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					                                                                                                                                                                              10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                         PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                       CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                       HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.


      A            B             C            D            E             F                               G                            H         I             J                            K                           L             M            N                         O                           P            Q            R               S               T             U             V
                                                                                                                                                                                                                                                                                                                             Registered       Regional
                                                                                                                                                      Violation Risk                                                                            Total                                                                          Entity          Entity
                                                                                                                                                                                                                                                                                                    Mitigation   Mitigation                                                  Separate      Signed
              Registered                NERC Violation            Date Identified                                                Reliability              Factor*                                               Violation Start   Violation   Penalty or Additional Factors for the Basis of                                Certification   Verification    Discovery
    Region                    NOC-ID                     NCR_ID                            Description of the Violation                        Req.                                Risk Assessment                                                                                                    Plan          Plan                                                    Settlement   Disposition
                Entity                      ID #                   or Received                                                   Standard                                                                            Date         End Date    Sanction                Penalty                                               of Mitigation   of Mitigation    Method
                                                                                                                                                                                                                                                                                                     Number      Completed                                                  Agreement       Letter
                                                                                                                                                      *See Attachment C                                                                          ($)                                                                            Plan            Plan
1                                                                                                                                                                                                                                                                                                                            Completion      Completion
    FRCC     City of Bartow   NOC-068   FRCC200800052 NCR00003      1/14/2008       The City of Bartow did not have              CIP-001-1      1        Medium           FRCC determined that the                6/18/2007       4/7/2008        $0     The violation was the first violation       MIT-08-      4/7/2008    6/3/2008        6/5/2008         Self-                         Yes
                                                                                    procedures for the recognition of, and for                                            violation did not constitute a                                                 of this reliability standard incurred        0282                                                  Certification
                                                                                    making its operating personnel aware of,                                              serious or substantial risk to the                                             by City of Bartow and it did not
                                                                                    sabotage events on its facilities.                                                    bulk power system because the                                                  constitute a serious or substantial
                                                                                                                                                                          City of Bartow's employees were                                                risk to the bulk power system.
                                                                                                                                                                          trained to be alert to, and respond                                            FRCC notes that City of Bartow
                                                                                                                                                                          to, abnormal conditions or                                                     did not meet its self-certification
                                                                                                                                                                          situations at its facilities in                                                deadline. However, once
                                                                                                                                                                          accordance with its Emergency                                                  contacted by FRCC, City of Bartow
                                                                                                                                                                          Response Plan.                                                                 provided the self-certification.
                                                                                                                                                                                                                                                         FRCC considered these factors
                                                                                                                                                                                                                                                         and determined that,
                                                                                                                                                                                                                                                         notwithstanding the late submittal
                                                                                                                                                                                                                                                         of its self-certification, a zero dollar
                                                                                                                                                                                                                                                         penalty was appropriate for this
                                                                                                                                                                                                                                                         violation.
2
    FRCC     City of Bartow   NOC-068   FRCC200800053 NCR00003      1/14/2008       The City of Bartow did not have              CIP-001-1      2        Medium           FRCC determined that the                6/18/2007       4/7/2008        $0     The violation was the first violation       MIT-08-      4/7/2008     6/3/2008       6/5/2008         Self-                         Yes
                                                                                    procedures for the communication of                                                   violation did not constitute a                                                 of this reliability standard incurred        0282                                                  Certification
                                                                                    information concerning sabotage events                                                serious or substantial risk to the                                             by City of Bartow and it did not
                                                                                    to appropriate parties in the                                                         bulk power system because the                                                  constitute a serious or substantial
                                                                                    Interconnection.                                                                      City of Bartow's employees were                                                risk to the bulk power system.
                                                                                                                                                                          trained to be alert to, and respond                                            FRCC notes that City of Bartow
                                                                                                                                                                          to, abnormal conditions or                                                     did not meet its self-certification
                                                                                                                                                                          situations at its facilities in                                                deadline. However, once
                                                                                                                                                                          accordance with its Emergency                                                  contacted by FRCC, City of Bartow
                                                                                                                                                                          Response Plan.                                                                 provided the self-certification.
                                                                                                                                                                                                                                                         FRCC considered these factors
                                                                                                                                                                                                                                                         and determined that,
                                                                                                                                                                                                                                                         notwithstanding the late submittal
                                                                                                                                                                                                                                                         of its self-certification, a zero dollar
                                                                                                                                                                                                                                                         penalty was appropriate for this
                                                                                                                                                                                                                                                         violation.
3
    FRCC     City of Bartow   NOC-068   FRCC200800054 NCR00003      1/14/2008       The City of Bartow did not provide its       CIP-001-1      3        Medium           FRCC determined that the                6/18/2007       4/7/2008        $0     The violation was the first violation       MIT-08-      4/7/2008     6/3/2008       6/5/2008         Self-                         Yes
                                                                                    operating personnel with sabotage                                                     violation did not constitute a                                                 of this reliability standard incurred        0282                                                  Certification
                                                                                    response guidelines, including personnel                                              serious or substantial risk to the                                             by City of Bartow and it did not
                                                                                    to contact, for reporting disturbances due                                            bulk power system because the                                                  constitute a serious or substantial
                                                                                    to sabotage events.                                                                   City of Bartow's employees were                                                risk to the bulk power system.
                                                                                                                                                                          trained to be alert to, and respond                                            FRCC notes that City of Bartow
                                                                                                                                                                          to, abnormal conditions or                                                     did not meet its self-certification
                                                                                                                                                                          situations at its facilities in                                                deadline. However, once
                                                                                                                                                                          accordance with its Emergency                                                  contacted by FRCC, City of Bartow
                                                                                                                                                                          Response Plan.                                                                 provided the self-certification.
                                                                                                                                                                                                                                                         FRCC considered these factors
                                                                                                                                                                                                                                                         and determined that,
                                                                                                                                                                                                                                                         notwithstanding the late submittal
                                                                                                                                                                                                                                                         of its self-certification, a zero dollar
                                                                                                                                                                                                                                                         penalty was appropriate for this
4                                                                                                                                                                                                                                                        violation.
    FRCC     City of Bartow   NOC-068   FRCC200800055 NCR00003      1/14/2008       The City of Bartow did not establish         CIP-001-1      4        Medium           FRCC determined that the                6/18/2007       4/7/2008        $0     The violation was the first violation       MIT-08-      4/7/2008     6/3/2008       6/5/2008         Self-                         Yes
                                                                                    communications contacts, as applicable,                                               violation did not constitute a                                                 of this reliability standard incurred        0282                                                  Certification
                                                                                    with local Federal Bureau of Investigation                                            serious or substantial risk to the                                             by City of Bartow and it did not
                                                                                    (FBI) officials and did not develop                                                   bulk power system because the                                                  constitute a serious or substantial
                                                                                    reporting procedures as appropriate to its                                            City of Bartow's employees were                                                risk to the bulk power system.
                                                                                    circumstances.                                                                        trained to be alert to, and respond                                            FRCC notes that City of Bartow
                                                                                                                                                                          to, abnormal conditions or                                                     did not meet its self-certification
                                                                                                                                                                          situations at its facilities in                                                deadline. However, once
                                                                                                                                                                          accordance with its Emergency                                                  contacted by FRCC, City of Bartow
                                                                                                                                                                          Response Plan.                                                                 provided the self-certification.
                                                                                                                                                                                                                                                         FRCC considered these factors
                                                                                                                                                                                                                                                         and determined that,
                                                                                                                                                                                                                                                         notwithstanding the late submittal
                                                                                                                                                                                                                                                         of its self-certification, a zero dollar
                                                                                                                                                                                                                                                         penalty was appropriate for this
5                                                                                                                                                                                                                                                        violation.




                                                                                                                                                                                               FRCC                                                                                                                                                                                         Page 1 of 80
                                                                                                                                                                            10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                       PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                     CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                     HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.


       A          B           C            D            E             F                               G                             H         I             J                            K                           L              M            N                        O                         P            Q            R               S             T           U             V
                                                                                                                                                                                                                                                                                                                         Registered       Regional
                                                                                                                                                    Violation Risk                                                                             Total                                                                       Entity          Entity
                                                                                                                                                                                                                                                                                                Mitigation   Mitigation                                              Separate      Signed
              Registered             NERC Violation            Date Identified                                                 Reliability              Factor*                                               Violation Start   Violation    Penalty or Additional Factors for the Basis of                             Certification   Verification    Discovery
     Region                NOC-ID                     NCR_ID                             Description of the Violation                        Req.                                Risk Assessment                                                                                                  Plan         Plan                                                 Settlement   Disposition
                Entity                   ID #                   or Received                                                    Standard                                                                            Date         End Date     Sanction                Penalty                                            of Mitigation   of Mitigation    Method
                                                                                                                                                                                                                                                                                                 Number      Completed                                              Agreement       Letter
                                                                                                                                                    *See Attachment C                                                                           ($)                                                                         Plan            Plan
1                                                                                                                                                                                                                                                                                                                        Completion      Completion
     FRCC      City of     NOC-078   FRCC200800071 NCR00037       4/1/2008       The City of Homestead did not maintain        BAL-005-0      2          High           FRCC determined that the                6/18/2007       7/29/2008     $15,000   The violation was the first violation    MIT-08-     7/29/2008   7/29/2008        9/9/2008        Audit                      Yes
              Homestead                                                          Regulating Reserve that could be                                                       violation did not constitute a                                                  of this reliability standard incurred     0622
                                                                                 controlled by AGC to meet the Control                                                  serious or substantial risk to the                                              by the City of Homestead and it
                                                                                 Performance Standard.                                                                  bulk power system because the                                                   did not constitute a serious or
                                                                                                                                                                        City of Homestead's residential                                                 substantial risk to the bulk power
                                                                                                                                                                        and commercial load was very                                                    system.
                                                                                                                                                                        static so it was able to accurately
                                                                                                                                                                        predict any changes in its load                                                 However, the City of Homestead
                                                                                                                                                                        profile. Moreover, the City of                                                  chose to make hourly power
                                                                                                                                                                        Homestead did not have any non-                                                 purchases from external entities to
                                                                                                                                                                        conforming load.                                                                balance its load and generation
                                                                                                                                                                                                                                                        instead of running any of its own
                                                                                                                                                                                                                                                        generation or arranging for
                                                                                                                                                                                                                                                        regulating reserve from another
                                                                                                                                                                                                                                                        entity therefore avoiding a higher
                                                                                                                                                                                                                                                        cost. In this case, FRCC
                                                                                                                                                                                                                                                        determined that the assessed
6                                                                                                                                                                                                                                                       monetary penalty was appropriate.
     FRCC      City of     NOC-078   FRCC200800072 NCR00037       4/1/2008       The City of Homestead did not operate         BAL-005-0      7        Medium           FRCC determined that the                6/18/2007       7/29/2008     $5,000    The violation was the first violation    MIT-08-     7/29/2008    7/29/2008       9/9/2008        Audit                      Yes
              Homestead                                                          AGC continuously to adjust generation.                                                 violation did not constitute a                                                  of this reliability standard incurred     0623
                                                                                                                                                                        serious or substantial risk to the                                              by the City of Homestead and it
                                                                                                                                                                        bulk power system because the                                                   did not constitute a serious or
                                                                                                                                                                        City of Homestead was able to                                                   substantial risk to the bulk power
                                                                                                                                                                        match the load profile through its                                              system. In this case, FRCC
                                                                                                                                                                        energy purchases and maintain                                                   determined that the assessed
                                                                                                                                                                        the thresholds of the CPS1 and                                                  monetary penalty was appropriate.
7                                                                                                                                                                       CPS2.
     FRCC      City of     NOC-078   FRCC200800073 NCR00037       4/1/2008       The City of Homestead did not provide         BAL-005-0      8        Medium           FRCC determined that the                6/18/2007       3/10/2008     $5,000    The violation was the first violation    MIT-08-     3/10/2008    6/19/2008      6/23/2008        Audit                      Yes
              Homestead                                                          redundant and independent frequency                                                    violation did not constitute a                                                  of this reliability standard incurred     0607
                                                                                 metering equipment that automatically                                                  serious or substantial risk to the                                              by the City of Homestead and it
                                                                                 activates upon detection of failure of the                                             bulk power system because the                                                   did not constitute a serious or
                                                                                 primary source.                                                                        City of Homestead had a                                                         substantial risk to the bulk power
                                                                                                                                                                        redundant frequency source. The                                                 system. In this case, FRCC
                                                                                                                                                                        source required manual operation                                                determined that the assessed
                                                                                                                                                                        to activate.                                                                    monetary penalty was appropriate.
8
     FRCC      City of     NOC-078   FRCC200800074 NCR00037       4/1/2008       The City of Homestead did not include         BAL-005-0     11        Medium           FRCC determined that the                6/18/2007        9/4/2008     $5,000    The violation was the first violation    MIT-08-      9/4/2008     9/8/2008       9/9/2008        Audit                      Yes
              Homestead                                                          the effect of ramp rates in its interchange                                            violation did not constitute a                                                  of this reliability standard incurred     0624
                                                                                 schedules.                                                                             serious or substantial risk to the                                              by the City of Homestead and it
                                                                                                                                                                        bulk power system because the                                                   did not constitute a serious or
                                                                                                                                                                        City of Homestead's load profile is                                             substantial risk to the bulk power
                                                                                                                                                                        steady and predictable, so it was                                               system. In this case, FRCC
                                                                                                                                                                        able to stay within its CPS1 and                                                determined that the assessed
                                                                                                                                                                        CPS2 without ramping.                                                           monetary penalty was appropriate.
9
     FRCC      City of     NOC-078   FRCC200800075 NCR00037       4/1/2008       The City of Homestead did not provide its EOP-001-0          6        Medium           FRCC determined that the                6/18/2007       3/24/2008     $1,000    The violation was the first violation    MIT-08-     3/24/2008    6/19/2008      7/23/2008        Audit                      Yes
              Homestead                                                          updated load shedding plan, including its                                              violation did not constitute a                                                  of this reliability standard incurred     0608
                                                                                 plans for operating emergencies on the                                                 serious or substantial risk to the                                              by the City of Homestead and it
                                                                                 transmission system, to its Reliability                                                bulk power system because it had                                                did not constitute a serious or
                                                                                 Coordinator and neighboring                                                            a load shedding plan and could                                                  substantial risk to the bulk power
                                                                                 Transmission Operators and Balancing                                                   have provided it upon request.                                                  system. In this case, FRCC
                                                                                 Authorities.                                                                                                                                                           determined that the assessed
                                                                                                                                                                                                                                                        monetary penalty was appropriate.
10
     FRCC      City of     NOC-078   FRCC200800076 NCR00037       4/1/2008       The City of Homestead did not document        FAC-008-1      1         Lower           FRCC determined that the                6/18/2007       10/31/2008    $1,000    The violation was the first violation    MIT-08-     10/31/2008   10/31/2008     2/16/2009        Audit                      Yes
              Homestead                                                          its current methodology used for                                                       violation did not constitute a                                                  of this reliability standard incurred     1669
                                                                                 developing Facility Ratings for terminal                                               serious or substantial risk to the                                              by the City of Homestead and it
                                                                                 equipment and relays and                                                               bulk power system because the                                                   did not constitute a serious or
                                                                                 normal/emergency ratings on other                                                      City of Homestead had                                                           substantial risk to the bulk power
                                                                                 facilities.                                                                            established ratings for relays and                                              system. In this case, FRCC
                                                                                                                                                                        terminal equipment and also had                                                 determined that the assessed
                                                                                                                                                                        normal and emergency ratings for                                                monetary penalty was appropriate.
11                                                                                                                                                                      all other equipment.
     FRCC      City of     NOC-078   FRCC200800077 NCR00037       4/1/2008       The City of Homestead did not provide         FAC-009-1      1        Medium           FRCC determined that the                6/18/2007       10/31/2008    $7,000    The violation was the first violation    MIT-08-     10/31/2008   10/31/2008     2/16/2009        Audit                      Yes
              Homestead                                                          evidence that its facility ratings for some                                            violation did not constitute a                                                  of this reliability standard incurred     1670
                                                                                 of its relays were established using its                                               serious or substantial risk to the                                              by the City of Homestead and it
                                                                                 Facility Ratings Methodology.                                                          bulk power system because the                                                   did not constitute a serious or
                                                                                                                                                                        ratings for the relays added as a                                               substantial risk to the bulk power
                                                                                                                                                                        part of the City of Homestead's                                                 system. In this case, FRCC
                                                                                                                                                                        limited system modification in                                                  determined that the assessed
                                                                                                                                                                        2007 were determined by the                                                     monetary penalty was appropriate.
                                                                                                                                                                        vendor rather than by the City of
                                                                                                                                                                        Homestead's own Facility Ratings
12                                                                                                                                                                      Methodology.




                                                                                                                                                                                             FRCC                                                                                                                                                                                   Page 2 of 80
                                                                                                                                                                         10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                    PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                  CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                  HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.


       A          B           C            D            E             F                              G                           H         I             J                             K                         L             M            N                        O                         P            Q            R               S               T             U             V
                                                                                                                                                                                                                                                                                                                    Registered       Regional
                                                                                                                                                 Violation Risk                                                                           Total                                                                       Entity          Entity
                                                                                                                                                                                                                                                                                           Mitigation   Mitigation                                                  Separate      Signed
              Registered             NERC Violation            Date Identified                                              Reliability              Factor*                                              Violation Start   Violation   Penalty or Additional Factors for the Basis of                             Certification   Verification    Discovery
     Region                NOC-ID                     NCR_ID                            Description of the Violation                      Req.                                Risk Assessment                                                                                                Plan         Plan                                                     Settlement   Disposition
                Entity                   ID #                   or Received                                                 Standard                                                                           Date         End Date    Sanction                Penalty                                            of Mitigation   of Mitigation    Method
                                                                                                                                                                                                                                                                                            Number      Completed                                                  Agreement       Letter
                                                                                                                                                 *See Attachment C                                                                         ($)                                                                         Plan            Plan
1                                                                                                                                                                                                                                                                                                                   Completion      Completion
     FRCC      City of     NOC-078   FRCC200800078 NCR00037       4/1/2008       The City of Homestead's Protection        PRC-005-1       1          High           FRCC determined that the               6/18/2007       3/19/2008    $4,000    The violation was the first violation    MIT-08-     3/19/2008   6/19/2008        7/234/08         Audit                         Yes
              Homestead                                                          System Maintenance and Testing                                                      violation did not constitute a                                                of this reliability standard incurred     0609
                                                                                 Program did not include intervals, their                                            serious or substantial risk to the                                            by the City of Homestead and it
                                                                                 bases and procedure for associated                                                  bulk power system because the                                                 did not constitute a serious or
                                                                                 communication systems. It did not                                                   Protection System equipment,                                                  substantial risk to the bulk power
                                                                                 include intervals, their bases and                                                  such as relays and station                                                    system. In this case, FRCC
                                                                                 procedure for voltage and current sensing                                           batteries, was being maintained                                               determined that the assessed
                                                                                 devices. It did not include intervals and                                           and tested.                                                                   monetary penalty was appropriate.
                                                                                 their bases for DC control circuitry.
13
     FRCC      City of     NOC-078   FRCC200800079 NCR00037       4/1/2008       The City of Homestead did not plan to      TOP-002-2      9         Lower           FRCC determined that the               6/18/2007       9/4/2008     $4,000    The violation was the first violation    MIT-08-      9/4/2008     9/8/2008       9/9/2008         Audit                         Yes
              Homestead                                                          meet Interchange Schedules and ramps.                                               violation did not constitute a                                                of this reliability standard incurred     0625
                                                                                                                                                                     serious or substantial risk to the                                            by the City of Homestead and it
                                                                                                                                                                     bulk power system because the                                                 did not constitute a serious or
                                                                                                                                                                     City of Homestead was able to                                                 substantial risk to the bulk power
                                                                                                                                                                     match the load profile through its                                            system. In this case, FRCC
                                                                                                                                                                     energy purchases and maintain                                                 determined that the assessed
                                                                                                                                                                     the thresholds of the CPS1 and                                                monetary penalty was appropriate.
14                                                                                                                                                                   CPS2.
     FRCC      Florida     NOC-140   FRCC200700009 NCR00022      12/17/2007      FMPA did not perform the assessments       TPL-001-0      1          High           FRCC determined that this              6/18/2007       9/30/2008       $0     The violation was the first violation    MIT-07-     9/30/2008    9/30/2008     10/14/2008         Self-                         Yes
              Municipal                                                          and studies as required by the standard.                                            violation did not constitute a                                                of this reliability standard incurred     0272                                                  Certification
               Power                                                                                                                                                 serious or substantial risk to the                                            by FMPA and it did not constitute a
               Agency                                                                                                                                                bulk power system because even                                                serious or substantial risk to the
                                                                                                                                                                     though FMPA did not provide the                                               bulk power system.
                                                                                                                                                                     assessments and studies, system
                                                                                                                                                                     planning was still being performed
                                                                                                                                                                     by its Planning Authority and the
                                                                                                                                                                     transmission planning working
15                                                                                                                                                                   group.
     FRCC      Florida     NOC-140   FRCC200700010 NCR00022      12/17/2007      FMPA was not compliant with this           TPL-001-0      2        Medium           FRCC determined that this              6/18/2007       9/30/2008       $0     The violation was the first violation    MIT-07-     9/30/2008    9/30/2008     10/14/2008         Self-                         Yes
              Municipal                                                          reliability standard because it had not                                             violation did not constitute a                                                of this reliability standard incurred     0272                                                  Certification
               Power                                                             conducted the assessments and studies                                               serious or substantial risk to the                                            by FMPA and it did not constitute a
               Agency                                                            required in R1.                                                                     bulk power system because even                                                serious or substantial risk to the
                                                                                                                                                                     though FMPA did not provide the                                               bulk power system.
                                                                                                                                                                     assessments and studies, system
                                                                                                                                                                     planning was still being performed
                                                                                                                                                                     by its Planning Authority and the
                                                                                                                                                                     transmission planning working
16                                                                                                                                                                   group.
     FRCC      Florida     NOC-140   FRCC200700011 NCR00022      12/17/2007      FMPA was not compliant with this           TPL-001-0      3         Lower           FRCC determined that this              6/18/2007       9/30/2008       $0     The violation was the first violation    MIT-07-     9/30/2008    9/30/2008     10/14/2008         Self-                         Yes
              Municipal                                                          reliability standard because it had not                                             violation did not constitute a                                                of this reliability standard incurred     0272                                                  Certification
               Power                                                             conducted the assessments and studies                                               serious or substantial risk to the                                            by FMPA and it did not constitute a
               Agency                                                            required in R1.                                                                     bulk power system because even                                                serious or substantial risk to the
                                                                                                                                                                     though FMPA did not provide the                                               bulk power system.
                                                                                                                                                                     assessments and studies, system
                                                                                                                                                                     planning was still being performed
                                                                                                                                                                     by its Planning Authority and the
                                                                                                                                                                     transmission planning working
17                                                                                                                                                                   group.
     FRCC      Florida     NOC-140   FRCC200700012 NCR00022      12/17/2007      FMPA did not perform the assessments       TPL-002-0      1          High           FRCC determined that this              6/18/2007       9/30/2008       $0     The violation was the first violation    MIT-07-     9/30/2008    9/30/2008     10/14/2008         Self-                         Yes
              Municipal                                                          and studies as required by the standard.                                            violation did not constitute a                                                of this reliability standard incurred     0273                                                  Certification
               Power                                                                                                                                                 serious or substantial risk to the                                            by FMPA and it did not constitute a
               Agency                                                                                                                                                bulk power system because even                                                serious or substantial risk to the
                                                                                                                                                                     though FMPA did not provide the                                               bulk power system.
                                                                                                                                                                     assessments and studies, system
                                                                                                                                                                     planning was still being performed
                                                                                                                                                                     by its Planning Authority and the
                                                                                                                                                                     transmission planning working
18                                                                                                                                                                   group.
     FRCC      Florida     NOC-140   FRCC200700013 NCR00022      12/17/2007      FMPA was not compliant with this           TPL-002-0      2        Medium           FRCC determined that this              6/18/2007       9/30/2008       $0     The violation was the first violation    MIT-07-     9/30/2008    9/30/2008     10/14/2008         Self-                         Yes
              Municipal                                                          reliability standard because it had not                                             violation did not constitute a                                                of this reliability standard incurred     0273                                                  Certification
               Power                                                             conducted the assessments and studies                                               serious or substantial risk to the                                            by FMPA and it did not constitute a
               Agency                                                            required in R1.                                                                     bulk power system because even                                                serious or substantial risk to the
                                                                                                                                                                     though FMPA did not provide the                                               bulk power system.
                                                                                                                                                                     assessments and studies, system
                                                                                                                                                                     planning was still being performed
                                                                                                                                                                     by its Planning Authority and the
                                                                                                                                                                     transmission planning working
19                                                                                                                                                                   group.




                                                                                                                                                                                           FRCC                                                                                                                                                                                    Page 3 of 80
                                                                                                                                                                         10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                    PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                  CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                  HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.


       A          B           C            D            E             F                              G                           H         I             J                            K                          L             M            N                        O                         P            Q            R               S               T             U             V
                                                                                                                                                                                                                                                                                                                    Registered       Regional
                                                                                                                                                 Violation Risk                                                                           Total                                                                       Entity          Entity
                                                                                                                                                                                                                                                                                           Mitigation   Mitigation                                                  Separate      Signed
              Registered             NERC Violation            Date Identified                                              Reliability              Factor*                                              Violation Start   Violation   Penalty or Additional Factors for the Basis of                             Certification   Verification    Discovery
     Region                NOC-ID                     NCR_ID                            Description of the Violation                      Req.                               Risk Assessment                                                                                                 Plan         Plan                                                     Settlement   Disposition
                Entity                   ID #                   or Received                                                 Standard                                                                           Date         End Date    Sanction                Penalty                                            of Mitigation   of Mitigation    Method
                                                                                                                                                                                                                                                                                            Number      Completed                                                  Agreement       Letter
                                                                                                                                                 *See Attachment C                                                                         ($)                                                                         Plan            Plan
1                                                                                                                                                                                                                                                                                                                   Completion      Completion
     FRCC      Florida     NOC-140   FRCC200700014 NCR00022      12/17/2007      FMPA was not compliant with this           TPL-002-0      3         Lower           FRCC determined that this              6/18/2007       9/30/2008       $0     The violation was the first violation    MIT-07-     9/30/2008   9/30/2008       10/14/2008        Self-                         Yes
              Municipal                                                          reliability standard because it had not                                             violation did not constitute a                                                of this reliability standard incurred     0273                                                  Certification
               Power                                                             conducted the assessments and studies                                               serious or substantial risk to the                                            by FMPA and it did not constitute a
               Agency                                                            required in R1.                                                                     bulk power system because even                                                serious or substantial risk to the
                                                                                                                                                                     though FMPA did not provide the                                               bulk power system.
                                                                                                                                                                     assessments and studies, system
                                                                                                                                                                     planning was still being performed
                                                                                                                                                                     by its Planning Authority and the
                                                                                                                                                                     transmission planning working
20                                                                                                                                                                   group.
     FRCC      Florida     NOC-140   FRCC200700015 NCR00022      12/17/2007      FMPA did not perform the assessments       TPL-003-0      1          High           FRCC determined that this              6/18/2007       9/30/2008       $0     The violation was the first violation    MIT-07-     9/30/2008    9/30/2008     10/14/2008         Self-                         Yes
              Municipal                                                          and studies as required by the standard.                                            violation did not constitute a                                                of this reliability standard incurred     0274                                                  Certification
               Power                                                                                                                                                 serious or substantial risk to the                                            by FMPA and it did not constitute a
               Agency                                                                                                                                                bulk power system because even                                                serious or substantial risk to the
                                                                                                                                                                     though FMPA did not provide the                                               bulk power system.
                                                                                                                                                                     assessments and studies, system
                                                                                                                                                                     planning was still being performed
                                                                                                                                                                     by its Planning Authority and the
                                                                                                                                                                     transmission planning working
21                                                                                                                                                                   group.
     FRCC      Florida     NOC-140   FRCC200700016 NCR00022      12/17/2007      FMPA was not compliant with this           TPL-003-0      2        Medium           FRCC determined that this              6/18/2007       9/30/2008       $0     The violation was the first violation    MIT-07-     9/30/2008    9/30/2008     10/14/2008         Self-                         Yes
              Municipal                                                          reliability standard because it had not                                             violation did not constitute a                                                of this reliability standard incurred     0274                                                  Certification
               Power                                                             conducted the assessments and studies                                               serious or substantial risk to the                                            by FMPA and it did not constitute a
               Agency                                                            required in R1.                                                                     bulk power system because even                                                serious or substantial risk to the
                                                                                                                                                                     though FMPA did not provide the                                               bulk power system.
                                                                                                                                                                     assessments and studies, system
                                                                                                                                                                     planning was still being performed
                                                                                                                                                                     by its Planning Authority and the
                                                                                                                                                                     transmission planning working
22                                                                                                                                                                   group.
     FRCC      Florida     NOC-140   FRCC200700017 NCR00022      12/17/2007      FMPA was not compliant with this           TPL-003-0      3         Lower           FRCC determined that this              6/18/2007       9/30/2008       $0     The violation was the first violation    MIT-07-     9/30/2008    9/30/2008     10/14/2008         Self-                         Yes
              Municipal                                                          reliability standard because it had not                                             violation did not constitute a                                                of this reliability standard incurred     0274                                                  Certification
               Power                                                             conducted the assessments and studies                                               serious or substantial risk to the                                            by FMPA and it did not constitute a
               Agency                                                            required in R1.                                                                     bulk power system because even                                                serious or substantial risk to the
                                                                                                                                                                     though FMPA did not provide the                                               bulk power system.
                                                                                                                                                                     assessments and studies, system
                                                                                                                                                                     planning was still being performed
                                                                                                                                                                     by its Planning Authority and the
                                                                                                                                                                     transmission planning working
23                                                                                                                                                                   group.
     FRCC      Florida     NOC-140   FRCC200700018 NCR00022      12/17/2007      FMPA did not perform the assessments       TPL-004-0      1        Medium           FRCC determined that this              6/18/2007       9/30/2008       $0     The violation was the first violation    MIT-07-     9/30/2008    9/30/2008     10/14/2008         Self-                         Yes
              Municipal                                                          and studies as required by the standard.                                            violation did not constitute a                                                of this reliability standard incurred     0275                                                  Certification
               Power                                                                                                                                                 serious or substantial risk to the                                            by FMPA and it did not constitute a
               Agency                                                                                                                                                bulk power system because even                                                serious or substantial risk to the
                                                                                                                                                                     though FMPA did not provide the                                               bulk power system.
                                                                                                                                                                     assessments and studies, system
                                                                                                                                                                     planning was still being performed
                                                                                                                                                                     by its Planning Authority and the
                                                                                                                                                                     transmission planning working
24                                                                                                                                                                   group.
     FRCC      Florida     NOC-140   FRCC200700049 NCR00022      12/17/2007      FMPA was not compliant with this           TPL-004-0      2         Lower           FRCC determined that this              6/18/2007       9/30/2008       $0     The violation was the first violation    MIT-07-     9/30/2008    9/30/2008     10/14/2008         Self-                         Yes
              Municipal                                                          reliability standard because it had not                                             violation did not constitute a                                                of this reliability standard incurred     0275                                                  Certification
               Power                                                             conducted the assessments and studies                                               serious or substantial risk to the                                            by FMPA and it did not constitute a
               Agency                                                            required in R1.                                                                     bulk power system because even                                                serious or substantial risk to the
                                                                                                                                                                     though FMPA did not provide the                                               bulk power system.
                                                                                                                                                                     assessments and studies, system
                                                                                                                                                                     planning was still being performed
                                                                                                                                                                     by its Planning Authority and the
                                                                                                                                                                     transmission planning working
25                                                                                                                                                                   group.




                                                                                                                                                                                          FRCC                                                                                                                                                                                     Page 4 of 80
                                                                                                                                                                               10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                          PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                        CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                        HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.


       A            B             C            D            E             F                               G                            H         I             J                            K                          L             M            N                         O                           P            Q            R               S               T             U             V
                                                                                                                                                                                                                                                                                                                             Registered       Regional
                                                                                                                                                       Violation Risk                                                                           Total                                                                          Entity          Entity
                                                                                                                                                                                                                                                                                                    Mitigation   Mitigation                                                  Separate      Signed
               Registered                NERC Violation            Date Identified                                                Reliability              Factor*                                              Violation Start   Violation   Penalty or Additional Factors for the Basis of                                Certification   Verification    Discovery
     Region                    NOC-ID                     NCR_ID                            Description of the Violation                        Req.                                Risk Assessment                                                                                                   Plan         Plan                                                     Settlement   Disposition
                 Entity                      ID #                   or Received                                                   Standard                                                                           Date         End Date    Sanction                Penalty                                               of Mitigation   of Mitigation    Method
                                                                                                                                                                                                                                                                                                     Number      Completed                                                  Agreement       Letter
                                                                                                                                                       *See Attachment C                                                                         ($)                                                                            Plan            Plan
1                                                                                                                                                                                                                                                                                                                            Completion      Completion
     FRCC        Florida       NOC-205   FRCC200700050 NCR00024      12/17/2007      Although FPL had a fully documented           PRC-005-1    2.1         High           FRCC determined that the               6/18/2007       12/8/2008       $0     The violation was the first violation       MIT-07-     12/8/2008   12/8/2008       3/25/2009         Self-                         Yes
                Power &                                                              maintenance and testing program, FPL                                                  violation was not a serious or                                                of this reliability standard incurred        0280                                                  Certification
                Light Co.                                                            did not, in some instances, enter correct                                             substantial risk to the bulk power                                            by FPL and it did not constitute a
                                                                                     dates for the next testing and                                                        system because FPL was                                                        serious or substantial risk to the
                                                                                     maintenance interval into its computer                                                conducting the maintenance and                                                bulk power system.
                                                                                     software tracking system, so FPL's                                                    testing on its generation and
                                                                                     testing and maintenance occurred                                                      transmission Protection Systems,
                                                                                     outside of its program intervals. There                                               although 360 relays out of 6417
                                                                                     also was a misinterpretation of program                                               were tested outside of the
                                                                                     flexibility with respect to intervals and the                                         schedule by up to 17 months.
                                                                                     coordination of generator overhaul                                                    Upon discovery of this violation,
                                                                                     schedules with other utilities and                                                    FPL promptly tested and
                                                                                     equipment outages.                                                                    maintained these relays.

26
     FRCC     Florida Public   NOC-179   FRCC200800097 NCR00025       2/4/2008       FPUC did not have procedures for the         CIP-001-1      1        Medium           FRCC determined that the               6/18/2007       6/1/2008        $0     The violation was the first violation       MIT-07-      6/1/2008    9/10/2008     11/17/2008         Self-                         Yes
                 Utilities                                                           recognition of, and for making its                                                    violation did not constitute a                                                of this reliability standard incurred        1126                                                  Certification
                Company                                                              operating personnel aware of, sabotage                                                serious or substantial risk to the                                            by FPUC and it did not constitute a
                                                                                     events on its facilities.                                                             bulk power system because                                                     serious or substantial risk to the
                                                                                                                                                                           FPUC's employees were trained                                                 bulk power system. The FRCC
                                                                                                                                                                           to be alert to, and respond to,                                               notes that FPUC did not meet its
                                                                                                                                                                           abnormal conditions or situations                                             self-certification deadline.
                                                                                                                                                                           at its facilities.                                                            However, once contacted by the
                                                                                                                                                                                                                                                         FRCC, FPUC provided the self-
                                                                                                                                                                                                                                                         certification. FRCC considered
                                                                                                                                                                                                                                                         these factors and determined that,
                                                                                                                                                                                                                                                         notwithstanding the late submittal
                                                                                                                                                                                                                                                         of its self-certification, a zero dollar
                                                                                                                                                                                                                                                         penalty was appropriate for this
                                                                                                                                                                                                                                                         violation.
27
     FRCC     Florida Public   NOC-179   FRCC200800098 NCR00025       2/4/2008       FPUC did not have procedures for the         CIP-001-1      2        Medium           FRCC determined that the               6/18/2007       6/1/2008        $0     The violation was the first violation       MIT-07-      6/1/2008    9/10/2008     11/17/2008         Self-                         Yes
                 Utilities                                                           communication of information concerning                                               violation did not constitute a                                                of this reliability standard incurred        1126                                                  Certification
                Company                                                              sabotage events to appropriate parties in                                             serious or substantial risk to the                                            by FPUC and it did not constitute a
                                                                                     the Interconnection.                                                                  bulk power system because                                                     serious or substantial risk to the
                                                                                                                                                                           FPUC's employees were trained                                                 bulk power system. The FRCC
                                                                                                                                                                           to be alert to, and respond to,                                               notes that FPUC did not meet its
                                                                                                                                                                           abnormal conditions or situations                                             self-certification deadline.
                                                                                                                                                                           at its facilities.                                                            However, once contacted by the
                                                                                                                                                                                                                                                         FRCC, FPUC provided the self-
                                                                                                                                                                                                                                                         certification. FRCC considered
                                                                                                                                                                                                                                                         these factors and determined that,
                                                                                                                                                                                                                                                         notwithstanding the late submittal
                                                                                                                                                                                                                                                         of its self-certification, a zero dollar
                                                                                                                                                                                                                                                         penalty was appropriate for this
                                                                                                                                                                                                                                                         violation.
28
     FRCC     Florida Public   NOC-179   FRCC200800099 NCR00025       2/4/2008       FPUC did not provide its operating           CIP-001-1      3        Medium           FRCC determined that the               6/18/2007       6/1/2008        $0     The violation was the first violation       MIT-07-      6/1/2008    9/10/2008     11/17/2008         Self-                         Yes
                 Utilities                                                           personnel with sabotage response                                                      violation did not constitute a                                                of this reliability standard incurred        1126                                                  Certification
                Company                                                              guidelines, including personnel to                                                    serious or substantial risk to the                                            by FPUC and it did not constitute a
                                                                                     contact, for reporting disturbances due to                                            bulk power system because                                                     serious or substantial risk to the
                                                                                     sabotage events.                                                                      FPUC's employees were trained                                                 bulk power system. The FRCC
                                                                                                                                                                           to be alert to, and respond to,                                               notes that FPUC did not meet its
                                                                                                                                                                           abnormal conditions or situations                                             self-certification deadline.
                                                                                                                                                                           at its facilities.                                                            However, once contacted by the
                                                                                                                                                                                                                                                         FRCC, FPUC provided the self-
                                                                                                                                                                                                                                                         certification. FRCC considered
                                                                                                                                                                                                                                                         these factors and determined that,
                                                                                                                                                                                                                                                         notwithstanding the late submittal
                                                                                                                                                                                                                                                         of its self-certification, a zero dollar
                                                                                                                                                                                                                                                         penalty was appropriate for this
                                                                                                                                                                                                                                                         violation.
29




                                                                                                                                                                                                FRCC                                                                                                                                                                                        Page 5 of 80
                                                                                                                                                                               10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                          PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                        CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                        HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.


