Reliability Coordinator Standards of Conduct Signatories

Date Signed

Section 3.1 Explanations

Temporary Suspension

Deviation

Electric Reliability Council of Texas (ERCOT)

9/1/2000

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Florida Power Corporation (FPC)

3/12/2002

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Florida Power & Light Company (FRCC)

8/21/2000

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Hydro-Quebec, TransEnergie (NPCC-TE)

10/19/2000

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Independent Coordinator Transmission - Entergy (ICTE)

9/7/2006

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ISO New England Inc. (ISNE)

8/28/2000

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Midwest ISO (MISO)

11/1/2006

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New Brunswick System Operator (NBSO)

1/10/2005

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New York Independent System Operator (NPCC-NYIS)

9/22/2000

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Ontario - Independent Electricity System Operator (NPCC-ONT)

9/11/2000

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PJM Interconnection, L.L.C. (PJM)

8/22/2000

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SaskPower (SPC)

2/2/2005

View

Southern Company Services Inc. (SERC-SOCO)

8/21/2000

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Southwest Power Pool (SPP)

8/23/2000

View

Tennessee Valley Authority (SERC-TVA)

10/13/2000

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VACAR-South (SERC-VACS)

10/5/2000

View

WECC Reliability Coordinator

9/5/2008

View

 

 

 

SECTION 3.1 EXPLANATIONS

(Reliability Coordinator explanations of how they are complying with the Reliability Coordinator Standards of Conduct.)

 

Electric Reliability Council or Texas (ERCOT)

The Security Coordinator function for the entire Electric Reliability Council Of Texas (ERCOT) Region is performed solely by the ERCOT Operations Group staff. ERCOT is a non-profit organization governed by a Board of Directors comprised of a balanced group of stakeholders from all segments of the electric utility industry including customers. All employees of ERCOT have no financial interest in any market or market participant activity and have signed an ethics agreement regarding their interface with market participants. The Security Coordinator function is performed in an ERCOT owned Control Center totally separate from any market participant.

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Florida Power Corporation (FPC)

None.
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Florida Power & Light Company (FRCC)

The FRCC’s real-time and next day Security Coordinator function is located at Florida Power and Light’s System Control Center. The main responsibilities, as defined in detail in the FRCC Security Process Document, are to ensure the reliable operation of the FRCC (Florida) electrical transmission grid and support power transfers for native loads and Merchant transactions.

FPL, per FERC’s Order 888, has physically separated its Transmission Operations / Security Coordinator functions from its Wholesale Merchant function. All Merchants, including FPL’s, must request transmission reservations via the Florida OASIS (FLOASIS), submit e-tags for approval by FPL’s transmission operators, and schedule through the appropriate Control Area(s).

At FPL, all direct links for automated scheduling between FPL’s Control Area and PSE have been eliminated.

FPL’s transmission operations and Security Coordinator do not participate in any purchase / sale negotiations resulting in any sales to native load or resale. However, FPL Control Area’s load balancing, which resides in the same location and has the same reporting structure as the Security Coordinator, develops a native load forecast, utilizes a unit commitment program to commit units for native load, and communicates to the FPL-PSE any requirements for additional purchases for native load or additional power available for the PSE to sell. Location of purchase / sales and price of sales are not discussed.

Both operating positions that perform the major Security Coordinator functions (real-time and next day) at FPL have transmission operating responsibilities, with no Control Area responsibilities. Both report to the Manager of System Dispatch. Both are concerned with the reliability of the FRCC. The only function they serve for FPL is approval of OASIS long term non-firm and next day firm requests. All other requests are handled by the Operations Planning group and the FPL Scheduling Coordinator.

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Hydro-Québec, TransEnergie (TE)

None.

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Independent Coordinator Transmission - Entergy (SPP-ICTE)

Southwest Power Pool, Inc. (SPP) is a non-profit organization governed by an independent Board of Directors. SPP acts as a NERC Regional Reliability Organization, Tariff Administrator and Security Coordinator on behalf of its members. In 2005, SPP recognized the industry-wide need to form a Contract Services department to administer specific contracts with non-member utilities. In furtherance of this objective, SPP is operating as the Independent Coordinator of Transmission for Entergy Services, Inc. (“SPPICT”) and is performing reliability coordination as well as tariff administration and transmission planning under the Entergy Open Access Transmission Tariff (“Entergy OATT”). Employees of SPPICT perform these functions independently of Entergy. SPPICT does not employ persons who engage in retail or wholesale merchant functions. Each SPPICT employee is required to sign a Standards of Conduct. The SPPICT Standards of Conduct, among other things, restricts any involvement in marketing, limits access to the SPPICT Coordination Center, requires proper disclosure of transmission system information, prohibits sharing of market information, and requires disposure of securities issued by transmission customers and transmission providers under the Entergy OATT.

