NERC Case Notes: Reliability Standard COM-001-1.1


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Cleco Corporation, FERC Docket No. NP11-265-000 (August 31, 2011)

Reliability Standard: COM-001-1.1

Requirement: R1

Violation Risk Factor: Lower

Violation Severity Level: Severe

Region: SPP

Issue: During a compliance audit in April 2010, SPP found that Cleco Corporation (Cleco), as a Balancing Authority and Transmission Owner, did not possess sufficient documentation showing that Cleco would be able to communicate with its substations if there was a loss of telecommunications connection. In addition, Cleco did not specify that its operations would move to a backup control center if the telecommunications connection was lost at Cleco's primary control center nor did it provide its operating personnel with written operating instructions and procedures for continuing system operations after a loss of the telecommunications facilities.

Finding: SPP and Cleco entered into a settlement agreement to resolve multiple violations, whereby Cleco agreed to pay a penalty of $27,000 and to undertake other mitigation measures. SPP found that the COM-001-1.1 violation only constituted a minimal risk to bulk power system reliability since SPP had procedures in place that would provide for the staffing of the substations with field personnel after a loss of communications with the substations. In addition, Cleco had multiple communication systems in place, which provided for numerous options in the face of telecommunications system failure. The duration of the COM-001-1.1 violation was from June 18, 2007 through May 13, 2010. In approving the settlement agreement, NERC found that these were Cleco's first violations of the relevant Reliability Standards; Cleco was cooperative during the enforcement process and did not conceal the violations; Cleco had a compliance program in place (which was evaluated as a mitigating factor); and there were no additional aggravating or mitigating factors or other extenuating circumstances.

Penalty: $27,000 (aggregate for 6 violations)

FERC Order: Issued September 30, 2011 (no further review)