       A            B             C            D            E             F                                 G                          H         I             J                              K                            L              M            N                         O                           P            Q            R               S               T             U             V
                                                                                                                                                                                                                                                                                                                                  Registered       Regional
                                                                                                                                                       Violation Risk                                                                                Total                                                                          Entity          Entity
                                                                                                                                                                                                                                                                                                         Mitigation   Mitigation                                                  Separate      Signed
               Registered                NERC Violation            Date Identified                                                Reliability              Factor*                                                  Violation Start   Violation    Penalty or Additional Factors for the Basis of                                Certification   Verification    Discovery
     Region                    NOC-ID                     NCR_ID                             Description of the Violation                       Req.                                 Risk Assessment                                                                                                       Plan          Plan                                                    Settlement   Disposition
                 Entity                      ID #                   or Received                                                   Standard                                                                               Date         End Date     Sanction                Penalty                                               of Mitigation   of Mitigation    Method
                                                                                                                                                                                                                                                                                                          Number      Completed                                                  Agreement       Letter
                                                                                                                                                       *See Attachment C                                                                              ($)                                                                            Plan            Plan
1                                                                                                                                                                                                                                                                                                                                 Completion      Completion
     FRCC     Florida Public   NOC-179   FRCC200800100 NCR00025       2/4/2008       FPUC did not establish communications        CIP-001-1      4        Medium           FRCC determined that the                   6/18/2007        6/1/2008        $0     The violation was the first violation       MIT-07-      6/1/2008   9/10/2008       11/17/2008        Self-                         Yes
                 Utilities                                                           contacts, as applicable, with local                                                   violation did not constitute a                                                     of this reliability standard incurred        1126                                                  Certification
                Company                                                              Federal Bureau of Investigation (FBI)                                                 serious or substantial risk to the                                                 by FPUC and it did not constitute a
                                                                                     officials and did not develop reporting                                               bulk power system because                                                          serious or substantial risk to the
                                                                                     procedures as appropriate to their                                                    FPUC's employees were trained                                                      bulk power system. The FRCC
                                                                                     circumstances.                                                                        to be alert to, and respond to,                                                    notes that FPUC did not meet its
                                                                                                                                                                           abnormal conditions or situations                                                  self-certification deadline.
                                                                                                                                                                           at its facilities.                                                                 However, once contacted by the
                                                                                                                                                                                                                                                              FRCC, FPUC provided the self-
                                                                                                                                                                                                                                                              certification. FRCC considered
                                                                                                                                                                                                                                                              these factors and determined that,
                                                                                                                                                                                                                                                              notwithstanding the late submittal
                                                                                                                                                                                                                                                              of its self-certification, a zero dollar
                                                                                                                                                                                                                                                              penalty was appropriate for this
                                                                                                                                                                                                                                                              violation.
30
     FRCC       Hardee         NOC-161   FRCC200800056 NCR00035      1/18/2008       Hardee did not have evidence that it had     CIP-001-1      4        Medium           FRCC determined that the                   6/18/2007       2/13/2008        $0     The violation was the first violation       MIT-08-     2/13/2008    2/15/2008       6/2/2008         Self-                         Yes
                 Power                                                               established communication contacts with                                               violation did not constitute a                                                     of this reliability standard by              0535                                                  Certification
                Partners                                                             the FBI and local Sheriff Department.                                                 serious or substantial risk to the                                                 Hardee and the violation did not
                 Limited                                                             While Hardee had telephone numbers for                                                bulk power system because                                                          constitute a serious or substantial
                                                                                     the FBI and local Sheriff's Department,                                               Hardee had a procedure to contact                                                  risk to the bulk power system.
                                                                                     there was no evidence that the numbers                                                the local FBI and Sheriff's
                                                                                     had been verified.                                                                    Department, and had telephone
                                                                                                                                                                           contact numbers, even though it
                                                                                                                                                                           had not verified that the telephone
31                                                                                                                                                                         numbers were correct.
     FRCC       Hardee         NOC-161   FRCC200800057 NCR00035      1/18/2008       Hardee did not complete relay testing for    PRC-005-1      2          High           FRCC determined that the                   6/18/2007       2/22/2008        $0     The violation was the first violation       MIT-08-     2/22/2008    2/22/2008       6/2/2008         Self-                         Yes
                 Power                                                               one of its generators during the fall of                                              violation did not constitute a                                                     of this reliability standard incurred        0536                                                  Certification
                Partners                                                             2007. There were 3 relays out of 357                                                  serious or substantial risk to the                                                 by Hardee and it did not constitute
                 Limited                                                             relays that were tested outside the                                                   bulk power system because                                                          a serious or substantial risk to the
                                                                                     interval by 3 months.                                                                 Hardee had a Maintenance and                                                       bulk power system.
                                                                                                                                                                           Testing Program and it had
                                                                                                                                                                           missed the testing and
                                                                                                                                                                           maintenance for only 3 relays out
                                                                                                                                                                           of 357 relays for a period of 3
                                                                                                                                                                           months. Therefore, it was a small
                                                                                                                                                                           quantity and a short duration of
32                                                                                                                                                                         risk exposure.
     FRCC     Hillsborough     NOC-204   FRCC200700019 NCR00036      12/14/2007      HCRRF did not have established facility   FAC-009-1         1        Medium           FRCC determined that the                   6/18/2007       5/21/2008        $0     The violation was the first violation       MIT-07-     5/21/2008     6/6/2008      3/18/2009         Self-                         Yes
                 County                                                              ratings for its solely and jointly owned                                              violation did not constitute a                                                     of this reliability standard incurred        0276                                                  Certification
               Resource                                                              facilities that were consistent with its                                              serious or substantial risk to the                                                 by HCRRF and it did not constitute
               Recovery                                                              Facility Ratings Methodology. HCRRF                                                   bulk power system because                                                          a serious or substantial risk to the
                  Facility                                                           was de-Registered as a Generator                                                      HCRRF had used nameplate                                                           bulk power system. After not
                                                                                     Owner and Generator Operator as of                                                    ratings since the 26 MW generator                                                  meeting its Mitigation Plan
                                                                                     February 2009 because it was connected                                                was put into service                                                               Completion Date, HCRRF filed for
                                                                                     to the bulk power system at less than 100                                             (approximately 20 years prior) but                                                 an extension and subsequently
                                                                                     kV.                                                                                   had not formally documented its                                                    completed its plan within the
                                                                                                                                                                           Facility Ratings Methodology.                                                      extended time. FRCC considered
                                                                                                                                                                           Further, the Facility Ratings for the                                              these factors and determined that,
                                                                                                                                                                           HCRRF is about 0.04% of the                                                        notwithstanding the late
                                                                                                                                                                           FRCC interconnected system daily                                                   completion of the Mitigation Plan,
                                                                                                                                                                           generating capacity.                                                               a zero dollar penalty was
                                                                                                                                                                                                                                                              appropriate for this violation.
33
     FRCC       Lakeland       NOC-152   FRCC200700022 NCR00044      12/7/2007       Lakeland's training program did not          PER-002-0     3.2       Medium           FRCC determined that the                   6/18/2007       12/22/2007       $0     The violation was the first violation       MIT-07-     12/22/2007   5/27/2008      6/30/2008         Audit                         Yes
                 Electric                                                            include a plan for the initial training of                                            violation did not constitute a                                                     of this reliability standard incurred        0599
                                                                                     Transmission Operators.                                                               serious or substantial risk to the                                                 by Lakeland and it did not
                                                                                                                                                                           bulk power system because there                                                    constitute a serious or substantial
                                                                                                                                                                           was a training program in place                                                    risk to the bulk power system.
                                                                                                                                                                           and initial training was being
                                                                                                                                                                           performed. However, Lakeland
                                                                                                                                                                           failed to include the initial training
                                                                                                                                                                           within its training program
34                                                                                                                                                                         document.




                                                                                                                                                                                                  FRCC                                                                                                                                                                                           Page 6 of 80
                                                                                                                                                                           10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                      PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                    CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                    HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.


       A           B           C            D            E             F                               G                           H         I             J                            K                           L             M            N                        O                         P            Q            R               S               T             U             V
                                                                                                                                                                                                                                                                                                                       Registered       Regional
                                                                                                                                                   Violation Risk                                                                            Total                                                                       Entity          Entity
                                                                                                                                                                                                                                                                                              Mitigation   Mitigation                                                  Separate      Signed
              Registered              NERC Violation            Date Identified                                               Reliability              Factor*                                               Violation Start   Violation   Penalty or Additional Factors for the Basis of                             Certification   Verification    Discovery
     Region                 NOC-ID                     NCR_ID                            Description of the Violation                       Req.                                Risk Assessment                                                                                                 Plan         Plan                                                     Settlement   Disposition
                Entity                    ID #                   or Received                                                  Standard                                                                            Date         End Date    Sanction                Penalty                                            of Mitigation   of Mitigation    Method
                                                                                                                                                                                                                                                                                               Number      Completed                                                  Agreement       Letter
                                                                                                                                                   *See Attachment C                                                                          ($)                                                                         Plan            Plan
1                                                                                                                                                                                                                                                                                                                      Completion      Completion
     FRCC     Lakeland      NOC-152   FRCC200700023 NCR00044      12/7/2007       Lakeland did not have evidence of a         PRC-005-1     1.1         High           FRCC determined that the                6/18/2007       6/12/2008       $0     The violation was the first violation    MIT-07-     6/12/2008   6/12/2008       11/17/2008        Audit                         Yes
               Electric                                                           Protection System Maintenance and                                                    violation did not constitute a                                                 of this reliability standard incurred     1664
                                                                                  Testing Program that included the basis                                              serious or substantial risk to the                                             by Lakeland and it did not
                                                                                  for testing and maintenance intervals for                                            bulk power system because                                                      constitute a serious or substantial
                                                                                  station batteries.                                                                   Lakeland was testing station                                                   risk to the bulk power system.
                                                                                                                                                                       batteries. Lakeland was                                                        Lakeland completed its Mitigation
                                                                                                                                                                       concerned that its testing                                                     Plan late (2 days after the
                                                                                                                                                                       equipment to test batteries for                                                Approved Completion Date).
                                                                                                                                                                       their maximum load capacity was                                                FRCC considered these factors
                                                                                                                                                                       harming the batteries, so it                                                   and determined that,
                                                                                                                                                                       ordered new testing equipment to                                               notwithstanding the late
                                                                                                                                                                       address this issue. Lakeland                                                   completion of the Mitigation Plan,
                                                                                                                                                                       suspended this one component of                                                a zero dollar penalty was
                                                                                                                                                                       the battery testing and                                                        appropriate for this violation.
                                                                                                                                                                       maintenance until the new
                                                                                                                                                                       equipment arrived in order to
                                                                                                                                                                       avoid further battery harm, which
                                                                                                                                                                       put its testing for battery load
                                                                                                                                                                       capacity out of its test interval.
                                                                                                                                                                       The other components of
                                                                                                                                                                       Lakeland's battery testing and
                                                                                                                                                                       maintenance continued to be
35                                                                                                                                                                     conducted.
     FRCC     Lakeland      NOC-152   FRCC200700024 NCR00044      12/7/2007       Lakeland did not provide evidence that      PRC-005-1 2/2.1       Lower/High         FRCC determined that the                6/18/2007       6/12/2008       $0     The violation was the first violation    MIT-07-     6/12/2008    6/12/2008     11/17/2008         Audit                         Yes
               Electric                                                           station batteries were load tested within                                            violation did not constitute a                                                 of this reliability standard incurred     1664
                                                                                  the defined intervals in its Protection                                              serious or substantial risk to the                                             by Lakeland and it did not
                                                                                  System Maintenance and Testing                                                       bulk power system because                                                      constitute a serious or substantial
                                                                                  Program.                                                                             Lakeland was testing station                                                   risk to the bulk power system.
                                                                                                                                                                       batteries but failed to include the                                            Lakeland completed its Mitigation
                                                                                                                                                                       basis for the testing and                                                      Plan late (2 days after the
                                                                                                                                                                       maintenance in its Protection                                                  Approved Completion Date).
                                                                                                                                                                       System document.                                                               FRCC considered these factors
                                                                                                                                                                                                                                                      and determined that,
                                                                                                                                                                                                                                                      notwithstanding the late
                                                                                                                                                                                                                                                      completion of the Mitigation Plan,
                                                                                                                                                                                                                                                      a zero dollar penalty was
36                                                                                                                                                                                                                                                    appropriate for this violation.
     FRCC     New Hope      NOC-067   FRCC200700025 NCR00051      12/17/2007      NHPP did not have procedures for the        CIP-001-1      1        Medium           FRCC determined that the                6/18/2007       6/30/2008       $0     The violation was the first violation    MIT-07-     6/30/2008    12/12/2008      9/8/2009         Self-                         Yes
                Power                                                             recognition of, and for making its                                                   violation did not constitute a                                                 of this reliability standard incurred     0532                                                  Certification
              Partnership                                                         operating personnel aware of, sabotage                                               serious or substantial risk to the                                             by NHPP and it did not constitute a
                                                                                  events on its facilities.                                                            bulk power system because                                                      serious or substantial risk to the
                                                                                                                                                                       NHPP's employees were trained                                                  bulk power system.
                                                                                                                                                                       to be alert to, and respond to,
                                                                                                                                                                       abnormal conditions or situations
                                                                                                                                                                       at its facilities. In addition,
                                                                                                                                                                       NHPP’s facility, which is
                                                                                                                                                                       connected to the bulk power
                                                                                                                                                                       system through a single 138 kV
                                                                                                                                                                       transmission line, has a peak
                                                                                                                                                                       output of 70 MW (approximately
                                                                                                                                                                       0.13% of the total FRCC
37                                                                                                                                                                     generation resources).
     FRCC     New Hope      NOC-067   FRCC200700066 NCR00051      12/17/2007      NHPP did not have procedures for the        CIP-001-1      2        Medium           FRCC determined that the                6/18/2007       6/30/2008       $0     The violation was the first violation    MIT-07-     6/30/2008    12/12/2008      9/8/2009         Self-                         Yes
                Power                                                             communication of information concerning                                              violation did not constitute a                                                 of this reliability standard incurred     0532                                                  Certification
              Partnership                                                         sabotage events to appropriate parties in                                            serious or substantial risk to the                                             by NHPP and it did not constitute a
                                                                                  the Interconnection.                                                                 bulk power system because                                                      serious or substantial risk to the
                                                                                                                                                                       NHPP's employees were trained                                                  bulk power system.
                                                                                                                                                                       to be alert to, and respond to,
                                                                                                                                                                       abnormal conditions or situations
                                                                                                                                                                       at its facilities. In addition,
                                                                                                                                                                       NHPP’s facility, which is
                                                                                                                                                                       connected to the bulk power
                                                                                                                                                                       system through a single 138 kV
                                                                                                                                                                       transmission line, has a peak
                                                                                                                                                                       output of 70 MW (approximately
                                                                                                                                                                       0.13% of the total FRCC
38                                                                                                                                                                     generation resources).




                                                                                                                                                                                            FRCC                                                                                                                                                                                      Page 7 of 80
                                                                                                                                                                            10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                       PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                     CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                     HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.


       A           B           C            D            E             F                               G                            H         I             J                           K                           L             M            N                        O                         P            Q            R               S               T             U             V
                                                                                                                                                                                                                                                                                                                       Registered       Regional
                                                                                                                                                    Violation Risk                                                                           Total                                                                       Entity          Entity
                                                                                                                                                                                                                                                                                              Mitigation   Mitigation                                                  Separate      Signed
              Registered              NERC Violation            Date Identified                                                Reliability              Factor*                                              Violation Start   Violation   Penalty or Additional Factors for the Basis of                             Certification   Verification    Discovery
     Region                 NOC-ID                     NCR_ID                            Description of the Violation                        Req.                               Risk Assessment                                                                                                 Plan         Plan                                                     Settlement   Disposition
                Entity                    ID #                   or Received                                                   Standard                                                                           Date         End Date    Sanction                Penalty                                            of Mitigation   of Mitigation    Method
                                                                                                                                                                                                                                                                                               Number      Completed                                                  Agreement       Letter
                                                                                                                                                    *See Attachment C                                                                         ($)                                                                         Plan            Plan
1                                                                                                                                                                                                                                                                                                                      Completion      Completion
     FRCC     New Hope      NOC-067   FRCC200700067 NCR00051      12/17/2007      NHPP did not provide its operating           CIP-001-1      3        Medium           FRCC determined that the               6/18/2007       6/30/2008       $0     The violation was the first violation    MIT-07-     6/30/2008 12/12/2008         9/8/2009         Self-                         Yes
                Power                                                             personnel with sabotage response                                                      violation did not constitute a                                                of this reliability standard incurred     0532                                                  Certification
              Partnership                                                         guidelines, including personnel to                                                    serious or substantial risk to the                                            by NHPP and it did not constitute a
                                                                                  contact, for reporting disturbances due to                                            bulk power system because                                                     serious or substantial risk to the
                                                                                  sabotage events.                                                                      NHPP's employees were trained                                                 bulk power system.
                                                                                                                                                                        to be alert to, and respond to,
                                                                                                                                                                        abnormal conditions or situations
                                                                                                                                                                        at its facilities. In addition,
                                                                                                                                                                        NHPP’s facility, which is
                                                                                                                                                                        connected to the bulk power
                                                                                                                                                                        system through a single 138 kV
                                                                                                                                                                        transmission line, has a peak
                                                                                                                                                                        output of 70 MW (approximately
                                                                                                                                                                        0.13% of the total FRCC
39                                                                                                                                                                      generation resources).
     FRCC     New Hope      NOC-067   FRCC200700068 NCR00051      12/17/2007      NHPP did not establish communications        CIP-001-1      4        Medium           FRCC determined that the               6/18/2007       6/30/2008       $0     The violation was the first violation    MIT-07-     6/30/2008    12/12/2008      9/8/2009         Self-                         Yes
                Power                                                             contacts, as applicable, with local                                                   violation did not constitute a                                                of this reliability standard incurred     0532                                                  Certification
              Partnership                                                         Federal Bureau of Investigation (FBI)                                                 serious or substantial risk to the                                            by NHPP and it did not constitute a
                                                                                  officials and did not develop reporting                                               bulk power system because                                                     serious or substantial risk to the
                                                                                  procedures as appropriate to their                                                    NHPP's employees were trained                                                 bulk power system.
                                                                                  circumstances.                                                                        to be alert to, and respond to,
                                                                                                                                                                        abnormal conditions or situations
                                                                                                                                                                        at its facilities. In addition,
                                                                                                                                                                        NHPP’s facility, which is
                                                                                                                                                                        connected to the bulk power
                                                                                                                                                                        system through a single 138 kV
                                                                                                                                                                        transmission line, has a peak
                                                                                                                                                                        output of 70 MW (approximately
                                                                                                                                                                        0.13% of the total FRCC
40                                                                                                                                                                      generation resources).
     FRCC     New Hope      NOC-067   FRCC200700026 NCR00051      12/17/2007      NHPP did not have a documented               FAC-008-1      1         Lower           FRCC determined that the               6/18/2007       6/30/2008       $0     The violation was the first violation    MIT-07-     6/30/2008    12/12/2008     8/24/2009         Self-                         Yes
                Power                                                             Facility Ratings Methodology.                                                         violation did not constitute a                                                of this reliability standard incurred     0533                                                  Certification
              Partnership                                                                                                                                               serious or substantial risk to the                                            by NHPP and it did not constitute a
                                                                                                                                                                        bulk power system because the                                                 serious or substantial risk to the
                                                                                                                                                                        facility was operating within the                                             bulk power system.
                                                                                                                                                                        ratings provided by equipment
41                                                                                                                                                                      manufacturers.
     FRCC     New Hope      NOC-067   FRCC200700027 NCR00051      12/17/2007      NHPP self-certified that it did not have     TOP-003-0      1        Medium           FRCC determined that the               6/18/2007       6/30/2008       $0     The violation was the first violation    MIT-07-     6/30/2008    12/12/2008     9/8//2009         Self-                         Yes
                Power                                                             records evidencing its communication of                                               violation did not constitute a                                                of this reliability standard incurred     0534                                                  Certification
              Partnership                                                         outage information to its Transmission                                                serious or substantial risk to the                                            by NHPP and it did not constitute a
                                                                                  Operator.                                                                             bulk power system because NHPP                                                serious or substantial risk to the
                                                                                                                                                                        was communicating on a daily                                                  bulk power system.
                                                                                                                                                                        basis with its Transmission
                                                                                                                                                                        Operator. However, its
                                                                                                                                                                        procedures did not require
                                                                                                                                                                        retaining evidence of its
42                                                                                                                                                                      communications.
     FRCC     New Hope      NOC-067   FRCC200700069 NCR00051      12/17/2007      NHPP self-certified that it did not have TOP-003-0          2        Medium           FRCC determined that the               6/18/2007       6/30/2008       $0     The violation was the first violation    MIT-07-     6/30/2008    12/12/2008      9/8/2009         Self-                         Yes
                Power                                                             records evidencing that it planned and                                                violation did not constitute a                                                of this reliability standard incurred     0534                                                  Certification
              Partnership                                                         coordinated scheduled outages of system                                               serious or substantial risk to the                                            by NHPP and it did not constitute a
                                                                                  voltage regulating equipment, such as                                                 bulk power system because NHPP                                                serious or substantial risk to the
                                                                                  automatic voltage regulators on                                                       was communicating on a daily                                                  bulk power system.
                                                                                  generators, supplementary excitation                                                  basis with its Transmission
                                                                                  control, synchronous condensers, shunt                                                Operator and Balancing Authority,
                                                                                  and series capacitors, and reactors,                                                  however its procedures did not
                                                                                  among affected Balancing Authorities                                                  require retaining evidence of its
                                                                                  and Transmission Operators as required.                                               communications.
43
     FRCC     New Hope      NOC-067   FRCC200700070 NCR00051      12/17/2007      NHPP self-certified that it did not have     TOP-003-0      3        Medium           FRCC determined that the               6/18/2007       6/30/2008       $0     The violation was the first violation    MIT-07-     6/30/2008    12/12/2008      9/8/2009         Self-                         Yes
                Power                                                             records evidencing that it planned and                                                violation did not constitute a                                                of this reliability standard incurred     0534                                                  Certification
              Partnership                                                         coordinated scheduled outages of                                                      serious or substantial risk to the                                            by NHPP and it did not constitute a
                                                                                  telemetering and control equipment and                                                bulk power system because NHPP                                                serious or substantial risk to the
                                                                                  associated communication channels                                                     was communicating on a daily                                                  bulk power system.
                                                                                  between the affected areas.                                                           basis with its Transmission
                                                                                                                                                                        Operator, Balancing Authority and
                                                                                                                                                                        Reliability Coordinator, however
                                                                                                                                                                        its procedures did not require
                                                                                                                                                                        retaining evidence of its
44                                                                                                                                                                      communications.




                                                                                                                                                                                            FRCC                                                                                                                                                                                      Page 8 of 80
                                                                                                                                                                           10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                      PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                    CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                    HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.


       A           B           C            D            E             F                              G                            H         I             J                             K                            L              M            N                        O                         P            Q            R               S               T             U             V
                                                                                                                                                                                                                                                                                                                          Registered       Regional
                                                                                                                                                   Violation Risk                                                                               Total                                                                       Entity          Entity
                                                                                                                                                                                                                                                                                                 Mitigation   Mitigation                                                  Separate      Signed
              Registered              NERC Violation            Date Identified                                               Reliability              Factor*                                                 Violation Start   Violation    Penalty or Additional Factors for the Basis of                             Certification   Verification    Discovery
     Region                 NOC-ID                     NCR_ID                            Description of the Violation                       Req.                                Risk Assessment                                                                                                    Plan          Plan                                                    Settlement   Disposition
                Entity                    ID #                   or Received                                                  Standard                                                                              Date         End Date     Sanction                Penalty                                            of Mitigation   of Mitigation    Method
                                                                                                                                                                                                                                                                                                  Number      Completed                                                  Agreement       Letter
                                                                                                                                                   *See Attachment C                                                                             ($)                                                                         Plan            Plan
1                                                                                                                                                                                                                                                                                                                         Completion      Completion
     FRCC       Pasco       NOC-206   FRCC200700063 NCR00058      12/17/2007      PCRRF did not have established facility     FAC-009-1      1        Medium           FRCC determined that the                  6/18/2007        6/5/2008        $0     The violation was the first violation    MIT-08-      6/5/2008    6/5/2008       2/10/2009         Self-                         Yes
                County                                                            ratings for its solely and jointly owned                                             violation did not constitute a                                                    of this reliability standard incurred     0538                                                  Certification
               Resource                                                           facilities that were consistent with its                                             serious or substantial risk to the                                                by PCRRF and it did not constitute
               Recovery                                                           Facility Ratings Methodology.                                                        bulk power system because the                                                     a serious or substantial risk to the
                Facility                                                                                                                                               PCRRF had used nameplate                                                          bulk power system. After not
                                                                                                                                                                       ratings since the 26 MW generator                                                 meeting its Mitigation Plan
                                                                                                                                                                       was put into service                                                              Completion Date, PCRRF filed for
                                                                                                                                                                       (approximately 16 years prior) but                                                an extension and subsequently
                                                                                                                                                                       had not formally documented its                                                   completed its plan within the
                                                                                                                                                                       Facility Ratings Methodology.                                                     extended time. FRCC considered
                                                                                                                                                                       Further, the Facility Ratings for the                                             these factors and determined that,
                                                                                                                                                                       PCRRF is about 0.04% of the                                                       notwithstanding the late
                                                                                                                                                                       FRCC interconnected system daily                                                  completion of the Mitigation Plan,
                                                                                                                                                                       generating capacity.                                                              a zero dollar penalty was
                                                                                                                                                                                                                                                         appropriate for this violation.
45
     FRCC      Progress     NOC-159   FRCC200700047 NCR00063      12/21/2007      The PEF generator operator at three of      VAR-002-1     3.1       Medium           FRCC determined that the                  6/18/2007       12/13/2007       $0     The violation was self-reported, it      MIT-07-     12/13/2007   12/21/2007     1/14/2008      Self-Report                      Yes
                Energy                                                            its generation facilities changed the                                                violation did not constitute a                                                    was the first violation of this           0278
                Florida                                                           status of the generator reactive power                                               serious or substantial risk to the                                                reliability standard by PEF and the
                                                                                  resource, from the power factor mode to                                              bulk power system because the                                                     violation did not constitute a
                                                                                  the automatic voltage control mode, and                                              automatic voltage regulator for all                                               serious or substantial risk to the
                                                                                  did not notify its Transmission Operator                                             three generating facilities was                                                   bulk power system.
                                                                                  within 30 minutes.                                                                   operating in the voltage control
46                                                                                                                                                                     mode.
     FRCC       Utilities   NOC-154   FRCC200700051 NCR00052      12/18/2007      While the Reliability Standard sub-         BAL-005-0     8.1       Medium           FRCC determined that the                  6/18/2007        5/8/2008        $0     The violation was self-reported, it      MIT-07-      5/8/2008    5/30/2008      8/15/2008      Self-Report                      Yes
              Commission                                                          requirement requires redundant and                                                   violation did not constitute a                                                    was the first violation of this           0281
                of New                                                            independent frequency metering                                                       serious or substantial risk to the                                                reliability standard by New Smyrna
                Smyrna                                                            equipment that shall automatically                                                   bulk power system because New                                                     Beach and the violation did not
                 Beach                                                            activate upon detection of failure of the                                            Smyrna Beach had metering in                                                      constitute a serious or substantial
                                                                                  primary source, New Smyrna Beach did                                                 place, properly gathered                                                          risk to the bulk power system.
                                                                                  not have a provision to automatically                                                frequency and used it in the
                                                                                  transfer from the primary frequency                                                  calculation of ACE. In addition, it                                               New Smyrna Beach had the
                                                                                  source to the backup frequency source in                                             had a second metering source                                                      equipment in place that needed to
                                                                                  the calculation of its Area Control Error                                            available within its system but it                                                be synchronized with the software
                                                                                  (ACE) on its Energy Management                                                       had not implemented the                                                           but completed its Mitigation Plan
                                                                                  System.                                                                              secondary metering source as a                                                    over 2 months after its approved
                                                                                                                                                                       redundant source within its energy                                                completion date of 3/1/2008.
                                                                                                                                                                       management system. Prior to                                                       FRCC considered these factors
                                                                                                                                                                       New Smyrna's Beach's                                                              and determined that,
                                                                                                                                                                       implementation of the second                                                      notwithstanding the late
                                                                                                                                                                       metering source into its energy                                                   completion of the Mitigation Plan,
                                                                                                                                                                       management system, its third                                                      a zero dollar penalty was
                                                                                                                                                                       party regulation services                                                         appropriate for this violation.
                                                                                                                                                                       contractor would have provided
                                                                                                                                                                       the frequency in the event that the
                                                                                                                                                                       primary source was not available.
                                                                                                                                                                       New Smyrna Beach is small; its
                                                                                                                                                                       peak load is approximately 100
47                                                                                                                                                                     MW (about .9% to the total FRCC
     FRCC       Utilities   NOC-177   FRCC200700028 NCR00052      12/21/2007      New Smyrna Beach did not have written       COM-001-       5         Lower           region summer peak). the
                                                                                                                                                                       FRCC determined that                      6/18/2007       10/14/2008       $0     The violation was the first violation    MIT-07-     10/14/2008   10/14/2008    11/15/2008         Audit                         Yes
              Commission                                                          operating instructions and procedures to       1                                     violation did not constitute a                                                    of this reliability standard incurred     1665
                of New                                                            enable continued operation of the                                                    serious or substantial risk to the                                                by New Smyrna Beach and it did
                Smyrna                                                            transmission system during the loss of                                               bulk power system because New                                                     not constitute a serious or
                 Beach                                                            data communications. While New                                                       Smyrna Beach had procedures to                                                    substantial risk to the bulk power
                                                                                  Smyrna Beach's COM-001-1 document                                                    handle the loss of both data and                                                  system.
                                                                                  covered continued operations with                                                    voice communications. New
                                                                                  respect to the loss of voice                                                         Smyrna Beach was able to
                                                                                  communications, it did not include the                                               demonstrate it had procedures in
                                                                                  loss of data communications.                                                         place but did not document the
                                                                                                                                                                       procedure for the loss of data
48                                                                                                                                                                     communications.
     FRCC       Utilities   NOC-177   FRCC200700029 NCR00052      12/21/2007      New Smyrna Beach's Emergency                EOP-001-0      4        Medium           FRCC determined that the                  6/18/2007       10/15/2008       $0     The violation was the first violation    MIT-07-     10/15/2008   10/15/2008    11/15/2008         Audit                         Yes
              Commission                                                          Response Plan did not include the tasks                                              violation did not constitute a                                                    of this reliability standard incurred     1666
                of New                                                            to be coordinated with and among                                                     serious or substantial risk to the                                                by New Smyrna Beach and it did
                Smyrna                                                            adjacent TOPs and BAs as required by                                                 bulk power system because New                                                     not constitute a serious or
                 Beach                                                            EOP-001-0 R4.3.                                                                      Smyrna Beach was able to                                                          substantial risk to the bulk power
                                                                                                                                                                       demonstrate it had procedures in                                                  system.
49                                                                                                                                                                     place but did not document them.




                                                                                                                                                                                             FRCC                                                                                                                                                                                        Page 9 of 80
                                                                                                                                                                           10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                      PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                    CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                    HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.


       A           B           C            D            E             F                              G                            H         I             J                            K                           L              M            N                        O                         P          Q             R              S             T           U             V
                                                                                                                                                                                                                                                                                                                      Registered       Regional
                                                                                                                                                   Violation Risk                                                                             Total                                                                     Entity          Entity
                                                                                                                                                                                                                                                                                               Mitigation Mitigation                                              Separate      Signed
              Registered              NERC Violation            Date Identified                                               Reliability              Factor*                                               Violation Start   Violation    Penalty or Additional Factors for the Basis of                           Certification   Verification    Discovery
     Region                 NOC-ID                     NCR_ID                            Description of the Violation                       Req.                                Risk Assessment                                                                                                  Plan       Plan                                                 Settlement   Disposition
                Entity                    ID #                   or Received                                                  Standard                                                                            Date         End Date     Sanction                Penalty                                          of Mitigation   of Mitigation    Method
                                                                                                                                                                                                                                                                                                Number Completed                                                 Agreement       Letter
                                                                                                                                                   *See Attachment C                                                                           ($)                                                                       Plan            Plan
1                                                                                                                                                                                                                                                                                                                     Completion      Completion
     FRCC       Utilities   NOC-177   FRCC200700030 NCR00052      12/21/2007      New Smyrna Beach did not have          EOP-001-0           6        Medium           FRCC determined that the                6/18/2007       10/15/2008       $0     The violation was the first violation    MIT-07- 10/15/2008 11/12/2008         1/22/2009        Audit                      Yes
              Commission                                                          evidence of coordinating its emergency                                               violation did not constitute a                                                  of this reliability standard incurred     1376
                of New                                                            plans with other Balancing Authorities                                               serious or substantial risk to the                                              by New Smyrna Beach and it did
                Smyrna                                                            and Transmission Operators, and there                                                bulk power system because there                                                 not constitute a serious or
                 Beach                                                            was no evidence that New Smyrna Beach                                                had been no changes to the New                                                  substantial risk to the bulk power
                                                                                  annually reviewed and updated its                                                    Smyrna Beach footprint and it had                                               system.
                                                                                  emergency plans.                                                                     static operations, load and
                                                                                                                                                                       relationships with its BA, TOP,
                                                                                                                                                                       and RC. In addition, its facilities
                                                                                                                                                                       and operating procedures were
50                                                                                                                                                                     stable.
     FRCC       Utilities   NOC-177   FRCC200700031 NCR00052      12/21/2007      New Smyrna Beach did not include a         EOP-001-0       7        Medium           FRCC determined that the                6/18/2007       10/15/2008       $0     The violation was the first violation    MIT-07-   10/15/2008   10/15/2008     1/23/2009        Audit                      Yes
              Commission                                                          statement within its emergency plans that                                            violation did not constitute a                                                  of this reliability standard incurred     1377
                of New                                                            the plans are to be coordinated with                                                 serious or substantial risk to the                                              by New Smyrna Beach and it did
                Smyrna                                                            neighboring entities and that the                                                    bulk power system because New                                                   not constitute a serious or
                 Beach                                                            coordination of transmission and                                                     Smyrna Beach was able to                                                        substantial risk to the bulk power
                                                                                  generator maintenance schedules will be                                              demonstrate it had procedures in                                                system.
                                                                                  done to maximize capacity (as required                                               place but did not document them.
51                                                                                by R7.3).
     FRCC       Utilities   NOC-177   FRCC200700033 NCR00052      12/21/2007      New Smyrna Beach did not include its       EOP-003-1       7          High           FRCC determined that the                6/18/2007       1/21/2009        $0     The violation was the first violation    MIT-07-   1/21/2009    1/21/2009      1/23/2009        Audit                      Yes
              Commission                                                          generating units in its automatic                                                    violation did not constitute a                                                  of this reliability standard by New       1378
                of New                                                            underfrequency load shedding program.                                                serious or substantial risk to the                                              Smyrna Beach and the violation
                Smyrna                                                            The other requirements included in the                                               bulk power system because New                                                   did not constitute a serious or
                 Beach                                                            reliability sub-standard (shunt capacitors                                           Smyrna Beach's generators were                                                  substantial risk to the bulk power
                                                                                  and other automatic actions) did not                                                 connected at less than 100 kV and                                               system.
                                                                                  apply to New Smyrna Beach.                                                           because of their location to the
                                                                                                                                                                       grid, the lack of coordination of
                                                                                                                                                                       these resources would not have
                                                                                                                                                                       an impact on the bulk power
                                                                                                                                                                       system. Further, these generators
                                                                                                                                                                       generally were not run, as the
                                                                                                                                                                       units were uneconomical and New
                                                                                                                                                                       Smyrna Beach relied upon third
                                                                                                                                                                       party power purchases to serve its
                                                                                                                                                                       load. FRCC notes that New
                                                                                                                                                                       Smyrna Beach was De-Registered
                                                                                                                                                                       as a Generator Owner and
                                                                                                                                                                       Generator Operator as of
                                                                                                                                                                       February 2009.

52
     FRCC       Utilities   NOC-177   FRCC200700045 NCR00052      12/21/2007      New Smyrna Beach's formal                  EOP-005-1       1        Medium           FRCC determined that the                6/18/2007       10/17/2008       $0     The violation was the first violation    MIT-07-   10/17/2008   10/17/2008     1/23/2009        Audit                      Yes
              Commission                                                          policy/procedure did not cover the loss of                                           violation did not constitute a                                                  of this reliability standard incurred     1387
                of New                                                            vital data telecommunications channels                                               serious or substantial risk to the                                              by New Smyrna Beach and it did
                Smyrna                                                            as required in the standard.                                                         bulk power system because New                                                   not constitute a serious or
                 Beach                                                                                                                                                 Smyrna Beach had procedures to                                                  substantial risk to the bulk power
                                                                                                                                                                       handle the loss of both data and                                                system.
                                                                                                                                                                       voice telecommunication
                                                                                                                                                                       channels. New Smyrna Beach was
                                                                                                                                                                       able to demonstrate it had
                                                                                                                                                                       procedures in place but did not
                                                                                                                                                                       document the procedure for the
                                                                                                                                                                       loss of data telecommunication
53                                                                                                                                                                     channels.
     FRCC       Utilities   NOC-177   FRCC200700046 NCR00052      12/21/2007      New Smyrna Beach did not provide            EOP-005-1      7          High           FRCC determined that the                6/18/2007       3/10/2009        $0     The violation was the first violation    MIT-07-   3/10/2009    3/10/2009      4/16/2009        Audit                      Yes
              Commission                                                          evidence of actual testing or simulation of                                          violation did not constitute a                                                  of this reliability standard incurred     1388
                of New                                                            its system restoration procedures.                                                   serious or substantial risk to the                                              by New Smyrna Beach and it did
                Smyrna                                                                                                                                                 bulk power system because New                                                   not constitute a serious or
                 Beach                                                                                                                                                 Smyrna Beach, although it                                                       substantial risk to the bulk power
                                                                                                                                                                       deviated from its documented                                                    system.
                                                                                                                                                                       plan, had successfully conducted
54                                                                                                                                                                     a restoration on April 14, 2004.
     FRCC       Utilities   NOC-177   FRCC200700034 NCR00052      12/21/2007      New Smyrna Beach did not address the        EOP-008-0      1        Medium           FRCC determined that the                6/18/2007       10/14/2008       $0     The violation was the first violation    MIT-07-   10/14/2008   10/14/2008    11/15/2008        Audit                      Yes
              Commission                                                          logging of significant events in its                                                 violation did not constitute a                                                  of this reliability standard incurred     1667
                of New                                                            contingency plan with respect to the loss                                            serious or substantial risk to the                                              by New Smyrna Beach and it did
                Smyrna                                                            of control center functionality.                                                     bulk power system because New                                                   not constitute a serious or
                 Beach                                                                                                                                                 Smyrna Beach was able to                                                        substantial risk to the bulk power
                                                                                                                                                                       demonstrate it had procedures in                                                system.
                                                                                                                                                                       place but did not document the
                                                                                                                                                                       procedure for the logging of
55                                                                                                                                                                     significant events.




