Public Power - October 2008 - (Page 43)

One public power organization helping its members with NERC audits is the Florida Municipal Power Agency. “We have not been audited, but some of our members have been,” said Ralph Anderson, an FMPA compliance officer and former auditor for one of NERC’s regions. FMPA assists its nine NERC-registered members with support services, including mock audits and dealing with violations. “The most important key is preparation, especially in having your documentation ready,” said Anderson. He recommends that utilities go down the “RSAWs” or Regional Standard Auditor Worksheets. These are the standards that include guidance for the auditors of acceptable evidence for each reliability standard. “Auditors go down these like a checklist,” he said. “They have to look at the RSAWs, follow them word for word, and look for the evidence,“ said Anderson. If you can show the auditors all the evidence and make it easy for them to verify, the audit will go smoothly. If auditors ask for a certain document, be able to provide it. “When I was doing audits, I could often provide final results to some utilities the same day, because they were so well prepared,” he said. “I could just go down the checklist.” Another key is to have is a well-developed compliance program, said Anderson. Some questions a utility should consider. • Does the utility have an established, formal program for internal compliance? • Is it well-documented and widely disseminated within the utility? • Is the program supervised www.APPAnet.org by an officer or other highranking official? • Does the compliance official report to or have independent access to the chief executive officer and/or the board of directors? • Is the program managed to be independent? • Are sufficient resources dedicated to the compliance program? • Is compliance fully supported by senior management? • How frequently does the company review and modify the compliance program? • How frequently is training provided to all employees? • Is the training sufficiently detailed and thorough to instill an understanding of relevant rules and the importance of compliance? • Does the utility have an ongoing process for compliance with FERC regulations? • How has the utility responded to prior wrongdoing? • Did it take disciplinary action against employees involved in violations? • When a violation occurs, is it a repeat of the same offense, or of a different nature? • Does the utility adopt and ensure enforcement of new and more effective internal controls and procedures to prevent a recurrence of misconduct? According to Anderson, FERC offers some additional recommendations for compliance program elements, which include: • Prepare an inventory of current compliance risks and practices. • Create an independent compliance officer who reports to the CEO and the board, or to a committee thereof. • Provide sufficient funding for the administration of com- pliance programs by the compliance officer. • Promote compliance by identifying measurable performance targets. • Tie regulatory compliance to personnel assessments and compensation, including compensation of management. • Provide for disciplinary consequences for infractions of commission requirements. • Provide frequent mandatory training programs, including relevant real world examples and a list of prohibited activities. • Implement an internal hotline through which personnel may anonymously report suspected compliance issues. • Implement a comprehensive compliance audit program, including the tracking and review of any incidents of noncompliance, with submission of the results to senior management and the board. In Nebraska, Omaha Public Power District has been audited by NERC twice—through a readiness evaluation and a compliance audit. Based on the utility’s experience with the two audits, Blaine Dinwiddie, division manager, T&D operations, for OPPD, agrees with Anderson: the key to success is preparation. “The first thing we did was an internal self-audit, reviewing all of the standards and verifying that we were in compliance with them,” he said. The utility also used this information to gather and organize support data. We were so organized, we were able to just hand the documents to the auditors as they asked for them, said Dinwiddie. “The more prepared you are, the easier it is for the auditors, and the more positively that is viewed,” he said. Another key is to look for and ask for input and help from the auditors, rather than getting defensive. “If they have suggestions, it is important to incorporate those suggestions,” he said. NERC frequently looks for industry support in the form of audit members and teams, said Dinwiddie. “We have had our own employees participate in audits of other utilities. While they can’t talk about the specifics of a given audit or its results, they can bring back their experiences of what went well and what didn’t go well, and we can incorporate this information into our operations.” T Order entry, work order and billing for video, data, and voice services Broadband Billing Solutions for Utilities Automated provisioning of FTTH Network and all other technologies Use your existing utility billing system or ETI’s optional module 800.332.1078 www.etisoftware.com OCTOBER 2008 43 http://www.etisoftware.com http://www.APPAnet.org

Table of Contents Feed for the Digital Edition of Public Power - October 2008

Public Power - October 2008 Contents Perspective 10 Questions The Future of Fuels in a Carbon-Constrained World An Energy Revolution Energy Policy in 2009 and Beyond A Green Reincarnation Beyond the Green Bandwagon Reliability Green Energy Community Broadband Customer Service Hometown Connections Human Resources Parting Shot

Public Power - October 2008

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