WECC COMPLIANCE 101
Webinar
Thursday, October 9, 2014
2
Agenda
 Introductions
Laura Scholl
 Overview of WECC and
Regulatory Structure
Connie White
 Audit – What to Expect
Stacia Ellis and Bill Fletcher
 Enforcement Overview
Rachael Ferrin, Richard Shiflett,
Haley Sousa, and Joelle Bohlender
 webCDMS and EFT
Brittany Power
Overview of WECC and Regulatory
Structure
Constance White
Vice President of Compliance and
Acting Regional Manager
COMPLIANCE 101
Overview of WECC
And Regulatory Structure
5
WECC Profile
The Western Electricity Coordinating Council
(WECC) is a non-profit corporation that exists to
assure a reliable bulk electric system in the
geographic area of the Western Interconnection.
This area includes all or parts of the 14 western
United States, two Canadian provinces, and the
northern portion of Baja California, Mexico.
6
WECC History
• Incorporated in 2002
• Predecessor, WSCC formed in 1967
• Largest geographic area of the eight Regional Entities
o Entire Western Interconnection (1.8 million square miles) includes all or part of 14 U.S. states, 2 Canadian provinces
and a portion of Baja California Norte, Mexico
• Non-Governmental
• Industry participants join together to promote system reliability
• Bifurcation in February 2014 changed functions
7
WECC Coverage Service Area
1.8 million square miles
126,285 miles of transmission
Population of 78 million
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9
WECC Organization
• Independent Board of Directors
o 9 members
o Committees
• Members Advisory Committee
• Members
• Grid owners, operators, users
• Stakeholders
• State and Provincial
10
Bifurcation
Peak Reliability assumed responsibility for
Reliability Coordination
o Operate two Reliability Coordination Offices (Vancouver WA
and Loveland CO) that provide situational awareness and
real-time supervision of the entire Western Interconnection
11
WECC Services
• Transmission expansion planning
o Management of a comprehensive planning database
o Provide coordination of sub-regional planning processes
o Analyses and modeling
• Studies
o Model the system and perform studies under a variety of
scenarios to set operating policies and limits
12
WECC Services
• Loads and Resources Assessments
o Perform annual assessment of 10-year loads and resources
o Maintain 10-year coordinated plan of system growth
o Provide information to NERC for summer and winter assessments of
the reliability and adequacy of the bulk-power system
• Operator Training
o Provide training sessions for operators, schedulers and dispatchers
• WREGIS
o Hosts the Western Renewable Energy Generation Information
System, which creates and tracks renewable energy certificates
13
WECC Services
Delegation Agreement
o Perform functions delegated to WECC as a Regional Entity
under Delegation Agreement with NERC, including
regulating entities subject to mandatory Reliability
Standards
14
Mandatory Reliability Regulation
• Northeast Blackout
of 2003
– 10 Million people
in Ontario, Canada
– 45 million people in
eight U.S. states
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16
17
Task Force Report
• Final report of the U.S.- Canada Power System
Outage Task Force on the 2003 blackout
concluded:
the single most important recommendation for
preventing future blackouts, and reducing the
scope of those that occur, is for the U.S.
government to make reliability standards
mandatory and enforceable.
18
Task Force Findings
Inadequate System Understanding
Inadequate Situational Awareness
Inadequate Tree Trimming
Inadequate Reliability Center
Diagnostic Support
Congressional Action
•Energy Policy Act of 2005
On August 8, 2005, the Energy Policy Act of 2005
(EPAct 2005) was signed into law.
•“Section 215”
Section 215 of the EPAct 2005 directed FERC to certify
an Electric Reliability Organization (ERO) and develop
procedures for establishing, approving and enforcing
electric reliability standards.