                                                                                                                                                                                            FRCC                                                                                                                                                                                Page 10 of 80
                                                                                                                                                                          10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                     PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                   CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                   HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.


       A           B           C            D            E             F                              G                           H         I             J                             K                            L              M            N                        O                         P          Q             R              S             T           U             V
                                                                                                                                                                                                                                                                                                                       Registered       Regional
                                                                                                                                                  Violation Risk                                                                               Total                                                                     Entity          Entity
                                                                                                                                                                                                                                                                                                Mitigation Mitigation                                              Separate      Signed
              Registered              NERC Violation            Date Identified                                              Reliability              Factor*                                                 Violation Start   Violation    Penalty or Additional Factors for the Basis of                           Certification   Verification    Discovery
     Region                 NOC-ID                     NCR_ID                            Description of the Violation                      Req.                                Risk Assessment                                                                                                    Plan       Plan                                                 Settlement   Disposition
                Entity                    ID #                   or Received                                                 Standard                                                                              Date         End Date     Sanction                Penalty                                          of Mitigation   of Mitigation    Method
                                                                                                                                                                                                                                                                                                 Number Completed                                                 Agreement       Letter
                                                                                                                                                  *See Attachment C                                                                             ($)                                                                       Plan            Plan
1                                                                                                                                                                                                                                                                                                                      Completion      Completion
     FRCC       Utilities   NOC-177   FRCC200700035 NCR00052      12/21/2007      New Smyrna Beach had a Facility           FAC-008-1       1         Lower           FRCC determined that the                  6/18/2007       10/14/2008       $0     The violation was the first violation    MIT-07- 10/14/2008 10/14/2008         1/23/2009        Audit                      Yes
              Commission                                                          Ratings Methodology for its transmission                                            violation did not constitute a                                                    of this reliability standard incurred     1379
                of New                                                            and generation facilities, but it did not                                           serious or substantial risk to the                                                by New Smyrna Beach and it did
                Smyrna                                                            document its Facility Rating Methodology                                            bulk power system because New                                                     not constitute a serious or
                 Beach                                                            for its generation facilities.                                                      Smyrna Beach had facility ratings                                                 substantial risk to the bulk power
                                                                                                                                                                      but did not document its                                                          system.
                                                                                                                                                                      methodology for its generation
                                                                                                                                                                      facilities. The facilities were
                                                                                                                                                                      operating within the ratings
                                                                                                                                                                      provided by equipment
56                                                                                                                                                                    manufacturers.
     FRCC       Utilities   NOC-177   FRCC200700036 NCR00052      12/21/2007      New Smyrna Beach did not have            FAC-009-1        1        Medium           FRCC determined that the                  6/18/2007       6/15/2008        $0     The violation was the first violation    MIT-07-   6/15/2008    10/14/2008    11/15/2008        Audit                      Yes
              Commission                                                          evidence that its Facility Ratings                                                  violation did not constitute a                                                    of this reliability standard incurred     1668
                of New                                                            Methodology was used to develop ratings                                             serious or substantial risk to the                                                by New Smyrna Beach and it did
                Smyrna                                                            at one 115 kV substation and two radial                                             bulk power system because New                                                     not constitute a serious or
                 Beach                                                            115 kV lines. New Smyrna Beach had                                                  Smyrna Beach had both a Facility                                                  substantial risk to the bulk power
                                                                                  applied its Facility Ratings Methodology                                            Rating Methodology and ratings                                                    system.
                                                                                  to its other transmission facilities.                                               for these three transmission
                                                                                                                                                                      facilities. However, the rating for
                                                                                                                                                                      the three transmission facilities
                                                                                                                                                                      were not developed in accordance
                                                                                                                                                                      with New Smyrna Beach's Facility
                                                                                                                                                                      Rating Methodology. The facilities
                                                                                                                                                                      ratings used did not overrate the
                                                                                                                                                                      capacity of the line.
57
     FRCC       Utilities   NOC-177   FRCC200700038 NCR00052      12/21/2007      During an on-site audit it was discovered PRC-005-1       1          High           FRCC determined that the                  6/18/2007        5/7/2009        $0     The violation was the first violation    MIT-07-    5/7/2009    5/13/2009      8/21/2009        Audit                      Yes
              Commission                                                          that New Smyrna Beach's Protection                                                  violation did not constitute a                                                    of this reliability standard incurred     1380
                of New                                                            System Maintenance and Testing                                                      serious or substantial risk to the                                                by New Smyrna Beach and it did
                Smyrna                                                            Program excluded the Protection                                                     bulk power system because New                                                     not constitute a serious or
                 Beach                                                            Systems for New Smyrna Beach's                                                      Smyrna Beach had a Protection                                                     substantial risk to the bulk power
                                                                                  generation facilities. Additionally, its                                            System Program for its generation                                                 system.
                                                                                  transmission facilities lacked the intervals                                        and transmission facilities, even
                                                                                  and their bases for the maintenance and                                             though it lacked certain required
                                                                                  testing of associated communication                                                 components, and New Smyrna
                                                                                  systems and DC control circuitry and did                                            Beach was performing
                                                                                  not include the intervals' basis for the                                            maintenance and testing on its
                                                                                  maintenance and testing of relays,                                                  transmission and generation
                                                                                  batteries and voltage and current sensing                                           Protection Systems.
58                                                                                devices.
     FRCC       Utilities   NOC-177   FRCC200700039 NCR00052      12/21/2007      New Smyrna Beach's formal                    TOP-004-1    6        Medium           FRCC determined that the                  6/18/2007       1/30/2009        $0     The violation was the first violation    MIT-07-   1/30/2009    1/30/2009      8/21/2009        Audit                      Yes
              Commission                                                          policy/procedure did not indicate that it                                           violation did not constitute a                                                    of this reliability standard incurred     1381
                of New                                                            needed to jointly coordinated with other                                            serious or substantial risk to the                                                by New Smyrna Beach and it did
                Smyrna                                                            TOPs on monitoring and controlling                                                  bulk power system because New                                                     not constitute a serious or
                 Beach                                                            voltage levels and real and reactive                                                Smyrna Beach had full monitoring                                                  substantial risk to the bulk power
                                                                                  power flows as required.                                                            capabilities of its real and reactive                                             system.
                                                                                                                                                                      power flows into or out of its
                                                                                                                                                                      system and guidelines for
59                                                                                                                                                                    acceptable voltage ranges.
     FRCC       Utilities   NOC-177   FRCC200700040 NCR00052      12/21/2007      New Smyrna Beach did not perform the       TPL-001-0      1          High           FRCC determined that this                 6/18/2007       6/12/2009        $0     The violation was the first violation    MIT-07-   6/12/2009    6/12/2009      8/21/2009        Audit                      Yes
              Commission                                                          assessments and studies as required by                                              violation did not constitute a                                                    of this reliability standard incurred     1382
                of New                                                            the standard.                                                                       serious or substantial risk to the                                                by New Smyrna Beach and it did
                Smyrna                                                                                                                                                bulk power system because even                                                    not constitute a serious or
                 Beach                                                                                                                                                though New Smyrna Beach did not                                                   substantial risk to the bulk power
                                                                                                                                                                      provide the assessments and                                                       system.
                                                                                                                                                                      studies, system planning was still
                                                                                                                                                                      being performed by its Planning
                                                                                                                                                                      Authority and the transmission
                                                                                                                                                                      planning working group. New
                                                                                                                                                                      Smyrna Beach is small (maximum
                                                                                                                                                                      monthly peak demand is less than
                                                                                                                                                                      95 MW) so any impact would not
                                                                                                                                                                      have been serious or substantial.
60




                                                                                                                                                                                            FRCC                                                                                                                                                                                 Page 11 of 80
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       A           B           C            D            E             F                              G                         H         I             J                            K                          L             M            N                        O                         P            Q            R               S             T           U             V
                                                                                                                                                                                                                                                                                                                   Registered       Regional
                                                                                                                                                Violation Risk                                                                           Total                                                                       Entity          Entity
                                                                                                                                                                                                                                                                                          Mitigation   Mitigation                                              Separate      Signed
              Registered              NERC Violation            Date Identified                                            Reliability              Factor*                                              Violation Start   Violation   Penalty or Additional Factors for the Basis of                             Certification   Verification    Discovery
     Region                 NOC-ID                     NCR_ID                            Description of the Violation                    Req.                               Risk Assessment                                                                                                 Plan         Plan                                                 Settlement   Disposition
                Entity                    ID #                   or Received                                               Standard                                                                           Date         End Date    Sanction                Penalty                                            of Mitigation   of Mitigation    Method
                                                                                                                                                                                                                                                                                           Number      Completed                                              Agreement       Letter
                                                                                                                                                *See Attachment C                                                                         ($)                                                                         Plan            Plan
1                                                                                                                                                                                                                                                                                                                  Completion      Completion
     FRCC       Utilities   NOC-177   FRCC200700041 NCR00052      12/21/2007      New Smyrna Beach did not perform the     TPL-002-0      1          High           FRCC determined that this              6/18/2007       6/12/2009       $0     The violation was the first violation    MIT-07-     6/12/2009   6/12/2009       8/21/2009        Audit                      Yes
              Commission                                                          assessments and studies as required by                                            violation did not constitute a                                                of this reliability standard incurred     1383
                of New                                                            the standard.                                                                     serious or substantial risk to the                                            by New Smyrna Beach and it did
                Smyrna                                                                                                                                              bulk power system because even                                                not constitute a serious or
                 Beach                                                                                                                                              though New Smyrna Beach did not                                               substantial risk to the bulk power
                                                                                                                                                                    provide the assessments and                                                   system.
                                                                                                                                                                    studies, system planning was still
                                                                                                                                                                    being performed by its Planning
                                                                                                                                                                    Authority and the transmission
                                                                                                                                                                    planning working group. New
                                                                                                                                                                    Smyrna Beach is small (maximum
                                                                                                                                                                    monthly peak demand is less than
                                                                                                                                                                    95 MW) so any impact would not
                                                                                                                                                                    have been serious or substantial.
61
     FRCC       Utilities   NOC-177   FRCC200700042 NCR00052      12/21/2007      New Smyrna Beach did not perform the     TPL-003-0      1          High           FRCC determined that this              6/18/2007       6/12/2009       $0     The violation was the first violation    MIT-07-     6/12/2009    6/12/2009      8/21/2009        Audit                      Yes
              Commission                                                          assessments and studies as required by                                            violation did not constitute a                                                of this reliability standard incurred     1384
                of New                                                            the standard.                                                                     serious or substantial risk to the                                            by New Smyrna Beach and it did
                Smyrna                                                                                                                                              bulk power system because even                                                not constitute a serious or
                 Beach                                                                                                                                              though New Smyrna Beach did not                                               substantial risk to the bulk power
                                                                                                                                                                    provide the assessments and                                                   system.
                                                                                                                                                                    studies, system planning was still
                                                                                                                                                                    being performed by its Planning
                                                                                                                                                                    Authority and the transmission
                                                                                                                                                                    planning working group. New
                                                                                                                                                                    Smyrna Beach is small (maximum
                                                                                                                                                                    monthly peak demand is less than
                                                                                                                                                                    95 MW) so any impact would not
                                                                                                                                                                    have been serious or substantial.
62
     FRCC       Utilities   NOC-177   FRCC200700043 NCR00052      12/21/2007      New Smyrna Beach did not perform the     TPL-004-0      1        Medium           FRCC determined that this              6/18/2007       6/12/2008       $0     The violation was the first violation    MIT-07-     6/12/2009    6/12/2009      8/21/2009        Audit                      Yes
              Commission                                                          assessments and studies as required by                                            violation did not constitute a                                                of this reliability standard incurred     1385
                of New                                                            the standard.                                                                     serious or substantial risk to the                                            by New Smyrna Beach and it did
                Smyrna                                                                                                                                              bulk power system because even                                                not constitute a serious or
                 Beach                                                                                                                                              though New Smyrna Beach did not                                               substantial risk to the bulk power
                                                                                                                                                                    provide the assessments and                                                   system.
                                                                                                                                                                    studies, system planning was still
                                                                                                                                                                    being performed by its Planning
                                                                                                                                                                    Authority and the transmission
                                                                                                                                                                    planning working group. New
                                                                                                                                                                    Smyrna Beach is small (maximum
                                                                                                                                                                    monthly peak demand is less than
                                                                                                                                                                    95 MW) so any impact would not
                                                                                                                                                                    have been serious or substantial.
63
     FRCC       Utilities   NOC-177   FRCC200700044 NCR00052      12/21/2007      During the on-site audit, on December   VAR-001-1       1          High           FRCC determined that the               6/18/2007       1/30/2009       $0     The violation was the first violation    MIT-07-     1/30/2009    1/30/2009      8/21/2009        Audit                      Yes
              Commission                                                          21, 2007, it was discovered that New                                              violation did not constitute a                                                of this reliability standard incurred     1386
                of New                                                            Smyrna Beach's policy document                                                    serious or substantial risk to the                                            by New Smyrna Beach and it did
                Smyrna                                                            specified cooperation with neighbors to                                           bulk power system because New                                                 not constitute a serious or
                 Beach                                                            support New Smyrna Beach's reactive                                               Smyrna Beach had procedures for                                               substantial risk to the bulk power
                                                                                  needs, however, no evidence was                                                   voltage and reactive controls and                                             system.
                                                                                  provided to indicate that New Smyrna                                              its policy document specified
                                                                                  Beach had, jointly with other                                                     cooperation with neighbors.
                                                                                  Transmission Operators, ensured that                                              FRCC considered that some risk
                                                                                  formal policies and procedures were                                               existed because the procedures
                                                                                  developed, maintained, and implemented                                            were not jointly developed,
                                                                                  for monitoring and controlling voltage                                            maintained and implemented, and
                                                                                  levels and MVAR flows within their                                                voltage levels could have been
                                                                                  individual areas and with the areas of                                            mismatched between TOPs.
                                                                                  neighboring Transmission Operators, as
                                                                                  required by VAR-001-1 R 1.
64




                                                                                                                                                                                         FRCC                                                                                                                                                                                Page 12 of 80
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      A            B            C            D            E            F                          G                          H          I           J                              K                           L          M           N                         O                         P            Q             R              S               T             U             V

                                                                                                                                                                                                                                                                                                               Registered     Regional
                                                                                                                                                                                                                                    Total
                                                                                                                                           Violation Risk                                                                                                                                                        Entity         Entity
                                                                    Date                                                                                                                                                           Penalty                                            Mitigation   Mitigation                                                  Separate      Signed
              Registered               NERC Violation                                                                   Reliability            Factor*                                                    Violation    Violation                       Additional Factors                                     Certification Verification of   Discovery
    Region                   NOC-ID                     NCR_ID   Identified or       Description of the Violation                     Req.                                 Risk Assessment                                            or                                                Plan         Plan                                                     Settlement   Disposition
                Entity                     ID #                                                                         Standard                                                                          Start Date   End Date                     for the Basis of Penalty                                  of Mitigation  Mitigation        Method
                                                                   Received                                                                                                                                                        Sanction                                            Number      Completed                                                  Agreement       Letter
                                                                                                                                            *See Attachment C                                                                                                                                                     Plan           Plan
                                                                                                                                                                                                                                     ($)
                                                                                                                                                                                                                                                                                                               Completion Completion
1
    MRO      City of Grand   NOC-057   MRO200700012 NCR00974     10/19/2007 GRIS stated that, at the time of the        PRC-005-1      1         High           MRO determined that the violation did     6/18/2007 6/17/2009         $0      The violation was the first violation    MIT-07-     6/17/2009     7/1/2009       7/1/2009         Self-                        Yes
             Island, NE                                                     violation, it had started the development                                           not pose a serious or substantial risk                                        of this reliability standard incurred     0445                                                  Certification
                                                                            of a written Maintenance and Testing                                                to the bulk power system because                                              by GRIS and it did not constitute a
                                                                            Program but it was not completed.                                                   GRIS had a policy in place to verify                                          serious or substantial risk to the
                                                                                                                                                                Protection System operation following                                         bulk power system.
                                                                                                                                                                a fault for proper operation, speed,
                                                                                                                                                                accuracy and other factors. With
                                                                                                                                                                respect to the seven generators
                                                                                                                                                                owned by GRIS the largest is rated at
                                                                                                                                                                100 MW. One generator is rated at
                                                                                                                                                                54 MW and five others are rated at 34
                                                                                                                                                                MW or less.
2
    MRO      City of Grand   NOC-057   MRO200700013 NCR00974     10/19/2007 GRIS was not adequately conducting          PRC-005-1      2         High           MRO determined that the violation did     6/18/2007    7/1/2009       $0      The violation was the first violation    MIT-07-     7/1/2009      7/1/2009       7/1/2009         Self-                        Yes
             Island, NE                                                     maintenance and testing of its Protection                                           not pose a serious or substantial risk                                        of this reliability standard incurred     0445                                                  Certification
                                                                            System devices and there was not                                                    to the bulk power system because                                              by GRIS and it did not constitute a
                                                                            adequate evidence to demonstrate when                                               GRIS had a policy to verify Protection                                        serious or substantial risk to the
                                                                            each Protection System device was last                                              System operation following a fault for                                        bulk power system.
                                                                            tested or maintained.                                                               proper operation, speed, accuracy
                                                                                                                                                                and other factors, and due to the
                                                                                                                                                                small size of the GRIS system. MRO
                                                                                                                                                                determined that GRIS owns an
                                                                                                                                                                estimated total of 90 Protection
                                                                                                                                                                System devices that are subject to
                                                                                                                                                                compliance with Reliability Standard
                                                                                                                                                                PRC-005-1. Using the intervals in its
                                                                                                                                                                Protection System Maintenance and
                                                                                                                                                                Testing Program that was developed
                                                                                                                                                                in mitigation of R1, at the time of the
                                                                                                                                                                self-certification GRIS was behind
                                                                                                                                                                schedule for testing and maintenance
                                                                                                                                                                for 20 relays. As a percentage, GRIS
                                                                                                                                                                had not completed the required
                                                                                                                                                                maintenance and testing for 22% of
                                                                                                                                                                its Protection System devices.

3




                                                                                                                                                                                    MRO                                                                                                                                                                                     Page 13 of 80
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      A            B            C            D             E             F                                      G                                     H         I             J                                         K                                     L           M                N                                      O                                  P            Q               R                  S                T             U             V

                                                                                                                                                                                                                                                                                                                                                                                                                Regional
                                                                                                                                                                                                                                                                                                                                                                                            Registered
                                                                                                                                                                      Violation Risk                                                                                                                                                                                                                              Entity
                                                                      Date                                                                                                                                                                                                                                                                                                    Mitigation        Entity                                           Separate      Signed
              Registered               NERC Violation                                                                                            Reliability             Factor*                                                                          Violation    Violation    Total Penalty or                     Additional Factors                      Mitigation                                   Verification of   Discovery
    Region                    NOC-ID                    NCR_ID     Identified or                  Description of the Violation                                 Req.                                            Risk Assessment                                                                                                                                                  Plan       Certification of                                     Settlement   Disposition
                Entity                     ID #                                                                                                  Standard                                                                                                 Start Date   End Date       Sanction ($)                    for the Basis of Penalty                  Plan Number                                    Mitigation        Method
                                                                     Received                                                                                                                                                                                                                                                                                                 Completed    Mitigation Plan                                      Agreement       Letter
                                                                                                                                                                      *See Attachment C                                                                                                                                                                                                                            Plan
                                                                                                                                                                                                                                                                                                                                                                                            Completion
                                                                                                                                                                                                                                                                                                                                                                                                               Completion
1
     RFC       Baltimore      NOC-     RFC200700121     NCR00689    10/1/2007      BGE had a Facility Ratings Methodology and had                FAC-009-1      1        Medium           RFC determined that the violation did not constitute a          6/18/2007    9/26/2008           $0           The violation was the first violation of this           MIT-07-1846   9/26/2008       2/9/2009           8/4/2009          Self-                        Yes
               Gas and         369                                                 established Facility Ratings for its solely and jointly                                                serious or substantial risk to the bulk power system                                                          reliability standard incurred by BGE and it did not                                                                     Certification
                Electric                                                           owned Facilities that were consistent with its                                                         because BGE had a Facility Ratings Methodology and                                                            constitute a serious or substantial risk to the bulk
               Company                                                             associated Facility Ratings Methodology. It also had a                                                 could determine the ratings for these three lines. The                                                        power system.
                                                                                   database of ratings. BGE discovered it did not have                                                    three 230 kV lines included a total of 6,000 feet of
                                                                                   documented ratings for three 230 kV lines when its                                                     transmission lines between two substations. The lines
                                                                                   Transmission Operator requested them.                                                                  were only interconnected with the two substations. BGE
                                                                                                                                                                                          owns 1,236 miles of transmission lines and therefore the
                                                                                                                                                                                          lines with unaccounted for ratings represented less than
                                                                                                                                                                                          .00009% of its total transmission. In addition, because
                                                                                                                                                                                          the ratings of the three 230 kV lines were not the most
                                                                                                                                                                                          limiting aspect of BGE's facility, the impact of this alleged
                                                                                                                                                                                          violation is considered to be of minimal risk to the bulk
2                                                                                                                                                                                         power system.
     RFC        City of       NOC-     RFC200800059     NCR00718    4/8/2008       The City of Lansing was testing its relays once every         PRC-005-1      2         Lower           RFC determined that the violation did not constitute a          6/18/2007    4/22/2008         $6,500         The violation was the first violation of this           MIT-08-1105   4/22/2008      6/23/2008          4/21/2009          Audit           Yes          Yes
             Lansing by its    252                                                 five years. The City of Lansing was late in testing 108                                                serious or substantial risk to the bulk power system                                                          reliability standard incurred by the City of Lansing
               Board of                                                            of its 709 relays, or 15 percent of its total relays.                                                  because all relays were found to be in working order and                                                      and it did not constitute a serious or substantial
              Water and                                                            Testing was scheduled to be completed by the end of                                                    there were no Misoperations. Furthermore, the ratings                                                         risk to the bulk power system. In this case, RFC
                 Light                                                             March 2008 but was not actually completed until April                                                  had been tested within the defined interval for the                                                           determined that the assessed monetary penalty
                                                                                   22, 2008, 22 days late.                                                                                majority of the City of Lansing's protective relay devices                                                    was appropriate.
                                                                                                                                                                                          (85 percent) and all relays were found to be in working
3                                                                                                                                                                                         order.
     RFC        City of       NOC-     RFC200800089     NCR00721    4/4/2008       The City of Rochelle did not address connection               FAC-001-0      1        Medium           RFC determined that the violation did not constitute a          6/18/2007    7/9/2009         $7,500*         The violation was a documentation issue, it was         MIT-08-1854    7/9/2009      7/31/2009          8/25/2009       Self-Report                     Yes
               Rochelle        371                                                 requirements for Generation, Transmission, and End-                                                    serious or substantial risk to the bulk power system                                                          self-reported, it was the first violation of this
                                                                                   User facilities. Specifically, the City of Rochelle did not                                            because, although the City of Rochelle did not document                                                       reliability standard incurred by the City of Rochelle
                                                                                   document, maintain, and publish facility connection                                                    its own facility connection requirements, it would have                                      (*Denotes an     and it did not constitute a serious or substantial
                                                                                   requirements to ensure compliance with NERC                                                            relied on those of a neighboring Transmission Owner,                                          aggregated      risk to the bulk power system. In this case, RFC
                                                                                   Reliability Standards and applicable Regional Entity,                                                  with whom it was interconnected. The City of Rochelle                                     settlement amount   determined that the assessed monetary penalty
                                                                                   sub-regional, Power Pool and individual Transmission                                                   did not receive any requests for connection to its                                        of RFC200800089     was appropriate.
                                                                                   Owner planning criteria and facility connection                                                        facilities during the period in which it had no documented                               and RFC200800090
                                                                                   requirements.                                                                                          connection procedures. The City of Rochelle's facilities                                 and RFC200800091
                                                                                                                                                                                          include 6 miles of 138 kV transmission line with a                                       and RFC200800092
                                                                                                                                                                                          summer peak load of 52 MW. Due to the transmission                                               and
                                                                                                                                                                                          system configuration and Protection System design,                                         RFC200800093.)
                                                                                                                                                                                          there is no steady-state current flowing through its
4                                                                                                                                                                                         system, just into its system.
     RFC        City of       NOC-     RFC200800090     NCR00721    4/4/2008       The City of Rochelle did not document, maintain, and          FAC-001-0      2        Medium           RFC determined that the violation did not constitute a          6/18/2007    7/9/2009         $7,500*         The violation was a documentation issue, it was         MIT-08-1855    7/9/2009      7/31/2009          8/28/2009       Self-Report                     Yes
               Rochelle        371                                                 publish facility connection requirements that address                                                  serious or substantial risk to the bulk power system                                                          self-reported, it was the first violation of this
                                                                                   the following items: 1) Procedures for coordinated joint                                               because, although the City of Rochelle did not document                                                       reliability standard incurred by the City of Rochelle
                                                                                   studies of new facilities and their impacts on the                                                     its own facility connection requirements, it would have                                      (*Denotes an     and it did not constitute a serious or substantial
                                                                                   interconnected transmission systems; 2) Procedures                                                     relied on those of a neighboring Transmission Owner,                                          aggregated      risk to the bulk power system. In this case, RFC
                                                                                   for notification of new or modified facilities to others as                                            with whom it was interconnected. The City of Rochelle                                     settlement amount   determined that the assessed monetary penalty
                                                                                   soon as feasible; 3) Voltage level and MW and MVAR                                                     did not receive any requests for connection to its                                        of RFC200800089     was appropriate.
                                                                                   capacity or demand at point of connection; 4) Breaker                                                  facilities during the period in which it had no documented                               and RFC200800090
                                                                                   duty and surge protection; 5) System protection and                                                    connection procedures. The City of Rochelle's facilities                                 and RFC200800091
                                                                                   coordination; 6) Metering and telecommunications; 7)                                                   include 6 miles of 138 kV transmission line with a                                       and RFC200800092
                                                                                   Grounding and safety issues; 8) Insulation and                                                         summer peak load of 52 MW. Due to the transmission                                               and
                                                                                   insulation coordination; 9) Voltage, Reactive Power,                                                   system configuration and Protection System design,                                         RFC200800093.)
                                                                                   and power factor control; 10) Power quality impacts;                                                   there is no steady-state current flowing through its
                                                                                   11) Equipment Ratings; 12) Synchronizing of facilities;                                                system, just into its system.
                                                                                   13) Maintenance coordination; 14) Operational issues
                                                                                   (abnormal frequency and voltage); 15) Inspection
                                                                                   requirements for existing or new facilities; and 16)
                                                                                   Communications procedures during normal and
                                                                                   emergency operating conditions.
5
     RFC        City of       NOC-     RFC200800091     NCR00721    4/4/2008       The City of Rochelle did not document its current             FAC-008-1      1         Lower           RFC determined that the violation did not constitute a          6/18/2007    7/9/2009         $7,500*         The violation was a documentation issue, it was         MIT-08-1856    7/9/2009      7/31/2009          8/31/2009       Self-Report                     Yes
               Rochelle        371                                                 methodology used for developing Facility Ratings                                                       serious or substantial risk to the bulk power system                                                          self-reported, it was the first violation of this
                                                                                   (Facility Ratings Methodology) of its solely and jointly                                               because, although the City of Rochelle did not document                                                       reliability standard incurred by the City of Rochelle
                                                                                   owned Facilities.                                                                                      its current methodology used for developing Facility                                         (*Denotes an     and it did not constitute a serious or substantial
                                                                                                                                                                                          Ratings (Facility Ratings Methodology) of its solely and                                      aggregated      risk to the bulk power system. In this case, RFC
                                                                                                                                                                                          jointly owned facilities, it referred to its 138 kV                                       settlement amount   determined that the assessed monetary penalty
                                                                                                                                                                                          transmission and substation system one-line drawing for                                   of RFC200800089     was appropriate.
                                                                                                                                                                                          component and equipment ratings until a final document                                   and RFC200800090
                                                                                                                                                                                          could be developed and implemented to meet                                               and RFC200800091
                                                                                                                                                                                          Requirement 1 of FAC-008-1.                                                              and RFC200800092
                                                                                                                                                                                                                                                                                           and
                                                                                                                                                                                                                                                                                     RFC200800093.)

6
     RFC        City of       NOC-     RFC200800092     NCR00721    4/4/2008       The City of Rochelle did not document its current             FAC-009-1      1        Medium           RFC determined that the violation did not constitute a          6/18/2007    7/9/2009         $7,500*         The violation was a documentation issue, it was         MIT-08-1857    7/9/2009      7/31/2009           9/4/2009       Self-Report                     Yes
               Rochelle        371                                                 methodology used for developing Facility Ratings                                                       serious or substantial risk to the bulk power system                                                          self-reported, it was the first violation of this
                                                                                   (Facility Ratings Methodology) of its solely and jointly                                               because, although the City of Rochelle did not document                                                       reliability standard incurred by the City of Rochelle
                                                                                   owned Facilities.                                                                                      its current methodology used for developing Facility                                         (*Denotes an     and it did not constitute a serious or substantial
                                                                                                                                                                                          Ratings (Facility Ratings Methodology) of its solely and                                      aggregated      risk to the bulk power system. In this case, RFC
                                                                                                                                                                                          jointly owned facilities, it referred to its 138 kV                                       settlement amount   determined that the assessed monetary penalty
                                                                                                                                                                                          transmission and substation system one-line drawing for                                   of RFC200800089     was appropriate.
                                                                                                                                                                                          component and equipment ratings until a final document                                   and RFC200800090
                                                                                                                                                                                          could be developed and implemented to meet                                               and RFC200800091
                                                                                                                                                                                          Requirement 1 of FAC-009-1.                                                              and RFC200800092
                                                                                                                                                                                                                                                                                           and
                                                                                                                                                                                                                                                                                     RFC200800093.)

7




                                                                                                                                                                                                                                    RFC                                                                                                                                                                                                                               Page 14 of 80
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                                                                                                                                                                                                         PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                                                       CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                                                       HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.




       A           B          C            D             E             F                                    G                                   H         I             J                                       K                                     L           M                N                                       O                                 P            Q               R                  S               T            U             V

                                                                                                                                                                                                                                                                                                                                                                                                        Regional
                                                                                                                                                                                                                                                                                                                                                                                    Registered
                                                                                                                                                                Violation Risk                                                                                                                                                                                                                            Entity
                                                                    Date                                                                                                                                                                                                                                                                                              Mitigation        Entity                                         Separate      Signed
               Registered            NERC Violation                                                                                        Reliability             Factor*                                                                       Violation    Violation     Total Penalty or                      Additional Factors                     Mitigation                                   Verification of   Discovery
     Region                 NOC-ID                    NCR_ID     Identified or                 Description of the Violation                              Req.                                           Risk Assessment                                                                                                                                                 Plan       Certification of                                   Settlement   Disposition
                 Entity                  ID #                                                                                              Standard                                                                                              Start Date   End Date        Sanction ($)                     for the Basis of Penalty                 Plan Number                                    Mitigation        Method
                                                                   Received                                                                                                                                                                                                                                                                                           Completed    Mitigation Plan                                    Agreement       Letter
                                                                                                                                                                *See Attachment C                                                                                                                                                                                                                          Plan
                                                                                                                                                                                                                                                                                                                                                                                    Completion
                                                                                                                                                                                                                                                                                                                                                                                                       Completion
1
      RFC        City of    NOC-     RFC200800093     NCR00721    4/4/2008       While the City of Rochelle was performing                 PRC-005-1      1          High           RFC determined that the violation did not constitute a       6/18/2007     7/9/2009         $7,500*         The violation was a documentation issue, it was         MIT-08-1858    7/9/2009      7/31/2009           9/3/2009       Self-Report                   Yes
                Rochelle     371                                                 maintenance and testing of its Protection Systems                                                  serious or substantial risk to the bulk power system                                                        self-reported, it was the first violation of this
                                                                                 according to an interconnected utility's Maintenance                                               because the City of Rochelle was performing                                                                 reliability standard incurred by the City of Rochelle
                                                                                 and Testing Program, it had not memorialized the                                                   maintenance and testing of its Protection Systems                                          (*Denotes an     and it did not constitute a serious or substantial
                                                                                 interconnected utility's program in its own written                                                according to an interconnected utility's Maintenance and                                    aggregated      risk to the bulk power system. In this case, RFC
                                                                                 materials.                                                                                         Testing Program.                                                                        settlement amount   determined that the assessed monetary penalty
                                                                                                                                                                                                                                                                            of RFC200800089     was appropriate.
                                                                                                                                                                                                                                                                           and RFC200800090
                                                                                                                                                                                                                                                                           and RFC200800091
                                                                                                                                                                                                                                                                           and RFC200800092
                                                                                                                                                                                                                                                                                   and
                                                                                                                                                                                                                                                                             RFC200800093.)

8
      RFC     Cloverland    NOC-     RFC200700008     NCR00724    9/28/2007      Cloverland did not have a procedure for the recognition   CIP-001-1      1        Medium           RFC determined that the violation did not constitute a       6/18/2007    12/17/2007           $0           The violation was self-reported, it was the first       MIT-07-0217   12/17/2007     12/17/2007        11/11/2008       Self-Report                   Yes
               Electric      075                                                 of sabotage events, including events that stem from                                                serious or substantial risk to the bulk power system                                                        violation of this reliability standard incurred by
              Cooperative                                                        sabotage, tampering, and vandalism. In its self-report,                                            because while Cloverland did not have a written                                                             Cloverland and it did not constitute a serious or
                                                                                 Cloverland stated that "Sabotage reporting is not                                                  sabotage plan, it had an Emergency Plan, and the                                                            substantial risk to the bulk power system.
                                                                                 included in our plan at this time, but we are in the                                               employees were required under that plan to notify
                                                                                 process of resolving this issue."                                                                  governmental authorities of a catastrophic event. No
                                                                                                                                                                                    sabotage events occurred at Cloverland during the
9                                                                                                                                                                                   period of noncompliance.
      RFC     Cloverland    NOC-     RFC200700010     NCR00724    9/28/2007      Cloverland did not have a procedure for                   CIP-001-1      2        Medium           RFC determined that the violation did not constitute a       6/18/2007    12/17/2007           $0           The violation was self-reported, it was the first       MIT-07-0218   12/17/2007     12/17/2007        11/11/2008       Self-Report                   Yes
               Electric      075                                                 communicating information to appropriate parties in the                                            serious or substantial risk to the bulk power system                                                        violation of this reliability standard incurred by
              Cooperative                                                        Interconnection concerning sabotage events.                                                        because while Cloverland did not have a written plan for                                                    Cloverland and it did not constitute a serious or
                                                                                 However, the Rural Utilities service to which                                                      sabotage notification, it had an Emergency Plan and the                                                     substantial risk to the bulk power system.
                                                                                 Cloverland belongs required its borrowers to maintain                                              employees were required, under that plan, to notify the
                                                                                 and demonstrate an Emergency Response Plan.                                                        appropriate parties of a catastrophic event. No sabotage
                                                                                 Therefore, while Cloverland did not have a sabotage                                                events occurred at Cloverland during the period of
                                                                                 reporting plan as required by Standard CIP-001-1                                                   noncompliance.
                                                                                 Requirement 2, Cloverland did have an Emergency
10                                                                               Response Plan.
      RFC     Cloverland    NOC-     RFC200700011     NCR00724    9/28/2007      Cloverland did not provide its operating personnel with   CIP-001-1      3        Medium           RFC determined that the violation did not constitute a       6/18/2007    12/17/2007           $0           The violation was self-reported, it was the first       MIT-07-0219   12/17/2007     12/17/2007        11/11/2008       Self-Report                   Yes
               Electric      075                                                 sabotage response guidelines, including who to                                                     serious or substantial risk to the bulk power system                                                        violation of this reliability standard incurred by
              Cooperative                                                        contact in the event of a need to report disturbances                                              because while Cloverland did not have a written                                                             Cloverland and it did not constitute a serious or
                                                                                 due to sabotage events.                                                                            sabotage plan, it had an Emergency Plan and the                                                             substantial risk to the bulk power system.
                                                                                                                                                                                    employees were were required to know who they needed
                                                                                                                                                                                    to notify of a catostrophic event. No sabotage events
                                                                                                                                                                                    occurred at Cloverland during the period of
11                                                                                                                                                                                  noncompliance.
      RFC     Cloverland    NOC-     RFC200700012     NCR00724    9/28/2007      Cloverland did not establish communication contacts       CIP-001-1      4        Medium           RFC determined that the violation did not constitute a       6/18/2007    12/17/2007           $0           The violation was self-reported, it was the first       MIT-07-0220   12/17/2007     12/17/2007        11/11/2008       Self-Report                   Yes
               Electric      075                                                 with the local FBI officials or develop reporting                                                  serious or substantial risk to the bulk power system                                                        violation of this reliability standard incurred by
              Cooperative                                                        procedures as appropriate for circumstances regarding                                              because while Cloverland did not have a written                                                             Cloverland and it did not constitute a serious or
                                                                                 Sabotage Reporting.                                                                                sabotage plan, it had an Emergency Plan and, under that                                                     substantial risk to the bulk power system.
                                                                                                                                                                                    plan, the employees were required to notify local
                                                                                                                                                                                    governmental authorities of a catastropic event. No
                                                                                                                                                                                    sabotage events occurred at Cloverland during the
12                                                                                                                                                                                  period of noncompliance.
      RFC     Commonwealt   NOC-     RFC200700013     NCR08013    12/4/2007      ComEd's Relay Maintenance Program is a formally             PRC-005-1   2.1         High           RFC determined that the violation did not constitute a       6/18/2007    12/10/2008           $0           The violation was self-reported, it was the first       MIT-07-0385   12/10/2008     12/10/2008         2/23/2009       Self-Report                   Yes
                h Edison     073                                                 documented Performance Centered Maintenance                                                        serious or substantial risk to the bulk power system                                                        violation of this reliability standard incurred by
                Company                                                          process. A key component of the program involves the                                               because outage contingency studies, simulating a                                                            ComEd and it did not constitute a serious or
                                                                                 selection of preventive maintenance activities                                                     Misoperation of the affected equipment and adjacent                                                         substantial risk to the bulk power system.
                                                                                 designed to minimize consequential failures. The                                                   equipment, had been performed to verify that abnormal
                                                                                 program provides for the scheduling of relay                                                       load flows and voltage conditions would not exist under
                                                                                 maintenance tasks in accordance with set intervals                                                 the present system summer base case. The studies did
                                                                                 defined within maintenance templates. While planning                                               not reveal any system problems for a peak load summer
                                                                                 future work associated with protective relay                                                       day. A review of historical relay maintenance test data
                                                                                 maintenance tasks, a Work Planner discovered an                                                    did not reveal any past problems or issues to be
                                                                                 error within the maintenance scheduling tool where                                                 concerned about. All calibration information,
                                                                                 some of the automatic relay maintenance work order                                                 instrumentation input checks and functional checks were
                                                                                 triggers were incorrectly set to “inactive” within the                                             previously found normal.
                                                                                 system. As a result, automatic notifications to schedule
                                                                                 work for these items were not generated. The system
                                                                                 was immediately reviewed to determine the extent of
                                                                                 the issue. An initial investigation of 14,587 system
                                                                                 maintenance tasks was conducted and it was
                                                                                 determined that a total of eleven work orders related to
                                                                                 transmission relays were not generated to assure
                                                                                 maintenance program intervals were met. All of the
13
                                                                                 transmission maintenance tasks at issue had either a
      RFC      Delmarva     NOC-     RFC200800061     NCR00752    5/21/2008      four (2) out of five hundred eighty-eight interval. A
                                                                                 Two year test interval or a nine year test (588) relays     PRC-005-1   2.1         High           RFC determined that the violation did not constitute a       7/2/2007     5/30/2008            $0           The violation was self-reported, it was the first       MIT-08-0597   5/30/2008      5/30/2008          4/15/2009       Self-Report      Yes          Yes
               Power &       259                                                 were found to be tested past their scheduled test                                                  serious or substantial risk to the bulk power system                                                        violation of this reliability standard incurred by
                 Light                                                           dates. Specifically, the last trip test date for a specific                                        because the majority of the relays had been tested within                                                   Delmarva and it did not constitute a serious or
               Company                                                           line terminal was incorrectly entered into the tracking                                            the defined intervals, and only 2 of 588 were not. All                                                      substantial risk to the bulk power system.
                                                                                 spreadsheet (listed as 12/07/03 rather than 02/07/03)                                              relays were found to be in working order. The relays in
                                                                                 which resulted in the trip testing of the front line and                                           question were microprocessor-based relays and as such
                                                                                 backup relays not being completed in the defined                                                   were self monitoring with remote alarming. For July and
                                                                                 interval. The terminal was trip tested on 9/12/07, well                                            August 2007, MW flows on the lines associated with the
                                                                                 within the defined interval based on the incorrect date                                            relays in question were at approximately 20% of the
                                                                                 of 12/07/03. However, based on the correct date                                                    normal line rating of 650 MVA summer normal and 805
                                                                                 (2/07/03), the interval was missed and corrected by a                                              MVA summer emergency. The missed relay tests
                                                                                 little more than two months.                                                                       represented only 0.34% of applicable protection devices
                                                                                                                                                                                    and the test interval was only missed by a little over two
14                                                                                                                                                                                  months.