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ISO New England (NPCC-ISNE)

ISO New England was established on July 1, 1997 and approved by the Federal Energy Regulatory Commission (FERC) as an Independent System Operation (ISO) in accordance with FERC's principles for ISO operation and governance as embodied in Order 888. These key principles include: providing independent, open and fair access to the region's transmission system; establishing a non-discriminatory governance structure; facilitating market based wholesale electric rates; and ensuring for the efficient management and reliable operation of the bulk power system. ISO New England has no merchant employees. The governance established for the ISO, which includes a Code of Conduct that must be executed and followed by each ISO employee, ensures independence from Participants in the New England electric markets.

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Midwest ISO (MISO)

None.

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New Brunswick System Operator (NBSO)

The NBSO is a not-for-profit, independent corporation with its own Board of Directors whose primary responsibility is to ensure the security and reliability of the electricity system and administer and supervise the rules governing transmission access and to facilitate the development and operations of competitive electricity market in New Brunswick. To view a copy of the New Brunswick Electricity Market Rules go to http://www.nbso.ca/

The NBSO employees, officers and agents are required to adhere to the NBSO Code of Conduct. The NBSO is also a member of the Northeast Power Coordinating Council (NPCC) and therefore obligated to adhere to the NPCC Code of Conduct.

The NBSO is going through the process to become the Reliability Coordinator (RC) by April 1, 2005, for the Canadian Maritime Provinces (New Brunswick, Nova Scotia and Prince Edward Island) and a portion of Northern Maine, USA, (Maine Public Service and Eastern Main Co-op). NBSO is registering as the Balancing Authority (BA) for the New Brunswick, Prince Edward Island and Maine Systems radially connected to New Brunswick. The NBSO is the Transmission Operator (TOP), the Transmission Service Provider and is the market operator for the New Brunswick Transmission System.

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New York Independent System Operator (NPCC-NYIS)

MS Word

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Ontario - Independent Electricity System Operator (ONT)

The IMO is a non-profit, regulated corporation without share capital established by the Electricity Act 1998, with its Directors appointed by the government. It is independent of all other players in the electricity industry. The IMO does not engage in retail or wholesale merchant functions. All employees are governed by the IMO's Code of Conduct that includes information confidentiality provisions.

The Independent Electricity Market Operator (IMO) is committed to abiding by the terms of the NERC Security Coordinator Standards of Conduct. However, specific to Rule 2.1.3 of the Standards of Conduct, there is not yet open access in Ontario and, hence, the IMO is not managing any transmission services on any OASIS site. Further, when there is open access in Ontario, the IMO will not use OASIS to provide transmission access information but will use the Market Participant Network approved for use in Ontario.

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PJM Interconnection, L.L.C. (PJM)

PJM Interconnection, L.L.C. (PJM) was approved by the Federal Energy Regulatory Commission (FERC) as an Independent System Operator (ISO) on November 25, 1997, in accordance with FERC's principles for ISO operation and governance as embodied in FERC Order No. 888. PJM acts as the Mid-Atlantic Area Reliability Council (MAAC) on behalf of its members. As such, PJM performs the role of Regional Security Coordinator. PJM is independent from its Members and other Market Participants. The PJM Board of Managers are elected by the PJM Members Committee from a slate of candidates prepared by an independent consultant. The PJM Operating Agreement requires that a Board member shall not be, and shall not have been at any time within five years of election to the PJM Board, a director, officer or employee of a PJM Member or of an Affiliate or Related Party of a Member. The PJM governance includes FERC Order No. 889 Standards of Conduct that apply to PJM Board Members, Officers and employees, which ensures independence from PJM Members, Market Participants or Eligible Customers (as such term is defined in PJM's Tariff). Each employee of PJM is required to execute a "Code of Conduct and Standards of Business Ethics Compliance Agreement," which incorporates the FERC Standards of Conduct. Additionally, PJM does not have any affiliates or employees engaged in retail or wholesale merchant functions.

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SaskPower (SPC)

SaskPower serves as the both the Reliability Coordinator and certified control area for the Province of Saskatchewan, within the Midwest Reliability Council Organization. The Reliability Coordinator Functions are carried out by the Manager of our Grid Control Center, who reports to the Vice President and General Manager of Transmission and Distribution. SaskPower has established a standard of conduct ensuring functional separation, independence, and governing the transmission activities, planning, and operations in a fashion aligned to NERC and FERC standards. All power marketing activities are carried out by our NorthPoint Energy Solutions subsidiary which exists in a separate headquarters than our Grid Control Center.