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Authority for Compliance Monitoring
• FERC Order 672 (Implementing Rule 18 CFR
39)
– Responsibility and oversight assigned to FERC
– FERC designated NERC as Electric Reliability
Organization
– NERC has delegation agreement with WECC and
seven other regions
Implementing Section 215
SECTION 215
Regional
Entities
Delegation
Agreement
• Creates Electrical Reliability Organization (ERO)
• FERC names NERC as ERO
• NERC selects 8 regional entities
• WECC is selected for Western Interconnection
• NERC and WECC sign agreements
• WECC oversight begins in Western
Interconnection
Development of Mandatory Reliability
Standards
Operations and Planning (O&P) Standards become mandatory
and enforceable
June17, 2007 (FERC Order 693)
Critical Infrastructure Protection (CIP) standards become
mandatory and enforceable December 2009
(FERC Order 706)
23
Order 693 & Order 706 Standards
• Order 693 (Operations and Planning) includes:
–
–
–
–
Resource and Demand Balancing (BAL)
Emergency Preparedness & Operations (EOP)
Facilities Design, Connection & Mtnce. (FAC)
Protection and Control (PRC)
• Order 706 (CIP) includes:
– Critical Cyber Asset Identification
– Personnel & Training
– Electronic Security Perimeters
24
WECC Compliance
• Recommends Registrations for Entities
o Register users, owners, operators according to function
• Monitors Compliance with Standards
o Monitor compliance by users, owners and operators of the bulk
power system in the United States
• Enforces Compliance
o Violation mitigation and settlement negotiation
o Representation of WECC in any hearing or appeal process
• Administration
o Audit coordination
o Reporting systems
o webCDMS and EFT
25
In summary…
Authority
CMEP
Reliability Standards
Delegation Agreement
Federal Power Act 2005
Registration
Registration
Authority
Registration
Monitoring
Authority
Monitoring
Registration
Enforcement
Authority
Education/Outreach
Authority
Enforcement
Monitoring
Registration
Education/Outreach
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Reference Documents
• Compliance Monitoring and Enforcement Program
(CMEP) & WECC’s annual plan
• Delegation Agreement
• Rules of Procedure
• NERC Standards and WECC Regional Standards
• NERC Guidance, Bulletins, Directives and Compliance
Application Notices (CANs)
• FERC Orders
Notice of Audit
Stacia Ellis
Compliance Program Coordinator
33
Notice of Compliance Audit Packet
• Notice of Audit Letter
• Compliance Monitoring Authority Letter
• Audit Team Biographies
• Confidentiality Agreements
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Notice of Compliance Audit Packet
• Certification Letter
• Pre-Audit Data Requests
• Pre-Audit Survey
• Audit Scope and WECC RSAWs
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Notice of Compliance Audit Letter
• 90-Day Notice of Audit Letter
– Details of your specific Audit
•
•
•
•
Dates of Audit
Audit Scope
Due Dates
Audit Team Composition, observers (if applicable)
– Observers can include FERC/NERC
• Date/time of proposed Pre-Audit Conference Call
• Opening Presentation Suggestions
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Notice of Compliance Audit Letter
• Audit Team Composition
– Primary Audit Team
• Individuals expected to participate in the Audit
– Alternate Audit Team
• Individuals available to act as backup or replacements
for Primary Team members
37
Attachments A, B and C
• Attachment A
– Informational; Explanation of Compliance
Monitoring Authority
• Attachment B
– Short Biographies of the WECC Audit Staff
• Attachment C
– Signed Confidentiality Agreements of the WECC
Audit Staff
38
Attachments D and E
• Attachment D
– Audit Scope
– RSAWs (Reliability Standard Audit Worksheets)
• Customized for your Entity and your audit
– Based on your Registered Functions and Audit Scope
• Attachment E
– Certification Letter
• Must be printed on your company letterhead and signed by
an Authorized Officer
• Certifies that the information being provided for the Audit is
accurate
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Attachment F
• Attachment F
– Pre-Audit Survey
•
•
•
•
Verify contact information
Audit Logistics
List any delegation agreements
Signed by Authorized Officer
• Please complete all applicable fields
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Attachment G
• Attachment G
– Pre-Audit Data Requests
• Why are we doing this to you?!?
o Clarifications for data submittals
o Specifying types of evidence to remove some
of the guesswork
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Att G – Operations & Planning (O&P) Data
• Some evidence may apply to more than one
Standard
– One copy is sufficient, but document inventories
or “roadmaps” are appreciated
• Single Line Diagram
– Requested for the majority of Audits
42
Att G – Cyber Security (CIP) Data
• CIP-004 – CIP-009 may not be applicable
based upon the Critical Asset/Critical Cyber
Asset determination
– Determined by CIP-002-3 Requirements 2 & 3
– Complete RSAWs indicating absence of CA/CCA
identification
– 2015 CIP audits will include CIP v5 outreach
If you have any questions please contact Brent Castagnetto at
bcastagnetto@wecc.biz or 801-819-7627
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Attachment H
• Attachment H
– Audit Feedback
– Now sending with initial package
• Feedback is encouraged for all phases of audit.