                                                                                                                                                                                                                            RFC                                                                                                                                                                                                                             Page 15 of 80
                                                                                                                                                                                                                 10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                                                            PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                                                          CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                                                          HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.




       A           B          C            D             E             F                                     G                                    H         I             J                                          K                                    L            M                N                                     O                                  P            Q               R                  S                T             U             V

                                                                                                                                                                                                                                                                                                                                                                                                            Regional
                                                                                                                                                                                                                                                                                                                                                                                        Registered
                                                                                                                                                                  Violation Risk                                                                                                                                                                                                                              Entity
                                                                    Date                                                                                                                                                                                                                                                                                                  Mitigation        Entity                                           Separate      Signed
              Registered             NERC Violation                                                                                          Reliability             Factor*                                                                          Violation    Violation     Total Penalty or                    Additional Factors                      Mitigation                                   Verification of   Discovery
     Region                 NOC-ID                    NCR_ID     Identified or                  Description of the Violation                               Req.                                             Risk Assessment                                                                                                                                                 Plan       Certification of                                     Settlement   Disposition
                Entity                   ID #                                                                                                Standard                                                                                                 Start Date   End Date        Sanction ($)                   for the Basis of Penalty                  Plan Number                                    Mitigation        Method
                                                                   Received                                                                                                                                                                                                                                                                                               Completed    Mitigation Plan                                      Agreement       Letter
                                                                                                                                                                  *See Attachment C                                                                                                                                                                                                                            Plan
                                                                                                                                                                                                                                                                                                                                                                                        Completion
                                                                                                                                                                                                                                                                                                                                                                                                           Completion
1
      RFC     DTE East      NOC-     RFC200800057     NCR08048    4/4/2008       DTE East China had a Facility Rating Methodology, but FAC-008-1            1         Lower           RFC determined that the violation did not constitute a          6/18/2007    7/23/2008         $5,000*        The violation was the first violation of this           MIT-08-0604   7/23/2008      7/23/2008           6/4/2009          Audit                        Yes
              China, LLC     370                                                 did not include the statement “Facility Rating shall                                                 serious or substantial risk to the bulk power system                                                          reliability standard incurred by DTE East China
                                                                                 equal the most limiting applicable Equipment Rating of                                               because DTE East China had a Facility Rating                                                                  and it did not constitute a serious or substantial
                                                                                 the individual equipment that comprises that Facility.”                                              Methodology, even though it did not have all of the                                          (*Denotes an     risk to the bulk power system. In this case, RFC
                                                                                 DTE East China did include a statement for a particular                                              required elements. This violation was documentary in                                          aggregated      determined that the assessed monetary penalty
                                                                                 piece of individual equipment stating it was the most                                                nature and none of the relay protection devices that were                                 settlement amount   was appropriate.
                                                                                 limiting and therefore was the rating of the facility.                                               missing ratings were considered to be the most limiting                                   of RFC200800057
                                                                                 Further, DTE East China did not address all elements                                                 factor.                                                                                          and
                                                                                 in the scope of its Facility Rating Methodology and did                                                                                                                                         RFC200800058.)
                                                                                 not address Normal and Emergency Ratings.
15
      RFC     DTE East      NOC-     RFC200800058     NCR08048    4/4/2008       DTE East China had a Facility Ratings Methodology,          FAC-009-1      1        Medium           RFC determined that the violation did not constitute a          6/18/2007    8/29/2008         $5,000*        The violation was the first violation of this           MIT-08-0604   8/29/2008      8/29/2008           6/4/2009          Audit                        Yes
              China, LLC     370                                                 but did not include ratings for relay protection devices.                                            serious or substantial risk to the bulk power system                                                          reliability standard incurred by DTE East China
                                                                                                                                                                                      because the relay devices that did not have facility                                                          and it did not constitute a serious or substantial
                                                                                                                                                                                      ratings were not the most limiting factor.                                                   (*Denotes an     risk to the bulk power system. In this case, RFC
                                                                                                                                                                                                                                                                                    aggregated      determined that the assessed monetary penalty
                                                                                                                                                                                                                                                                                settlement amount   was appropriate.
                                                                                                                                                                                                                                                                                of RFC200800057
                                                                                                                                                                                                                                                                                       and
                                                                                                                                                                                                                                                                                 RFC200800058.)
16
      RFC       Illinois    NOC-     RFC200700038     NCR00795   12/18/2007 IMEA did not have a procedure for the recognition of             CIP-001-1      1        Medium           RFC determined that the violation did not constitute a          6/18/2007    12/14/2007           $0          The violation was the first violation of this           MIT-07-0222   12/14/2007     12/20/2007         8/25/2008          Self-                        Yes
               Municipal     076                                            sabotage events, including events that stem from                                                          serious or substantial risk to the bulk power system                                                          reliability standard incurred by IMEA and it did not                                                                    Certification
                Electric                                                    sabotage, tampering, and vandalism.                                                                       because of the nature and location of IMEA's facilities.                                                      constitute a serious or substantial risk to the bulk
                Agency                                                                                                                                                                No sabotage events occurred at IMEA during the period                                                         power system.
17                                                                                                                                                                                    of noncompliance.
      RFC       Illinois    NOC-     RFC200700039     NCR00795   12/18/2007 IMEA did not have a procedure for communicating                  CIP-001-1      2        Medium           RFC determined that the violation did not constitute a          6/18/2007    12/14/2007           $0          The violation was the first violation of this           MIT-07-0222   12/14/2007     12/20/2007         8/25/2008          Self-                        Yes
               Municipal     076                                            information to appropriate parties in the                                                                 serious or substantial risk to the bulk power system                                                          reliability standard incurred by IMEA and it did not                                                                    Certification
                Electric                                                    Interconnection concerning sabotage events.                                                               because of the nature and location of IMEA's facilities.No                                                    constitute a serious or substantial risk to the bulk
                Agency                                                                                                                                                                sabotage events occurred at IMEA during the period of                                                         power system.
18                                                                                                                                                                                    noncompliance.
      RFC       Illinois    NOC-     RFC200700040     NCR00795   12/18/2007 IMEA did not provide its operating personnel with                CIP-001-1      3        Medium           RFC determined that the violation did not constitute a          6/18/2007    12/14/2007           $0          The violation was the first violation of this           MIT-07-0222   12/14/2007     12/20/2007         8/25/2008          Self-                        Yes
               Municipal     076                                            sabotage response guidelines, including who to                                                            serious or substantial risk to the bulk power system                                                          reliability standard incurred by IMEA and it did not                                                                    Certification
                Electric                                                    contact in the event of a need to report disturbances                                                     because of the nature and location of IMEA's facilities.                                                      constitute a serious or substantial risk to the bulk
                Agency                                                      due to sabotage events.                                                                                   No sabotage events occurred at IMEA during the period                                                         power system.
19                                                                                                                                                                                    of noncompliance.
      RFC       Illinois    NOC-     RFC200700041     NCR00795   12/18/2007 IMEA did not establish communication contacts with               CIP-001-1      4        Medium           RFC determined that the violation did not constitute a          6/18/2007    12/14/2007           $0          The violation was the first violation of this           MIT-07-0222   12/14/2007     12/20/2007         8/25/2008          Self-                        Yes
               Municipal     076                                            the local FBI officials or develop reporting procedures                                                   serious or substantial risk to the bulk power system                                                          reliability standard incurred by IMEA and it did not                                                                    Certification
                Electric                                                    as appropriate to its circumstances regarding                                                             because of the nature and location of IMEA's facilities.                                                      constitute a serious or substantial risk to the bulk
                Agency                                                      Sabotage Reporting.                                                                                       No sabotage events occurred at IMEA during the period                                                         power system.
20                                                                                                                                                                                    of noncompliance.
      RFC        LSP-       NOC-     RFC200800062     NCR00817    6/4/2008       LSP WW submitted a Facility Ratings Methodology         FAC-009-1          1        Medium           RFC determined that the violation did not constitute a          6/18/2007    1/16/2009         $6,000*        The violation was the first violation of this           MIT-08-1242   1/16/2009       4/2/2009           6/4/2009          Audit           Yes          Yes
              Whitewater,    256                                                 stating that the scope of equipment addressed shall                                                  serious or substantial risk to the bulk power system                                                          reliability standard incurred by LSP WW and it did
                  LP                                                             "include, but will not be limited to, generators,                                                    because LSP WW had determined the most limiting                                                               not constitute a serious or substantial risk to the
                                                                                 transmission conductors, transformers, relay protective                                              component and had established its facility rating based                                      *Denotes an      bulk power system. In this case, RFC determined
                                                                                 devices, terminal equipment, and series and shunt                                                    on that component. None of the devices for which                                              aggregated      that the assessed monetary penalty was
                                                                                 compensation devices." Although relay protective                                                     ratings were missing were considered to be the most                                       settlement amount   appropriate.
                                                                                 devices were listed as Facilities in the Methodology                                                 limiting factor in this particular facility.                                              of RFC200800062
                                                                                 document, LSP WW did not establish ratings for relay                                                                                                                                           and RFC200800063
                                                                                 protective devices. LSP WW provided photographs of
                                                                                 device nameplates, contending that the device
                                                                                 nameplates evidenced the ratings. The nameplate
                                                                                 photographs did not, however, sufficiently define the
                                                                                 ratings. While ratings are typically included on the
                                                                                 nameplate information, the violation results from the
                                                                                 fact that LSP WW's relays are adjustable; therefore the
                                                                                 rating varies and a single nameplate rating is
21
                                                                                 insufficient.
      RFC        LSP-       NOC-     RFC200800063     NCR00817    6/4/2008       LSP WW’s schedule of maintenance and testing          PRC-005-1            1          High           RFC determined that the violation did not constitute a          6/18/2007    1/16/2009         $6,000*        The violation was the first violation of this           MIT-08-1242   1/16/2009       4/2/2009           6/4/2009          Audit           Yes          Yes
              Whitewater,    256                                                 intervals for Protection Systems was contained in a                                                  serious or substantial risk to the bulk power system                                                          reliability standard incurred by LSP WW and it did
                  LP                                                             document entitled "Transmission and Generation                                                       because LSP WW's submitted documentation showed                                                               not constitute a serious or substantial risk to the
                                                                                 Protection System Maintenance and Testing."                                                          that all relays had been tested within the past three years                                  (*Denotes an     bulk power system. In this case, RFC determined
                                                                                 Although this procedure provided the basis for the                                                   and all relays were found to be in working order.                                             aggregated      that the assessed monetary penalty was
                                                                                 testing intervals and maintenance testing procedures,                                                                                                                                          settlement amount   appropriate.
                                                                                 the information provided did not include specific                                                                                                                                              of RFC200800062
                                                                                 maintenance and testing intervals. Rather, the                                                                                                                                                        and
                                                                                 document provided that "Testing will be performed per                                                                                                                                           RFC200800063.)
                                                                                 manufacturer's recommendation and/or industry
22                                                                               standard practices during planned major outages."
      RFC       Mirant      NOC-     RFC200700006     NCR00830    08/31/07       With respect to Mirant Potomac, a total of 23 out of  PRC-005-1           2.1         High           RFC determined that the violation did not constitute a          6/18/2007    5/30/2008         $5,000         The violation was the first violation of this           MIT-07-0215   5/30/2008      2/19/2008         12/20/2008          Self-                        Yes
              Potomac        150                                                 132 relays, or 17% of the relays were not maintained                                                 serious or substantial risk to the bulk power system                                                          reliability standard incurred by Mirant Potomac                                                                         Certification
              River, LLC                                                         and tested within the defined intervals of its                                                       because, when CTs and PTs were tested, all performed                                                          and it did not constitute a serious or substantial
                                                                                 Maintenance and Testing Program. In addition, 16 out                                                 as intended and Mirant Potomac had no Misoperations                                                           risk to the bulk power system. Additionally, Mirant
                                                                                 of 20 Potential Transformers (PTs) and 136 out of 205                                                to report for the duration of the violation. In addition, the                                                 Potomac incorrectly certified that it had completed
                                                                                 Current Transformers (CTs) did not have calibration                                                  violation was limited to one facility and all relays had                                                      it's Mitigation Plan on February 19, 2008, which
                                                                                 completed within the past 4 years as required by the                                                 been calibrated and functionally tested since 2002 (or                                                        resulted in an assessed penalty. RFC verified
                                                                                 Protective System Program. Battery testing had not                                                   later).                                                                                                       that the Mitigation Plan was completed on May
                                                                                 been done as required by Mirant Potomac's Preventive                                                                                                                                                               30, 2008. In this case, RFC determined that the
                                                                                 Maintenance (PM) Program.                                                                                                                                                                                          assessed monetary penalty was appropriate.
23
      RFC     The City of   NOC-     RFC200700004     NCR08073    08/31/07       The City of Hamilton was performing maintenance and         PRC-005-1      2         Lower           RFC determined that the violation did not constitute a          6/18/2007    12/28/2007           $0          The violation was the first violation of this           MIT-07-1122   12/28/2007     11/3/2008         11/26/2008          Self-                        Yes
               Hamilton,     149                                                 testing of its Protection Systems and had a                                                          serious or substantial risk to the bulk power system                                                          reliability standard incurred by the City of Hamilton                                                                   Certification
                 Ohio                                                            documented Maintenance and Testing Program.                                                          because the City of Hamilton was performing                                                                   and it did not constitute a serious or substantial
                                                                                 However, it was not maintaining its records related to                                               maintenance and testing.                                                                                      risk to the bulk power system.
24                                                                               the program.




                                                                                                                                                                                                                                RFC                                                                                                                                                                                                                               Page 16 of 80
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      A           B           C            D             E             F                                     G                                    H         I             J                                        K                                            L                M                   N                                        O                                P            Q               R                S               T            U             V
                                                                                                                                                                                                                                                                                                                                                                                                                        Regional
                                                                                                                                                                                                                                                                                                                                                                                                      Registered
                                                                                                                                                                  Violation Risk                                                                                                                                                                                                                                          Entity
                                                                    Date                                                                                                                                                                                                                                                                                                                Mitigation        Entity                                       Separate      Signed
             Registered              NERC Violation                                                                                          Reliability              Factor*                                                                                                Violation   Total Penalty or Sanction                                                         Mitigation                                 Verification of   Discovery
    Region                  NOC-ID                     NCR_ID    Identified or                 Description of the Violation                                Req.                                           Risk Assessment                           Violation Start Date                                                 Additional Factors for the Basis of Penalty                      Plan       Certification of                                 Settlement   Disposition
               Entity                    ID #                                                                                                Standard                                                                                                                        End Date               ($)                                                                   Plan Number                                  Mitigation        Method
                                                                   Received                                                                                                                                                                                                                                                                                                             Completed    Mitigation Plan                                  Agreement       Letter
                                                                                                                                                                  *See Attachment C                                                                                                                                                                                                                                        Plan
                                                                                                                                                                                                                                                                                                                                                                                                      Completion
1                                                                                                                                                                                                                                                                                                                                                                                                                      Completion
    SERC      Associated    NOC-     SERC200800149    NCR01177    6/27/2008      On 6/27/08, AECI submitted a detailed Self-Report           BAL-005-0     8.1       Medium           SERC determined that the violation did not pose a                The redundant         4/14/2008            $6,000             The violation was self-reported, it was the first    MIT-08-1129   4/14/2008      10/28/2008       11/4/2008       Self-Report                   Yes
               Electric      087                                                 identifying a possible violation of BAL-005 R8.1. From                                               serious or significant risk to the bulk power system       equipment was removed                                               violation of this reliability standard incurred by
             Cooperative,                                                        the date of mandatory standards (6/18/07) AECI had a                                                 because AECI’s frequency bias setting was 44.5 MW per from service on 11/19/07.                                                AECI and it did not constitute a serious or
                 Inc.                                                            functional automatic backup for the frequency device.                                                0.1Hz during the period of time when the device failed                                                                         substantial risk to the bulk power system. In this
                                                                                 On 11/19/07, AECI removed the secondary device                                                       and operation on flat tie-line control ensued. AECI’s      BAL-005-0 R8.1 requires                                             case, SERC determined that the assessed
                                                                                 from service and operated without automatic                                                          peak online generation on April 11-12, 2008 was 1,906         99.95% availability.                                             monetary penalty was appropriate.
                                                                                 secondary back-up until 4/14/08. Therefore, the device                                               MW and the average frequency deviation during the            Outages of up to 4.38
                                                                                 was not available for automatic activation from                                                      period of flat tie-line control was 0.003 Hz. Given AECI’s  hours is allowed within
                                                                                 11/19/07 until 4/14/08. Furthermore, during the time                                                 low frequency bias setting, a significant frequency          that requirement. The
                                                                                 the secondary device was removed from service, the                                                   deviation on the Eastern Interconnection would not have     ability to calculate ACE
                                                                                 primary frequency metering failed and as a result                                                    resulted in a significant adjustment by AECI’s units on            was lost for
                                                                                 frequency monitoring capability was not available for a                                              Automatic Generation Control (AGC) and the units’           approximately 20 hours
                                                                                 period of 20 hours on 4/11/08 to 4/12/08. System                                                     failure to respond would not have had a significant           and 5 minutes. That
                                                                                 operators were operating on flat tie-line control to                                                 impact to system frequency recovery. Additionally, AECI      exceeds the standard
                                                                                 determine Area Control Error during this time and had                                                system operators had alerted AECI’s Reliability            requirement by 15 hours
                                                                                 appropriately notified the Reliability Coordinator of the                                            Coordinator of AECI’s operation on flat tie-line control.       and 42 minutes.
                                                                                 situation. The minimum availability requirement of                                                   Had a significant frequency disturbance occurred, AECI          Additionally, the
                                                                                 99.95% equates to 4.38 hours of outage per year.                                                     system operators, working with its RC, could have            secondary device was
                                                                                 Thus, the availability of the installation was less than                                             manually entered an offset into AGC to account for the          not available for
                                                                                 the minimum availability of 99.95% required by the                                                   disturbance.                                               automatic activation from
                                                                                 standard (20 hours is greater than 4.38 hours).                                                                                                                 November 19, 2007 until
                                                                                                                                                                                                                                                        April 14, 2008.


2
    SERC     Duke Energy     N/A     SERC200800110    NCR01219    4/15/2008      Duke Energy Carolinas, as a Transmission Operator,          FAC-008-1      1        Medium           SERC determined that the violation did not pose a                  6/18/2007           4/30/2008           $8,000*             The violation was self-reported, it was a            MIT-07-0595   4/30/2008      5/21/2008        11/17/2008      Self-Report                   Yes
              Carolinas                                                          failed to specify that the methodology used to                                                       serious or significant risk to the bulk power system                                                                           documentation issue, it was the first violation of
                                                                                 determine normal ratings was the same as that used to                                                because, although not documented, the emergency                                                    (*Denotes an aggregated     this reliability standard incurred by Duke Energy
                                                                                 determine emergency ratings for its affiliate                                                        ratings were the same as the previously communicated                                                 settlement amount of      Carolinas and it did not constitute a serious or
                                                                                 transmission facilities.                                                                             normal ratings and the scope of the facilities impacted                                              SERC200800107 and         substantial risk to the bulk power system. In this
                                                                                                                                                                                      represented less than 2% of the entity's system.                                                      SERC200800110.)          case, SERC determined that the assessed
                                                                                                                                                                                                                                                                                                                     monetary penalty was appropriate.




3
    SERC     Duke Energy     N/A     SERC200800107    NCR01219    4/15/2008      Duke Energy Carolinas' Facility Ratings Methodology         FAC-009-1      1        Medium           SERC determined that the violation did not pose a                  6/18/2007           5/9/2008            $8,000*         The violation was self-reported, it was the first        MIT-07-0595    5/9/2008      5/21/2008        11/17/2008      Self-Report                   Yes
              Carolinas                                                          was not correctly applied because it did not consider                                                serious or significant risk to the bulk power system                                                                       violation of this reliability standard incurred by
                                                                                 the most limiting element, resulting in ratings that                                                 because the error affected only 11 out of over 600                                                 (*Denotes an aggregated Duke Energy Carolinas and it did not constitute a
                                                                                 exceeded ratings that otherwise would have been                                                      facilities (representing less than 2% of Duke Energy                                                 settlement amount of  serious or substantial risk to the bulk power
                                                                                 calculated for 11 transmission facilities.                                                           Carolinas' system) and subsequent to the re-rating, no                                               SERC200800107 and     system. In this case, SERC determined that the
                                                                                                                                                                                      facilities required upgrading to handle projected flows.                                              SERC200800110.)      assessed monetary penalty was appropriate.
4




                                                                                                                                                                                                                                    SERC                                                                                                                                                                                                                                 Page 17 of 80
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       A           B           C            D             E             F                                       G                                   H         I             J                                        K                                      L             M               N                                      O                               P            Q               R                  S                T             U             V
                                                                                                                                                                                                                                                                                                                                                                                                            Regional
                                                                                                                                                                                                                                                                                                                                                                                        Registered
                                                                                                                                                                     Violation                                                                                                                                                                                                                                Entity
                                                                     Date                                                                                                                                                                                                                                                                                                 Mitigation        Entity                                           Separate      Signed
              Registered              NERC Violation                                                                                           Reliability          Risk Factor*                                                                     Violation Start   Violation   Total Penalty or                                                          Mitigation                                   Verification of   Discovery
     Region                  NOC-ID                     NCR_ID    Identified or                   Description of the Violation                               Req.                                           Risk Assessment                                                                               Additional Factors for the Basis of Penalty                       Plan       Certification of                                     Settlement   Disposition
                Entity                    ID #                                                                                                 Standard                                                                                                   Date         End Date      Sanction ($)                                                           Plan Number                                    Mitigation        Method
                                                                    Received                                                                                                                                                                                                                                                                                              Completed    Mitigation Plan                                      Agreement       Letter
                                                                                                                                                                    *See Attachment C                                                                                                                                                                                                                          Plan
                                                                                                                                                                                                                                                                                                                                                                                        Completion
1                                                                                                                                                                                                                                                                                                                                                                                                          Completion
      SPP     Southwestern   NOC-     SPP200700007     NCR01145   12/21/2007 SPS submitted a self report on December 21, 2007 in               PRC-008-0      2        Medium           SPP RE determined that the violation did not create a         12/31/2007       3/6/2008           $0          The violation was self-reported, it was the first     MIT-07-0224   3/6/2008        3/6/2008          6/15/2008       Self-Report                     Yes
                 Public       051                                            which it stated it would be unable to complete its UFLS                                                    serious or substantial risk to the bulk power system                                                          violation of this reliability standard incurred by
               Service Co.                                                   relay testing in 2007. SPS' Maintenance and Testing                                                        because, based on the two [2] UFLS surveys performed                                                          SPS and it did not constitute a serious or
                                                                             Program identified 15 specific UFLS relays for                                                             by the SPP RE, SPS had more than the minimum                                                                  substantial risk to the bulk power system.
                                                                             maintenance and testing in 2007. Due to a customer's                                                       required UFLS relay installations [Summer survey results-
                                                                             request to delay a plant outage, one (1) relay could not                                                    33% installed versus 30% standard] and could
                                                                             be tested by the end of 2007. SPS proposed to test the                                                     adequately respond to a system underfrequency event.
                                                                             UFLS relay in the first quarter of 2008 when a plant                                                       Therefore, in SPP RE's judgment there were ample
                                                                             outage could be performed without harming the                                                              UFLS relays in service to meet the load shed
                                                                             customer.                                                                                                  requirements of SPS and sufficient load shed would
                                                                                                                                                                                        have occurred had there been a system underfrequency
                                                                                                                                                                                        event.

2
      SPP      USACE -       NOC-     SPP200700008     NCR01357    1/18/2008      USACE-KC did not have a documented Facility                  FAC-008-1      1        Medium           SPP RE determined that the violation did not create a          7/10/2007       3/3/2008           $0          The violation was the first violation of this         MIT-07-0466   3/3/2008        3/7/2008         10/10/2008          Self-                        Yes
              Kansas City     141                                                 Ratings Methodology. Therefore, it did not address the                                                serious or substantial risk to the bulk power system                                                          reliability standard incurred by USACE-KC and it                                                                      Certification
                District                                                          most limiting applicable Equipment rating. However,                                                   because although USACE-KC did not have a                                                                      did not constitute a serious or substantial risk to
                                                                                  USACE-KC was using the original equipment ratings                                                     documented Facilities Rating Methodology, USACE-KC                                                            the bulk power system. FERC has determined to
                                                                                  and capacity and was providing the equipment ratings                                                  was establishing ratings for its facilities based upon the                                                    separately address jurisdictional issues with
                                                                                  to its Transmission Operator.                                                                         original equipment ratings and these facility ratings were                                                    respect to the USACE and other Federal Entities
                                                                                                                                                                                        communicated to its Transmission Operator and                                                                 in Docket No. NP09-26.
                                                                                                                                                                                        Southwest Power Pool.

3
      SPP      USACE -       NOC-     SPP200700009     NCR01357    1/18/2008      USACE-KC did not have a documented Facility                  FAC-008-1      2         Lower           SPP RE determined that the violation did not create a          7/10/2007       3/3/2008           $0          The violation was the first violation of this         MIT-07-0466   3/3/2008        3/7/2008         10/10/2008          Self-                        Yes
              Kansas City     141                                                 Ratings Methodology. Therefore, USACE-KC did not                                                      serious or substantial risk to the bulk power system                                                          reliability standard incurred by USACE-KC and it                                                                      Certification
                District                                                          address the method by which the ratings were                                                          because although USACE-KC did not have a                                                                      did not constitute a serious or substantial risk to
                                                                                  determined. However, USACE-KC was using the                                                           documented Facilities Rating Methodology, USACE-KC                                                            the bulk power system. FERC has determined to
                                                                                  original equipment ratings and capacity and was                                                       was establishing ratings for its facilities based upon the                                                    separately address jurisdictional issues with
                                                                                  providing the equipment ratings to its Transmission                                                   original equipment ratings and these facility ratings were                                                    respect to the USACE and other Federal Entities
                                                                                  Operator.                                                                                             communicated to its Transmission Operator and                                                                 in Docket No. NP09-26.
4                                                                                                                                                                                       Southwest Power Pool.
      SPP      USACE -       NOC-     SPP200700010     NCR01357    1/18/2008      USACE-KC did not have a documented Facility                  FAC-008-1      3         Lower           SPP RE determined that the violation did not create a          7/10/2007       3/3/2008           $0          The violation was the first violation of this         MIT-07-0466   3/3/2008        3/7/2008         10/10/2008          Self-                        Yes
              Kansas City     141                                                 Ratings Methodology. Therefore, USACE-KC did not                                                      serious or substantial risk to the bulk power system                                                          reliability standard incurred by USACE-KC and it                                                                      Certification
                District                                                          address other considerations as required by the                                                       because although USACE-KC did not have a                                                                      did not constitute a serious or substantial risk to
                                                                                  standard. However, USACE-KC was using the original                                                    documented Facilities Rating Methodology, USACE-KC                                                            the bulk power system. FERC has determined to
                                                                                  equipment ratings and capacity and was providing the                                                  was establishing ratings for its facilities based upon the                                                    separately address jurisdictional issues with
                                                                                  equipment ratings to its Transmission Operator.                                                       original equipment ratings and these facility ratings were                                                    respect to the USACE and other Federal Entities
                                                                                                                                                                                        communicated to its Transmission Operator and                                                                 in Docket No. NP09-26.
5                                                                                                                                                                                       Southwest Power Pool.
      SPP      USACE -       NOC-     SPP200700011     NCR01357    1/18/2008      Because USACE-KC did not have a documented                   FAC-009-1      1        Medium           SPP RE determined that the violation did not create a          7/10/2007       7/25/2008          $0          The violation was the first violation of this         MIT-07-0467   7/25/2008      7/25/2008         10/10/2008          Self-                        Yes
              Kansas City     141                                                 Facilities Rating Methodology, it had not established                                                 serious or substantial risk to the BPS because although                                                       reliability standard incurred by USACE-KC and it                                                                      Certification
                District                                                          ratings for its facilities consistent with such a Facility                                            USACE-KC did not have a documented Facilities Rating                                                          did not constitute a serious or substantial risk to
                                                                                  Ratings Methodology.                                                                                  Methodology, USACE-KC was establishing ratings for its                                                        the bulk power system. FERC has determined to
                                                                                                                                                                                        facilities based upon the original equipment ratings and                                                      separately address jurisdictional issues with
                                                                                                                                                                                        these facility ratings were communicated to its                                                               respect to the USACE and other Federal Entities
                                                                                                                                                                                        Transmission Operator and Southwest Power Pool.                                                               in Docket No. NP09-26.
6
      SPP      USACE -       NOC-     SPP200700012     NCR01357    1/18/2008      Because USACE-KC did not have a Facility Rating              FAC-009-1      2        Medium           SPP RE determined that the violation did not create a          7/10/2007       7/25/2008          $0          The violation was the first violation of this         MIT-07-0467   7/25/2008      7/25/2008         10/10/2008          Self-                        Yes
              Kansas City     141                                                 Methodology for its facilities; it had not established                                                serious or substantial risk to the BPS because although                                                       reliability standard incurred by USACE-KC and it                                                                      Certification
                District                                                          facility ratings for its facilities consistent with such a                                            USACE-KC did not have a documented Facilities Rating                                                          did not constitute a serious or substantial risk to
                                                                                  Facility Ratings Methodology. Therefore, USACE-KC                                                     Methodology, USACE-KC was establishing ratings for its                                                        the bulk power system. FERC has determined to
                                                                                  could not provide facility ratings consistent with the                                                facilities based upon the original equipment ratings and                                                      separately address jurisdictional issues with
                                                                                  methodology to the identified entities.                                                               these facility ratings were communicated to its                                                               respect to the USACE and other Federal Entities
                                                                                                                                                                                        Transmission Operator and Southwest Power Pool.                                                               in Docket No. NP09-26.
7
      SPP      USACE -       NOC-     SPP200700013     NCR01357    1/18/2008      USACE-KC did not have documented procedures for              PRC-004-1      1          High           SPP RE determined that the violation did not create a          7/10/2007       3/3/2008           $0          The violation was the first violation of this         MIT-07-0468   3/3/2008        3/7/2008         10/10/2008          Self-                        Yes
              Kansas City     141                                                 the analysis of transmission Protection System                                                        serious or substantial risk to the bulk power system                                                          reliability standard incurred by USACE-KC and it                                                                      Certification
                District                                                          Misoperations and the development of Corrective                                                       because USACE-KC performs analysis of transmission                                                            did not constitute a serious or substantial risk to
                                                                                  Action Plans.                                                                                         Protection System Misoperations occurring on its system                                                       the bulk power system. FERC has determined to
                                                                                                                                                                                        but does not report the Misoperations to Southwest                                                            separately address jurisdictional issues with
                                                                                                                                                                                        Power Pool.                                                                                                   respect to the USACE and other Federal Entities
8                                                                                                                                                                                                                                                                                                     in Docket No. NP09-26.
      SPP      USACE -       NOC-     SPP200700014     NCR01357    1/18/2008      USACE-KC did not have documented procedures for              PRC-004-1      2          High           SPP RE determined that the violation did not create a          7/10/2007       3/3/2008           $0          The violation was the first violation of this         MIT-07-0468   3/3/2008        3/7/2008         10/10/2008          Self-                        Yes
              Kansas City     141                                                 the analysis of generation Protection System                                                          serious or substantial risk to the bulk power system                                                          reliability standard incurred by USACE-KC and it                                                                      Certification
                District                                                          Misoperations and the development of Corrective                                                       because USACE-KC performs analysis of generation                                                              did not constitute a serious or substantial risk to
                                                                                  Action Plans.                                                                                         Protection System Misoperations occurring on its system                                                       the bulk power system. FERC has determined to
                                                                                                                                                                                        but does not report the Misoperations to Southwest                                                            separately address jurisdictional issues with
                                                                                                                                                                                        Power Pool.                                                                                                   respect to the USACE and other Federal Entities
9                                                                                                                                                                                                                                                                                                     in Docket No. NP09-26.
      SPP      USACE -       NOC-     SPP200700015     NCR01357    1/18/2008      USACE-KC did not report transmission Protection              PRC-004-1      3         Lower           SPP RE determined that the violation did not create a          7/10/2007       3/3/2008           $0          The violation was the first violation of this         MIT-07-0468   3/3/2008        3/7/2008         10/10/2008          Self-                        Yes
              Kansas City     141                                                 System Misoperations and Corrective Action Plans to                                                   serious or substantial risk to the bulk power system                                                          reliability standard incurred by USACE-KC and it                                                                      Certification
                District                                                          the Southwest Power Pool, as required by the                                                          because USACE-KC performs analysis of transmission                                                            did not constitute a serious or substantial risk to
                                                                                  Reliability Standard.                                                                                 Protection System Misoperations occurring on its system                                                       the bulk power system. FERC has determined to
                                                                                                                                                                                        but does not report the Misoperations to Southwest                                                            separately address jurisdictional issues with
                                                                                                                                                                                        Power Pool.                                                                                                   respect to the USACE and other Federal Entities
10                                                                                                                                                                                                                                                                                                    in Docket No. NP09-26.




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       A           B          C            D             E             F                                    G                                  H         I             J                                       K                                     L              M               N                                    O                                 P            Q               R                  S                T             U             V
                                                                                                                                                                                                                                                                                                                                                                                                      Regional
                                                                                                                                                                                                                                                                                                                                                                                  Registered
                                                                                                                                                                Violation                                                                                                                                                                                                                               Entity
                                                                    Date                                                                                                                                                                                                                                                                                            Mitigation        Entity                                           Separate      Signed
              Registered             NERC Violation                                                                                       Reliability          Risk Factor*                                                                   Violation Start   Violation    Total Penalty or                                                          Mitigation                                   Verification of   Discovery
     Region                 NOC-ID                     NCR_ID    Identified or                 Description of the Violation                             Req.                                           Risk Assessment                                                                              Additional Factors for the Basis of Penalty                       Plan       Certification of                                     Settlement   Disposition
                Entity                   ID #                                                                                             Standard                                                                                                 Date         End Date       Sanction ($)                                                           Plan Number                                    Mitigation        Method
                                                                   Received                                                                                                                                                                                                                                                                                         Completed    Mitigation Plan                                      Agreement       Letter
                                                                                                                                                               *See Attachment C                                                                                                                                                                                                                         Plan
                                                                                                                                                                                                                                                                                                                                                                                  Completion
1                                                                                                                                                                                                                                                                                                                                                                                                    Completion
      SPP      USACE -      NOC-     SPP200700016     NCR01357    1/18/2008      The USACE-KC Protection System Maintenance and           PRC-005-1      1          High           SPP RE determined that the violation did not create a        7/10/2007       12/31/2008          $0          The violation was the first violation of this         MIT-07-0469   12/31/2008      1/8/2009          1/21/2009          Self-                        Yes
              Kansas City    141                                                 Testing Program did not include documentation of                                                  serious or substantial risk to the bulk power system                                                         reliability standard incurred by USACE-KC and it                                                                      Certification
                District                                                         testing for its protective relays. USACE-KC identified                                            because the USACE-KC had a comprehensive                                                                     did not constitute a serious or substantial risk to
                                                                                 133 protective relays in its program – 26 of the 133                                              Protection System Maintenance and Testing Program                                                            the bulk power system. FERC has determined to
                                                                                 protective relays were the new microprocessor relays.                                             and was conducting the testing for its relays. The                                                           separately address jurisdictional issues with
                                                                                 USACE-KC was testing its microprocessor relays on a                                               potential impact on the bulk power system is limited to                                                      respect to the USACE and other Federal Entities
                                                                                 5 year basis and electromechanical relays on a 2 year                                             two small hydroelectric generating facilities and USACE-                                                     in Docket No. NP09-26.
                                                                                 basis, but it did not have complete documentation                                                 KC had replaced a significant number of its mechanical
                                                                                 regarding the historical tests.                                                                   Protection System relays with microprocessor relays,
                                                                                                                                                                                   enhancing the reliability of its generator Protection
                                                                                                                                                                                   Systems.


