White & Case
  Case Notes: Reliability Standard IRO-STD-006-0

Arizona Public Service Company, FERC Docket No. NP10-2-000 (October 14, 2009)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: R1
  • Violation Risk Factor: N/A
  • Violation Severity Level: Not provided
  • Region: WECC
  • Issue: Arizona Public Service Company (APSC) self-reported that on May 22, 2008 it had not cut a transaction tag in a timely manner as needed since it did not have the relevant redundant procedures to guarantee that it received the Unscheduled Flow (USF) alarm. This regional standard requires entities, when faced with USF that cannot be otherwise controlled and absorbed, to reduce schedules, and thereby the amount of power flowing, in order to reduce the amount of USF.
  • Finding: WECC found that this violation did not involve a serious or substantial risk to bulk power system reliability since the Balancing Authority operator took immediate corrective actions to reduce the USF (such as reducing generation schedules in order to reduce the overloads on Path 22) and APSC M&T later cut a tag. In addition, APSC self-reported the violation; this was APSC's first violation of this Reliability Standard; and it completed a mitigation plan.
  • Penalty: $0
  • FERC Order: Issued November 13, 2009 (no further review)

Arizona Public Service Company, FERC Docket No. NP10-2-000 (October 14, 2009)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: Not provided
  • Region: WECC
  • Issue: Arizona Public Service Company (APSC) self-reported that on June 30, 2008 it had not cut a transaction tag in a timely manner as needed since it did not have the relevant redundant procedures to guarantee that it received the Unscheduled Flow (USF) alarm. This regional standard requires entities, when faced with USF that cannot be otherwise controlled and absorbed, to reduce schedules, and thereby the amount of power flowing, in order to reduce the amount of USF. This was APSC's second violation of this standard.
  • Finding: WECC found that this violation did not constitute a serious or substantial risk to bulk power system reliability since this violation only had a minimal impact (as it involved only 2 MW of flow on a 4,800 MW path). In addition, APSC self-reported the violation and it completed a mitigation plan. And even though this was APSC's second violation of this standard, no penalty was imposed.
  • Penalty: $0
  • FERC Order: Issued November 13, 2009 (no further review)

Black Hills Power, Inc., FERC Docket No. NP10-2-000 (October 14, 2009)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: R1
  • Violation Risk Factor: N/A
  • Violation Severity Level: Not provided
  • Region: WECC
  • Issue: In August 2007, Black Hills Power, Inc. provided -3 MW of relief at a time when it was supposed to provide 0 MW of relief (which caused a .46% increase in Unscheduled Flow).
  • Finding: WECC found that this violation did not constitute a serious or substantial risk to bulk power system reliability by Black Hills Power, Inc. since the provision of -3 MW of relief did not result in a violation of the Operating Transfer Capability. This was Black Hills Power, Inc.'s first violation of this Reliability Standard and it completed a mitigation plan.
  • Penalty: $0
  • FERC Order: Issued November 13, 2009 (no further review)

Black Hills Power, Inc., FERC Docket No. NP11-13-000 (November 5, 2010)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: N/A
  • Region: WECC
  • Issue: Black Hills created a restricted transaction that contributed 1.5 MW to a qualified path, but failed to take corresponding measures to compensate for the full impact on the qualified path as required by the standard.
  • Finding: It was determined by WECC that the violation did not constitute a serious or substantial risk to the bulk power system because Black Hills' violation did not result in an overload of the transmission system. The duration of violation was from October 24, 2009 through October 24, 2009 for an hour.
  • Penalty: $0
  • FERC Order: Issued December 3, 2010 (no further review)