44
Audit Periods Defined
• Audit Periods, for O&P and CIP, are clearly
defined in Attachment G for both:
• Operations and Planning (O&P)
• Cyber Security (CIP)
45
Audit Frequency
• 3 year cycle
Entities registered as a:
– Balancing Authority (BA)
– Transmission Operator (TOP) or
– Reliability Coordinator (RC)
• All others
– Generally a 6 year cycle. Subject to flexibility in
the future as part of NERC’s Reliability Assurance
Initiative (RAI).
46
Outreach
• “Howdy Call”
– A few days after Notice of Audit Packet is
uploaded to the EFT Server.
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Recommendations
•
•
•
•
•
Know the Reliability Standards
Use the RSAWs as guides
Ask questions
Participate in Outreach (CUG/CIPUG)
We are here for you…
– Questions
– Comments
– Concerns
Audit Approach and Best Evidence
William Fletcher
Senior Compliance Auditor,
Operations and Planning
49
Compliance Audit (on-site vs. off-site)
• Primary difference is:
– Location of audit conduct
• Scope is typically smaller for off site.
• On-Site – Required for RC, BA, TOP functions
• Per NERC Rules of Procedure 403.11.2
50
Compliance Audit (on-site vs. off-site)
• On-Site
– Documentation sent to WECC before audit for preliminary review
– The audit team reviews evidence during off-site week or the first week of the
audit and completes its review during the second week or on-site week
– Data Requests or DRs
– In-person interviews for clarification
• Off-Site
– Documentation sent to WECC before audit for preliminary review
– Data Requests or DRs
– Entity may be present at audit if desired
– Telephone interviews for clarification
Audit Approaches
•We audit to the Requirements of the Standards
•General Approaches included in RSAW
•RSAW may ask specific questions
•Always includes the section:
“Describe, in narrative form, how you meet compliance with
this requirement.”
52
Audit Approaches
“Describe, in narrative form, how you meet
compliance with this requirement.”
• Describe here how your company knows it is compliant with
this requirement and how you know you have been
compliant for the entire period of the audit.
• Your place to describe your internal controls.
• Your evidence should support your narrative.
53
Audit Approaches
• List the evidence provided in the RSAW.
o This road map is important
• Compliance Assessment Approach in RSAW is used as
a checklist.
o Data Request (DR) for gaps or samples
• Document & record review is primary
• Interviews and observations are usually for
Corroborating
54
Sufficient Audit Evidence
Sufficiency of Evidence
• The measure of the quantity of evidence
• Quantity of evidence is dependent on the scope of
the audit
• Extra quantity does not make up for poor quality
• Ensure you provide enough evidence to demonstrate
compliance for the entire audit period.
55
Sufficient Audit Evidence
Sampling is used to limit the amount of detailed
evidence provided.
• Normally used in conjunction with summary of a full
set of data.
• Sampling used to assess details.
• Reduces the burden on the Audit Team but not really
on the Entity
• Audit Team must select the samples
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Appropriate Audit Evidence
Appropriateness
The measure of the quality of evidence
• Relevance
• Validity
• Reliability
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Appropriate Audit Evidence
Quality of Evidence
• Good Internal Controls point to reliable evidence.
• Direct observation is more reliable than indirect observation.
• Examination of original documents is more reliable than
examination of copies.
• Testimonial evidence from system experts is more reliable
than from personnel with indirect or partial knowledge.
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Types of Evidence
• Physical Evidence
• Documentary Evidence
• Testimonial Evidence
Compliance Audits may use all three types but Documentary
Evidence is by far the most frequent type of evidence
assessed and relied on.
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Testimonial Evidence
• Attestations of Compliance or Statements of
Compliance are generally not accepted as the only
available evidence.
• Attestations may be used to explain minor gaps in
documentation or to state if no conditions occurred
which are subject to a requirement.
• Attestor must be knowledgable and qualified.
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Evidence for Procedural Documents
The characteristics of a valid procedural or
policy document include:
– Document title
– Definition or Purpose
– Revision level
– Effective dates
– Authorizing signatures
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Non Applicable Requirements
Three instances are acceptable for use of term
“Not Applicable”
1) Entity is not registered for the applicable
function. (only TOP responsible for TOP requirements)
2) Entity does not own, operate or maintain the
equipment addressed by the requirement. (UVLS,
UFLS, SPS etc.)