11
      SPP      USACE -      NOC-     SPP200700017     NCR01357    1/18/2008      Because USACE-KC had a violation of PRC-005 R1, it PRC-005-1            2          High           SPP RE determined that the violation did not create a        7/10/2007       12/31/2008          $0          The violation was the first violation of this         MIT-07-0469   12/31/2008      1/8/2009          1/21/2009          Self-                        Yes
              Kansas City    141                                                 could not provide the documentation as required by R2.                                            serious or substantial risk to the bulk power system                                                         reliability standard incurred by USACE-KC and it                                                                      Certification
                District                                                                                                                                                           because USACE-KC had a Protection System                                                                     did not constitute a serious or substantial risk to
                                                                                                                                                                                   maintenance and testing program, the potential impact                                                        the bulk power system. FERC has determined to
                                                                                                                                                                                   on the bulk power system is limited to two small                                                             separately address jurisdictional issues with
                                                                                                                                                                                   hydroelectric generating facilities, and USACE-KC had                                                        respect to the USACE and other Federal Entities
                                                                                                                                                                                   replaced a significant number of its mechanical                                                              in Docket No. NP09-26.
                                                                                                                                                                                   Protection System relays with microprocessor relays,
                                                                                                                                                                                   enhancing the reliability of its generator Protection
12                                                                                                                                                                                 Systems.




                                                                                                                                                                                                                          SPP                                                                                                                                                                                                                               Page 19 of 80
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              A                         B                            C                       D                       E                   F                G                                       H                                    I             J         K           L                          M                             N                     O               P                             Q                             R            S              T               U              V            W                X
                                                                                                                                   Date                 Date
                                                                                                                                Identified or                                                                                                                         Violation                                                                                                                                                                              Registered       Regional
                                                                                                                                                    Identified or                                                                                                                                                                                                       Total
                                                                                                                                 Received                                                                                                                               Risk                                                                                                                                                                                   Entity          Entity
                                                                                                                                                      Received                                                                                  Regional                                                                                                               Penalty                                                    Mitigation   Mitigation                                                  Separate
                                                                                 NERC Violation ID                               (Pre-June                                                                                        Reliability                          Factor*                                             Violation Start Date                                                 Additional Factors                                          Certification   Verification    Discovery                    Signed
          Region              Registered Entity                  NOC-ID                                         NCR_ID                               (Post-June                      Description of the Violation                               Reliability   Req.                           Risk Assessment                                      Violation End Date      or                                                        Plan         Plan                                                     Settlement
                                                                                        #                                            18                                                                                           Standard                                                                                (Post-June 18, 2007)                                               for the Basis of Penalty                                       of Mitigation   of Mitigation    Method                  Disposition Letter
                                                                                                                                                    18 Violation)                                                                               Standard                                                                                                               Sanction                                                    Number      Completed                                                  Agreement
                                                                                                                                 Violation)*                                                                                                                              *See                                                                                                                                                                                  Plan            Plan
                                                                                                                                                                                                                                                                                                                                                                         ($)
                                                                                                                                                                                                                                                                      Attachment C                                                                                                                                                                           Completion     Completion1
1                                                                                                                                  *if applicable

          WECC               AES Alamitos LLC                  NOC-0276           WECC200800790               NCR05002                               4/28/2008       AES Alamitos was not reporting changes in capabilities       TOP-002-2                   14       Medium         WECC determined that the                 6/18/2007              5/9/2008            $0      The violation was self-reported, it was the      MIT-08-      5/9/2008      5/9/2008       12/2/2008      Self-Report                      Yes
                                                                                                                                                                     and characteristics to its Transmission Operator.                                                               violation did not constitute a                                                               first violation of this Reliability Standard      1451
                                                                                                                                                                                                                                                                                     serious or substantial risk to the                                                           incurred by AES Alamitos and it did not
                                                                                                                                                                                                                                                                                     bulk power system because AES                                                                constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                     Alamitos, as the Generator                                                                   the bulk power system.
                                                                                                                                                                                                                                                                                     Operator, had regular
                                                                                                                                                                                                                                                                                     communications with its Balancing
                                                                                                                                                                                                                                                                                     Authority and Transmission
2                                                                                                                                                                                                                                                                                    Operator.
          WECC               AES Alamitos LLC                  NOC-0276           WECC200800893               NCR05002                               7/3/2008        AES Alamitos failed to run one generator (Unit 5) with       VAR-STD-         WR          1         N/A          WECC determined that the                 6/18/2007              7/31/2008           $0      The violation was self-reported, it was the      MIT-08-     7/31/2008     7/31/2008        9/2/2008      Self-Report                      Yes
                                                                                                                                                                     power system stabilizers (PSS) for 6 days without an          002b-1                                            violation did not constitute a                                                               first violation of this Reliability Standard      1038
                                                                                                                                                                     exemption.                                                                                                      serious or substantial risk to the                                                           incurred by AES Alamitos and it did not
                                                                                                                                                                                                                                                                                     bulk power system because there                                                              constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                     were close communications                                                                    the bulk power system.
                                                                                                                                                                                                                                                                                     between AES Alamitos and its
                                                                                                                                                                                                                                                                                     Balancing Authority. AES
                                                                                                                                                                                                                                                                                     Alamitos' Balancing Authority
                                                                                                                                                                                                                                                                                     discovered that Unit 5 was not
3                                                                                                                                                                                                                                                                                    operating with PSS.
          WECC           AES Huntington Beach                  NOC-0278           WECC200800792               NCR05004                               5/2/2008        AES Huntington Beach was not reporting changes in            TOP-002-2                   14       Medium         WECC determined that the                 6/18/2007              6/3/2008            $0      The violation was self-reported, it was the      MIT-08-      6/3/2008      6/4/2008        6/4/2008      Self-Report                      Yes
                                 LLC                                                                                                                                 capabilities and characteristics to its Transmission                                                            violation did not constitute a                                                               first violation of this Reliability Standard      0839
                                                                                                                                                                     Operator.                                                                                                       serious or substantial risk to the                                                           incurred by AES Huntington Beach and it
                                                                                                                                                                                                                                                                                     bulk power system because AES                                                                did not constitute a serious or substantial
                                                                                                                                                                                                                                                                                     Huntington Beach, as the                                                                     risk to the bulk power system. AES
                                                                                                                                                                                                                                                                                     Generator Operator, had regular                                                              Huntington Beach completed its Mitigation
                                                                                                                                                                                                                                                                                     communications with its Balancing                                                            Plan 2 weeks after its approved completion
                                                                                                                                                                                                                                                                                     Authority and Transmission                                                                   date of 5/19/2008. WECC considered
                                                                                                                                                                                                                                                                                     Operator.                                                                                    these factors and determined that,
                                                                                                                                                                                                                                                                                                                                                                                  notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                                                                                                                  Mitigation Plan, a zero dollar penalty was
4                                                                                                                                                                                                                                                                                                                                                                                 appropriate for this violation.
          WECC          AES Redondo Beach LLC                  NOC-0279           WECC200800789               NCR05007                               4/24/2008       AES Redondo Beach was not reporting changes in               TOP-002-2                   14       Medium        WECC determined that the                  6/18/2007              5/6/2008            $0      The violation was self-reported, it was the      MIT-08-      5/6/2008     5/30/2008       9/29/2008      Self-Report                      Yes
                                                                                                                                                                     capabilities and characteristics to its Transmission                                                            violation did not constitute a                                                               first violation of this Reliability Standard      0838
                                                                                                                                                                     Operator.                                                                                                       serious or substantial risk to the                                                           incurred by AES Redondo Beach and it did
                                                                                                                                                                                                                                                                                     bulk power system because the                                                                not constitute a serious or substantial risk
                                                                                                                                                                                                                                                                                     Generating Units at Redondo are                                                              to the bulk power system.
5                                                                                                                                                                                                                                                                                    off line.
          WECC          Alameda Municipal Power                NOC-0368           WECC200801048               NCR10042                               6/2/2008        APAT did not have procedures for the recognition of and      CIP-001-1                    1       Medium        WECC determined that the                  8/23/2007             12/31/2008           $0      The violation was self-reported, it was the      MIT-07-     12/31/2008    2/11/2009       8/31/2009      Self-Report                      Yes
                                                                                                                                                                     for making its operating personnel aware of sabotage                                                            violation did not constitute a                                                               first violation of this Reliability Standard      1094
                                                                                                                                                                     events on its facilities.                                                                                       serious or substantial risk to the                                                           incurred by APAT and it did not constitute a
                                                                                                                                                                                                                                                                                     bulk power system because of the                                                             serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                     nature and the location of APAT's                                                            system.
6                                                                                                                                                                                                                                                                                    assets.
          WECC          Alameda Municipal Power                NOC-0368           WECC200801049               NCR10042                               6/2/2008        APAT did not have procedures for the communication of        CIP-001-1                    2       Medium        WECC determined that the                  8/23/2007             12/31/2008           $0      The violation was self-reported, it was the      MIT-07-     12/31/2008    2/11/2009       8/31/2009      Self-Report                      Yes
                                                                                                                                                                     information concerning sabotage events to appropriate                                                           violation did not constitute a                                                               first violation of this Reliability Standard      1094
                                                                                                                                                                     parties in the Interconnection.                                                                                 serious or substantial risk to the                                                           incurred by APAT and it did not constitute a
                                                                                                                                                                                                                                                                                     bulk power system because of the                                                             serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                     nature and the location of APAT's                                                            system.
7                                                                                                                                                                                                                                                                                    assets.
          WECC          Alameda Municipal Power                NOC-0368           WECC200801050               NCR10042                               6/2/2008        APAT did not provide its operating personnel with            CIP-001-1                    3       Medium        WECC determined that the                  8/23/2007             12/31/2008           $0      The violation was self-reported, it was the      MIT-07-     12/31/2008    2/11/2009       8/31/2009      Self-Report                      Yes
                                                                                                                                                                     sabotage response guidelines, including personnel to                                                            violation did not constitute a                                                               first violation of this Reliability Standard      1094
                                                                                                                                                                     contact, for reporting disturbances due to sabotage                                                             serious or substantial risk to the                                                           incurred by APAT and it did not constitute a
                                                                                                                                                                     events.                                                                                                         bulk power system because of the                                                             serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                     nature and the location of APAT's                                                            system.
8                                                                                                                                                                                                                                                                                    assets.
          WECC          Alameda Municipal Power                NOC-0368           WECC200801051               NCR10042                               6/2/2008        APAT did not have established communications contacts,       CIP-001-1                    4       Medium        WECC determined that the                  8/23/2007             12/31/2008           $0      The violation was self-reported, it was the      MIT-07-     12/31/2008    2/11/2009       8/31/2009      Self-Report                      Yes
                                                                                                                                                                     as applicable, with local Federal Bureau of Investigation                                                       violation did not constitute a                                                               first violation of this Reliability Standard      1094
                                                                                                                                                                     (FBI) officials and did not develop documented reporting                                                        serious or substantial risk to the                                                           incurred by APAT and it did not constitute a
                                                                                                                                                                     procedures as appropriate to the circumstances.                                                                 bulk power system because of the                                                             serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                     nature and the location of APAT's                                                            system.
9                                                                                                                                                                                                                                                                                    assets.
          WECC            Arizona Public Service               NOC-0280           WECC200800843               NCR05016                               5/22/2008       AZPS did not cut an applicable transaction tag in a timely   IRO-STD-         WR          1         N/A         WECC determined that the                  6/18/2007              7/2/2008            $0      The violation was self-reported, it was the      MIT-08-      7/2/2008      7/2/2008      11/18/2008      Self-Report                      Yes
                                Company                                                                                                                              manner because it did not have redundant procedures in         006-0                                            violation did not constitute a                                                               first violation of this Reliability Standard      1293
                                                                                                                                                                     place to ensure that it received the Unscheduled Flow                                                           serious or substantial risk to the                                                           incurred by AZPS and it did not constitute a
                                                                                                                                                                     (USF) alarm. Violations of this regional standard have                                                          bulk power system because                                                                    serious or substantial risk to the bulk power
                                                                                                                                                                     diminished, in part, due to better communication tools                                                          actions taken by the Balancing                                                               system. AZPS completed its Mitigation
                                                                                                                                                                     (primarily more entities utilizing better software (e.g.,                                                       Authority operator to reduce                                                                 Plan 2 weeks after its approved completion
                                                                                                                                                                     webSAS)). Unscheduled flow (USF) occurs in the                                                                  generation schedules to reduce                                                               date of 6/13/2008. WECC considered
                                                                                                                                                                     Western Interconnection because of concentrated load                                                            overloads on Path 22 reduced the                                                             these factors and determined that,
                                                                                                                                                                     centers (mainly on the West Coast), remote generation                                                           USF as an immediate corrective                                                               notwithstanding the late completion of the
                                                                                                                                                                     resources (many on the Eastern side of WECC) and long                                                           action. AZPS M&T cut a Tag                                                                   Mitigation Plan, a zero dollar penalty was
                                                                                                                                                                     transmission lines in between. The WECC high voltage                                                            subsequently.                                                                                appropriate for this violation.
                                                                                                                                                                     transmission lines form a circle (“О”) in the
                                                                                                                                                                     Interconnection, which results in the electricity from the
                                                                                                                                                                     generation resources dividing, with some small
                                                                                                                                                                     percentage flowing around the opposite side of the “O” to
                                                                                                                                                                     reach the load centers (this is the USF). USF can occur
                                                                                                                                                                     at any time depending on the amount of power being
                                                                                                                                                                     generated and used in the load centers. Certain actions
                                                                                                                                                                     are taken to control and absorb the USF (e.g., adjusting
                                                                                                                                                                     phase shifting transformers, accommodation, etc.) but
                                                                                                                                                                     ultimately an entity may have to reduce schedules,
                                                                                                                                                                     thereby reducing the amount of power flowing (thereby
                                                                                                                                                                     reducing the amount of unscheduled flow). While an
10
                                                                                                                                                                     entity may be taking action to address this, an entity may




                                                                                                                                                                                                                                                                                           WECC
     1
         Date of Verification of Completion is the WECC RSAW date, if complete. Otherwise, it is date of the Verification letter sent by WECC to the Registered Entity.                                                                                                                                                                                                                                                                                                                                                  Page 20 of 80
                                                                                                                                                                                                                                                                               10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                                                                                                                          PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                                                                                                                        CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                                                                                                                        HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.




              A                         B                            C                       D                       E                   F                G                                        H                                      I             J         K           L                           M                              N                       O                P                              Q                              R            S              T               U              V            W                X
                                                                                                                                   Date                 Date
                                                                                                                                Identified or                                                                                                                            Violation                                                                                                                                                                                     Registered       Regional
                                                                                                                                                    Identified or                                                                                                                                                                                                               Total
                                                                                                                                 Received                                                                                                                                  Risk                                                                                                                                                                                          Entity          Entity
                                                                                                                                                      Received                                                                                     Regional                                                                                                                    Penalty                                                      Mitigation   Mitigation                                                  Separate
                                                                                 NERC Violation ID                               (Pre-June                                                                                           Reliability                          Factor*                                               Violation Start Date                                                    Additional Factors                                            Certification   Verification    Discovery                    Signed
          Region              Registered Entity                  NOC-ID                                         NCR_ID                               (Post-June                      Description of the Violation                                  Reliability   Req.                            Risk Assessment                                        Violation End Date        or                                                          Plan         Plan                                                     Settlement
                                                                                        #                                            18                                                                                              Standard                                                                                  (Post-June 18, 2007)                                                  for the Basis of Penalty                                         of Mitigation   of Mitigation    Method                  Disposition Letter
                                                                                                                                                    18 Violation)                                                                                  Standard                                                                                                                    Sanction                                                      Number      Completed                                                  Agreement
                                                                                                                                 Violation)*                                                                                                                                 *See                                                                                                                                                                                         Plan            Plan
                                                                                                                                                                                                                                                                                                                                                                                 ($)
                                                                                                                                                                                                                                                                         Attachment C                                                                                                                                                                                  Completion     Completion1
1                                                                                                                                  *if applicable

          WECC            Arizona Public Service               NOC-0280           WECC200801171               NCR05016                               6/30/2008       AZPS did not cut an applicable transaction tag in a timely IRO-STD-              WR          1         N/A         WECC determined that the                    6/18/2007                7/2/2008             $0      The violation was self-reported and it did         MIT-08-     7/2/2008      7/18/2008      11/18/2008      Self-Report                      Yes
                                Company                                                                                                                              manner because it did not have redundant procedures in        006-0                                                violation did not constitute a                                                                    not constitute a serious or substantial risk        1203
                                                                                                                                                                     place to ensure that it received the Unscheduled Flow                                                              serious or substantial risk to the                                                                to the bulk power system.
                                                                                                                                                                     (USF) alarm. This was a second violation of this                                                                   bulk power system because the
                                                                                                                                                                     standard. While there were occurrences of repeat IRO-                                                              violation represented less than 2                                                                 In determining the penalty, WECC took into
                                                                                                                                                                     STD-006 violations in 2007 into 2008, repeat violations                                                            MW of flow on a 4800 MW path so                                                                   account that this was the second violation
                                                                                                                                                                     have diminished, in part, due to better communication                                                              this actual event would have                                                                      of this Reliability Standard incurred by
                                                                                                                                                                     tools (primarily more entities utilizing better software                                                           minimal impact.                                                                                   AZPS.
                                                                                                                                                                     (e.g., webSAS)). Unscheduled flow (USF) occurs in the
                                                                                                                                                                     Western Interconnection because of concentrated load
                                                                                                                                                                     centers (mainly on the West Coast), remote generation
                                                                                                                                                                     resources (many on the Eastern side of WECC) and long
                                                                                                                                                                     transmission lines in between. The WECC high voltage
                                                                                                                                                                     transmission lines form a circle (“О”) in the
                                                                                                                                                                     Interconnection, which results in the electricity from the
                                                                                                                                                                     generation resources dividing, with some small
                                                                                                                                                                     percentage flowing around the opposite side of the “O” to
                                                                                                                                                                     reach the load centers (this is the USF). USF can occur
                                                                                                                                                                     at any time depending on the amount of power being
                                                                                                                                                                     generated and used in the load centers. Certain actions
                                                                                                                                                                     are taken to control and absorb the USF (e.g., adjusting
                                                                                                                                                                     phase shifting transformers, accommodation, etc.) but
                                                                                                                                                                     ultimately an entity may have to reduce schedules,
                                                                                                                                                                     thereby reducing the amount of power flowing (thereby
11
                                                                                                                                                                     reducing the amount of unscheduled flow). While an
          WECC            Arizona Public Service               NOC-0280           WECC200801210               NCR05016                               1/29/2008       AZPS exceeded the maximum amount of power allowed           TOP-STD-             WR          1         N/A         WECC determined that this                   11/7/2007           2/6/2008    (Event        $0      The violation was self-reported, it was the        MIT-08-     2/6/2008      3/31/2008       9/10/2008      Self-Report                      Yes
                                Company                                                                                                                              over the Operating Transfer Capability (OTC) for a total of   007-0                                                violation did not constitute a                                    occurred for 50                 first violation of this Reliability Standard        1318
                                                                                                                                                                     50 minutes.                                                                                                        serious or substantial risk to the                             minutes on 11/7/2007)              incurred by AZPS and it did not constitute a
                                                                                                                                                                                                                                                                                        bulk power system because AZPS                                                                    serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                        maintained contact with the                                                                       system. During the event, AZPS took steps
                                                                                                                                                                                                                                                                                        Reliability Coordinator throughout                                                                within its control to reduce its load.
                                                                                                                                                                                                                                                                                        the event and worked with the
                                                                                                                                                                                                                                                                                        Reliability Coordinator to restore
                                                                                                                                                                                                                                                                                        its system back within normal
12                                                                                                                                                                                                                                                                                      operating limits.
          WECC             Blachly-Lane Electric               NOC-0281           WECC200710062               NCR05028            5/23/2007         10/31/2007 Blachly-Lane Electric/PNGC did not have procedures to                 TOP-002-2                    3       Medium        WECC determined that the                    6/18/2007               5/28/2008             $0      The violation was self-reported, it was the        MIT-07-     5/28/2008     5/29/2008       12/2/2008      Self-Report                      Yes
                               Coop/PNGC                                                                                                                       coordinate its current-day, next-day, and seasonal                                                                       violation did not constitute a                                                                    first violation of this Reliability Standard        0686
                                                                                                                                                               operations with its Balancing Authority and Transmission                                                                 serious or substantial risk to the                                                                incurred by Blachly-Lane Electric/PNGC
                                                                                                                                                               Service Provider.                                                                                                        bulk power system because                                                                         and it did not constitute a serious or
                                                                                                                                                                                                                                                                                        Blachly-Lane Electric/PNGC was                                                                    substantial risk to the bulk power system.
                                                                                                                                                                                                                                                                                        coordinating with the Balancing                                                                   However, the Mitigation Plan for the related
                                                                                                                                                                                                                                                                                        Authority and Transmission                                                                        pre-June 18 violation (WECC200701883)
                                                                                                                                                                                                                                                                                        Service Provider although not as                                                                  was not completed on time, which resulted
                                                                                                                                                                                                                                                                                        required by the standard.                                                                         in this post-June 18 violation. Additionally,
                                                                                                                                                                                                                                                                                                                                                                                          Blachly-Lane Electric/PNGC completed its
                                                                                                                                                                                                                                                                                                                                                                                          Mitigation Plan approximately 2 months
                                                                                                                                                                                                                                                                                                                                                                                          after its approved completion date of
                                                                                                                                                                                                                                                                                                                                                                                          3/31/2008. WECC considered these
                                                                                                                                                                                                                                                                                                                                                                                          factors and determined that,
                                                                                                                                                                                                                                                                                                                                                                                          notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                                                                                                                          Mitigation Plan, a zero dollar penalty was
                                                                                                                                                                                                                                                                                                                                                                                          appropriate for this violation.
13
          WECC             Blachly-Lane Electric               NOC-0281           WECC200800762               NCR05028                               3/28/2008       Blachly-Lane Electric/PNGC did not have documentation           TOP-002-2                   18       Medium        WECC determined that the                    6/18/2007                8/8/2008             $0      The violation was self-reported, it was a          MIT-08-     8/8/2008       8/8/2008        9/3/2008      Self-Report                      Yes
                               Coop/PNGC                                                                                                                             to show they used uniform line identifiers when referring                                                          violation did not constitute a                                                                    documentation issue, it was the first               0726
                                                                                                                                                                     to transmission facilities among a shared interconnect.                                                            serious or substantial risk to the                                                                violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                        bulk power system because there                                                                   by Blachly-Lane Electric/PNGC and it did
                                                                                                                                                                                                                                                                                        were historical practices regarding                                                               not constitute a serious or substantial risk
                                                                                                                                                                                                                                                                                        line identification between Blachly-                                                              to the bulk power system. Blachly-Lane
                                                                                                                                                                                                                                                                                        Lane Electric/PNGC and its                                                                        Electric/PNGC completed its Mitigation Plan
                                                                                                                                                                                                                                                                                        Transmission Service Provider                                                                     over 2 months after its approved
                                                                                                                                                                                                                                                                                        and Transmission Operator.                                                                        completion date of 5/30/2008. WECC
                                                                                                                                                                                                                                                                                                                                                                                          considered these factors and determined
                                                                                                                                                                                                                                                                                                                                                                                          that, notwithstanding the late completion of
                                                                                                                                                                                                                                                                                                                                                                                          the Mitigation Plan, a zero dollar penalty
                                                                                                                                                                                                                                                                                                                                                                                          was appropriate for this violation.
14
          WECC            Black Hills Power, Inc.              NOC-0282           WECC200700413               NCR05030                               8/30/2007       Black Hills Power was supposed to provide 0 MW of relief        IRO-STD-         WR          1         N/A         WECC determined that the                    6/18/2007               9/13/2007             $0      The violation was the first violation of this      MIT-07-     9/13/2007     7/21/2009        9/1/2009      Exception                        Yes
                                                                                                                                                                     but supplied -3 MW. For the event, the percent of USF             006-0                                            violation did not constitute a                                                                    Reliability Standard incurred by Black Hills        1923                                                    Reporting
                                                                                                                                                                     increases due to Black Hills Power resulted in a                                                                   serious or substantial risk to the                                                                Power and it did not constitute a serious or
                                                                                                                                                                     contributory change of .46%. Violations of this regional                                                           bulk power system because no                                                                      substantial risk to the bulk power system.
                                                                                                                                                                     standard have diminished, in part, due to better                                                                   violations of the Operating
                                                                                                                                                                     communication tools (primarily more entities utilizing                                                             Transfer Capability occurred.
                                                                                                                                                                     better software (e.g., webSAS)). Unscheduled flow (USF)
                                                                                                                                                                     occurs in the Western Interconnection because of
                                                                                                                                                                     concentrated load centers (mainly on the West Coast),
                                                                                                                                                                     remote generation resources (many on the Eastern side
                                                                                                                                                                     of WECC) and long transmission lines in between. The
                                                                                                                                                                     WECC high voltage transmission lines form a circle (“О”)
                                                                                                                                                                     in the Interconnection, which results in the electricity from
                                                                                                                                                                     the generation resources dividing, with some small
                                                                                                                                                                     percentage flowing around the opposite side of the “O” to
                                                                                                                                                                     reach the load centers (this is the USF). USF can occur
                                                                                                                                                                     at any time depending on the amount of power being
                                                                                                                                                                     generated and used in the load centers. Certain actions
                                                                                                                                                                     are taken to control and absorb the USF (e.g., adjusting
                                                                                                                                                                     phase shifting transformers, accommodation, etc.) but
15
                                                                                                                                                                     ultimately an entity may have to reduce schedules,
                                                                                                                                                                     thereby reducing the amount of power flowing (thereby




                                                                                                                                                                                                                                                                                              WECC
     1
         Date of Verification of Completion is the WECC RSAW date, if complete. Otherwise, it is date of the Verification letter sent by WECC to the Registered Entity.                                                                                                                                                                                                                                                                                                                                                            Page 21 of 80
                                                                                                                                                                                                                                                                         10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                                                                                                                    PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                                                                                                                  CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                                                                                                                  HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.




              A                         B                            C                       D                       E                   F                G                                      H                                  I             J         K           L                          M                              N                     O               P                              Q                              R            S              T               U              V            W                X
                                                                                                                                   Date                 Date
                                                                                                                                Identified or                                                                                                                      Violation                                                                                                                                                                                 Registered       Regional
                                                                                                                                                    Identified or                                                                                                                                                                                                     Total
                                                                                                                                 Received                                                                                                                            Risk                                                                                                                                                                                      Entity          Entity
                                                                                                                                                      Received                                                                               Regional                                                                                                                Penalty                                                      Mitigation   Mitigation                                                  Separate
                                                                                 NERC Violation ID                               (Pre-June                                                                                     Reliability                          Factor*                                              Violation Start Date                                                 Additional Factors                                            Certification   Verification    Discovery                    Signed
          Region              Registered Entity                  NOC-ID                                         NCR_ID                               (Post-June                     Description of the Violation                             Reliability   Req.                            Risk Assessment                                      Violation End Date      or                                                          Plan         Plan                                                     Settlement
                                                                                        #                                            18                                                                                        Standard                                                                                 (Post-June 18, 2007)                                               for the Basis of Penalty                                         of Mitigation   of Mitigation    Method                  Disposition Letter
                                                                                                                                                    18 Violation)                                                                            Standard                                                                                                                Sanction                                                      Number      Completed                                                  Agreement
                                                                                                                                 Violation)*                                                                                                                           *See                                                                                                                                                                                     Plan            Plan
                                                                                                                                                                                                                                                                                                                                                                       ($)
                                                                                                                                                                                                                                                                   Attachment C                                                                                                                                                                              Completion     Completion1
1                                                                                                                                  *if applicable

          WECC         Burney Forest Products, A               NOC-0283           WECC200810230               NCR05039            6/15/2007          2/13/2008       R1 requires the Transmission Owner and Generator            FAC-008-1                  1        Lower        WECC determined that the                   6/18/2007              2/12/2009           $0      The violation was self-reported, it was the        MIT-07-     2/12/2009     2/12/2009       7/22/2009      Self-Report                      Yes
                             Joint Venture                                                                                                                           Owner to document its current methodology used for                                                           violation did not constitute a                                                                first violation of this Reliability Standard        1844
                                                                                                                                                                     developing Facility Ratings (Facility Ratings Methodology)                                                   serious or substantial risk to the                                                            incurred by Burney Forest and it did not
                                                                                                                                                                     of its solely and jointly owned Facilities. Burney Forest                                                    bulk power system because of the                                                              constitute a serious or substantial risk to
                                                                                                                                                                     failed to document its Facility Ratings Methodology and                                                      nature and location of Burney                                                                 the bulk power system. However, the
                                                                                                                                                                     did not complete its evaluation of the facilities rating by                                                  Forest's facilities. In addition,                                                             Mitigation Plan for the related pre-June 18
                                                                                                                                                                     assessing the ratings of all critical components.                                                            Burney Forest had facility ratings                                                            violation (WECC200705994) was not
                                                                                                                                                                                                                                                                                  for certain facilities in place,                                                              completed on time, which resulted in this
                                                                                                                                                                                                                                                                                  although the methodology needed                                                               post-June 18 violation. WECC considered
                                                                                                                                                                                                                                                                                  to be documented and the                                                                      these factors and determined that,
                                                                                                                                                                                                                                                                                  evaluation of the ratings needed to                                                           notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                  be completed.                                                                                 Mitigation Plan, a zero dollar penalty was
16                                                                                                                                                                                                                                                                                                                                                                              appropriate for this violation.
          WECC         Burney Forest Products, A               NOC-0283           WECC200810231               NCR05039            6/15/2007          2/13/2008       Because Burney Forest was in violation of FAC-008 R1, it FAC-009-1                     1       Medium        WECC determined that the                   6/18/2007              2/12/2009           $0      The violation was self-reported, it was the        MIT-07-     2/12/2009     2/12/2009       7/22/2009      Self-Report                      Yes
                             Joint Venture                                                                                                                           also had a violation of FAC-009 R1, which requires the                                                       violation did not constitute a                                                                first violation of this Reliability Standard        1845
                                                                                                                                                                     application of the Facility Ratings Methodology to                                                           serious or substantial risk to the                                                            incurred by Burney Forest and it did not
                                                                                                                                                                     establish Facility Ratings for its solely and jointly owned                                                  bulk power system because of the                                                              constitute a serious or substantial risk to
                                                                                                                                                                     Facilities that are consistent with the associated Facility                                                  nature and location of Burney                                                                 the bulk power system. However, the
                                                                                                                                                                     Ratings Methodology. The estimate of the most limiting                                                       Forest's facilities. In addition,                                                             Mitigation Plan for the related pre-June 18
                                                                                                                                                                     average real power and VAR outputs to be as reported in                                                      Burney Forest had facility ratings                                                            violation (WECC200706041) was not
                                                                                                                                                                     attachment 32 based on FAC-008 was not performed                                                             for certain facilities in place,                                                              completed on time, which resulted in this
                                                                                                                                                                     because FAC-008 was not complete.                                                                            although the methodology needed                                                               post-June 18 violation. WECC considered
                                                                                                                                                                                                                                                                                  to be documented and the                                                                      these factors and determined that,
                                                                                                                                                                                                                                                                                  evaluation of the ratings needed to                                                           notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                  be completed.                                                                                 Mitigation Plan, a zero dollar penalty was
17                                                                                                                                                                                                                                                                                                                                                                              appropriate for this violation.
          WECC          California Department of               NOC-0284           WECC200810041               NCR05047            6/15/2007          2/19/2008       CDWR did not have an annual implementation plan for its FAC-003-1                      1         High        WECC determined that the                   6/18/2007              4/27/2009           $0      The violation was self-reported, it was a          MIT-07-     4/27/2009     4/30/2009       6/22/2009      Self-Report                      Yes
                            Water Resources                                                                                                                          TVMP for its jointly owned transmission lines.                                                               violation did not constitute a                                                                documentation issue, it was the first               0845
                                                                                                                                                                                                                                                                                  serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                  bulk power system because the                                                                 by CDWR and it did not constitute a serious
                                                                                                                                                                                                                                                                                  vegetation in these ROWs was                                                                  or substantial risk to the bulk power system.
                                                                                                                                                                                                                                                                                  being managed by the other                                                                     However, the Mitigation Plan for the related
                                                                                                                                                                                                                                                                                  owner of these transmission lines,                                                            pre-June 18 violation (WECC200705848)
                                                                                                                                                                                                                                                                                  and CDWR did not have a                                                                       was not completed on time, which resulted
                                                                                                                                                                                                                                                                                  vegetation-caused outage.                                                                     in this post-June 18 violation. WECC
                                                                                                                                                                                                                                                                                                                                                                                considered these factors and determined
                                                                                                                                                                                                                                                                                                                                                                                that, notwithstanding the late completion of
                                                                                                                                                                                                                                                                                                                                                                                the Mitigation Plan, a zero dollar penalty
                                                                                                                                                                                                                                                                                                                                                                                was appropriate for this violation.
18
          WECC          California Department of               NOC-0284           WECC200810042               NCR05047            6/15/2007          2/19/2008       CDWR did not have documentation for its TVMP for its      FAC-003-1                    2         High        WECC determined that the                   6/18/2007              4/27/2009           $0      The violation was self-reported, it was a          MIT-07-     4/27/2009     4/30/2009       6/22/2009      Self-Report                      Yes
                            Water Resources                                                                                                                          jointly owned transmission lines.                                                                            violation did not constitute a                                                                documentation issue, it was the first               0845
                                                                                                                                                                                                                                                                                  serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                  bulk power system because the                                                                 by CDWR and it did not constitute a serious
                                                                                                                                                                                                                                                                                  vegetation in these ROWs was                                                                  or substantial risk to the bulk power system.
                                                                                                                                                                                                                                                                                  being managed by the other                                                                     However, the Mitigation Plan for the related
                                                                                                                                                                                                                                                                                  owner of these transmission lines,                                                            pre-June 18 violation (WECC200705841)
                                                                                                                                                                                                                                                                                  and CDWR did not have a                                                                       was not completed on time, which resulted
                                                                                                                                                                                                                                                                                  vegetation-caused outage.                                                                     in this post-June 18 violation. WECC
                                                                                                                                                                                                                                                                                                                                                                                considered these factors and determined
                                                                                                                                                                                                                                                                                                                                                                                that, notwithstanding the late completion of
                                                                                                                                                                                                                                                                                                                                                                                the Mitigation Plan, a zero dollar penalty
                                                                                                                                                                                                                                                                                                                                                                                was appropriate for this violation.
19
          WECC          California Department of               NOC-0284           WECC200810043               NCR05047            6/15/2007          2/19/2008       CDWR did not have a procedure to directly report          FAC-003-1                    3         High        WECC determined that the                   6/18/2007              4/27/2009           $0      The violation was self-reported, it was a          MIT-07-     4/27/2009     4/30/2009       6/22/2009      Self-Report                      Yes
                            Water Resources                                                                                                                          outages as required by the standard.                                                                         violation did not constitute a                                                                documentation issue, it was the first               0845
                                                                                                                                                                                                                                                                                  serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                  bulk power system because the                                                                 by CDWR and it did not constitute a serious
                                                                                                                                                                                                                                                                                  vegetation in these ROWs was                                                                  or substantial risk to the bulk power system.
                                                                                                                                                                                                                                                                                  being managed by the other                                                                     However, the Mitigation Plan for the related
                                                                                                                                                                                                                                                                                  owner of these transmission lines,                                                            pre-June 18 violation (WECC200705842)
                                                                                                                                                                                                                                                                                  and CDWR did not have a                                                                       was not completed on time, which resulted
                                                                                                                                                                                                                                                                                  vegetation-caused outage.                                                                     in this post-June 18 violation. WECC
                                                                                                                                                                                                                                                                                                                                                                                considered these factors and determined
                                                                                                                                                                                                                                                                                                                                                                                that, notwithstanding the late completion of
                                                                                                                                                                                                                                                                                                                                                                                the Mitigation Plan, a zero dollar penalty
                                                                                                                                                                                                                                                                                                                                                                                was appropriate for this violation.
20
          WECC          California Department of               NOC-0284           WECC200810044               NCR05047            6/15/2007          2/19/2008       CDWR had not memorialized, as its own document, the        FAC-008-1                   1        Lower        WECC determined that the                   6/18/2007              3/14/2008           $0      The violation was self-reported, it was the        MIT-07-     3/14/2008     5/27/2008        7/6/2008      Self-Report                      Yes
                            Water Resources                                                                                                                          Facilities Rating Methodology used by the entity operating                                                   violation did not constitute a                                                                first violation of this Reliability Standard        0846
                                                                                                                                                                     its 4 transmission lines.                                                                                    serious or substantial risk to the                                                            incurred by CDWR and it did not constitute
                                                                                                                                                                                                                                                                                  bulk power system because                                                                     a serious or substantial risk to the bulk
                                                                                                                                                                                                                                                                                  CDWR's 4 operating transmission                                                               power system. However, the Mitigation
                                                                                                                                                                                                                                                                                  lines were operated by another                                                                Plan for the related pre-June 18 violation
                                                                                                                                                                                                                                                                                  entity and had ratings. Two of the                                                            (WECC200705843) was not completed on
                                                                                                                                                                                                                                                                                  transmission lines are jointly                                                                time, which resulted in this post-June 18
                                                                                                                                                                                                                                                                                  owned with the other entity and                                                               violation. WECC considered these factors
                                                                                                                                                                                                                                                                                  this same entity operates the other                                                           and determined that, notwithstanding the
                                                                                                                                                                                                                                                                                  2 transmission lines for CDWR.                                                                late completion of the Mitigation Plan, a
                                                                                                                                                                                                                                                                                                                                                                                zero dollar penalty was appropriate for this
21                                                                                                                                                                                                                                                                                                                                                                              violation.




                                                                                                                                                                                                                                                                                        WECC
     1
         Date of Verification of Completion is the WECC RSAW date, if complete. Otherwise, it is date of the Verification letter sent by WECC to the Registered Entity.                                                                                                                                                                                                                                                                                                                                                  Page 22 of 80
                                                                                                                                                                                                                                                                         10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                                                                                                                    PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                                                                                                                  CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                                                                                                                  HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.