California Independent System Operator Corporation, FERC Docket No. NP10-47-000 (February 1, 2010)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: Not provided
  • Region: WECC
  • Issue: IRO-STD-006-0 is designed to mitigate transmission overloads due to unscheduled line flow on qualified paths. In response to a WECC inquiry, California Independent System Operator Corporation (CAISO) self-reported to FERC a violation of IRO-STD-006-0 for its failure to provide the proper amount of required relief on a qualified path during a multi-hour unscheduled flow event on October 2, 2007. Specifically, CAISO's scheduler missed an off-path schedule of 25 MW that should have been cut to 10.5 MW to provide the required 2.6 MW of relief on the qualified path. WECC confirmed that a violation of IRO-STD-006-0 occurred.
  • Finding: WECC recommended a penalty of $0. In reaching this recommendation, WECC took into consideration the following: (i) the sanction table in the standard sets the sanction for the two occurrences of a letter with no monetary penalty; (ii) the violation was not deemed to pose serious or substantial risk to the bulk power system; (iii) the violation was the first time CAISO violated this standard; (iv) there were no aggravating factors; (v) CAISO was cooperative during the compliance process; (vi) there was no evidence that CAISO attempted to conceal the violation; and (vii) there was no evidence that CAISO intentionally violated the reliability standard. NERC approved SERC's recommendation for these reasons.
  • Total Penalty: $0
  • FERC Order: Issued March 3, 2010 (no further review)

City of Anaheim, FERC Docket No. NP11-141-000 (March 30, 2011)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: N/A
  • Region: WECC
  • Issue: The City of Anaheim (ANHM), a Load Serving Entity, changed a restricted transaction, which led to an increased flow on the qualified path; in turn, ANHM did not take effective alternative action to achieve the required reduction in Unscheduled Flow across the constrained Qualified Transfer Path.
  • Finding: The NERC Board of Trustees Compliance Committee (NERC BOTCC) approved a penalty in the amount of $0 for this violation. In reaching this determination, the NERC BOTCC considered the following facts, among others: the violation constituted ANHM's first violation of the subject NERC Reliability Standard; ANHM cooperated during the compliance enforcement process; the violation did not create a serious or substantial risk to the bulk power system; and there were no other mitigating or aggravating factors or extenuating circumstances.
  • Penalty: $0
  • FERC Order: Issued April 29, 2011 (no further review)

City of Glendale, FERC Docket No. NP12-10 (December 30, 2011)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: N/A
  • Region: WECC
  • Issue: The City of Glendale (City), as an LSE, self-reported a violation of Regional Reliability Standard, IRO-STD-006-0 as a result of Unscheduled Flow (USF) violations by its agent for real-time trading and scheduling, ACES Power Marketing LLC (APM). The first violation occurred when a trader failed to respond for one hour resulting in 2.2 MW of non-compliance. A second time, APM reacted to an alarm and curtailed a tag by 4 MW for relief. After that action, a purchase was made that accidentally caused the line to go over its limit causing 0.8 MW of non-compliance. Although APM attempted to correct the error, WAPA-Lower Colorado rejected the adjustment because the submission was late. The third violation occurred when APM did not respond to a 3 MW schedule and tag that should have been adjusted to 0 MW causing 1.0 MW of non-compliance.
  • Finding: WECC found the violation constituted a minimal risk to BPS reliability. Although AES Alamitos had not tested the batteries according to the time specified in its M&T program, the batteries had been tested. Also, any malfunction of the batteries would set off an alarm alerting employees to a problem. The duration of the violation was June 18, 2007 through March 31, 2011. WECC took the following under consideration when determining the appropriate penalty amount: AES Alamitos took appropriate measures to fix the problem; the violation was self-reported; AES Alamitos’ compliance program; the violation was not a repeat violation; AES Alamitos was cooperative during the compliance process; there was no evidence AES Alamitos attempted to hide the violation or that it was intentional; and there were no aggravating factors.
  • Penalty: $8,700
  • FERC Order: Issued January 27, 2012 (no further review)

City of Redding, FERC Docket No. NP10-2-000 (October 14, 2009)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: Not provided
  • Region: WECC
  • Issue: It was determined in October 2007 that the City of Redding had not provided the unscheduled flow relief as required.
  • Finding: WECC found that this violation did not involve a serious or substantial risk to bulk power system reliability since the City of Redding's actions did not cause the Operating Capability limit to be violated. This was the City of Redding's first violation of this Reliability Standard and a Mitigation Plan was completed.
  • Penalty: $0
  • FERC Order: Issued November 13, 2009 (no further review)