3) Entity does not use the program or process
specified by the requirement. (and is not required to…
ATC, CBM, etc)
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Evidence for Tasks Performed
• When the standard calls for a task to be performed it
must be documented.
–
–
–
–
–
–
–
Records
Logs
Reports
Work Orders
Phone recordings
Transcripts of phone recordings
Shift Schedules
• Dates & Times are critical
63
Evidence of “Coordination” with other entities
• Typical evidence provided initially is a single email.
“…If you have any comments please contact ______”
This alone is neither sufficient or appropriate to demonstrate
coordination between two or more parties.
• If emails or correspondence are used
– Two way communications are needed
• Better are:
– Meeting Agendas
– Meeting Minutes
– Attendance Lists
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Evidence of “Distribution” of information
• Typical evidence provided initially is a single email with a large
distribution list.
“…please see attached”
This alone is typically neither sufficient or appropriate to
demonstrate distribution to others.
• If emails or correspondence are used
– Need clear identification of the personnel on the distribution list.
• Even Better is corroboration by receipt acknowledgement
Enforcement 101
October 9, 2014
Rachael Ferrin
Richard Shiflett
Haley Sousa
Joelle Bohlender
66
Agenda
• What is a violation?
• How does WECC know about a violation?
• What is the submittal and review process for
possible violations?
• What is the submittal and review process for
Mitigation Plans?
67
What is a violation?
A violation is a failure to demonstrate compliance
pursuant to applicable NERC Reliability Standard
Requirement
– Possible Violation (PV)
• The identification by the Compliance Enforcement Authority of a
possible failure by a registered Entity to comply with a Reliability
Standard that is applicable to the Registered Entity. NERC Rules of
Procedure, Appendix 2 (January 31, 2012).
68
How does the Entity discover a possible
violation?
Internal
Audits
Internal
Assessments
Compliance
Culture
Ongoing
Compliance
Assessments
69
How does WECC know about a possible
violation?
Compliance Monitoring
• Self-Reports
• Self-Certifications
– New possible violation
– Change in scope
• Compliance Audits
• Spot Checks
• Compliance Investigations
• Periodic Data Submittals
• Complaints
70
Possible Violation Submittal
• Submit Self-Reports and Self-Certifications via
webCDMS
• Self Report/Self Certification Content Checklist
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Self-Report/Self-Certification
Content Checklist
• Is the version of the standard (in effect at the time of the violation)
identified?
• Are all multiple subrequirements in scope identified?
• Has this violation been previously reported?
• Does the violation description include:
– All devices/facilities/personnel in scope?
– Names/IDs of devices/facilities/personnel?
– Where are these devices located?
– What are these devices used for?
– What type of access do the personnel have?
– Any additional information to assess the VSL?
• Is the start date and end date identified?
• Are the compensating measures identified?
72
Possible Violation Review
• WECC Subject Matter Experts (SME) reviews the
“possible violation”
• Analyze facts and circumstances
• Data Requests/conference call if necessary
• Technical assessment
– Facts and Timelines
– Risk Assessment
• Recommendation of Dismissal or Acceptance to
Case Managers
73
Entity’s next step after reporting a Possible
Violation
• Submit Mitigation Plan
– Notice of Alleged Violation triggers
Mitigation Plan due date
– Timely Mitigation is encouraged
– Not admission of violation
Every violation goes through the same process.
74
Mitigation Plan Submittal
• Submit via webCDMS
– One violation per plan
• Eight Steps to Prevention and Mitigation
• Mitigation Plan Content Checklist
75
Mitigation and Prevention Checklist
•
•
•
•
•
•
•
•
Symptom
Root Cause
Corrective Actions
Preventive Actions
Detective Actions
Assign tasks
Timeline and milestones
Interim Risk
76
Mitigation Plan Content Checklist
• Has the scope of the violation being mitigated changed?
• Has the root cause been identified?
• Does the mitigation plan include:
– What is being fixed?
– How it is being fixed?
– When it is being fixed?
• Do the mitigation actions:
– Relate to the requirements in scope?
– Identify preventative measures?
– Identify detection measures?