              A                         B                            C                       D                       E                   F                G                                      H                                  I             J         K           L                          M                              N                     O               P                              Q                              R            S              T               U               V             W                X
                                                                                                                                   Date                 Date
                                                                                                                                Identified or                                                                                                                      Violation                                                                                                                                                                                 Registered       Regional
                                                                                                                                                    Identified or                                                                                                                                                                                                     Total
                                                                                                                                 Received                                                                                                                            Risk                                                                                                                                                                                      Entity          Entity
                                                                                                                                                      Received                                                                               Regional                                                                                                                Penalty                                                      Mitigation   Mitigation                                                    Separate
                                                                                 NERC Violation ID                               (Pre-June                                                                                     Reliability                          Factor*                                              Violation Start Date                                                 Additional Factors                                            Certification   Verification    Discovery                      Signed
          Region              Registered Entity                  NOC-ID                                         NCR_ID                               (Post-June                     Description of the Violation                             Reliability   Req.                            Risk Assessment                                      Violation End Date      or                                                          Plan         Plan                                                       Settlement
                                                                                        #                                            18                                                                                        Standard                                                                                 (Post-June 18, 2007)                                               for the Basis of Penalty                                         of Mitigation   of Mitigation    Method                    Disposition Letter
                                                                                                                                                    18 Violation)                                                                            Standard                                                                                                                Sanction                                                      Number      Completed                                                    Agreement
                                                                                                                                 Violation)*                                                                                                                           *See                                                                                                                                                                                     Plan            Plan
                                                                                                                                                                                                                                                                                                                                                                       ($)
                                                                                                                                                                                                                                                                   Attachment C                                                                                                                                                                              Completion     Completion1
1                                                                                                                                  *if applicable

          WECC                Central Electric                 NOC-0285           WECC200710069               NCR05061            5/23/2007         10/31/2007 CEC/PNGC did not have evidence that it was providing            TOP-002-2                    3       Medium        WECC determined that the                   6/18/2007              5/28/2008           $0      The violation was self-reported, it was the        MIT-07-     5/28/2008     5/29/2008       12/2/2008      Self-Report                        Yes
                               Coop/PNGC                                                                                                                       forecasts to Host Balancing Authorities except BPA.                                                                violation did not constitute a                                                                first violation of this Reliability Standard        0776
                                                                                                                                                                                                                                                                                  serious or substantial risk to the                                                            incurred by CEC/PNGC and it did not
                                                                                                                                                                                                                                                                                  bulk power system because                                                                     constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                  CEC/PNGC was coordinating with                                                                the bulk power system. However, the
                                                                                                                                                                                                                                                                                  the Balancing Authority and                                                                   Mitigation Plan for the related pre-June 18
                                                                                                                                                                                                                                                                                  Transmission Service Provider                                                                 violation (WECC200702595) was not
                                                                                                                                                                                                                                                                                  although not as required by the                                                               completed on time, which resulted in this
                                                                                                                                                                                                                                                                                  standard.                                                                                     post-June 18 violation. Additionally,
                                                                                                                                                                                                                                                                                                                                                                                CEC/PNGC completed its Mitigation Plan
                                                                                                                                                                                                                                                                                                                                                                                approximately 2 months after its approved
                                                                                                                                                                                                                                                                                                                                                                                completion date of 3/31/2008. WECC
                                                                                                                                                                                                                                                                                                                                                                                considered these factors and determined
                                                                                                                                                                                                                                                                                                                                                                                that, notwithstanding the late completion of
                                                                                                                                                                                                                                                                                                                                                                                the Mitigation Plan, a zero dollar penalty
22                                                                                                                                                                                                                                                                                                                                                                              was appropriate for this violation.
          WECC          Central Lincoln People's               NOC-0286           WECC200810225               NCR05062            5/25/2007          3/13/2008       CLPD did not provide its operating personnel with         CIP-001-1                    3       Medium        WECC determined that the                   6/18/2007              3/31/2008           $0      The violation was self-reported, it was the        MIT-07-     3/31/2008     3/31/2008      11/20/2008      Self-Report                        Yes
                             Utility District                                                                                                                        sabotage response guidelines, including personnel to                                                         violation did not constitute a                                                                first violation of this Reliability Standard        1054
                                                                                                                                                                     contact, for reporting disturbances due to sabotage                                                          serious or substantial risk to the                                                            incurred by CLPD and it did not constitute a
                                                                                                                                                                     events.                                                                                                      bulk power system because it had                                                              serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                  sabotage procedures and the                                                                   system. However, the Mitigation Plan for
                                                                                                                                                                                                                                                                                  sabotage procedures were                                                                      the related pre-June 18 violation
                                                                                                                                                                                                                                                                                  documented.                                                                                   (WECC200701965) was not completed on
                                                                                                                                                                                                                                                                                                                                                                                time, which resulted in this post-June 18
                                                                                                                                                                                                                                                                                                                                                                                violation. WECC considered these factors
                                                                                                                                                                                                                                                                                                                                                                                and determined that, notwithstanding the
                                                                                                                                                                                                                                                                                                                                                                                late completion of the Mitigation Plan, a
                                                                                                                                                                                                                                                                                                                                                                                zero dollar penalty was appropriate for this
23                                                                                                                                                                                                                                                                                                                                                                              violation.
          WECC          Central Lincoln People's               NOC-0286           WECC200800595               NCR05062                               1/16/2008       CLPD did not have a Protection System Maintenance and PRC-005-1                        1         High        WECC determined that the                   6/18/2007              3/5/2008            $0      The violation was self-reported, it was the        MIT-08-      3/5/2008      3/5/2008       3/13/2008      Self-Report                        Yes
                             Utility District                                                                                                                        Testing Program as required by the standard.                                                                 violation did not constitute a                                                                first violation of this Reliability Standard        0814
                                                                                                                                                                                                                                                                                  serious or substantial risk to the                                                            incurred by CLPD and it did not constitute a
                                                                                                                                                                     Specifically, this violation was Self–Reported on January                                                    bulk power system because of the                                                              serious or substantial risk to the bulk power
                                                                                                                                                                     16, 2008. CLPD stated that it needed to document which                                                       nature and location of CLPD's                                                                 system.
                                                                                                                                                                     Protection Systems affect the reliability of the bulk power                                                  facilities.
                                                                                                                                                                     system, write a maintenance and testing schedule for the
                                                                                                                                                                     affected equipment, implement the schedule, and
                                                                                                                                                                     document the implementation. CLPD completed
                                                                                                                                                                     mitigation of this violation on March 5, 2008. CLPD is a
24                                                                                                                                                                   small utility.
          WECC          Central Lincoln People's               NOC-0286           WECC200801560               NCR05062                               1/16/2008       CLPD did not implement its Protection System                PRC-005-1                 2.1        High        WECC determined that the                   6/18/2007              3/5/2008            $0      The violation was the first violation of this MIT-07-1941       3/5/2008      3/5/2008       3/13/2008         Self-                           Yes
                             Utility District                                                                                                                        Maintenance and Testing Program.                                                                             violation did not pose a serious or                                                           Reliability Standard incurred by CLPD and it                                                                Certification
                                                                                                                                                                                                                                                                                  substantial risk to the bulk power                                                            did not constitute a serious or substantial
                                                                                                                                                                                                                                                                                  system because of the nature and                                                              risk to the bulk power system.
25                                                                                                                                                                                                                                                                                location of CLPD's system.
          WECC               City of Healdsburg                NOC-0061           WECC200700453               NCR05491                               8/28/2007       The City of Healdsburg did not have written procedures    CIP-001-1                    1       Medium        WECC determined that the                   8/10/2007              10/9/2007           $0      The violation was self-reported, it was a          MIT-07-     10/9/2007    10/10/2007       2/21/2008      Self-Report                        Yes
                                                                                                                                                                     for the recognition of and for making its operating                                                          violation did not constitute a                                                                documentation issue, it was the first               0612
                                                                                                                                                                     personnel aware of sabotage events on its facilities.                                                        serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                  bulk power system because the                                                                 by the City of Healdsburg and it did not
                                                                                                                                                                                                                                                                                  City of Healdsburg had an                                                                     constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                  Emergency Management Plan in                                                                  the bulk power system.
                                                                                                                                                                                                                                                                                  place although it did not cover all
                                                                                                                                                                                                                                                                                  elements required by the
26                                                                                                                                                                                                                                                                                Reliability Standard.
          WECC               City of Healdsburg                NOC-0061           WECC200700454               NCR05491                               8/28/2007       The City of Healdsburg did not have written procedures    CIP-001-1                    2       Medium        WECC determined that the                   8/10/2007              10/9/2007           $0      The violation was self-reported, it was a          MIT-07-     10/9/2007    10/10/2007       2/21/2008      Self-Report                        Yes
                                                                                                                                                                     for the communication of information concerning                                                              violation did not constitute a                                                                documentation issue, it was the first               0612
                                                                                                                                                                     sabotage events to appropriate parties in the                                                                serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                     Interconnection.                                                                                             bulk power system because the                                                                 by the City of Healdsburg and it did not
                                                                                                                                                                                                                                                                                  City of Healdsburg had an                                                                     constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                  Emergency Management Plan in                                                                  the bulk power system.
                                                                                                                                                                                                                                                                                  place although it did not cover all
                                                                                                                                                                                                                                                                                  elements required by the
27                                                                                                                                                                                                                                                                                Reliability Standard.
          WECC               City of Healdsburg                NOC-0061           WECC200700455               NCR05491                               8/28/2007       The City of Healdsburg did not provide its operating      CIP-001-1                    3       Medium        WECC determined that the                   8/10/2007              10/9/2007           $0      The violation was self-reported, it was a          MIT-07-     10/9/2007    10/10/2007       2/21/2008      Self-Report                        Yes
                                                                                                                                                                     personnel with sabotage response guidelines, including                                                       violation did not constitute a                                                                documentation issue, it was the first               0612
                                                                                                                                                                     personnel to contact, for reporting disturbances due to                                                      serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                     sabotage events.                                                                                             bulk power system because the                                                                 by the City of Healdsburg and it did not
                                                                                                                                                                                                                                                                                  City of Healdsburg had an                                                                     constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                  Emergency Management Plan in                                                                  the bulk power system.
                                                                                                                                                                                                                                                                                  place although it did not cover all
                                                                                                                                                                                                                                                                                  elements required by the
28                                                                                                                                                                                                                                                                                Reliability Standard.
          WECC               City of Healdsburg                NOC-0061           WECC200700456               NCR05491                               8/28/2007       The City of Healdsburg did not establish communications   CIP-001-1                    4       Medium        WECC determined that the                   8/10/2007              10/9/2007           $0      The violation was self-reported, it was a          MIT-07-     10/9/2007    10/10/2007       5/13/2008      Self-Report                        Yes
                                                                                                                                                                     contacts, as applicable, with local Federal Bureau of                                                        violation did not constitute a                                                                documentation issue, it was the first               0612
                                                                                                                                                                     Investigation (FBI) officials and develop reporting                                                          serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                     procedures as appropriate to the circumstances.                                                              bulk power system because the                                                                 by the City of Healdsburg and it did not
                                                                                                                                                                                                                                                                                  City of Healdsburg had an                                                                     constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                  Emergency Management Plan in                                                                  the bulk power system.
                                                                                                                                                                                                                                                                                  place that required notification of
                                                                                                                                                                                                                                                                                  local government officials, who in
29                                                                                                                                                                                                                                                                                turn would contact the FBI.
          WECC               City of Healdsburg                NOC-0061           WECC200700457               NCR05491                               8/28/2007       The City of Healdsburg did not provide its underfrequency PRC-007-0                    2        Lower        WECC determined that the                   8/10/2007             12/26/2007           $0      The violation was self-reported, it was the        MIT-07-     12/26/2007   12/26/2007        3/5/2008      Self-Report                        Yes
                                                                                                                                                                     data annually as required by the standard.                                                                   violation did not constitute a                                                                first violation of this Reliability Standard        0613
                                                                                                                                                                                                                                                                                  serious or substantial risk to the                                                            incurred by the City of Healdsburg and it did
                                                                                                                                                                                                                                                                                  bulk power system because the                                                                 not constitute a serious or substantial risk
                                                                                                                                                                                                                                                                                  City of Healdsburg had a UFLS                                                                 to the bulk power system.
30                                                                                                                                                                                                                                                                                program.




                                                                                                                                                                                                                                                                                        WECC
     1
         Date of Verification of Completion is the WECC RSAW date, if complete. Otherwise, it is date of the Verification letter sent by WECC to the Registered Entity.                                                                                                                                                                                                                                                                                                                                                    Page 23 of 80
                                                                                                                                                                                                                                                                             10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                                                                                                                        PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                                                                                                                      CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                                                                                                                      HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.




              A                         B                            C                       D                       E                   F                G                                       H                                     I             J         K           L                          M                              N                     O               P                              Q                               R           S              T               U               V             W                X
                                                                                                                                   Date                 Date
                                                                                                                                Identified or                                                                                                                          Violation                                                                                                                                                                                 Registered       Regional
                                                                                                                                                    Identified or                                                                                                                                                                                                         Total
                                                                                                                                 Received                                                                                                                                Risk                                                                                                                                                                                      Entity          Entity
                                                                                                                                                      Received                                                                                   Regional                                                                                                                Penalty                                                      Mitigation   Mitigation                                                    Separate
                                                                                 NERC Violation ID                               (Pre-June                                                                                         Reliability                          Factor*                                              Violation Start Date                                                 Additional Factors                                            Certification   Verification    Discovery                      Signed
          Region              Registered Entity                  NOC-ID                                         NCR_ID                               (Post-June                      Description of the Violation                                Reliability   Req.                            Risk Assessment                                      Violation End Date      or                                                          Plan         Plan                                                       Settlement
                                                                                        #                                            18                                                                                            Standard                                                                                 (Post-June 18, 2007)                                               for the Basis of Penalty                                         of Mitigation   of Mitigation    Method                    Disposition Letter
                                                                                                                                                    18 Violation)                                                                                Standard                                                                                                                Sanction                                                      Number      Completed                                                    Agreement
                                                                                                                                 Violation)*                                                                                                                               *See                                                                                                                                                                                     Plan            Plan
                                                                                                                                                                                                                                                                                                                                                                           ($)
                                                                                                                                                                                                                                                                       Attachment C                                                                                                                                                                              Completion     Completion1
1                                                                                                                                  *if applicable

          WECC               City of Healdsburg                NOC-0061           WECC200700458               NCR05491                               8/28/2007       The City of Healdsburg did not provide documentation of PRC-007-0                          3        Lower        WECC determined that the                   8/10/2007             12/26/2007           $0      The violation was self-reported, it was the         MIT-07-    12/26/2007   12/26/2007        3/5/2008      Self-Report                        Yes
                                                                                                                                                                     its UFLS program to its Regional Entity as required by the                                                       violation did not constitute a                                                                first violation of this Reliability Standard         0613
                                                                                                                                                                     standard.                                                                                                        serious or substantial risk to the                                                            incurred by the City of Healdsburg and it did
                                                                                                                                                                                                                                                                                      bulk power system because the                                                                 not constitute a serious or substantial risk
                                                                                                                                                                                                                                                                                      City of Healdsburg had a UFLS                                                                 to the bulk power system.
31                                                                                                                                                                                                                                                                                    program.
          WECC               City of Healdsburg                NOC-0061           WECC200700460               NCR05491                               8/28/2007       The City of Healdsburg had not documented its UFLS            PRC-008-0                    1       Medium        WECC determined that the                   8/10/2007             12/26/2007           $0      The violation was self-reported, it was a           MIT-07-    12/26/2007   12/26/2007       3/25/2008      Self-Report                        Yes
                                                                                                                                                                     equipment maintenance and testing program as required                                                            violation did not constitute a                                                                documentation issue, it was the first                0614
                                                                                                                                                                     by the standard.                                                                                                 serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                      bulk power system because of                                                                  by the City of Healdsburg and it did not
                                                                                                                                                                     The City of Healdsburg had contracted with a third party                                                         nature and location of the City of                                                            constitute a serious or substantial risk to
                                                                                                                                                                     to conduct the testing and maintenance of the equipment,                                                         Healdsburg interconnection. The                                                               the bulk power system.
                                                                                                                                                                     but the procedures that the third party used to perform                                                          City of Healdsburg is
                                                                                                                                                                     the testing were not documented and the City of                                                                  interconnected by a 60 kV radial
                                                                                                                                                                     Healdsburg had not memorialized the procedures as its                                                            feed system.
                                                                                                                                                                     own program.
                                                                                                                                                                                                                                                                                      The City of Healdsburg owns,
                                                                                                                                                                                                                                                                                      operates, and maintains a UFLS.
                                                                                                                                                                                                                                                                                      While testing and maintenance of
                                                                                                                                                                                                                                                                                      the equipment was taking place, it
                                                                                                                                                                                                                                                                                      was not in accordance with the
                                                                                                                                                                                                                                                                                      requirements of the Reliability
32
                                                                                                                                                                                                                                                                                      Standard.
          WECC               City of Healdsburg                NOC-0061           WECC200700461               NCR05491                               8/28/2007       The City of Healdsburg had not implemented its UFLS       PRC-008-0                        2       Medium        WECC determined that the                   6/18/2007             12/26/2007           $0      The violation was self-reported, it was a           MIT-07-    12/26/2007   12/26/2007       3/25/2008      Self-Report                        Yes
                                                                                                                                                                     equipment maintenance and testing program as required                                                            violation did not constitute a                                                                documentation issue, it was the first                0614
                                                                                                                                                                     by the standard. The City of Healdsburg had contracted                                                           serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                     with a third party to conduct the testing and maintenance                                                        bulk power system because of the                                                              by the City of Healdsburg and it did not
                                                                                                                                                                     of the equipment, but the procedures that the third party                                                        nature and location of the City of                                                            constitute a serious or substantial risk to
                                                                                                                                                                     used to perform the testing were not documented and the                                                          Healdsburg interconnection.                                                                   the bulk power system.
                                                                                                                                                                     City of Healdsburg had not memorialized the procedures
                                                                                                                                                                     as its own program.                                                                                              The City of Healdsburg had
                                                                                                                                                                                                                                                                                      contracted with a third party to
                                                                                                                                                                                                                                                                                      conduct the testing and
                                                                                                                                                                                                                                                                                      maintenance of the equipment,
                                                                                                                                                                                                                                                                                      but the procedures that the third
                                                                                                                                                                                                                                                                                      party used to perform the testing
                                                                                                                                                                                                                                                                                      were not documented and the City
                                                                                                                                                                                                                                                                                      of Healdsburg had not
                                                                                                                                                                                                                                                                                      memorialized the procedures as
                                                                                                                                                                                                                                                                                      its own program.



33
          WECC           City of Pasadena Water                NOC-0287           WECC200801590               NCR05090                               4/9/2008        CYPW did not have procedures for the recognition of and       CIP-001-1                    1       Medium        WECC determined that the                   6/18/2007              7/25/2007           $0      The violation was the first violation of this     MIT-07-1953 7/25/2007       4/9/2008       6/10/2008         Self-                           Yes
                                 and Power                                                                                                                           for making its operating personnel aware of sabotage                                                             violation did not constitute a                                                                Reliability Standard incurred by CYPW and                                                                   Certification
                                                                                                                                                                     events on its facilities and multi-site sabotage affecting                                                       serious or substantial risk to the                                                            it did not constitute a serious or substantial
                                                                                                                                                                     larger portions of the Interconnection until July 25, 2007,                                                      bulk power system because of the                                                              risk to the bulk power system.
                                                                                                                                                                     when it officially adopted its Sabotage Reporting Policy                                                         nature and the location of CYPW's
34                                                                                                                                                                   and Procedure.                                                                                                   assets.
          WECC           City of Pasadena Water                NOC-0287           WECC200801591               NCR05090                               4/9/2008        CYPW did not have procedures for the communication of         CIP-001-1                    2       Medium        WECC determined that the                   6/18/2007              7/25/2007           $0      The violation was the first violation of this     MIT-07-1953 7/25/2007       4/9/2008       6/10/2008         Self-                           Yes
                                 and Power                                                                                                                           information concerning sabotage events to appropriate                                                            violation did not constitute a                                                                Reliability Standard incurred by CYPW and                                                                   Certification
                                                                                                                                                                     parties in the Interconnection until July 25, 2007, when it                                                      serious or substantial risk to the                                                            it did not constitute a serious or substantial
                                                                                                                                                                     officially adopted its Sabotage Reporting Policy and                                                             bulk power system because of the                                                              risk to the bulk power system.
                                                                                                                                                                     Procedure.                                                                                                       nature and the location of CYPW's
35                                                                                                                                                                                                                                                                                    assets.
          WECC           City of Pasadena Water                NOC-0287           WECC200801592               NCR05090                               4/9/2008        CYPW had not provided its operating personnel with            CIP-001-1                    3       Medium        WECC determined that the                   6/18/2007              7/25/2007           $0      The violation was the first violation of this     MIT-07-1953 7/25/2007       4/9/2008       6/10/2008         Self-                           Yes
                                 and Power                                                                                                                           sabotage response guidelines, including personnel to                                                             violation did not constitute a                                                                Reliability Standard incurred by CYPW and                                                                   Certification
                                                                                                                                                                     contact, for reporting disturbances due to sabotage                                                              serious or substantial risk to the                                                            it did not constitute a serious or substantial
                                                                                                                                                                     events. CYPW officially adopted its Sabotage Reporting                                                           bulk power system because of the                                                              risk to the bulk power system.
                                                                                                                                                                     Policy and Procedure July 25, 2007.                                                                              nature and the location of CYPW's
36                                                                                                                                                                                                                                                                                    assets.
          WECC           City of Pasadena Water                NOC-0287           WECC200801593               NCR05090                               4/9/2008        CYPW had not established communications contacts, as          CIP-001-1                    4       Medium        WECC determined that the                   6/18/2007              7/25/2007           $0      The violation was the first violation of this     MIT-07-1953 7/25/2007       4/9/2008       6/10/2008         Self-                           Yes
                                 and Power                                                                                                                           applicable, with local Federal Bureau of Investigation                                                           violation did not constitute a                                                                Reliability Standard incurred by CYPW and                                                                   Certification
                                                                                                                                                                     (FBI) or Royal Canadian Mounted Police (RCMP) officials                                                          serious or substantial risk to the                                                            it did not constitute a serious or substantial
                                                                                                                                                                     and had not developed reporting procedures as                                                                    bulk power system because of the                                                              risk to the bulk power system.
                                                                                                                                                                     appropriate to their circumstances. CYPW officially                                                              nature and the location of CYPW's
                                                                                                                                                                     adopted its Sabotage Reporting Policy and Procedure                                                              assets.
37                                                                                                                                                                   July 25, 2007.
          WECC                 City of Redding                 NOC-0288           WECC200700532               NCR05091                               10/2/2007       The required unscheduled flow relief was not provided.        IRO-STD-         WR          1         N/A         WECC determined that the                   6/18/2007              3/28/2008           $0      The violation was the first violation of this       MIT-07-    3/28/2008     3/28/2008       12/3/2008      Exception                          Yes
                                                                                                                                                                     Violations of this regional standard have diminished, in        006-0                                            violation did not constitute a                                                                Reliability Standard incurred by the City of         1650                                                   Reporting
                                                                                                                                                                     part, due to better communication tools (primarily more                                                          serious or substantial risk to the                                                            Redding and it did not constitute a serious
                                                                                                                                                                     entities utilizing better software (e.g., webSAS)).                                                              bulk power system because the                                                                 or substantial risk to the bulk power system.
                                                                                                                                                                     Unscheduled flow (USF) occurs in the Western                                                                     noncompliance did not result in a
                                                                                                                                                                     Interconnection because of concentrated load centers                                                             Operating Transfer Capability limit
                                                                                                                                                                     (mainly on the West Coast), remote generation resources                                                          to be exceeded.
                                                                                                                                                                     (many on the Eastern side of WECC) and long
                                                                                                                                                                     transmission lines in between. The WECC high voltage
                                                                                                                                                                     transmission lines form a circle (“О”) in the
                                                                                                                                                                     Interconnection, which results in the electricity from the
                                                                                                                                                                     generation resources dividing, with some small
                                                                                                                                                                     percentage flowing around the opposite side of the “O” to
                                                                                                                                                                     reach the load centers (this is the USF). USF can occur
                                                                                                                                                                     at any time depending on the amount of power being
                                                                                                                                                                     generated and used in the load centers. Certain actions
                                                                                                                                                                     are taken to control and absorb the USF (e.g., adjusting
                                                                                                                                                                     phase shifting transformers, accommodation, etc.) but
                                                                                                                                                                     ultimately an entity may have to reduce schedules,
                                                                                                                                                                     thereby reducing the amount of power flowing (thereby
38
                                                                                                                                                                     reducing the amount of unscheduled flow). While an
                                                                                                                                                                     entity may be taking action to address this, an entity may


                                                                                                                                                                                                                                                                                            WECC
     1
         Date of Verification of Completion is the WECC RSAW date, if complete. Otherwise, it is date of the Verification letter sent by WECC to the Registered Entity.                                                                                                                                                                                                                                                                                                                                                        Page 24 of 80
                                                                                                                                                                                                                                                                             10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                                                                                                                        PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                                                                                                                      CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                                                                                                                      HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.




              A                         B                            C                       D                       E                   F                G                                       H                                     I             J         K           L                          M                              N                     O               P                              Q                              R            S              T               U               V             W                X
                                                                                                                                   Date                 Date
                                                                                                                                Identified or                                                                                                                          Violation                                                                                                                                                                                 Registered       Regional
                                                                                                                                                    Identified or                                                                                                                                                                                                         Total
                                                                                                                                 Received                                                                                                                                Risk                                                                                                                                                                                      Entity          Entity
                                                                                                                                                      Received                                                                                   Regional                                                                                                                Penalty                                                      Mitigation   Mitigation                                                    Separate
                                                                                 NERC Violation ID                               (Pre-June                                                                                         Reliability                          Factor*                                              Violation Start Date                                                 Additional Factors                                            Certification   Verification    Discovery                      Signed
          Region              Registered Entity                  NOC-ID                                         NCR_ID                               (Post-June                      Description of the Violation                                Reliability   Req.                            Risk Assessment                                      Violation End Date      or                                                          Plan         Plan                                                       Settlement
                                                                                        #                                            18                                                                                            Standard                                                                                 (Post-June 18, 2007)                                               for the Basis of Penalty                                         of Mitigation   of Mitigation    Method                    Disposition Letter
                                                                                                                                                    18 Violation)                                                                                Standard                                                                                                                Sanction                                                      Number      Completed                                                    Agreement
                                                                                                                                 Violation)*                                                                                                                               *See                                                                                                                                                                                     Plan            Plan
                                                                                                                                                                                                                                                                                                                                                                           ($)
                                                                                                                                                                                                                                                                       Attachment C                                                                                                                                                                              Completion     Completion1
1                                                                                                                                  *if applicable

          WECC                City of Roseville                NOC-0289           WECC200700631               NCR05094                               6/18/2007       The City of Roseville did not have procedures for the         CIP-001-1                    1       Medium        WECC determined that the                   6/18/2007              8/30/2007           $0      The violation was self-reported, it was the        MIT-07-     8/30/2007     8/30/2007       9/24/2007      Self-Report                        Yes
                                                                                                                                                                     recognition of and for making its operating personnel                                                            violation did not constitute a                                                                first violation of this Reliability Standard        0680
                                                                                                                                                                     aware of sabotage events on its facilities. However, a                                                           serious or substantial risk to the                                                            incurred by the City of Roseville and it did
                                                                                                                                                                     draft plan had been prepared as of June 18, 2007.                                                                bulk power system because of the                                                              not constitute a serious or substantial risk
                                                                                                                                                                                                                                                                                      nature and the location of the City                                                           to the bulk power system.
39                                                                                                                                                                                                                                                                                    of Roseville's assets.
          WECC                City of Roseville                NOC-0289           WECC200700632               NCR05094                               6/18/2007       The City of Roseville did not have procedures for the         CIP-001-1                    2       Medium        WECC determined that the                   6/18/2007              8/30/2007           $0      The violation was self-reported, it was the        MIT-07-     8/30/2007     8/30/2007       9/24/2007      Self-Report                        Yes
                                                                                                                                                                     communication of information concerning sabotage                                                                 violation did not constitute a                                                                first violation of this Reliability Standard        0680
                                                                                                                                                                     events to appropriate parties in the Interconnection.                                                            serious or substantial risk to the                                                            incurred by the City of Roseville and it did
                                                                                                                                                                     However, a draft plan had been prepared as of June 18,                                                           bulk power system because of the                                                              not constitute a serious or substantial risk
                                                                                                                                                                     2007.                                                                                                            nature and the location of the City                                                           to the bulk power system.
40                                                                                                                                                                                                                                                                                    of Roseville's assets.
          WECC                City of Roseville                NOC-0289           WECC200700633               NCR05094                               6/18/2007       The City of Roseville did not have procedures to provide      CIP-001-1                    3       Medium        WECC determined that the                   6/18/2007              8/30/2007           $0      The violation was self-reported, it was the        MIT-07-     8/30/2007     8/30/2007       9/24/2007      Self-Report                        Yes
                                                                                                                                                                     its operating personnel with sabotage response                                                                   violation did not constitute a                                                                first violation of this Reliability Standard        0680
                                                                                                                                                                     guidelines, including personnel to contact, for reporting                                                        serious or substantial risk to the                                                            incurred by the City of Roseville and it did
                                                                                                                                                                     disturbances due to sabotage events. However, a draft                                                            bulk power system because of the                                                              not constitute a serious or substantial risk
                                                                                                                                                                     plan had been prepared as of June 18, 2007.                                                                      nature and the location of the City                                                           to the bulk power system.
41                                                                                                                                                                                                                                                                                    of Roseville's assets.
          WECC                City of Roseville                NOC-0289           WECC200700634               NCR05094                               6/18/2007       The City of Roseville did not establish communications        CIP-001-1                    4       Medium        WECC determined that the                   6/18/2007              2/5/2008            $0      The violation was self-reported, it was the        MIT-07-     2/5/2008       2/5/2008       2/14/2008      Self-Report                        Yes
                                                                                                                                                                     contacts, as applicable, with local Federal Bureau of                                                            violation did not constitute a                                                                first violation of this Reliability Standard        0680
                                                                                                                                                                     Investigation (FBI) officials and develop reporting                                                              serious or substantial risk to the                                                            incurred by the City of Roseville and it did
                                                                                                                                                                     procedures as appropriate to the circumstances.                                                                  bulk power system because of the                                                              not constitute a serious or substantial risk
                                                                                                                                                                     However, a draft plan had been prepared as of June 18,                                                           nature and the location of the City                                                           to the bulk power system.
42                                                                                                                                                                   2007.                                                                                                            of Roseville's assets.
          WECC                City of Roseville                NOC-0062           WECC200700050               NCR05094                               6/18/2007       The City of Roseville had not documented its UFLS             PRC-008-0                    1       Medium        WECC determined that the                   6/18/2007              8/9/2007            $0      The violation was self-reported, it was a          MIT-07-     8/9/2007       8/9/2007       11/5/2007      Self-Report                        Yes
                                                                                                                                                                     equipment maintenance and testing program as required                                                            violation did not constitute a                                                                documentation issue, it was the first               0301
                                                                                                                                                                     by the standard.                                                                                                 serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                      bulk power system because the                                                                 by the City of Roseville and it did not
                                                                                                                                                                                                                                                                                      City of Roseville was performing                                                              constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                      testing but specific documentation                                                            the bulk power system.
                                                                                                                                                                                                                                                                                      of equipment was not complete.
43
          WECC                City of Roseville                NOC-0062           WECC200700051               NCR05094                               6/18/2007       The City of Roseville had not documented its UVLS      PRC-011-0                           1       Medium        WECC determined that the                   6/18/2007              7/13/2007           $0      The violation was self-reported, it was a          MIT-07-     7/13/2007     7/13/2007       5/14/2008      Self-Report                        Yes
                                                                                                                                                                     Maintenance and Testing Program in accordance with the                                                           violation did not constitute a                                                                documentation issue, it was the first               0302
                                                                                                                                                                     Reliability Standard requirement.                                                                                serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                      bulk power system because,                                                                    by the City of Roseville and it did not
                                                                                                                                                                                                                                                                                      although it had not documented in                                                             constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                      accordance with the Reliability                                                               the bulk power system.
                                                                                                                                                                                                                                                                                      Standard requirement's Program,
                                                                                                                                                                                                                                                                                      the City of Roseville was already
                                                                                                                                                                                                                                                                                      conducting maintenance and
                                                                                                                                                                                                                                                                                      testing on applicable system
44                                                                                                                                                                                                                                                                                    components.
          WECC                City of Roseville                NOC-0062           WECC200700052               NCR05094                               6/18/2007       The City of Roseville was not able to provide all of the      PRC-021-1                    2        Lower        WECC determined that the                   6/18/2007              8/3/2007            $0      The violation was self-reported, it was a          MIT-07-     8/3/2007       8/3/2007       11/5/2008      Self-Report                        Yes
                                                                                                                                                                     required UVLS program data within 30 calendar days                                                               violation did not constitute a                                                                documentation issue, it was the first               0303
                                                                                                                                                                     because the overall clearing time data would not have                                                            serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                     been available until system testing was completed in July                                                        bulk power system because the                                                                 by the City of Roseville and it did not
                                                                                                                                                                     2007.                                                                                                            reporting of the overall clearing                                                             constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                      time would not affect the operation                                                           the bulk power system.
45                                                                                                                                                                                                                                                                                    of the UVLS.
          WECC              City of Shasta Lake                NOC-0290           WECC200801052               NCR05095                               4/10/2008       The City of Shasta Lake did not update its procedures for     CIP-001-1                    1       Medium        WECC determined that the                   6/18/2007              4/10/2008           $0      The violation was the first violation of this      MIT-07-     4/10/2008     4/10/2008      11/18/2008         Self-                           Yes
                                                                                                                                                                     the recognition of, and for making its operating personnel                                                       violation did not constitute a                                                                Reliability Standard incurred by the City of        1184                                                    Certification
                                                                                                                                                                     aware of sabotage, events on its facilities annually.                                                            serious or substantial risk to the                                                            Shasta Lake and it did not constitute a
                                                                                                                                                                                                                                                                                      bulk power system because of the                                                              serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                      nature and the location of the City                                                           system.
46                                                                                                                                                                                                                                                                                    of Shasta Lake's assets.
          WECC              City of Shasta Lake                NOC-0290           WECC200801053               NCR05095                               4/10/2008       The City of Shasta Lake did not have procedures for the       CIP-001-1                    2       Medium        WECC determined that the                   6/18/2007              4/10/2008           $0      The violation was the first violation of this      MIT-07-     4/10/2008     4/10/2008      11/18/2008         Self-                           Yes
                                                                                                                                                                     communication of information concerning sabotage                                                                 violation did not constitute a                                                                Reliability Standard incurred by the City of        1184                                                    Certification
                                                                                                                                                                     events to appropriate parties in the Interconnection.                                                            serious or substantial risk to the                                                            Shasta Lake and it did not constitute a
                                                                                                                                                                                                                                                                                      bulk power system because of the                                                              serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                      nature and the location of the City                                                           system.
47                                                                                                                                                                                                                                                                                    of Shasta Lake's assets.
          WECC              City of Shasta Lake                NOC-0290           WECC200801054               NCR05095                               4/10/2008       The City of Shasta Lake did not provide its operating         CIP-001-1                    3       Medium        WECC determined that the                   6/18/2007              4/10/2008           $0      The violation was the first violation of this      MIT-07-     4/10/2008     4/10/2008      11/18/2008         Self-                           Yes
                                                                                                                                                                     personnel with sabotage response guidelines, including                                                           violation did not constitute a                                                                Reliability Standard incurred by the City of        1184                                                    Certification
                                                                                                                                                                     personnel to contact, for reporting disturbances due to                                                          serious or substantial risk to the                                                            Shasta Lake and it did not constitute a
                                                                                                                                                                     sabotage events.                                                                                                 bulk power system because of the                                                              serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                      nature and the location of the City                                                           system.
48                                                                                                                                                                                                                                                                                    of Shasta Lake's assets.
          WECC              City of Shasta Lake                NOC-0290           WECC200801055               NCR05095                               4/10/2008       The City of Shasta Lake did not provide evidence that it      CIP-001-1                    4       Medium        WECC determined that the                   6/18/2007              4/10/2008           $0      The violation was the first violation of this      MIT-07-     4/10/2008     4/10/2008      11/18/2008         Self-                           Yes
                                                                                                                                                                     had established communications contacts, as applicable,                                                          violation did not constitute a                                                                Reliability Standard incurred by the City of        1184                                                    Certification
                                                                                                                                                                     with local Federal Bureau of Investigation (FBI) officials.                                                      serious or substantial risk to the                                                            Shasta Lake and it did not constitute a
                                                                                                                                                                                                                                                                                      bulk power system because of the                                                              serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                      nature and the location of the City                                                           system.
49                                                                                                                                                                                                                                                                                    of Shasta Lake's assets.
          WECC                   City of Ukiah                 NOC-0355           WECC200800661               NCR05494                               1/2/2008        Although the City of Ukiah had emergency procedures in        CIP-001-1                    1       Medium        WECC determined that the                   8/10/2007              6/17/2008           $0      The violation was self-reported, it was the        MIT-07-     6/17/2008     6/17/2008       12/2/2008      Self-Report                  Auto-accepted
                                                                                                                                                                     place to deal with electric system emergencies, it did not                                                       violation did not constitute a                                                                first violation of this Reliability Standard        0716
                                                                                                                                                                     have procedures for the recognition of and for making its                                                        serious or substantial risk to the                                                            incurred by the City of Ukiah and it did not
                                                                                                                                                                     operating personnel aware of sabotage events on its                                                              bulk power system because the                                                                 constitute a serious or substantial risk to
                                                                                                                                                                     facilities.                                                                                                      City of Ukiah had emergency                                                                   the bulk power system. The City of Ukiah
                                                                                                                                                                                                                                                                                      procedures in place to deal with                                                              failed to complete its original Mitigation Plan
                                                                                                                                                                                                                                                                                      electric system emergencies and                                                               by the approved 3/15/2008 completion date.
                                                                                                                                                                                                                                                                                      the nature and the location of the                                                             WECC approved a revised Mitigation Plan
                                                                                                                                                                                                                                                                                      City of Ukiah's assets.                                                                       that was completed on 6/17/2008. WECC
                                                                                                                                                                                                                                                                                                                                                                                    considered these factors and determined
                                                                                                                                                                                                                                                                                                                                                                                    that, notwithstanding the late completion of
                                                                                                                                                                                                                                                                                                                                                                                    the Mitigation Plan, a zero dollar penalty
                                                                                                                                                                                                                                                                                                                                                                                    was appropriate for this violation.
50




                                                                                                                                                                                                                                                                                            WECC
     1
         Date of Verification of Completion is the WECC RSAW date, if complete. Otherwise, it is date of the Verification letter sent by WECC to the Registered Entity.                                                                                                                                                                                                                                                                                                                                                        Page 25 of 80
                                                                                                                                                                                                                                                                            10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                                                                                                                       PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                                                                                                                     CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                                                                                                                     HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.