Colorado Springs Utilities, FERC Docket No. NP10-190-000 (September 30, 2010)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: Not provided
  • Region: WECC
  • Issue: Colorado Springs self-certified that it had created a Restricted Transaction on WECC Path 66 and failed to provide required relief during a USF Event.
  • Finding: It was determined by WECC that the violation did not constitute a serious or substantial risk to the bulk power system because the magnitude of the impact was very small compared to the transfer capability of the constrained path. The violations occurred solely on July 10, 2008. In determining the penalty amount, WECC also considered that this was Colorado Springs' first violation of the standard, and that it had self-reported or self-certified 6 of the 9 violations that gave rise to the penalty.
  • Penalty: $31,000 (aggregate for multiple violations)
  • FERC Order: Issued October 29, 2010 (no further review)

Deseret Generation & Transmission Co-operative, FERC Docket No. NP10-2-000 (October 14, 2009)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: Not provided
  • Region: WECC
  • Issue: It was determined in May 2008 that an employee of Deseret Generation & Transmission Co-operative (DGTC) used an incorrect path matrix, and when taking correcting action, he did not notice the visual indication of potential non-compliance on the software tool.
  • Finding: WECC found that this violation did not involve a serious or substantial risk to bulk power system reliability since there was only a very limited amount of loop flow (approximately 2.4 MWh, or <0.1%) that continued on the path, when it should have been relieved. DGTC self-reported this violation; it was DGTC's first violation of this Reliability Standard; and DGTC completed a Mitigation Plan.
  • Penalty: $0
  • FERC Order: Issued November 13, 2009 (no further review)

Gila River Power, LP - BA, FERC Docket No. NP11-90-000 (January 31, 2011)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: N/A
  • Region: WECC
  • Issue: WECC found that Gila River Power, LP – BA (GRMA), as a Balancing Authority, had not followed a request it received on July 26, 2007 from the Transfer Path Operator after an Unscheduled Flow (USF) Procedure had been initiated – and actually caused an Unscheduled Flow (USF) increase of 4 MW.
  • Finding: WECC and GRMA entered into a settlement agreement to resolve multiple violations, whereby GRMA agreed to undertake other mitigation measures to resolve the violations. WECC found that the IRO-STD-006-0 violation did not constitute a serious or substantial risk to bulk power system reliability since in this instance GRMA only had one occurrence of unscheduled line flow on the Qualified Path (which constituted less than 1% of the overall path rating). The duration of the IRO-STD-006-0 violation was from July 26, 2007 through November 1, 2007. In approving the settlement agreement, NERC found that this was GRMA's first violation of the relevant Reliability Standards; GRMA was cooperative during the enforcement process and did not conceal the violations; and there were no additional mitigating or aggravating factors.
  • Penalty: $0
  • FERC Order: Issued March 2, 2011 (no further review)

Los Angeles Department of Water and Power, FERC Docket No. NP10-141-000 (July 6, 2010)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: Not provided
  • Region: WECC
  • Issue: LADWP self-reported that it had initiated restricted transactions without providing the required relief during a multiple-hour Unscheduled Flow event on May 17, 2008, and did so again during a single-hour event on May 29, 2008. WECC also found that it had not complied with requests from Transfer Path Operators to take actions that would have reduced unscheduled flow on a Qualified Path.
  • Finding: Duration of the violation was from May 17, 2008 through October 14, 2008. The violation did not pose a serious or substantial risk to the reliability of the bulk power system because events involved less than one percent of the 840 MW path rating for each of the affected hours. LADWP was given credit for self-reporting the violation.
  • Penalty: $225,000 (aggregate for multiple violations)
  • FERC Order: Issued Oct. 8, 2010 (no further review)

Los Angeles Department of Water and Power (LADWP), Docket No. NP12-47-000 (September 28, 2012)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: N/A
  • Region: WECC
  • Issue: LADWP created a restricted transaction on a qualified path during an Unscheduled Flow Event (USF), but failed to take corresponding measures to compensate for the full impact on the qualified path as required by the Standard.
  • Finding: The violation was deemed to pose minimal risk to BPS reliability because the incident involved a small transaction, which was only discovered during LADWP's review of all USF events. The transaction had such a small effect on the BPS it was not even noticed until LADWP brought it to the attention of WECC. In determining the appropriate penalty, WECC considered LADWP's Internal Compliance Program as a mitigating factor. LADWP neither admitted to nor denied WECC's findings.
  • Penalty: $6,000 (aggregate for three violations)
  • FERC Order: Issued October 26, 2012 (no further review)