77
Mitigation Plan Review
• WECC Subject Matter Experts (SME) conduct
reviews
• Review the mitigation plan
– Actions (Corrective, Detective and Preventive)
– Duration
• Data Requests/conference call if necessary
• Notice of Acceptance or Rejection via auto
notification or EFT server
78
Mitigation Plan Extensions
• Extension Requests
– Accepted Mitigation Plan completion date =
date Completion Certification and evidence
submitted to WECC
– Five business days prior to completion date
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CMP Submittal
• Submit Completion Certification and evidence
via webCDMS
• CMP Content Checklist
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CMP Content Checklist
• Has the scope changed since the Mitigation Plan was
accepted?
– Have you included a brief statement to confirm the
scope?
• Is the evidence uploaded with a description for each file?
• Is there a mapping of actions to evidence?
• Is there a completion date for each action?
81
Mitigation Plan Completion Review
• WECC Subject Matter Experts (SME) conduct
reviews
• Analyze Evidence
– Were all actions outlined in the plan completed?
– Has both procedural and implementation evidence been
submitted?
• Data Requests/conference call if necessary
• Notice of Acceptance or Rejection via auto
notification or EFT Server
82
Summary
• Violation life cycle
– Submitting violations and mitigation plans
– WECC’s review of violations and mitigation plans
• Resources
– http://www.wecc.biz/compliance/outreach/Lists/
101Links/AllItems.aspx
83
The Hand-Off
Possible
Violation
Submittal
Technical
SME
Review
The Handoff to Case
Manager
Case
Manager
Review
4 Methods
of PV
Disposition
Confirmed
Violation
84
WECC Enforcement Case Managers
Primary Role: Determining Violation Disposition
(disposition analysis)
• Case analysis
•
•
•
•
•
Violation Disposition
Policy analysis
Assess penalties
Conduct settlements
Build relationships
85
Enforcement Processes
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Disposition Analysis
•
•
•
•
Dismissal
Find, Fix and Track (“FFT”)
Notice of Alleged Violation (“NOAV”)
Expedited Settlement Agreement (“ESA”)
87
Dismissal
• Disposition method used when the Case
Manager determines the possible violation is
not enforceable
– For Example…
– Standard Requirement does not apply to Entity
– Facts and circumstances warrant a violation of a
different Standard Requirement
– Entity produced additional evidence
demonstrating compliance
88
What does a dismissal look like?
• Case Manager will issue a “Notice of Dismissal and
Completion of Enforcement Action”
• WECC:
– Withdraws the Possible Violation from Entity’s compliance
record
– Any data retention directives relating to the possible
violation are released
• Entity:
– Does not need to respond to notice
– Questions/concerns contact Case Manager
89
Not a Dismissal, Now what?
•
•
•
•
Dismissal
Find, Fix and Track (“FFT”)
Notice of Alleged Violation (“NOAV”)
Expedited Settlement Agreement (“ESA”)
90
PVs for FFT Review
WECC Reviews All PVs for FFT Treatment
“Strong” FFT Candidates:
• Are not Repeat PVs
• PV does not reveal programmatic or systematic
shortcomings
• Found and Fixed by the Entity
• Mitigation Plan has been submitted
91
What does an FFT look like?
• WECC Enforcement will issue a “Notice of
Find, Fix and Track”
– Remediation Required
– No Penalty or sanction
– FFT is filed with NERC but does not become a
“confirmed violation”
• FFT will become part of an Entity’s compliance
history
92
What to do with an FFT?
• Within five (5) days of receiving an FFT Notice
an Entity Must:
• Submit to WECC an affidavit, signed by an officer
with knowledge of remediation,
OR
• Submit to WECC written notification opting out of
the FFT processing
– If an Entity opts out of the FFT disposition, then WECCs
policy is to issue the violation through the traditional
NOAV process.
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4 Disposition Methods
•
•
•
•
Dismissal
Find, Fix and Track (“FFT”)
Notice of Alleged Violation (“NOAV”)
Expedited Settlement Agreement (“ESA”)
94
What does a NOAV look like?
CMEP Section 5.3
•
•
•
•
NERC Rules of Procedure, Appendix 4C §5.3 (“CMEP”)
Alleged Violation Facts
Mitigation Plan Summary (if applicable)
Enforcement Violation Determinations
– BES Impact Statement
• Minimal
• Moderate
• Severe
– Violation Severity Level (“VSL”)
– Violation Risk Factor (“VRF”)
• Penalty
95
What to do with a NOAV?