              A                         B                            C                       D                       E                   F                G                                       H                                    I             J         K           L                          M                             N                     O               P                              Q                              R            S              T               U               V             W                X
                                                                                                                                   Date                 Date
                                                                                                                                Identified or                                                                                                                         Violation                                                                                                                                                                                Registered       Regional
                                                                                                                                                    Identified or                                                                                                                                                                                                       Total
                                                                                                                                 Received                                                                                                                               Risk                                                                                                                                                                                     Entity          Entity
                                                                                                                                                      Received                                                                                  Regional                                                                                                               Penalty                                                      Mitigation   Mitigation                                                    Separate
                                                                                 NERC Violation ID                               (Pre-June                                                                                        Reliability                          Factor*                                             Violation Start Date                                                 Additional Factors                                            Certification   Verification    Discovery                      Signed
          Region              Registered Entity                  NOC-ID                                         NCR_ID                               (Post-June                      Description of the Violation                               Reliability   Req.                            Risk Assessment                                     Violation End Date      or                                                          Plan         Plan                                                       Settlement
                                                                                        #                                            18                                                                                           Standard                                                                                (Post-June 18, 2007)                                               for the Basis of Penalty                                         of Mitigation   of Mitigation    Method                    Disposition Letter
                                                                                                                                                    18 Violation)                                                                               Standard                                                                                                               Sanction                                                      Number      Completed                                                    Agreement
                                                                                                                                 Violation)*                                                                                                                              *See                                                                                                                                                                                    Plan            Plan
                                                                                                                                                                                                                                                                                                                                                                         ($)
                                                                                                                                                                                                                                                                      Attachment C                                                                                                                                                                             Completion     Completion1
1                                                                                                                                  *if applicable

          WECC                   City of Ukiah                 NOC-0355           WECC200800622               NCR05494                               1/2/2008        Although the City of Ukiah had emergency procedures in       CIP-001-1                    2       Medium        WECC determined that the                  8/10/2007              6/17/2008           $0      The violation was self-reported, it was the        MIT-07-     6/17/2008     6/17/2008       12/2/2008      Self-Report                  Auto-accepted
                                                                                                                                                                     place to deal with electric system emergencies, it did not                                                      violation did not constitute a                                                               first violation of this Reliability Standard        0716
                                                                                                                                                                     have procedures for the communication of information                                                            serious or substantial risk to the                                                           incurred by the City of Ukiah and it did not
                                                                                                                                                                     concerning sabotage events to appropriate parties in the                                                        bulk power system because the                                                                constitute a serious or substantial risk to
                                                                                                                                                                     Interconnection.                                                                                                City of Ukiah had emergency                                                                  the bulk power system. The City of Ukiah
                                                                                                                                                                                                                                                                                     procedures in place to deal with                                                             failed to complete its original Mitigation Plan
                                                                                                                                                                                                                                                                                     electric system emergencies and                                                              by the approved 3/15/2008 completion date.
                                                                                                                                                                                                                                                                                     the nature and the location of the                                                            WECC approved a revised Mitigation Plan
                                                                                                                                                                                                                                                                                     City of Ukiah's assets.                                                                      that was completed on 6/17/2008. WECC
                                                                                                                                                                                                                                                                                                                                                                                  considered these factors and determined
                                                                                                                                                                                                                                                                                                                                                                                  that, notwithstanding the late completion of
                                                                                                                                                                                                                                                                                                                                                                                  the Mitigation Plan, a zero dollar penalty
                                                                                                                                                                                                                                                                                                                                                                                  was appropriate for this violation.
51
          WECC                   City of Ukiah                 NOC-0355           WECC200800623               NCR05494                               1/2/2008        Although the City of Ukiah had emergency procedures in       CIP-001-1                    3       Medium        WECC determined that the                  8/10/2007              6/17/2008           $0      The violation was self-reported, it was the        MIT-07-     6/17/2008     6/17/2008       12/2/2008      Self-Report                  Auto-accepted
                                                                                                                                                                     place to deal with electric system emergencies, it did not                                                      violation did not constitute a                                                               first violation of this Reliability Standard        0716
                                                                                                                                                                     provide its operating personnel with sabotage response                                                          serious or substantial risk to the                                                           incurred by the City of Ukiah and it did not
                                                                                                                                                                     guidelines, including personnel to contact, for reporting                                                       bulk power system because the                                                                constitute a serious or substantial risk to
                                                                                                                                                                     disturbances due to sabotage events.                                                                            City of Ukiah had emergency                                                                  the bulk power system. The City of Ukiah
                                                                                                                                                                                                                                                                                     procedures in place to deal with                                                             failed to complete its original Mitigation Plan
                                                                                                                                                                                                                                                                                     electric system emergencies and                                                              by the approved 3/15/2008 completion date.
                                                                                                                                                                                                                                                                                     the nature and the location of the                                                            WECC approved a revised Mitigation Plan
                                                                                                                                                                                                                                                                                     City of Ukiah's assets.                                                                      that was completed on 6/17/2008. WECC
                                                                                                                                                                                                                                                                                                                                                                                  considered these factors and determined
                                                                                                                                                                                                                                                                                                                                                                                  that, notwithstanding the late completion of
                                                                                                                                                                                                                                                                                                                                                                                  the Mitigation Plan, a zero dollar penalty
                                                                                                                                                                                                                                                                                                                                                                                  was appropriate for this violation.
52
          WECC                   City of Ukiah                 NOC-0355           WECC200800624               NCR05494                               1/2/2008        Although the City of Ukiah had emergency procedures in       CIP-001-1                    4       Medium        WECC determined that the                  8/10/2007              6/17/2008           $0      The violation was self-reported, it was the        MIT-07-     6/17/2008     6/17/2008       12/2/2008      Self-Report                  Auto-accepted
                                                                                                                                                                     place to deal with electric system emergencies, it did not                                                      violation did not constitute a                                                               first violation of this Reliability Standard        0716
                                                                                                                                                                     provide evidence that it had established communications                                                         serious or substantial risk to the                                                           incurred by the City of Ukiah and it did not
                                                                                                                                                                     contacts, as applicable, with local Federal Bureau of                                                           bulk power system because the                                                                constitute a serious or substantial risk to
                                                                                                                                                                     Investigation (FBI) officials and developed reporting                                                           City of Ukiah had emergency                                                                  the bulk power system. The City of Ukiah
                                                                                                                                                                     procedures as appropriate to the circumstances.                                                                 procedures in place to deal with                                                             failed to complete its original Mitigation Plan
                                                                                                                                                                                                                                                                                     electric system emergencies and                                                              by the approved 3/15/2008 completion date.
                                                                                                                                                                                                                                                                                     the nature and the location of the                                                            WECC approved a revised Mitigation Plan
                                                                                                                                                                                                                                                                                     City of Ukiah's assets.                                                                      that was completed on 6/17/2008. WECC
                                                                                                                                                                                                                                                                                                                                                                                  considered these factors and determined
                                                                                                                                                                                                                                                                                                                                                                                  that, notwithstanding the late completion of
                                                                                                                                                                                                                                                                                                                                                                                  the Mitigation Plan, a zero dollar penalty
                                                                                                                                                                                                                                                                                                                                                                                  was appropriate for this violation.
53
          WECC                Clatskanie PUD                   NOC-0292           WECC200801178               NCR05100                               6/25/2008       Clatskanie PUD did not have procedures for the               CIP-001-1                    1       Medium        WECC determined that the                  6/18/2007              8/1/2008            $0      The violation was the first violation of this      MIT-07-     8/1/2008      7/16/2009        9/1/2009         Self-                           Yes
                                                                                                                                                                     recognition of and for making its operating personnel                                                           violation did not constitute a                                                               Reliability Standard incurred by Clatskanie         1210                                                    Certification
                                                                                                                                                                     aware of sabotage events on its facilities because it was                                                       serious or substantial risk to the                                                           PUD and it did not constitute a serious or
                                                                                                                                                                     had been relying upon the Balancing Authority to perform                                                        bulk power system because of the                                                             substantial risk to the bulk power system.
                                                                                                                                                                     this function.                                                                                                  nature and the location of
54                                                                                                                                                                                                                                                                                   Clatskanie PUD's assets.
          WECC                Clatskanie PUD                   NOC-0292           WECC200801179               NCR05100                               6/25/2008       Clatskanie PUD did not have procedures for the               CIP-001-1                    2       Medium        WECC determined that the                  6/18/2007              8/1/2008            $0      The violation was the first violation of this      MIT-07-     8/1/2008      7/16/2009        9/1/2009         Self-                           Yes
                                                                                                                                                                     communication of information concerning sabotage                                                                violation did not constitute a                                                               Reliability Standard incurred by Clatskanie         1210                                                    Certification
                                                                                                                                                                     events to appropriate parties in the Interconnection                                                            serious or substantial risk to the                                                           PUD and it did not constitute a serious or
                                                                                                                                                                     because it had been relying upon the Balancing Authority                                                        bulk power system because of the                                                             substantial risk to the bulk power system.
                                                                                                                                                                     to perform this function.                                                                                       nature and the location of
55                                                                                                                                                                                                                                                                                   Clatskanie PUD's assets.
          WECC                Clatskanie PUD                   NOC-0292           WECC200801180               NCR05100                               6/25/2008       Clatskanie PUD did not provide its operating personnel       CIP-001-1                    3       Medium        WECC determined that the                  6/18/2007              8/1/2008            $0      The violation was the first violation of this      MIT-07-     8/1/2008      7/16/2009        9/1/2009         Self-                           Yes
                                                                                                                                                                     with sabotage response guidelines, including personnel                                                          violation did not constitute a                                                               Reliability Standard incurred by Clatskanie         1210                                                    Certification
                                                                                                                                                                     to contact, for reporting disturbances due to sabotage                                                          serious or substantial risk to the                                                           PUD and it did not constitute a serious or
                                                                                                                                                                     events because it was had been relying upon the                                                                 bulk power system because of the                                                             substantial risk to the bulk power system.
                                                                                                                                                                     Balancing Authority to perform this function.                                                                   nature and the location of
56                                                                                                                                                                                                                                                                                   Clatskanie PUD's assets.
          WECC                Clatskanie PUD                   NOC-0292           WECC200801181               NCR05100                               6/25/2008       Clatskanie PUD did not provide evidence that it had       CIP-001-1                       4       Medium        WECC determined that the                  6/18/2007              8/1/2008            $0      The violation was the first violation of this      MIT-07-     8/1/2008      7/16/2009        9/1/2009         Self-                           Yes
                                                                                                                                                                     established communications contacts, as applicable, with                                                        violation did not constitute a                                                               Reliability Standard incurred by Clatskanie         1210                                                    Certification
                                                                                                                                                                     local Federal Bureau of Investigation (FBI) officials and                                                       serious or substantial risk to the                                                           PUD and it did not constitute a serious or
                                                                                                                                                                     developed reporting procedures as appropriate to the                                                            bulk power system because of the                                                             substantial risk to the bulk power system.
                                                                                                                                                                     circumstances because it was had been relying upon the                                                          nature and the location of
57                                                                                                                                                                   Balancing Authority to perform this function.                                                                   Clatskanie PUD's assets.
          WECC                Clatskanie PUD                   NOC-0292           WECC200801035               NCR05100                               5/9/2008        Clatskanie PUD did not have a disturbance reporting       EOP-004-1                       2       Medium        WECC determined that the                  6/18/2007              6/24/2008           $0      The violation was the first violation of this      MIT-07-     6/24/2008     3/23/2009        9/2/2009         Self-                           Yes
                                                                                                                                                                     procedure and did not provide a written report of its                                                           violation did not constitute a                                                               Reliability Standard incurred by Clatskanie         1088                                                    Certification
                                                                                                                                                                     disturbances to the RE and NERC. Clatskanie relied                                                              serious or substantial risk to the                                                           PUD and it did not constitute a serious or
                                                                                                                                                                     upon the Balancing Authority, who owns, operates and                                                            bulk power system because the                                                                substantial risk to the bulk power system.
                                                                                                                                                                     maintains the transmission line to perform this function                                                        Balancing Authority was
                                                                                                                                                                     on its behalf and had not memorialized the Balancing                                                            performing the function on
                                                                                                                                                                     Authority's procedure as its own.                                                                               Clatskanie's behalf and due to the
                                                                                                                                                                                                                                                                                     nature and the location of
58                                                                                                                                                                                                                                                                                   Clatskanie PUD's assets.
          WECC                Clatskanie PUD                   NOC-0292           WECC200801036               NCR05100                               5/9/2008        Clatskanie PUD experienced two transmission line             EOP-004-1                    3        Lower        WECC determined that the                  6/18/2007              6/24/2008           $0      The violation was the first violation of this      MIT-07-     6/24/2008     3/23/2009        9/2/2009         Self-                           Yes
                                                                                                                                                                     outages that should have been reported and analyzed as                                                          violation did not constitute a                                                               Reliability Standard incurred by Clatskanie         1088                                                    Certification
                                                                                                                                                                     a disturbance. Clatskanie had been relying upon the                                                             serious or substantial risk to the                                                           PUD and it did not constitute a serious or
                                                                                                                                                                     Balancing Authority to perform this function.                                                                   bulk power system because the                                                                substantial risk to the bulk power system.
                                                                                                                                                                                                                                                                                     Balancing Authority, who owns,
                                                                                                                                                                                                                                                                                     operates and maintains the
                                                                                                                                                                                                                                                                                     transmission line, reported the
59                                                                                                                                                                                                                                                                                   outage.




                                                                                                                                                                                                                                                                                           WECC
     1
         Date of Verification of Completion is the WECC RSAW date, if complete. Otherwise, it is date of the Verification letter sent by WECC to the Registered Entity.                                                                                                                                                                                                                                                                                                                                                      Page 26 of 80
                                                                                                                                                                                                                                                                            10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                                                                                                                       PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                                                                                                                     CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                                                                                                                     HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.




              A                         B                            C                       D                       E                   F                G                                       H                                    I             J         K           L                          M                              N                     O               P                              Q                              R            S              T               U              V            W                X
                                                                                                                                   Date                 Date
                                                                                                                                Identified or                                                                                                                         Violation                                                                                                                                                                                 Registered       Regional
                                                                                                                                                    Identified or                                                                                                                                                                                                        Total
                                                                                                                                 Received                                                                                                                               Risk                                                                                                                                                                                      Entity          Entity
                                                                                                                                                      Received                                                                                  Regional                                                                                                                Penalty                                                      Mitigation   Mitigation                                                  Separate
                                                                                 NERC Violation ID                               (Pre-June                                                                                        Reliability                          Factor*                                              Violation Start Date                                                 Additional Factors                                            Certification   Verification    Discovery                    Signed
          Region              Registered Entity                  NOC-ID                                         NCR_ID                               (Post-June                      Description of the Violation                               Reliability   Req.                            Risk Assessment                                      Violation End Date      or                                                          Plan         Plan                                                     Settlement
                                                                                        #                                            18                                                                                           Standard                                                                                 (Post-June 18, 2007)                                               for the Basis of Penalty                                         of Mitigation   of Mitigation    Method                  Disposition Letter
                                                                                                                                                    18 Violation)                                                                               Standard                                                                                                                Sanction                                                      Number      Completed                                                  Agreement
                                                                                                                                 Violation)*                                                                                                                              *See                                                                                                                                                                                     Plan            Plan
                                                                                                                                                                                                                                                                                                                                                                          ($)
                                                                                                                                                                                                                                                                      Attachment C                                                                                                                                                                              Completion     Completion1
1                                                                                                                                  *if applicable

          WECC               Clearwater Power                  NOC-0127           WECC200810240               NCR05101            5/23/2007          2/12/2008       CLPC did not have documentation of its Protection     PRC-005-1                           1         High        WECC determined that the                   6/18/2007             10/20/2008           $0      The violation was self-reported, it was a          MIT-07-     10/20/2008   10/20/2008      11/10/2008      Self-Report                      Yes
                                 Company                                                                                                                             System Maintenance and Testing Program as required by                                                           violation did not constitute a                                                                documentation issue, it was the first               0852
                                                                                                                                                                     the standard.                                                                                                   serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                     bulk power system because CLPC                                                                by CLPC and it did not constitute a serious
                                                                                                                                                                                                                                                                                     was performing maintenance and                                                                or substantial risk to the bulk power system.
                                                                                                                                                                                                                                                                                     testing, but did not have its                                                                  However, the Mitigation Plan for the related
                                                                                                                                                                                                                                                                                     Protection System Maintenance                                                                 pre-June 18 violation (WECC200702599)
                                                                                                                                                                                                                                                                                     and Testing Program documented.                                                               was not completed on time, which resulted
                                                                                                                                                                                                                                                                                                                                                                                   in this post-June 18 violation. Additionally,
                                                                                                                                                                                                                                                                                                                                                                                   CLPC completed its Mitigation Plan over 3
                                                                                                                                                                                                                                                                                                                                                                                   months after its approved completion plan
                                                                                                                                                                                                                                                                                                                                                                                   date of 7/11/2008. WECC considered
                                                                                                                                                                                                                                                                                                                                                                                   these factors and determined that,
                                                                                                                                                                                                                                                                                                                                                                                   notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                                                                                                                   Mitigation Plan, a zero dollar penalty was
                                                                                                                                                                                                                                                                                                                                                                                   appropriate for this violation.
60
          WECC               Clearwater Power                  NOC-0127           WECC200810241               NCR05101            5/23/2007          2/12/2008       CLPC did not have documentation of its Protection     PRC-005-1                           2        Lower        WECC determined that the                   6/18/2007             10/20/2008           $0      The violation was self-reported, it was a          MIT-07-     10/20/2008   10/20/2008      11/10/2008      Self-Report                      Yes
                                 Company                                                                                                                             System Maintenance and Testing Program as required by                                                           violation did not constitute a                                                                documentation issue, it was the first               0852
                                                                                                                                                                     the standard.                                                                                                   serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                     bulk power system because CLPC                                                                by CLPC and it did not constitute a serious
                                                                                                                                                                                                                                                                                     was performing maintenance and                                                                or substantial risk to the bulk power system.
                                                                                                                                                                                                                                                                                     testing, but did not have its                                                                  However, the Mitigation Plan for the related
                                                                                                                                                                                                                                                                                     Protection System Maintenance                                                                 pre-June 18 violation (WECC200702701)
                                                                                                                                                                                                                                                                                     and Testing documented.                                                                       was not completed on time, which resulted
                                                                                                                                                                                                                                                                                                                                                                                   in this post-June 18 violation. Additionally,
                                                                                                                                                                                                                                                                                                                                                                                   CLPC completed its Mitigation Plan over 3
                                                                                                                                                                                                                                                                                                                                                                                   months after its approved completion plan
                                                                                                                                                                                                                                                                                                                                                                                   date of 7/11/2008. WECC considered
                                                                                                                                                                                                                                                                                                                                                                                   these factors and determined that,
                                                                                                                                                                                                                                                                                                                                                                                   notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                                                                                                                   Mitigation Plan, a zero dollar penalty was
                                                                                                                                                                                                                                                                                                                                                                                   appropriate for this violation.
61
          WECC               Clearwater Power                  NOC-0127           WECC200800763               NCR05101                               3/28/2008       CLPC, a member of PNGC, did not have documentation           TOP-002-2                   18       Medium        WECC determined that the                   6/18/2007             11/11/2008           $0      The violation was self-reported, it was a          MIT-08-     11/11/2008   11/11/2008      11/24/2008      Self-Report                      Yes
                                 Company                                                                                                                             to show it used uniform line identifiers when referring to                                                      violation did not constitute a                                                                documentation issue, it was the first               0727
                                                                                                                                                                     transmission facilities among a shared interconnect.                                                            serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                     bulk power system because there                                                               by CLPC and it did not constitute a serious
                                                                                                                                                                                                                                                                                     were historical practices regarding                                                           or substantial risk to the bulk power system.
                                                                                                                                                                                                                                                                                     line identification between CLPC                                                               CLPC completed its Mitigation Plan 5.5
                                                                                                                                                                                                                                                                                     and its Transmission Service                                                                  months after its approved completion date
                                                                                                                                                                                                                                                                                     Provider and Transmission                                                                     of 5/30/2008. WECC considered these
                                                                                                                                                                                                                                                                                     Operator.                                                                                     factors and determined that,
                                                                                                                                                                                                                                                                                                                                                                                   notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                                                                                                                   Mitigation Plan, a zero dollar penalty was
                                                                                                                                                                                                                                                                                                                                                                                   appropriate for this violation.

62
          WECC         Colorado Green Holdings,                NOC-0293           WECC200810242               NCR05104            6/15/2007          5/5/2008        Because CGH had not documented its Facility Ratings          FAC-009-1                    1       Medium        WECC determined that the                   6/18/2007              5/9/2008            $0      The violation was self-reported, it was a          MIT-07-      5/9/2008      5/9/2008       9/12/2008      Self-Report                      Yes
                                 LLC                                                                                                                                 Methodology, it could not implement such Methodology                                                            violation did not constitute a                                                                documentation issue, it was the first               1786
                                                                                                                                                                     as required by FAC-009 R1.                                                                                      serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                     bulk power system because CGH                                                                 by CGH and it did not constitute a serious
                                                                                                                                                                                                                                                                                     had facility ratings.                                                                         or substantial risk to the bulk power system.
                                                                                                                                                                                                                                                                                                                                                                                    However, the Mitigation Plan for the related
                                                                                                                                                                                                                                                                                                                                                                                   pre-June 18 violation (WECC200704981)
                                                                                                                                                                                                                                                                                                                                                                                   was not completed on time, which resulted
                                                                                                                                                                                                                                                                                                                                                                                   in this post-June 18 violation. WECC
                                                                                                                                                                                                                                                                                                                                                                                   considered these factors and determined
                                                                                                                                                                                                                                                                                                                                                                                   that, notwithstanding the late completion of
                                                                                                                                                                                                                                                                                                                                                                                   the Mitigation Plan, a zero dollar penalty
                                                                                                                                                                                                                                                                                                                                                                                   was appropriate for this violation.
63
          WECC         Colorado Green Holdings,                NOC-0293           WECC200810243               NCR05104            6/15/2007          5/5/2008        CGH did not have documentation of its Protection System PRC-005-1                         1         High        WECC determined that the                   6/18/2007              8/14/2008           $0      The violation was self-reported, it was a          MIT-07-     8/14/2008     8/14/2008       8/14/2008      Self-Report                      Yes
                                 LLC                                                                                                                                 Maintenance and Testing Program as required by the                                                              violation did not constitute a                                                                documentation issue, it was the first               1055
                                                                                                                                                                     standard.                                                                                                       serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                     bulk power system because,                                                                    by CGH and it did not constitute a serious
                                                                                                                                                                                                                                                                                     although CGH owned the                                                                        or substantial risk to the bulk power system.
                                                                                                                                                                                                                                                                                     Generator, its Generator Operator                                                              However, the Mitigation Plan for the related
                                                                                                                                                                                                                                                                                     was performing Protection System                                                              pre-June 18 violation (WECC200704951)
                                                                                                                                                                                                                                                                                     maintenance and testing.                                                                      was not completed on time, which resulted
                                                                                                                                                                                                                                                                                                                                                                                   in this post-June 18 violation. WECC
                                                                                                                                                                                                                                                                                                                                                                                   considered these factors and determined
                                                                                                                                                                                                                                                                                                                                                                                   that, notwithstanding the late completion of
                                                                                                                                                                                                                                                                                                                                                                                   the Mitigation Plan, a zero dollar penalty
                                                                                                                                                                                                                                                                                                                                                                                   was appropriate for this violation.
64
          WECC              Colorado River                     NOC-0063           WECC200700307               NCR05105                               6/25/2007       The Reliability Standard Requirement requires a              CIP-001-1                    1       Medium        WECC determined that the                   6/18/2007             12/22/2007           $0      The violation was self-reported, it was the        MIT-07-     12/22/2007   12/27/2007       12/2/2008      Self-Report                      Yes
                         Commission of Nevada                                                                                                                        Registered Entity to have procedures for the recognition                                                        violation did not constitute a                                                                first violation of this Reliability Standard        0353
                                                                                                                                                                     of and for making its operating personnel aware of                                                              serious or substantial risk to the                                                            incurred by the CRC and it did not
                                                                                                                                                                     sabotage events on its facilities. The CRC's safety                                                             bulk power system because CRC                                                                 constitute a serious or substantial risk to
                                                                                                                                                                     program contains some, but not all, of the elements                                                             had a safety program, although it                                                             the bulk power system.
                                                                                                                                                                     required by CIP-001-1.                                                                                          did not conform to the Reliability
                                                                                                                                                                                                                                                                                     Standard Requirement. In
                                                                                                                                                                                                                                                                                     addition, WECC determined that
                                                                                                                                                                                                                                                                                     the violation did not constitute a
                                                                                                                                                                                                                                                                                     serious or substantial risk to the
                                                                                                                                                                                                                                                                                     bulk power system because of the
                                                                                                                                                                                                                                                                                     nature and the location of CRC's
65                                                                                                                                                                                                                                                                                   assets.




                                                                                                                                                                                                                                                                                           WECC
     1
         Date of Verification of Completion is the WECC RSAW date, if complete. Otherwise, it is date of the Verification letter sent by WECC to the Registered Entity.                                                                                                                                                                                                                                                                                                                                                     Page 27 of 80
                                                                                                                                                                                                                                                                             10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                                                                                                                        PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                                                                                                                      CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                                                                                                                      HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.




              A                         B                            C                       D                       E                   F                G                                       H                                     I             J         K           L                           M                            N                     O               P                              Q                              R            S              T               U              V            W                X
                                                                                                                                   Date                 Date
                                                                                                                                Identified or                                                                                                                          Violation                                                                                                                                                                                Registered       Regional
                                                                                                                                                    Identified or                                                                                                                                                                                                        Total
                                                                                                                                 Received                                                                                                                                Risk                                                                                                                                                                                     Entity          Entity
                                                                                                                                                      Received                                                                                   Regional                                                                                                               Penalty                                                      Mitigation   Mitigation                                                  Separate
                                                                                 NERC Violation ID                               (Pre-June                                                                                         Reliability                          Factor*                                             Violation Start Date                                                 Additional Factors                                            Certification   Verification    Discovery                    Signed
          Region              Registered Entity                  NOC-ID                                         NCR_ID                               (Post-June                      Description of the Violation                                Reliability   Req.                            Risk Assessment                                     Violation End Date      or                                                          Plan         Plan                                                     Settlement
                                                                                        #                                            18                                                                                            Standard                                                                                (Post-June 18, 2007)                                               for the Basis of Penalty                                         of Mitigation   of Mitigation    Method                  Disposition Letter
                                                                                                                                                    18 Violation)                                                                                Standard                                                                                                               Sanction                                                      Number      Completed                                                  Agreement
                                                                                                                                 Violation)*                                                                                                                               *See                                                                                                                                                                                    Plan            Plan
                                                                                                                                                                                                                                                                                                                                                                          ($)
                                                                                                                                                                                                                                                                       Attachment C                                                                                                                                                                             Completion     Completion1
1                                                                                                                                  *if applicable

          WECC              Colorado River                     NOC-0063           WECC200700308               NCR05105                               6/25/2007       The Reliability Standard Requirement requires a               CIP-001-1                    2       Medium        WECC determined that the                  6/18/2007             12/22/2007           $0      The violation was self-reported, it was the        MIT-07-     12/22/2007   12/27/2007       12/2/2008      Self-Report                      Yes
                         Commission of Nevada                                                                                                                        Registered Entity to have procedures for the                                                                     violation did not constitute a                                                               first violation of this Reliability Standard        0353
                                                                                                                                                                     communication of information concerning sabotage                                                                 serious or substantial risk to the                                                           incurred by the CRC and it did not
                                                                                                                                                                     events to appropriate parties in the Interconnection. The                                                        bulk power system because CRC                                                                constitute a serious or substantial risk to
                                                                                                                                                                     CRC's safety program contains some, but not all, of the                                                          had a safety program, although it                                                            the bulk power system.
                                                                                                                                                                     elements required by CIP-001-1.                                                                                  did not conform to the Reliability
                                                                                                                                                                                                                                                                                      Standard Requirement. In
                                                                                                                                                                                                                                                                                      addition, WECC determined that
                                                                                                                                                                                                                                                                                      the violation did not constitute a
                                                                                                                                                                                                                                                                                      serious or substantial risk to the
                                                                                                                                                                                                                                                                                      bulk power system because of the
                                                                                                                                                                                                                                                                                      nature and the location of CRC's
66                                                                                                                                                                                                                                                                                    assets.
          WECC              Colorado River                     NOC-0063           WECC200700309               NCR05105                               6/25/2007       The Reliability Standard Requirement requires a               CIP-001-1                    3       Medium        WECC determined that the                  6/18/2007             12/22/2007           $0      The violation was self-reported, it was the        MIT-07-     12/22/2007   12/27/2007       12/2/2008      Self-Report                      Yes
                         Commission of Nevada                                                                                                                        Registered Entity to provide its operating personnel with                                                        violation did not constitute a                                                               first violation of this Reliability Standard        0353
                                                                                                                                                                     sabotage response guidelines, including personnel to                                                             serious or substantial risk to the                                                           incurred by the CRC and it did not
                                                                                                                                                                     contact, for reporting disturbances due to sabotage                                                              bulk power system because CRC                                                                constitute a serious or substantial risk to
                                                                                                                                                                     events. The CRC had a safety program, but the program                                                            had a safety program, although it                                                            the bulk power system.
                                                                                                                                                                     did not contain all of the elements required by CIP-001-1.                                                       did not conform to the Reliability
                                                                                                                                                                                                                                                                                      Standard Requirement. In
                                                                                                                                                                                                                                                                                      addition, WECC determined that
                                                                                                                                                                                                                                                                                      the violation did not constitute a
                                                                                                                                                                                                                                                                                      serious or substantial risk to the
                                                                                                                                                                                                                                                                                      bulk power system because of the
                                                                                                                                                                                                                                                                                      nature and the location of CRC's
67                                                                                                                                                                                                                                                                                    assets.
          WECC              Colorado River                     NOC-0063           WECC200700310               NCR05105                               6/25/2007       CRC did not establish communications contacts, as             CIP-001-1                    4       Medium        WECC determined that the                  6/18/2007             12/22/2007           $0      The violation was self-reported, it was the        MIT-07-     12/22/2007   12/27/2007       12/2/2008      Self-Report                      Yes
                         Commission of Nevada                                                                                                                        applicable, with local Federal Bureau of Investigation                                                           violation did not constitute a                                                               first violation of this Reliability Standard        0353
                                                                                                                                                                     (FBI) officials. The CRC had a safety program, but the                                                           serious or substantial risk to the                                                           incurred by the CRC and it did not
                                                                                                                                                                     program did not contain all of the elements required by                                                          bulk power system because CRC                                                                constitute a serious or substantial risk to
                                                                                                                                                                     CIP-001-1.                                                                                                       had a safety program, although it                                                            the bulk power system.
                                                                                                                                                                                                                                                                                      did not conform to the Reliability
                                                                                                                                                                                                                                                                                      Standard Requirement. In
                                                                                                                                                                                                                                                                                      addition, WECC determined that
                                                                                                                                                                                                                                                                                      the violation did not constitute a
                                                                                                                                                                                                                                                                                      serious or substantial risk to the
                                                                                                                                                                                                                                                                                      bulk power system because of the
                                                                                                                                                                                                                                                                                      nature and the location of CRC's
68                                                                                                                                                                                                                                                                                    assets.
          WECC          Colorado Springs Utilities             NOC-0294           WECC200810244               NCR05106            6/15/2007          2/12/2008       Although Colorado Springs was performing the                  COM-001-                     2       Medium        WECC determined that the                  6/18/2007              9/25/2008           $0      The violation was self-reported, it was a          MIT-07-     9/25/2008     9/25/2008       1/22/2009      Self-Report                      Yes
                                                                                                                                                                     managing, alarming, testing and/or active monitoring of          1                                               violation did not constitute a                                                               documentation issue, it was the first               1468
                                                                                                                                                                     vital telecommunications facilities, it lacked the                                                               serious or substantial risk to the                                                           violation of this Reliability Standard incurred
                                                                                                                                                                     documentation of these activities.                                                                               bulk power system because                                                                    by Colorado Springs and it did not
                                                                                                                                                                                                                                                                                      Colorado Springs was performing                                                              constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                      the managing, alarming, testing                                                              the bulk power system. However, the
                                                                                                                                                                                                                                                                                      and/or active monitoring of vital                                                            Mitigation Plan for the related pre-June 18
                                                                                                                                                                                                                                                                                      telecommunications facilities.                                                               violation (WECC200705313) was not
                                                                                                                                                                                                                                                                                      However, it lacked the                                                                       completed on time, which resulted in this
                                                                                                                                                                                                                                                                                      documentation of these activities.                                                           post-June 18 violation. WECC considered
                                                                                                                                                                                                                                                                                                                                                                                   these factors and determined that,
                                                                                                                                                                                                                                                                                                                                                                                   notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                                                                                                                   Mitigation Plan, a zero dollar penalty was
69                                                                                                                                                                                                                                                                                                                                                                                 appropriate for this violation.
          WECC          Colorado Springs Utilities             NOC-0294           WECC200810245               NCR05106            6/15/2007          2/12/2008       Colorado Springs had a training program, but its              PER-002-0                    3         High        WECC determined that the                  6/18/2007              8/1/2008            $0      The violation was self-reported, it was a          MIT-07-      8/1/2008     8/27/2008        9/4/2008      Self-Report                      Yes
                                                                                                                                                                     documentation did not include the criteria of this                                                               violation did not constitute a                                                               documentation issue, it was the first               0853
                                                                                                                                                                     requirement of the Reliability Standard.                                                                         serious or substantial risk to the                                                           violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                      bulk power system because                                                                    by Colorado Springs and it did not
                                                                                                                                                                                                                                                                                      Colorado Springs was conducting                                                              constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                      training and certification for its                                                           the bulk power system. However, the
                                                                                                                                                                                                                                                                                      operators.                                                                                   Mitigation Plan for the related pre-June 18
                                                                                                                                                                                                                                                                                                                                                                                   violation (WECC200704654) was not
                                                                                                                                                                                                                                                                                                                                                                                   completed on time, which resulted in this
                                                                                                                                                                                                                                                                                                                                                                                   post-June 18 violation. WECC considered
                                                                                                                                                                                                                                                                                                                                                                                   these factors and determined that,
                                                                                                                                                                                                                                                                                                                                                                                   notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                                                                                                                   Mitigation Plan, a zero dollar penalty was
70                                                                                                                                                                                                                                                                                                                                                                                 appropriate for this violation.
          WECC          Columbia River People's                NOC-0101           WECC200700067               NCR05109                               6/18/2007       CRPUD did not have documentation of its Protection            PRC-005-1                    1         High        WECC determined that the                  6/18/2007              9/3/2008            $0      The violation was self-reported, it was a          MIT-07-      9/3/2008    12/19/2008        2/5/2009      Self-Report                      Yes
                             Utility District                                                                                                                        System Maintenance and Testing Program.                                                                          violation did not constitute a                                                               documentation issue, it was the first               0311
                                                                                                                                                                                                                                                                                      serious or substantial risk to the                                                           violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                      bulk power system because                                                                    by CRPUD and it did not constitute a
                                                                                                                                                                                                                                                                                      CRPUD had a Protection System                                                                serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                      Maintenance and Testing Program                                                              system.
                                                                                                                                                                                                                                                                                      but had not documented it.
71
          WECC          Columbia River People's                NOC-0101           WECC200700468               NCR05109                               6/18/2007       Although CRPUD was performing maintenance and                 PRC-005-1                    2        Lower        WECC determined that the                  6/18/2007              9/3/2008            $0      The violation was self-reported, it was a          MIT-07-      9/3/2008    12/19/2008        2/5/2009      Self-Report                      Yes
                             Utility District                                                                                                                        testing, it did not have records evidencing that Protection                                                      violation did not constitute a                                                               documentation issue, it was the first               0311
                                                                                                                                                                     System maintenance and testing were taking place as                                                              serious or substantial risk to the                                                           violation of this Reliability Standard incurred
                                                                                                                                                                     required by the standard.                                                                                        bulk power system because                                                                    by CRPUD and it did not constitute a
                                                                                                                                                                                                                                                                                      CRPUD was performing                                                                         serious or substantial risk to the bulk power
72                                                                                                                                                                                                                                                                                    maintenance and testing.                                                                     system.




                                                                                                                                                                                                                                                                                            WECC
     1
         Date of Verification of Completion is the WECC RSAW date, if complete. Otherwise, it is date of the Verification letter sent by WECC to the Registered Entity.                                                                                                                                                                                                                                                                                                                                                     Page 28 of 80
                                                                                                                                                                                                                                                                            10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                                                                                                                       PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                                                                                                                     CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                                                                                                                     HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.