NorthWestern Corporation, FERC Docket No. NP10-2-000 (October 14, 2009)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: Not provided
  • Region: WECC
  • Issue: In August 2007, it was determined that NorthWestern Corporation (NorthWestern) did not provide the 1 MW of requested relief that was ordered in response to an unscheduled flow event. Instead, NorthWestern did not reduce its schedules and provided no relief.
  • Finding: WECC found that this violation did not pose a serious or substantial risk to the bulk power system since the relief requested was minimal (only 1 MW). This was NorthWestern's first violation of this Reliability Standard. A mitigation plan has been completed.
  • Penalty: $0
  • FERC Order: Issued November 13, 2009 (no further review)

Northwestern Corporation, FERC Docket No. NP11-266-000 (August 31, 2011)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: N/A
  • Region: WECC
  • Issue: Northwestern Corporation (NWC) self-reported that it did not provide Unscheduled Flow (USF) relief during a USF event on WECC Qualified Transfer Path 66.
  • Finding: WECC found that the violation did not constitute a serious or substantial risk to the bulk power system because NWC's increased flow on the affected path was virtually undetectable, and the path operator was capable of curtailing transactions to reduce loading if necessary, but curtailment did not become necessary. Duration of violation was June 17, 2010.
  • Penalty: $0
  • FERC Order: Issued September 30, 2011 (no further review)

Public Utility District No. 1 of Chelan County, FERC Docket No. NP10-2-000 (October 14, 2009)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: Not provided
  • Region: WECC
  • Issue: In October 2007, Public Utility District No. 1 of Chelan County (CHPD) self-reported that it was unable to comply with requests from (Qualified) Transfer Path Operators to take actions to reduce unscheduled flow on the Qualified Path.
  • Finding: WECC found that this violation did not pose a serious or substantial risk to the bulk power system since CHPD was actually taking some actions (even as it could not comply with the requests of the (Qualified) Transfer Path Operators as required). The violation was self-reported and this was CHPD's first violation of this Reliability Standard. A mitigation plan has been completed.
  • Penalty: $0
  • FERC Order: Issued November 13, 2009 (no further review)

Sacramento Municipal Utility District, FERC Docket NP10-106-000 (May 3, 2010)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: Not provided
  • Region: WECC
  • Issue: WECC discovered through Sacramento Municipal Utility District's (SMUD) exception report that on June 28, 2009, SMUD had modified a Restricted Transaction for two hours without taking alternative actions to compensate for the impact of the transaction on the affected transmission path.
  • Finding: Duration of the violation was from June 28, 2009 through July 23, 2009 when SMUD completed a mitigation plan. The violation did not pose a serious or substantial threat to the bulk power system because the path on which the Restricted Transaction occurred had a high path rating, and SMUD's actions contributed to less than 0.2% of the Path Rating. The Transmission Operator also had curtailment options with respect to transactions directly scheduled on the affected path to reduce congestion if such action had been necessary. In addition, this was SMUD's first violation of this standard.
  • Penalty: $9,900 (aggregate for multiple violations)
  • FERC Order: Issued May 28, 2010 (no further review)

Sacramento Municipal Utility District (SMUD), FERC Docket No. NP12-5 (November 30, 2011)

  • Reliability Standard: IRO-STD-006
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: N/A
  • Region: WECC
  • Issue: SMUD, an LSE, submitted both a Self-Certification and Self-Report explaining a violation of IRO-STD-006-0. SMUD reported that during an Unscheduled Flow (USF) event, during which a Curtailment Procedure had been implemented, an operator started a Restricted Transaction by scheduling 20 MW on an off-path which contributed 3.4 MW of unscheduled flow during the USF event. The violation is considered a Level One Noncompliance.
  • Finding: WECC determined the violation posed a minimal risk to BPS reliability because the small amount of unscheduled flow would not have a significant impact on BPS reliability and compensating measures were available in the event the unscheduled flow would have possibly caused a system overload. SMUD initially scheduled 20 MW, but stopped the schedule within three minutes of the time the Curtailment Procedure was in place. Also, the affected Path had not reached its operating limit and had a 250 MW available margin. In determining the appropriate penalty, WECC considered the severity and the duration of the violation as mitigating factors.
  • Penalty: $0
  • FERC Order: Issued December 30, 2011 (no further review)