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Southern Company Services, Inc. (SERC-Southern)

Southern Company Services, Inc. ("SCS") is the Security Coordinator for the Southern Subregion of SERC. The Security Coordinator functions are performed by employees of SCS in the Bulk Power Operations function. Those employees have received training on and are in compliance with the FERC Standards of Conduct. SCS has filed procedures with FERC describing the implementation of those Standards of Conduct and FERC has accepted that filing. Since the Standards of Conduct proposed by NERC largely mirror those adopted by FERC, the implementation procedures adopted by SCS should satisfy the NERC Security Coordinator Standards of Conduct. In this regard, SCS has signed the NERC Security Coordinator Standards of Conduct.

The key elements of the implementation process involve compliance with the Standards of Conduct. In this regard, the employees who perform Security Coordinator functions operate independently from merchant employees and their contact with merchant employees is within the confines of applicable FERC regulations and NERC policies. SCS employees who perform Security Coordinator functions are directed by the Senior Vice President of Transmission Planning and Operations. The employees who perform merchant functions are directed by the President of Southern Company Generation. Employees that perform Security Coordinator functions and those that perform merchant activities are located on separate floors.

In addition, there is a secure card entry system to the area where Security Coordinator functions are performed. This secure card entry system prevents employees of the merchant function from accessing this area. SCS has distributed copies of the NERC Standards of Conduct to personnel who perform Security Coordinator functions.

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Southwest Power Pool (SPP)

Southwest Power Pool, Inc. (SPP) is a non-profit organization governed by a Board of Directors equally represented by Transmission Owner, Transmission User, and Independent stakeholders. SPP acts as a NERC Regional Reliability Organization, Tariff Administrator and Security Coordinator on behalf of its members. Employees of SPP perform these functions independently of its members. SPP does not employ persons who engage in retail or wholesale merchant functions. Each SPP employee is required to sign a Standards of Conduct. The SPP Standards of Conduct, among other things, restricts any involvement in marketing, limits access to the SPP Coordination Center, requires proper disclosure of transmission system information, prohibits sharing of market information, and requires disposure of securities issued by transmission customers and transmission providers under the SPP Open Access Transmission Tariff.

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Tennessee Valley Authority (SERC-TVA)

TVA serves as the Reliability Coordinator for the following members of SERC: Associated Electric Cooperative, Inc. (AECI), Big Rivers Electric Cooperative (BREC), East Kentucky Power Cooperative (EKPC), Electric Energy, Inc. (EEI), E.ON US (LGEE/KU), Tennessee Valley Authority (TVA). The Reliability Coordinator functions are carried out by the Manager of Transmission System Services who reports to the Vice-President of Transmission and Reliability (TRO). TRO is under the Executive Vice President of Power System Operations (PSO). The marketing function at TVA is carried out by Bulk Power Trading which is under the Vice President of Energy Trading. Although both TRO and Bulk Power Trading both ultimately report to TVA's Chief Operating Officer, Transmission and Reliability is physically and functionally separate from TVA's marketing group.

The Manager of Transmission System Services, the Reliability Engineers, and the Reliability Coordinator System Operators perform their functions of security and transmission provider independently of TVA's merchant function and merchant employees. Communications between TVA Transmission System Services and TVA Marketing are performed only through OASIS and the NERC Tagging system. Comparable treatment of all Marketers is maintained.

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VACAR-South (SERC-VACS)

Pursuant to the SERC Security Plan, filed with and approved by NERC, Duke Energy Carolinas is the RC agent responsible for providing Reliability Coordinator services for a portion of the VACAR sub-region (VACAR South area) which includes the systems of Duke Energy Carolinas, Progress Energy Carolinas, South Carolina Electric and Gas, South Carolina Public Service Authority, Southeastern Power Administration, and the Yadkin Division of Alcoa Power Generating, Inc. According to the provisions of this plan, Duke control center employees staff the Reliability Coordinator function. These control center employees are held to the provisions of the FERC Standards of Conduct as well as the NERC Confidentiality Agreement for Electric System Security Data. In accordance with these provisions, Duke control center employees are instructed to not share with any marketer any information that would conflict with the requirements of these documents. In addition, Duke control center employees do not direct the actions of any marketer or provide non-public transmission system information to any marketer, including the Duke retail marketer, and do not engage (except for the receipt or delivery of emergency energy pursuant to an existing reserve sharing agreement -- such deliveries are publicly posted on the Duke OASIS site) in any marketing, wholesale or retail, functions.

VACAR South RC Agent may discuss information with market participants that is available on the NERC Internet site. We interpret such information to be publicly available; therefore this practice is not prohibited by these Standards of Conduct.

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WECC Reliability Coordinator (WECC)

WECC Reliability Coordinator performs the role of Regional Reliability Coordinator for Western interconnection. The WECC RC does not have any affiliates or employees that engage in retail or wholesale merchant functions. As a Reliability Coordinator, WECC RC operates independently of its members who may have employees engaged in retail or wholesale merchant functions.

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