• Submit a NOAV Response within 30 days
• The NOAV Response must conform to one of
three options
– Agree with the violation AND penalty
– Agree with the violation, but contest penalty
– Contest both the violation AND penalty
• Failure to submit a NOAV Response within 30
days will automatically result in confirmed
violations with penalties
96
NOAV Response: “Option 1”
Does not contest
• Does not contest violation facts as alleged in the
NOAV
• May identify errors that should be corrected in
the “Notice of Confirmed Violation” (“NOCV”)
• Submit a Mitigation Plan
Enforcement will issue a Notice of
Confirmed Violation within ten (10)
days of receiving a NOAV Response
that “agrees with or does not contest
an alleged violation.”
97
NOAV Response: “Option 2”
Contests Penalty
• NOAV Response will be submitted to Enforcement
using the EFT Server within thirty (30) calendar days
of receiving the NOAV.
• Submit a Mitigation Plan.
• NOAV Response must explicitly contest penalty and
request settlement.
– NOAV Response must articulate basis for each penalty
– NOAV Response should include a proposed penalty the Entity
believes to be reasonable including the basis for proposed
penalty
98
NOAV Response: “Option 3”
Contests Alleged Violation & Penalties
• NOAV Response must be submitted to Enforcement using
the EFT Server within thirty (30) calendar days of receiving
the NOAV.
• NOAV Response must explicitly contest each alleged
violation and proposed penalty and request settlement.
• Each Contention must be supported by:
– An explanation of the Entity’s position
– Basis for Contention
– Additional Information or evidence
99
A Word on Penalties
• Attached to violations disposed of using the NOAV or
ESA processes
• Based on:
– NERC Sanction Guidelines (January 31, 2012)
– Penalty Range
• Penalty range depends upon Violation Severity Level
(“VSL”) and Violation Risk Factor (“VRF”)
• Penalties are then adjusted for either Mitigating or
Aggravating Factors
100
Reaching Settlement
Work with
Case
Manager
C&T
Agreement
NOAV
NOAV
Response
Schedule
Settlement
Settlement
Agreement
Settlement
Negotiation
101
4 Disposition Methods
•
•
•
•
Dismissal
Find, Fix and Track (“FFT”)
Notice of Alleged Violation (“NOAV”)
Expedited Settlement Agreement (“ESA”)
102
ESA: Expedited Settlement Process
ESA
Settlement
Agreement
103
What does an ESA look like?
• Expedites Formal Settlement Negotiations
• The ESA will contain
– Facts and circumstances of the violation
– Risk Assessment Summary
– Mitigation Plan Summary
– VSL and VRF determinations
– Penalty determination
104
What to do with an ESA?
• Entity will have 15 days to review the ESA…
– The Entity will contact Case Manager with questions or concerns.
• If the Entity accepts the terms of the ESA…
– The Entity must submit a signed copy of the ESA to WECC within 15
days of receipt of the ESA issuance.
• If the Entity rejects the ESA or does not respond
within 15 days…
– WECC will issue a Notice of Alleged Violation and Proposed Penalty
and Sanction.
105
Settlement Agreements &
Expedited Settlement Agreements
106
Payment & Closure of Enforcement Action
• After NOP becomes effective,
WECC issues a “Payment Due
Notice”
• The Penalty will be due thirty
(30) days from the date the
Notice is issued
• Public NOP filings can be found
on the NERC website
107
Enforcement Process Summary
Possible
Violation
Submittal
Technical
SME Review
The Handoff to Case
Manager
Case
Manager
Review
4 Methods
of PV
Disposition
• Lifecycle of a Possible Violation
• Best Compliance Practices
• http://www.wecc.biz/compliance/Pages/Best-Practices.aspx
• Possible Violation Disposition and Entity
Responses
Confirmed
Violation
Compliance 101
Brittany Power
Data Coordinator
109
webCDMS
110
webCDMS Regions
1.MRO
2.SPP
3.WECC
4.Texas RE
5.RFC
111
EFT Server
WECC EFT Server
112
Compliance Standards Index
Compliance Standards
Index
113
Compliance Standards Index
114
Compliance Standards Index
115
Compliance Standards Index
116
Reminder: Help Desk
WECC Support
OATI Support
• Call @ 801-883-6879
• Types of calls for WECC
o EFT Questions
o Registration Questions
o Historical Questions
o Standard Questions
o Non-technical Questions
• support@wecc.biz
• Call @ 673-220-2020
• Types of calls for OATI
o Technical Problems
o webCDMS Login Problems
o Certificate Problems
o Access Problems