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W A 1 E R E N E R G Y L € <br /> RIVERSIDE PUBLIC UTILITIES <br /> Board Memorandum <br /> PUBLIC UTILITIES <br /> BOARD OF PUBLIC UTILITIES DATE: March 4, 2011 <br /> ITEM NO: 8 <br /> SUBJECT: PUBLIC UTILITIES NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION- <br /> WESTERN ELECTRICITY COORDINATING COUNCIL INTERNAL COMPLIANCE <br /> PROGRAM (ICP) <br /> ISSUE: <br /> That the Board of Public Utilities approve the Amendment to the Internal Compliance Program ("ICP") <br /> governing Riverside Public Utilities ('RPU") compliance with North American Electric Reliability <br /> Corporation ("NERC") Reliability Standards ("RS") applicable to all users, owners and operators of the <br /> bulk power system. <br /> RECOMMENDATIONS: <br /> That the Board of Public Utilities recommend that the City Council: <br /> 1. Adopt a resolution approving the attached Amendment to the Internal Compliance Program; <br /> and <br /> 2. Approve that substantive modifications to the ICP which are necessary to comply with <br /> additional or revised FERC, NERC, and/or WECC regulations may be approved by the Public <br /> Utilities General Manager and the Public Utilities Assistant General Manager- <br /> Finance/Administration in consultation with the Regulatory Compliance Manager and the City <br /> Attorney's Office. <br /> COMMITTEE RECOMMENDATION: <br /> The Finance/Marketing Committee at its regular meeting on January 28, 2011 recommended that the <br /> Board of Public Utilities recommend that the City Council approve the Amendment to the ICP, <br /> BACKGROUND: <br /> In 2007, to help insure reliable operation of the bulk electric system, electric utility industry's compliance <br /> (including RPU's) with the NERCIWestern Electricity Coordinating Council ("WECC") RS, as approved by <br /> the Federal Energy Regulatory Commission ("FERC"), became mandatory. RPU is registered with the <br /> WECC and NERC, and is responsible for the associated RS, as a Distribution Provider, Load-Serving <br /> Entity, Resource Planner and Purchasing/Selling Entity. RPU was recently unregistered by <br /> NERCIWECC as a Generator Owner and Generator Operator due to physical configuration of RPU's <br /> generating units and their inability to impact the reliable operation of the bulk electric transmission <br /> system. <br /> While an ICP is not a mandatory requirement, FERC views ICPs as an important proactive tool and will <br /> take into consideration the presence of an effective program in determining the magnitude of penalties in <br /> the event of a R5 violation. RPU's ICP has been effective, and RPU has not been sanctioned, assessed <br /> any penalties, or notified of any violations of RS. <br />