an update of Alameda Municipal Power's (AMP) North American
Electric Reliability Corporation (NERC) Internal Compliance Program (ICP).
BACKGROUND
The Federal Energy Policy Act of 2005 (Act) provides the Federal Energy Regulatory
Commission (FERC) authority to approve and enforce rules and regulations to protect and
improve the reliability of the nation’s bulk power system. Through this Act all electric power
entities that impact the Bulk Electric System must comply with FERC approved standards and
public utilities that sell electricity at market-based rates must comply with market rules of
conduct and ongoing reporting and compliance requirements. Under this statutory framework,
standards are proposed by electric reliability organizations and approved by FERC.
NERC has been delegated authority as the electric reliability organization for the four
interconnections in North America that include Quebec, ERCOT, Eastern and Western
Interconnections. NERC has further delegated regional reliability organization functionality to
eight regional entities. Mandatory compliance with the first set of standards approved by FERC
came into effect on June 18, 2007. Alameda Municipal Power is required to comply with all
FERC requirements including approved Reliability Standards applicable to its registered
functions as a Load Serving Entity (LSE) and Distribution Provider (DP).
DISCUSSION
The AMP regulatory Internal Compliance Program (ICP) is modeled after Western Electric
Coordinating Council’s (WECC) Internal Compliance Program Self-Assessment Survey
Update and the four-pillars of compliance framework presented in the Federal Energy
Regulatory Commission’s October 2008 Policy Statement on Compliance:
AGENDA ITEM NO.: 4.E.2
MEETING DATE: 05/18/2015
ADMINISTRATIVE REPORT NO.: 2015-59
1.
2.
3.
4.
Role of senior management in fostering compliance;
Effective preventive measures to ensure compliance;
Prompt detection, cessation, and reporting of violations; and
Remediation efforts.
The ICP facilitates and promotes AMP’s culture of compliance with a focus on compliance
with the FERC reporting requirements and NERC and WECC Reliability Standards.
The purpose of this ICP is to foster a culture of compliance within AMP. The ICP objectives
are laid out to control the organization’s activities so that they become a part of the
organization’s compliance infrastructure, leading to a very high level of compliance on a
routine basis. It also demonstrates how AMP’s ICP meets the intent of the FERC
recommendation.
The AMP policy is to investigate all potential violations and to immediately self-report
confirmed compliance violations. AMP encourages and requires a commitment to compliance
by all employees. AMP’s senior management supports and is committed to effective preventive
measures, prompt detection/cessation/reporting of violations, and any necessary remediation,
learning and discipline efforts.
This program outlines AMP’s internal control foundation, providing discipline and structure to
guide compliance with the Reliability Standards. Subject matter experts oversee, communicate,
track, document, and monitor reliability standard compliance. The ICP applies to all AMP
employees, contractors, and vendor personnel responsible for reliability compliance and is
made readily available to all employees.
As required by the plan, AMP conducted an annual review of the ICP and updated AMP’s
organizational chart and validated that the various sections in the procedure were applicable.
FINANCIAL IMPACT
There are sufficient funds in the FY2016 budget for the implementation of the ICP.
LINKS TO KEY RESULTS AREA AND GOALS
KRA 3:
Initiative 3.1.5:
System Resiliency
Maintain Compliance with NERC Standards
EXHIBIT
A. Alameda Municipal Power Internal Compliance Program
AGENDA ITEM NO.: 4.E. - EXHIBIT A
MEETING DATE: 05/18/2015