Tri-State Generation and Transmission Association, Inc.-Marketing, FERC Docket No. NP10-2-000 (October 14, 2009)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: Not provided
  • Region: WECC
  • Issue: Tri-State Generation and Transmission Association, Inc.-Marketing (TSMD) reported three separate violations (in August 2007, May 2008, and June 2008) of IRO-STD-006-0 in which it was unable to comply with requests from (Qualified) Transfer Path Operators to take actions to reduce unscheduled flow on the Qualified Path.
  • Finding: WECC found that the violations did not pose a serious or substantial risk to the bulk power system since TSMD was actually taking some actions (even though it could not comply with the requests of the (Qualified) Transfer Path Operators as required). Mitigation plans have been completed for the three violations. Two of the violations were self-reported (whereas as the first incident was reported through exception reporting).
  • Penalty: $0
  • FERC Order: Issued November 13, 2009 (no further review)

Tri-State Generation and Transmission Association, Inc. – Marketing, FERC Docket No. NP10-100-000 (April 28, 2010)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: Level 1 Non-Compliance
  • Region: WECC
  • Issue: In July 2009, Tri-State Generation and Transmission Association, Inc. – Marketing (TSMD) self-reported that on June 23, 2009 it engaged in a Restricted Transaction during an unscheduled flow (USF) event, without fully compensating for the impact of that transaction on the Qualified Path. TSMD impermissibly commenced a transaction that had a Transfer Distribution Factor greater than 5% (thereby qualifying as a Restricted Transaction) in order to re-balance load and generation between scheduling hubs. When compensating for the impact of this transaction, TSMD provided approximately 2 MW less of relief than what was required by the Path Operator. TSMD had new employees on duty during the incident who were not experienced with curtailment responses to USF events.
  • Finding: WECC found that the violation did not pose a serious or substantial risk to the bulk power system since TSMD contributed less than .01% of the Path Rating (and the impact on the bulk power system is based on the amount of flow on a potentially overloaded path). Although this was TSMD's fourth alleged violation of IRO-STD-006 WR1, the other violations involved TSMD not providing requested relief during a USF event, whereas this violation involved TSMD initiating a Restricted Transaction during a USF event. Therefore, this violation was not considered a repeated violation. In addition, TSMD was cooperative during the compliance enforcement process, did not conceal the violation, and the violation was not intentional. A mitigation plan has been completed.
  • Penalty: $0
  • FERC Order: Issued May 28, 2010 (no further review)

Unidentified Registered Entity, FERC Docket No. NP11-2-000 (October 7, 2010)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: N/A
  • Region: WECC
  • Issue: Records provided by WECC's webSAS application indicated that an Unidentified Registered Entity (URE) failed to properly respond to Unscheduled Flow Procedure requests issued by the WECC Path Operator and consequently failed to provide sufficient transmission loading relief upon request on one occasion, and failed to reduce sufficient flow upon request on another occasion.
  • Finding: The violation did not pose a serious or substantial risk to the reliability of the bulk power system because it was an isolated incident. Although widespread failure to comply with this Standard could significantly impact the bulk power system, this incident did not result in an overload of the transmission system. The Transmission Operator retained the capability of curtailing transactions to reduce load in the event of an overload.
  • Penalty: $9,000 (aggregate for multiple violations)
  • FERC Order: Issued November 5, 2010 (no further review)

