COMPLIANCE UPDATE

ERCOT ROS Meeting

April 9, 2002

NERC SAR’s

• Blackstart• Abnormal Conditions• Coordinating

Interchange• Coordinating

Operations• Disturbance

Conditions

• Facility Ratings• Operating within

Limits• Physical Connection

Requirements• Protection Systems• Transmission

Assessments

Support for SAR Process –NEED ROS APPROVAL

• ERCOT will draft response

• Forward to ROS and to relevant working groups

• Ask chairs to gather comments, or concur with ERCOT view

• TIME IS SHORT. Due early May to NERC

NERC Compliance Enforcement ProgramBackground – Overall Program/Process

NERC CEP Is Beginning Its 4th Year. New Measurements Were Introduced for

Field-testing During Each of the 1st, 2nd, and 3rd Years.

New Measures for the 4th Year Have Been DelayedNO New Standards Will Be Introduced Unless

They Have Been through the New Standards Process.

Current Operating Policies Do NOT Support Formal Compliance.

How Did We Do? -2001 Compliance Program

Major Objectives

Field-tested 30 “New” Planning Measures and 1 “New” Operating Measure

Further Refine the ProcessConduct Audits – Both Reliability Authority

(Formerly, Called Security Coordinator)

and Control AreaContinue TLR Investigations

Initiated When TLR 5 (Firm Curtailments) Occur

TotalViolations

Planning Subtotal 169 32 42 809 1052 $1.5M43 me as ure s

Ope rating Subtotal 161 101 175 590 1027 $8.3M17 me as ure s

Total  330 133 217 1399 2079 $9.8M

Compliance Results2000 2001 2001 w/non-submittals

Planning Measures 89% 93% 84%Operating Measures 90% 92% 91%

TOTAL 90% 93% 88%

S an ction s w/ n on

su bm i ttal s

Preliminary NERC 2001 Compliance Program Summary

Level 1 Level 2 Level 3 Level 4 S tandards

2001 Compliance Program2001 Compliance ProgramPreliminary ResultsPreliminary Results

2001 Report to NERC

• Planning – evaluated 39 measures, 98% compliance, $14000 possible fines

• Operations – evaluated 13 measures, 91% compliance, $816,331 possible fines

• Other non-compliance exists – QSE’s not assessed; generator modelling not assessed; small TDSP’s not assessed

NERC TSOLV PENALTY MATRIXPercentage by violation of OSL

Limit exceeded > 30 minutes, up to 35 minutes

Limit exceeded > 35 - 40 minutes

Limit exceeded > 40 - 45 minutes

Limit exceeded > 45 minutes

0-5% Level 1 Level 2 Level 2 Level 3

5-10% Level 2 Level 2 Level 3 Level 3

10-15% Level 2 Level 3 Level 3 Level 4

15-20% Level 3 Level 3 Level 4 Level 4

20-25% Level 3 Level 4 Level 4 Level 4

>25% Level 4 Level 4 Level 4 Level 4

REPORTED 2001 ERCOT TSOLV’S

Month ViolationsLevel

1Level

2Level

3Level

4

July-Aug 20 1 6 5 8

Sept 6 1 4

OctNov 2 1 1

Dec 5 1 1 2 2Totals 33 2 8 8 15

2002 NERC Compliance

• Basically, repeat activities from 2002

• Schedules and measure details will be posted on the website

• Generator information will be followed up, rather than re-certified.

• QSE reviews will continue

ERCOT Specific Issues 2002(Protocol Compliance)

• Net dependable capability testing – use old RSS templates as a pilot

• Reactive testing – same as above• QSE frequency control performance• Execution of ERCOT dispatch instructions• QSE qualification process

Frequency CONTROL Study

• Consultant hired

• Interviewed stakeholder representatives and ERCOT staff

• Initial data for analysis has been collected or is being collected

• Howard is staying on track to supply preliminary assessments at the end of May

Transmission Issues

• The annual underfrequency load shedding survey will be conducted on May 9.

• Security criteria violations – TO’s are sending log information, ERCOT Operations and Compliance reviewing.

• Planning issues. ERCOT expects compliance with the schedules and procedures of its working groups.

Other Issues from Operating Guides, Etc.

• Load as a resource

• Reactive standards

• Power system stabilizers

QSE/Generation Issues• Modelling. Working with System Planning

to first identify which are complete, will begin “discussions” with those who are not.

• 4 ½ QSE’s reviewed for energy emergency plans and real time.

• Compliance has asked for data from QSE’s to support the frequency study, disturbance analysis and explanation of “apparent Protocol violations”