Unidentified Registered Entity, FERC Docket No. NP11-180-000 (April 29, 2011)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: N/A
  • Region: WECC
  • Issue: The Unidentified Registered Entity (URE) self-reported that it had not provided the full amount of requested relief in response to an unscheduled flow (USF) event called by a Transmission Operator. In response to the USF event, the URE was ordered to provide 12.1 MW of relief by curtailing two pre-existing transactions as well as a transaction that it created after the USF event started (a restricted transaction). The URE only provided 4.2 MW of relief since it did not curtail the restricted transaction.
  • Finding: WECC and the URE entered into a settlement agreement to resolve multiple violations, whereby the URE agreed to pay a penalty of $71,500 and to undertake other mitigation measures. WECC found that the violation of IRO-STD-006-0 constituted a minimal risk to bulk power system reliability since the amount of flow increase on the relevant line accounted for less than 1% of the line rating, and this violation did not cause an overload of the transmission system. The duration of the IRO-STD-006-0 violation was one day. In approving the settlement agreement and the penalty determination, NERC considered the fact that the violations were the URE's first violations of the relevant Reliability Standards; most of the violations were self-reported; the URE was cooperative during the enforcement process and did not conceal the violations; the URE had a compliance program in place (which was evaluated as a mitigating factor); the penalty for the violation of IRO-STD-006-0 WR1 was based on a specified Sanction Table; the violations of IRO-005-2 R13 and TOP-008-1 R2 resulted from a single noncompliance occurrence; and there were no additional aggravating or mitigating factors.
  • Penalty: $71,500 (aggregate for 9 violations)
  • FERC Order: May 27, 2011 (no further review)

Unidentified Registered Entity, FERC Docket No. NP12-38 (July 31, 2012)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: Level 1 Non-Compliance (3 occurrences in one month)
  • Region: WECC
  • Issue: URE self-reported non-compliance with the Regional Reliability Standard related to Unscheduled Flow (USF) events. First, a USF Procedure was initiated by the Path Operator (PO) for an event that lasted seven hours. During that time, URE initiated a real-time energy transaction (that was not in place prior to the USF event reaching Step 4), which incurred relief obligations as a Restricted Transaction for six hours. For two other USF Procedures initiated by the PO for an event that lasted one hour, URE initiated real-time energy transactions (that were not in place prior to the USF events reaching Step 4), and each transaction incurred relief obligations as a Restricted Transaction for the hour. During these events, URE did not provide the relief required by the USF Procedures or equivalent relief through any alternate actions.
  • Finding: WECC found that the IRO-STD-006-0 violation only constituted a minimal risk to BPS reliability since the three occurrences represented only minor instances of non-compliance. The risk in an USF situation depends on how much an entity contributes to the electricity flow on the potentially overloaded path, as well as the other resources that are available to the transmission operators to mitigate potential overloads on the transmission system. In the case of URE, the non-compliance occurrences did not overload the system, and the TOP continued to have the ability to curtail transactions that were directly scheduled on the qualified paths in order to reduce loading. In approving the settlement agreement, the NERC BOTCC considered the fact that some of the violations were URE’s second or third violation of the relevant Reliability Standards; some of the violations were self-reported; URE was cooperative during the enforcement process and did not conceal the violations; URE had an internal compliance program (which was evaluated as a mitigating factor); the violations did not constitute a serious or substantial risk to BPS reliability; and there were no additional aggravating or mitigating factors.
  • Penalty: $72,000 (aggregate for 12 violations)
  • FERC Order: Issued August 30, 2012 (no further review)

Unidentified Registered Entity (URE), Docket No. NP12-47-000 (September 28, 2012)

  • Reliability Standard: IRO-STD-006-0
  • Requirement: WR1
  • Violation Risk Factor: N/A
  • Violation Severity Level: N/A
  • Region: WECC
  • Issue: URE was found to be in violation of IRO-STD-006-0 WR1 because URE did not respond to a schedule curtailment request for 29 minutes.
  • Finding: The violation was deemed to pose minimal risk to BPS reliability. The identified Qualified Path was rated at approximately 500 MW at the time and was flowing at less than the rate of the Qualified Path, accommodating 100 MW of unscheduled flow. URE's curtailment obligation equaled 0.28% of the flow on the path. The required schedule relief in the curtailment request was 1.4 MW and the duration lasted 29 minutes. In determining the appropriate penalty, URE was given mitigating credit for its internal compliance program.
  • Penalty: $65,000 (for 11 violations)
  • FERC Order: Issued October 26, 2012 (no further review)