              A                         B                            C                       D                       E                   F                G                                       H                                    I             J         K           L                           M                             N                     O               P                              Q                              R            S              T               U              V            W                X
                                                                                                                                   Date                 Date
                                                                                                                                Identified or                                                                                                                         Violation                                                                                                                                                                                 Registered       Regional
                                                                                                                                                    Identified or                                                                                                                                                                                                        Total
                                                                                                                                 Received                                                                                                                               Risk                                                                                                                                                                                      Entity          Entity
                                                                                                                                                      Received                                                                                  Regional                                                                                                                Penalty                                                      Mitigation   Mitigation                                                  Separate
                                                                                 NERC Violation ID                               (Pre-June                                                                                        Reliability                          Factor*                                              Violation Start Date                                                 Additional Factors                                            Certification   Verification    Discovery                    Signed
          Region              Registered Entity                  NOC-ID                                         NCR_ID                               (Post-June                      Description of the Violation                               Reliability   Req.                            Risk Assessment                                      Violation End Date      or                                                          Plan         Plan                                                     Settlement
                                                                                        #                                            18                                                                                           Standard                                                                                 (Post-June 18, 2007)                                               for the Basis of Penalty                                         of Mitigation   of Mitigation    Method                  Disposition Letter
                                                                                                                                                    18 Violation)                                                                               Standard                                                                                                                Sanction                                                      Number      Completed                                                  Agreement
                                                                                                                                 Violation)*                                                                                                                              *See                                                                                                                                                                                     Plan            Plan
                                                                                                                                                                                                                                                                                                                                                                          ($)
                                                                                                                                                                                                                                                                      Attachment C                                                                                                                                                                              Completion     Completion1
1                                                                                                                                  *if applicable

          WECC           Consumer's Power, Inc.                NOC-0295           WECC200810246               NCR05114            5/23/2007          3/6/2008        Consumer's Power did not have documentation of its           PRC-005-1                    2        Lower        WECC determined that the                   6/18/2007              11/6/2008           $0      The violation was self-reported, it was a          MIT-07-     11/6/2008     11/6/2008      11/11/2008      Self-Report                      Yes
                                                                                                                                                                     Protection System maintenance and testing as required                                                           violation did not constitute a                                                                documentation issue, it was the first               0854
                                                                                                                                                                     by the standard.                                                                                                serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                     bulk power system because                                                                     by Consumer's Power and it did not
                                                                                                                                                                                                                                                                                     Consumer's Power was                                                                          constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                     performing maintenance and                                                                    the bulk power system. However, the
                                                                                                                                                                                                                                                                                     testing.                                                                                      Mitigation Plan for the related pre-June 18
                                                                                                                                                                                                                                                                                                                                                                                   violation (WECC200702677) was not
                                                                                                                                                                                                                                                                                                                                                                                   completed on time, which resulted in this
                                                                                                                                                                                                                                                                                                                                                                                   post-June 18 violation. WECC considered
                                                                                                                                                                                                                                                                                                                                                                                   these factors and determined that,
                                                                                                                                                                                                                                                                                                                                                                                   notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                                                                                                                   Mitigation Plan, a zero dollar penalty was
73                                                                                                                                                                                                                                                                                                                                                                                 appropriate for this violation.
          WECC              Coos-Curry Electric                NOC-0296           WECC200810377               NCR05116            5/15/2007          4/8/2008        Coos-Curry, a member of PNGC, did not provide its            CIP-001-1                    3       Medium        WECC determined that the                   6/18/2007              6/5/2008            $0      The violation was self-reported, it was a          MIT-07-     6/5/2008       6/9/2008      11/20/2008      Self-Report                      Yes
                             Cooperative, Inc.                                                                                                                       operating personnel with sabotage response guidelines,                                                          violation did not constitute a                                                                documentation issue, it was the first               1063
                                                                                                                                                                     including personnel to contact, for reporting disturbances                                                      serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                     due to sabotage events.                                                                                         bulk power system because Coos-                                                               by Coos-Curry and it did not constitute a
                                                                                                                                                                                                                                                                                     Curry had Sabotage Reporting                                                                  serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                     Procedures.                                                                                   system. However, the Mitigation Plan for
                                                                                                                                                                                                                                                                                                                                                                                   the related pre-June 18 violation
                                                                                                                                                                                                                                                                                                                                                                                   (WECC200701691) was not completed on
                                                                                                                                                                                                                                                                                                                                                                                   time, which resulted in this post-June 18
                                                                                                                                                                                                                                                                                                                                                                                   violation. WECC considered these factors
                                                                                                                                                                                                                                                                                                                                                                                   and determined that, notwithstanding the
                                                                                                                                                                                                                                                                                                                                                                                   late completion of the Mitigation Plan, a
                                                                                                                                                                                                                                                                                                                                                                                   zero dollar penalty was appropriate for this
74                                                                                                                                                                                                                                                                                                                                                                                 violation.
          WECC              Coos-Curry Electric                NOC-0296           WECC200800765               NCR05116                               3/28/2008       Coos-Curry, a member of PNGC, did not have                   TOP-002-2                   18       Medium        WECC determined that the                   6/18/2007              8/8/2008            $0      The violation was self-reported, it was a          MIT-08-     8/8/2008       8/8/2008        9/3/2008      Self-Report                      Yes
                             Cooperative, Inc.                                                                                                                       documentation to show it used uniform line identifiers                                                          violation did not constitute a                                                                documentation issue, it was the first               0729
                                                                                                                                                                     when referring to transmission facilities among a shared                                                        serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                     interconnect.                                                                                                   bulk power system because there                                                               by Coos-Curry and it did not constitute a
                                                                                                                                                                                                                                                                                     were historical practices regarding                                                           serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                     line identification between Coos-                                                             system. Coos-Curry completed its
                                                                                                                                                                                                                                                                                     Curry and its Transmission                                                                    Mitigation Plan over 2 months after its
                                                                                                                                                                                                                                                                                     Service Provider and                                                                          approved completion date of 5/30/2008.
                                                                                                                                                                                                                                                                                     Transmission Operator.                                                                        WECC considered these factors and
                                                                                                                                                                                                                                                                                                                                                                                   determined that, notwithstanding the late
                                                                                                                                                                                                                                                                                                                                                                                   completion of the Mitigation Plan, a zero
                                                                                                                                                                                                                                                                                                                                                                                   dollar penalty was appropriate for this
75                                                                                                                                                                                                                                                                                                                                                                                 violation.
          WECC         Cowlitz County PUD No. 1                NOC-0297           WECC200810255               NCR05123            5/30/2007          5/9/2008        Cowlitz PUD did not provide its operating personnel with     CIP-001-1                    3       Medium        WECC determined that the                   6/18/2007              5/30/2008           $0      The violation was self-reported, it was the        MIT-07-     5/30/2008     5/30/2008      11/20/2008      Self-Report                      Yes
                                                                                                                                                                     sabotage response guidelines, including personnel to                                                            violation did not constitute a                                                                first violation of this Reliability Standard        0855
                                                                                                                                                                     contact, for reporting disturbances due to sabotage                                                             serious or substantial risk to the                                                            incurred by Cowlitz PUD and it did not
                                                                                                                                                                     events as required by the standard.                                                                             bulk power system because,                                                                    constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                     although Cowlitz PUD did not                                                                  the bulk power system. However, the
                                                                                                                                                                                                                                                                                     have written procedures in place,                                                             Mitigation Plan for the related pre-June 18
                                                                                                                                                                                                                                                                                     Cowlitz PUD reported that its                                                                 violation (WECC200705501) was not
                                                                                                                                                                                                                                                                                     operations personnel would                                                                    completed on time, which resulted in this
                                                                                                                                                                                                                                                                                     immediately contact its dispatcher                                                            post-June 18 violation. Additionally, Cowlitz
                                                                                                                                                                                                                                                                                     in response to any sabotage                                                                   PUD completed its Mitigation Plan 2 days
                                                                                                                                                                                                                                                                                     events, who then would                                                                        after its approved completion date of
                                                                                                                                                                                                                                                                                     immediately contact local                                                                     5/28/2008. WECC considered these
                                                                                                                                                                                                                                                                                     government officials.                                                                         factors and determined that,
                                                                                                                                                                                                                                                                                                                                                                                   notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                                                                                                                   Mitigation Plan, a zero dollar penalty was
76                                                                                                                                                                                                                                                                                                                                                                                 appropriate for this violation.
          WECC          Crockett Cogeneration, a               NOC-0298           WECC200710256               NCR05124            5/31/2007         11/20/2007 Crockett did not have a Transmission Vegetation                    FAC-003-1                    1         High        WECC determined that the                   6/18/2007              4/29/2008           $0      The violation was self-reported, it was the        MIT-07-     4/29/2008     4/29/2008        5/7/2008      Self-Report                      Yes
                           California Limited                                                                                                                  Management Program (TVMP) as required by the                                                                          violation did not constitute a                                                                first violation of this Reliability Standard        0991
                              Partnership                                                                                                                      standard.                                                                                                             serious or substantial risk to the                                                            incurred by Crockett and it did not
                                                                                                                                                                                                                                                                                     bulk power system because                                                                     constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                     Crocket's transmission line is the                                                            the bulk power system. However, the
                                                                                                                                                                                                                                                                                     tie line/interconnect for the plant                                                           Mitigation Plan for the related pre-June 18
                                                                                                                                                                                                                                                                                     generation only.                                                                              violation (WECC200702834) was not
                                                                                                                                                                                                                                                                                                                                                                                   completed on time, which resulted in this
                                                                                                                                                                                                                                                                                                                                                                                   post-June 18 violation. WECC considered
                                                                                                                                                                                                                                                                                                                                                                                   these factors and determined that,
                                                                                                                                                                                                                                                                                                                                                                                   notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                                                                                                                   Mitigation Plan, a zero dollar penalty was
77                                                                                                                                                                                                                                                                                                                                                                                 appropriate for this violation.
          WECC          Crockett Cogeneration, a               NOC-0298           WECC200710257               NCR05124            5/31/2007         11/20/2007 Because Crockett had a violation of R1, it had a violation         FAC-003-1                    2         High        WECC determined that the                   6/18/2007              4/29/2008           $0      The violation was self-reported, it was the        MIT-07-     4/29/2008     4/29/2008        5/7/2008      Self-Report                      Yes
                           California Limited                                                                                                                  of R2. Because it did not have a TVMP, Crockett did not                                                               violation did not constitute a                                                                first violation of this Reliability Standard        0991
                              Partnership                                                                                                                      create and implement an annual plan to implement its                                                                  serious or substantial risk to the                                                            incurred by Crockett and it did not
                                                                                                                                                               TVMP.                                                                                                                 bulk power system because                                                                     constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                     Crocket's transmission line is the                                                            the bulk power system. However, the
                                                                                                                                                                                                                                                                                     tie line/interconnect for the plant                                                           Mitigation Plan for the related pre-June 18
                                                                                                                                                                                                                                                                                     generation only.                                                                              violation (WECC200702390) was not
                                                                                                                                                                                                                                                                                                                                                                                   completed on time, which resulted in this
                                                                                                                                                                                                                                                                                                                                                                                   post-June 18 violation. WECC considered
                                                                                                                                                                                                                                                                                                                                                                                   these factors and determined that,
                                                                                                                                                                                                                                                                                                                                                                                   notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                                                                                                                   Mitigation Plan, a zero dollar penalty was
78                                                                                                                                                                                                                                                                                                                                                                                 appropriate for this violation.




                                                                                                                                                                                                                                                                                           WECC
     1
         Date of Verification of Completion is the WECC RSAW date, if complete. Otherwise, it is date of the Verification letter sent by WECC to the Registered Entity.                                                                                                                                                                                                                                                                                                                                                     Page 29 of 80
                                                                                                                                                                                                                                                                             10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                                                                                                                        PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                                                                                                                      CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                                                                                                                      HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.




              A                         B                            C                       D                       E                   F                G                                       H                                     I             J         K           L                           M                            N                     O               P                              Q                              R            S              T               U              V            W                X
                                                                                                                                   Date                 Date
                                                                                                                                Identified or                                                                                                                          Violation                                                                                                                                                                                Registered       Regional
                                                                                                                                                    Identified or                                                                                                                                                                                                        Total
                                                                                                                                 Received                                                                                                                                Risk                                                                                                                                                                                     Entity          Entity
                                                                                                                                                      Received                                                                                   Regional                                                                                                               Penalty                                                      Mitigation   Mitigation                                                  Separate
                                                                                 NERC Violation ID                               (Pre-June                                                                                         Reliability                          Factor*                                             Violation Start Date                                                 Additional Factors                                            Certification   Verification    Discovery                    Signed
          Region              Registered Entity                  NOC-ID                                         NCR_ID                               (Post-June                      Description of the Violation                                Reliability   Req.                            Risk Assessment                                     Violation End Date      or                                                          Plan         Plan                                                     Settlement
                                                                                        #                                            18                                                                                            Standard                                                                                (Post-June 18, 2007)                                               for the Basis of Penalty                                         of Mitigation   of Mitigation    Method                  Disposition Letter
                                                                                                                                                    18 Violation)                                                                                Standard                                                                                                               Sanction                                                      Number      Completed                                                  Agreement
                                                                                                                                 Violation)*                                                                                                                               *See                                                                                                                                                                                    Plan            Plan
                                                                                                                                                                                                                                                                                                                                                                          ($)
                                                                                                                                                                                                                                                                       Attachment C                                                                                                                                                                             Completion     Completion1
1                                                                                                                                  *if applicable

          WECC           Deseret Generation &                  NOC-0299           WECC200710053               NCR05127            5/17/2007         10/12/2007 Deseret Generation & Transmission did not provide                   CIP-001-1                    4       Medium        WECC determined that the                  6/18/2007              3/10/2008           $0      The violation was self-reported, it was a          MIT-07-     3/10/2008     3/10/2008      11/19/2008      Self-Report                Auto-accepted
                       Transmission Co-operative                                                                                                               evidence that it had established communications                                                                        violation did not constitute a                                                               documentation issue, it was the first               0813
                                                                                                                                                               contacts, as applicable, with local Federal Bureau of                                                                  serious or substantial risk to the                                                           violation of this Reliability Standard incurred
                                                                                                                                                               Investigation (FBI) officials.                                                                                         bulk power system because of the                                                             by Deseret Generation & Transmission and
                                                                                                                                                                                                                                                                                      nature and the location of Deseret                                                           it did not constitute a serious or substantial
                                                                                                                                                                                                                                                                                      Generation & Transmission's                                                                  risk to the bulk power system. However,
                                                                                                                                                                                                                                                                                      assets and the documentation                                                                 the Mitigation Plan for the related pre-June
                                                                                                                                                                                                                                                                                      nature of the violation.                                                                     18 violation (WECC200701466) was not
                                                                                                                                                                                                                                                                                                                                                                                   completed on time, which resulted in this
                                                                                                                                                                                                                                                                                                                                                                                   post-June 18 violation. WECC considered
                                                                                                                                                                                                                                                                                                                                                                                   these factors and determined that,
                                                                                                                                                                                                                                                                                                                                                                                   notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                                                                                                                   Mitigation Plan, a zero dollar penalty was
                                                                                                                                                                                                                                                                                                                                                                                   appropriate for this violation.
79
          WECC           Deseret Generation &                  NOC-0299           WECC200800845               NCR05127                               5/29/2008       An employee used an incorrect path matrix and failed to       IRO-STD-         WR          1         N/A         WECC determined that the                  6/18/2007              7/17/2008           $0      The violation was self-reported, it was the        MIT-08-     7/17/2008     7/17/2008       8/13/2008      Self-Report                Auto-accepted
                       Transmission Co-operative                                                                                                                     note visual indication on webSas tool of potential non-         006-0                                            violation did not constitute a                                                               first violation of this Reliability Standard        1710
                                                                                                                                                                     compliance when taking corrective action.                                                                        serious or substantial risk to the                                                           incurred by Deseret Generation &
                                                                                                                                                                                                                                                                                      bulk power system because                                                                    Transmission and it did not constitute a
                                                                                                                                                                     Violations of this regional standard have diminished, in                                                         approximately 2.4 MWh of loop                                                                serious or substantial risk to the bulk power
                                                                                                                                                                     part, due to better communication tools (primarily more                                                          flow (<0.1%) continued on the                                                                system.
                                                                                                                                                                     entities utilizing better software (e.g., webSAS)).                                                              path that should have been
                                                                                                                                                                     Unscheduled flow (USF) occurs in the Western                                                                     relieved.
                                                                                                                                                                     Interconnection because of concentrated load centers
                                                                                                                                                                     (mainly on the West Coast), remote generation resources
                                                                                                                                                                     (many on the Eastern side of WECC) and long
                                                                                                                                                                     transmission lines in between. The WECC high voltage
                                                                                                                                                                     transmission lines form a circle (“О”) in the
                                                                                                                                                                     Interconnection, which results in the electricity from the
                                                                                                                                                                     generation resources dividing, with some small
                                                                                                                                                                     percentage flowing around the opposite side of the “O” to
                                                                                                                                                                     reach the load centers (this is the USF). USF can occur
                                                                                                                                                                     at any time depending on the amount of power being
                                                                                                                                                                     generated and used in the load centers. Certain actions
                                                                                                                                                                     are taken to control and absorb the USF (e.g., adjusting
                                                                                                                                                                     phase shifting transformers, accommodation, etc.) but
                                                                                                                                                                     ultimately an entity may have to reduce schedules,
                                                                                                                                                                     thereby reducing the amount of power flowing (thereby
80
          WECC           Deseret Generation &                  NOC-0299           WECC200800871               NCR05127                               6/20/2008       reducing the rerouted unscheduled flow). While an
                                                                                                                                                                     An employeeamount ofenergy deliveries to avoid having         IRO-STD-         WR          1         N/A         WECC determined that the                  6/18/2007              7/17/2008           $0      The violation was self-reported, it was a          MIT-08-     7/17/2008     7/17/2008       8/13/2008      Self-Report                Auto-accepted
                       Transmission Co-operative                                                                                                                     schedules curtailed and failed to note visual indication on     006-0                                            violation did not constitute a                                                               documentation issue, and it did not                 1710
                                                                                                                                                                     webSas tool of potential non-compliance following                                                                serious or substantial risk to the                                                           constitute a serious or substantial risk to
                                                                                                                                                                     schedule rerouting.                                                                                              bulk power system because                                                                    the bulk power system.
                                                                                                                                                                                                                                                                                      approximately 2.1 MWh of loop
                                                                                                                                                               Violations of this regional standard have diminished, in                                                               flow (<0.1%) continued on the                                                                In determining the penalty, WECC took into
                                                                                                                                                               part, due to better communication tools (primarily more                                                                path that should have been                                                                   account that this was the second violation
                                                                                                                                                               entities utilizing better software (e.g., webSAS)).                                                                    relieved.                                                                                    of this Reliability Standard incurred by
                                                                                                                                                               Unscheduled flow (USF) occurs in the Western                                                                                                                                                                        Deseret Generation & Transmission.
                                                                                                                                                               Interconnection because of concentrated load centers
                                                                                                                                                               (mainly on the West Coast), remote generation resources
                                                                                                                                                               (many on the Eastern side of WECC) and long
                                                                                                                                                               transmission lines in between. The WECC high voltage
                                                                                                                                                               transmission lines form a circle (“О”) in the
                                                                                                                                                               Interconnection, which results in the electricity from the
                                                                                                                                                               generation resources dividing, with some small
                                                                                                                                                               percentage flowing around the opposite side of the “O” to
                                                                                                                                                               reach the load centers (this is the USF). USF can occur
                                                                                                                                                               at any time depending on the amount of power being
                                                                                                                                                               generated and used in the load centers. Certain actions
                                                                                                                                                               are taken to control and absorb the USF (e.g., adjusting
                                                                                                                                                               phase shifting transformers, accommodation, etc.) but
                                                                                                                                                               ultimately an entity may have to reduce schedules,
                                                                                                                                                               thereby reducing the amount of power flowing (thereby
81                                                                                                                                                             reducing the amount of unscheduled flow). While an
          WECC                   Dynegy Inc.                   NOC-0102           WECC200700470               NCR05136                              11/13/2007 entity may be taking action to address this, operated may VAR-002-1
                                                                                                                                                               On Wednesday October 24, 2007, Dynegy an entity                                                  2       Medium         WECC determined that the                 11/5/2007             11/21/2007           $0      The violation was self-reported, it was the        MIT-07-     11/21/2007    12/4/2007       2/28/2008      Self-Report                Auto-accepted
                                                                                                                                                               outside of the voltage schedule range by .4. The hourly                                                                violation did not constitute a                                                               first violation of this Reliability Standard        0577
                                                                                                                                                               integrated Morro Bay transmission bus voltage for the                                                                  serious or substantial risk to the                                                           incurred by Dynegy and it did not constitute
                                                                                                                                                               period 2100-2200 was 236.4 kV. This value was outside                                                                  bulk power system because the                                                                a serious or substantial risk to the bulk
                                                                                                                                                               the specified voltage schedule range of 232 kV – 236 kV                                                                voltage amount, at .4, was                                                                   power system.
                                                                                                                                                               specified by the Transmission Owner.                                                                                   minimal and the duration was
                                                                                                                                                                                                                                                                                      limited to 1 hour. Additionally,
                                                                                                                                                                                                                                                                                      PG&E did not communicate any
                                                                                                                                                                                                                                                                                      voltage problems or issues to the
                                                                                                                                                                                                                                                                                      Plant during the time that the
                                                                                                                                                                                                                                                                                      Morro Bay transmission bus
                                                                                                                                                                                                                                                                                      voltage was outside the voltage
                                                                                                                                                                                                                                                                                      schedule range specified by
82                                                                                                                                                                                                                                                                                    PG&E.
          WECC          Elmhurst Mutual P&L Co.                NOC-0103           WECC200700196               NCR05144                               6/18/2007       Elmhurst Mutual did not have procedures for the               CIP-001-1                    1       Medium        WECC determined that the                  6/18/2007              9/30/2007           $0      The violation was self-reported, it was the        MIT-07-     9/30/2007     9/30/2007        8/8/2008      Self-Report                Auto-accepted
                                                                                                                                                                     recognition of and for making its operating personnel                                                            violation did not constitute a                                                               first violation of this Reliability Standard        0346
                                                                                                                                                                     aware of sabotage events on its facilities.                                                                      serious or substantial risk to the                                                           incurred by Elmhurst Mutual and it did not
                                                                                                                                                                                                                                                                                      bulk power system because of the                                                             constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                      nature and the location of                                                                   the bulk power system.
83                                                                                                                                                                                                                                                                                    Elmhurst Mutual's assets.
          WECC          Elmhurst Mutual P&L Co.                NOC-0103           WECC200700197               NCR05144                               6/18/2007       Elmhurst Mutual did not have procedures for the               CIP-001-1                    2       Medium        WECC determined that the                  6/18/2007              9/30/2007           $0      The violation was self-reported, it was the        MIT-07-     9/30/2007     9/30/2007        8/8/2008      Self-Report                Auto-accepted
                                                                                                                                                                     communication of information concerning sabotage                                                                 violation did not constitute a                                                               first violation of this Reliability Standard        0346
                                                                                                                                                                     events to appropriate parties in the Interconnection.                                                            serious or substantial risk to the                                                           incurred by Elmhurst Mutual and it did not
                                                                                                                                                                                                                                                                                      bulk power system because of the                                                             constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                      nature and the location of                                                                   the bulk power system.
84                                                                                                                                                                                                                                                                                    Elmhurst Mutual's assets.



                                                                                                                                                                                                                                                                                            WECC
     1
         Date of Verification of Completion is the WECC RSAW date, if complete. Otherwise, it is date of the Verification letter sent by WECC to the Registered Entity.                                                                                                                                                                                                                                                                                                                                                     Page 30 of 80
                                                                                                                                                                                                                                                                            10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                                                                                                                       PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                                                                                                                     CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                                                                                                                     HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.




              A                         B                            C                       D                       E                   F                G                                       H                                    I             J         K           L                          M                              N                     O               P                              Q                               R            S              T               U               V             W                X
                                                                                                                                   Date                 Date
                                                                                                                                Identified or                                                                                                                         Violation                                                                                                                                                                                  Registered       Regional
                                                                                                                                                    Identified or                                                                                                                                                                                                        Total
                                                                                                                                 Received                                                                                                                               Risk                                                                                                                                                                                       Entity          Entity
                                                                                                                                                      Received                                                                                  Regional                                                                                                                Penalty                                                      Mitigation    Mitigation                                                    Separate
                                                                                 NERC Violation ID                               (Pre-June                                                                                        Reliability                          Factor*                                              Violation Start Date                                                 Additional Factors                                             Certification   Verification    Discovery                      Signed
          Region              Registered Entity                  NOC-ID                                         NCR_ID                               (Post-June                      Description of the Violation                               Reliability   Req.                            Risk Assessment                                      Violation End Date      or                                                          Plan          Plan                                                       Settlement
                                                                                        #                                            18                                                                                           Standard                                                                                 (Post-June 18, 2007)                                               for the Basis of Penalty                                          of Mitigation   of Mitigation    Method                    Disposition Letter
                                                                                                                                                    18 Violation)                                                                               Standard                                                                                                                Sanction                                                      Number       Completed                                                    Agreement
                                                                                                                                 Violation)*                                                                                                                              *See                                                                                                                                                                                      Plan            Plan
                                                                                                                                                                                                                                                                                                                                                                          ($)
                                                                                                                                                                                                                                                                      Attachment C                                                                                                                                                                               Completion     Completion1
1                                                                                                                                  *if applicable

          WECC          Elmhurst Mutual P&L Co.                NOC-0103           WECC200700198               NCR05144                               6/18/2007       Elmhurst Mutual did not provide its operating personnel      CIP-001-1                    3       Medium        WECC determined that the                   6/18/2007              9/30/2007           $0      The violation was self-reported, it was the         MIT-07-     9/30/2007     9/30/2007        8/8/2008      Self-Report                  Auto-accepted
                                                                                                                                                                     with sabotage response guidelines, including personnel                                                          violation did not constitute a                                                                first violation of this Reliability Standard         0346
                                                                                                                                                                     to contact, for reporting disturbances due to sabotage                                                          serious or substantial risk to the                                                            incurred by Elmhurst Mutual and it did not
                                                                                                                                                                     events.                                                                                                         bulk power system because of the                                                              constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                     nature and the location of                                                                    the bulk power system.
85                                                                                                                                                                                                                                                                                   Elmhurst Mutual's assets.
          WECC          Elmhurst Mutual P&L Co.                NOC-0103           WECC200700199               NCR05144                               6/18/2007       Elmhurst Mutual did not provide evidence that it had         CIP-001-1                    4       Medium        WECC determined that the                   6/18/2007              9/30/2007           $0      The violation was self-reported, it was the         MIT-07-     9/30/2007     9/30/2007        8/8/2008      Self-Report                  Auto-accepted
                                                                                                                                                                     established communications contacts, as applicable, with                                                        violation did not constitute a                                                                first violation of this Reliability Standard         0346
                                                                                                                                                                     local Federal Bureau of Investigation (FBI) officials and                                                       serious or substantial risk to the                                                            incurred by Elmhurst Mutual and it did not
                                                                                                                                                                     developed reporting procedures as appropriate to the                                                            bulk power system because of the                                                              constitute a serious or substantial risk to
                                                                                                                                                                     circumstances.                                                                                                  nature and the location of                                                                    the bulk power system.
86                                                                                                                                                                                                                                                                                   Elmhurst Mutual's assets.
          WECC           Emerald People's Utility              NOC-0300           WECC200801585               NCR05146                               6/18/2007       Although EPD had an emergency Response Plan in               CIP-001-1                    1       Medium        WECC determined that the                   6/18/2007              9/4/2009            $0      The violation was self-reported, it was the       MIT-07-1951    9/4/2009      9/4/2009        9/4/2009      Self-Report                        Yes
                                 District                                                                                                                            place, it had not documented its procedures for the                                                             violation did not constitute a                                                                first violation of this Reliability Standard
                                                                                                                                                                     recognition of and for making its operating personnel                                                           serious or substantial risk to the                                                            incurred by EPD and it did not constitute a
                                                                                                                                                                     aware of sabotage events on its facilities and multi-site                                                       bulk power system because of the                                                              serious or substantial risk to the bulk power
                                                                                                                                                                     sabotage affecting larger portions of the Interconnection.                                                      nature and the location of EPD's                                                              system.
87                                                                                                                                                                                                                                                                                   assets.
          WECC           Emerald People's Utility              NOC-0300           WECC200801586               NCR05146                               6/18/2007       Although EPD had an emergency Response Plan in               CIP-001-1                    2       Medium        WECC determined that the                   6/18/2007              9/4/2009            $0      The violation was self-reported, it was the       MIT-07-1951    9/4/2009      9/4/2009        9/4/2009      Self-Report                        Yes
                                 District                                                                                                                            place, it had not documented its procedures for the                                                             violation did not constitute a                                                                first violation of this Reliability Standard
                                                                                                                                                                     communication of information concerning sabotage                                                                serious or substantial risk to the                                                            incurred by EPD and it did not constitute a
                                                                                                                                                                     events to appropriate parties in the Interconnection.                                                           bulk power system because of the                                                              serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                     nature and the location of EPD's                                                              system.
88                                                                                                                                                                                                                                                                                   assets.
          WECC           Emerald People's Utility              NOC-0300           WECC200801587               NCR05146                               6/18/2007       Although EPD had an emergency Response Plan in               CIP-001-1                    3       Medium        WECC determined that the                   6/18/2007              9/4/2009            $0      The violation was self-reported, it was the       MIT-07-1951    9/4/2009      9/4/2009        9/4/2009      Self-Report                        Yes
                                 District                                                                                                                            place, it had not documented its procedures to provide its                                                      violation did not constitute a                                                                first violation of this Reliability Standard
                                                                                                                                                                     operating personnel with sabotage response guidelines,                                                          serious or substantial risk to the                                                            incurred by EPD and it did not constitute a
                                                                                                                                                                     including personnel to contact, for reporting disturbances                                                      bulk power system because of the                                                              serious or substantial risk to the bulk power
                                                                                                                                                                     due to sabotage events.                                                                                         nature and the location of EPD's                                                              system.
89                                                                                                                                                                                                                                                                                   assets.
          WECC           Emerald People's Utility              NOC-0104           WECC200700200               NCR05146                               6/18/2007       Although EPD had an emergency Response Plan in               CIP-001-1                    4       Medium        WECC determined that the                   6/18/2007              9/4/2009            $0      The violation was self-reported, it was the         MIT-07-      9/4/2009      9/4/2009        9/4/2009      Self-Report                        Yes
                                 District                                                                                                                            place, it had not established communications contacts,                                                          violation did not constitute a                                                                first violation of this Reliability Standard         0347
                                                                                                                                                                     as applicable, with local Federal Bureau of Investigation                                                       serious or substantial risk to the                                                            incurred by EPD and it did not constitute a
                                                                                                                                                                     (FBI) officials and developed reporting procedures as                                                           bulk power system because of the                                                              serious or substantial risk to the bulk power
                                                                                                                                                                     appropriate to the circumstances.                                                                               nature and the location of EPD's                                                              system.
90                                                                                                                                                                                                                                                                                   assets.
          WECC                Empire Electric                  NOC-0301           WECC200710056               NCR05147            5/31/2007          11/5/2007       EEA was not able to provide documentation or other           PRC-008-0                    1       Medium        WECC determined that the                   6/18/2007              8/22/2007           $0      The violation was self-reported, it was a           MIT-07-     8/22/2007      2/7/2008       1/14/2009      Self-Report                        Yes
                              Association, Inc.                                                                                                                      evidence of having a UFLS equipment maintenance and                                                             violation did not constitute a                                                                documentation issue, it was the first                1779
                                                                                                                                                                     testing program.                                                                                                serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                     bulk power system because EEA                                                                 by EEA and it did not constitute a serious or
                                                                                                                                                                                                                                                                                     was testing the UFLS relays. To                                                               substantial risk to the bulk power system.
                                                                                                                                                                                                                                                                                     confirm the validity of the ongoing                                                           However, the Mitigation Plan for the related
                                                                                                                                                                                                                                                                                     testing, EEA performed a test on                                                              pre-June 18 violation (WECC200702152)
                                                                                                                                                                                                                                                                                     all relays in August 2007 and                                                                 was not completed on time, which resulted
                                                                                                                                                                                                                                                                                     provided the results to WECC                                                                  in this post-June 18 violation. WECC
                                                                                                                                                                                                                                                                                     showing successful testing of the                                                             considered these factors and determined
                                                                                                                                                                                                                                                                                     relays.                                                                                       that, notwithstanding the late completion of
                                                                                                                                                                                                                                                                                                                                                                                   the Mitigation Plan, a zero dollar penalty
                                                                                                                                                                                                                                                                                                                                                                                   was appropriate for this violation.
91
          WECC                Empire Electric                  NOC-0301           WECC200710057               NCR05147            5/31/2007          11/5/2007       Although EEA was able to provide evidence of testing its PRC-008-0                        2       Medium        WECC determined that the                   6/18/2007              8/22/2007           $0      The violation was self-reported, it was the         MIT-07-     8/22/2007      2/7/2008       1/14/2009      Self-Report                        Yes
                              Association, Inc.                                                                                                                      Underfrequency Load Shedding relays, EEA did not have                                                           violation did not constitute a                                                                first violation of this Reliability Standard         1779
                                                                                                                                                                     a UFLS equipment maintenance and testing program and                                                            serious or substantial risk to the                                                            incurred by EEA and it did not constitute a
                                                                                                                                                                     therefore was not able to implement that program as                                                             bulk power system because EEA                                                                 serious or substantial risk to the bulk power
                                                                                                                                                                     required by the standard.                                                                                       was testing the UFLS relays. To                                                               system. However, the Mitigation Plan for
                                                                                                                                                                                                                                                                                     confirm the validity of the ongoing                                                           the related pre-June 18 violation
                                                                                                                                                                                                                                                                                     testing, EEA performed a test on                                                              (WECC200702130) was not completed on
                                                                                                                                                                                                                                                                                     all relays in August 2007 and                                                                 time, which resulted in this post-June 18
                                                                                                                                                                                                                                                                                     provided the results to WECC                                                                  violation. WECC considered these factors
                                                                                                                                                                                                                                                                                     showing successful testing of the                                                             and determined that, notwithstanding the
                                                                                                                                                                                                                                                                                     relays.                                                                                       late completion of the Mitigation Plan, a
                                                                                                                                                                                                                                                                                                                                                                                   zero dollar penalty was appropriate for this
92                                                                                                                                                                                                                                                                                                                                                                                 violation.
          WECC                Fall River Rural                 NOC-0302           WECC200800841               NCR05154                               4/10/2008       FRRE's Protection System Maintenance and Testing             PRC-005-1                    1         High        WECC determined that the                   6/18/2007             11/13/2008           $0      The violation was the first violation of this       MIT-08-     11/13/2008   11/14/2008      12/10/2008         Self-                           Yes
                               Electric/PNGC                                                                                                                         Program did not include all of the required elements                                                            violation did not constitute a                                                                Reliability Standard incurred by FRRE and it         0841                                                    Certification
                                                                                                                                                                     required by the reliability standard. Specifically, FRRE's                                                      serious or substantial risk to the                                                            did not constitute a serious or substantial
                                                                                                                                                                     Maintenance and Testing Program did not include the                                                             bulk power system because, while                                                              risk to the bulk power system.
                                                                                                                                                                     maintenance and testing for station batteries.                                                                  FRRE's Maintenance and Testing
                                                                                                                                                                                                                                                                                     Program did not include station
                                                                                                                                                                     WECC was notified of the violation on April 10, 2008.                                                           batteries, it included the other
                                                                                                                                                                     FRRE stated that, after gaining a better understanding of                                                       equipment required by the
                                                                                                                                                                     what WECC was expecting for compliance for this                                                                 standard.
                                                                                                                                                                     Standard during a Compliance User Group meeting,
                                                                                                                                                                     FRRE did a gap analysis. During this gap analysis,
                                                                                                                                                                     FRRE discovered that its members with Protection
                                                                                                                                                                     Systems were not in compliance because they did not
                                                                                                                                                                     address sub-components of Protection Systems,
                                                                                                                                                                     including batteries. FRRE stated that it needed to modify
                                                                                                                                                                     its maintenance and testing procedures and perform
                                                                                                                                                                     maintenance and testing. FRRE completed mitigation of
                                                                                                                                                                     this violation on November 13, 2008. FRRE is a small
                                                                                                                                                                     utility.

93




                                                                                                                                                                                                                                                                                           WECC
     1
         Date of Verification of Completion is the WECC RSAW date, if complete. Otherwise, it is date of the Verification letter sent by WECC to the Registered Entity.                                                                                                                                                                                                                                                                                                                                                        Page 31 of 80
                                                                                                                                                                                                                                                                             10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                                                                                                                        PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                                                                                                                      CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                                                                                                                      HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.




               A                         B                            C                       D                       E                   F                G                                       H                                    I             J         K           L                           M                             N                     O               P                              Q                              R            S              T               U               V             W                X
                                                                                                                                    Date                 Date
                                                                                                                                 Identified or                                                                                                                         Violation                                                                                                                                                                                 Registered       Regional
                                                                                                                                                     Identified or                                                                                                                                                                                                        Total
                                                                                                                                  Received                                                                                                                               Risk                                                                                                                                                                                      Entity          Entity
                                                                                                                                                       Received                                                                                  Regional                                                                                                                Penalty                                                      Mitigation   Mitigation                                                    Separate
                                                                                  NERC Violation ID                               (Pre-June                                                                                        Reliability                          Factor*                                              Violation Start Date                                                 Additional Factors                                            Certification   Verification    Discovery                      Signed
           Region              Registered Entity                  NOC-ID                                         NCR_ID                               (Post-June                      Description of the Violation                               Reliability   Req.                            Risk Assessment                                      Violation End Date      or                                                          Plan         Plan                                                       Settlement
                                                                                         #                                            18                                                                                           Standard                                                                                 (Post-June 18, 2007)                                               for the Basis of Penalty                                         of Mitigation   of Mitigation    Method                    Disposition Letter
                                                                                                                                                     18 Violation)                                                                               Standard                                                                                                                Sanction                                                      Number      Completed                                                    Agreement
                                                                                                                                  Violation)*                                                                                                                              *See                                                                                                                                                                                     Plan            Plan
                                                                                                                                                                                                                                                                                                                                                                           ($)
                                                                                                                                                                                                                                                                       Attachment C                                                                                                                                                                              Completion     Completion1
1                                                                                                                                   *if applicable

           WECC                Fall River Rural                 NOC-0302           WECC200800842               NCR05154                               4/10/2008       FRRE's Protection System Maintenance and Testing          PRC-005-1                       2        Lower        WECC determined that the                   6/18/2007             11/13/2008           $0      The violation was the first violation of this      MIT-08-     11/13/2008   11/14/2008      12/10/2008         Self-                           Yes
                                Electric/PNGC                                                                                                                         Program procedures did not include station batteries, and                                                       violation did not constitute a                                                                Reliability Standard incurred by FRRE and it        0841                                                    Certification
                                                                                                                                                                      therefore FRRE was not documenting its program with                                                             serious or substantial risk to the                                                            did not constitute a serious or substantial
                                                                                                                                                                      respect to station batteries.                                                                                   bulk power system because, while                                                              risk to the bulk power system.
                                                                                                                                                                                                                                                                                      FRRE's Maintenance and Testing
                                                                                                                                                                      WECC was notified of the violation on April 10, 2008.                                                           Program did not include station
                                                                                                                                                                      FRRE stated that after gaining a better understanding of                                                        batteries, it included the other
                                                                                                                                                                      what WECC was expecting for compliance for this                                                                 equipment required by the
                                                                                                                                                                      Standard during a Compliance User Group meeting,                                                                standard.
                                                                                                                                                                      FRRE did a gap analysis. During this gap analysis,
                                                                                                                                                                      FRRE discovered that its members with Protection
                                                                                                                                                                      Systems were not in compliance because they did not
                                                                                                                                                                      address of sub-components of Protection Systems,
                                                                                                                                                                      including batteries. FRRE stated that it needed to modify
                                                                                                                                                                      its maintenance and testing procedures and perform
                                                                                                                                                                      maintenance and testing. FRRE completed mitigation of
                                                                                                                                                                      this violation on November 13, 2008. FRRE is a small
94
                                                                                                                                                                      utility.
           WECC                Fall River Rural                 NOC-0302           WECC200800766               NCR05154                               3/28/2008       FRRE, a member of PNGC, did not have documentation           TOP-002-2                   18       Medium        WECC determined that the                   6/18/2007             11/11/2008           $0      The violation was self-reported, it was a          MIT-08-     11/11/2008   11/11/2008       12/1/2008      Self-Report                        Yes
                                Electric/PNGC                                                                                                                         to show it used uniform line identifiers when referring to                                                      violation did not constitute a                                                                documentation issue, it was the first               0730
                                                                                                                                                                      transmission facilities among a shared interconnect.                                                            serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                      bulk power system because there                                                               by FRRE and it did not constitute a serious
                                                                                                                                                                                                                                                                                      were historical practices regarding                                                           or substantial risk to the bulk power system.
                                                                                                                                                                                                                                                                                      line identification between FRRE                                                               FRRE completed its Mitigation Plan over 5
                                                                                                                                                                                                                                                                                      and its Transmission Service                                                                  months after its approved completion date
                                                                                                                                                                                                                                                                                      Provider and Transmission                                                                     of 5/30/2008. WECC considered these
                                                                                                                                                                                                                                                                                      Operator.                                                                                     factors and determined that,
                                                                                                                                                                                                                                                                                                                                                                                    notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                                                                                                                    Mitigation Plan, a zero dollar penalty was
                                                                                                                                                                                                                                                                                                                                                                                    appropriate for this violation.

95
           WECC           Flathead Electric Coop.,              NOC-0303           WECC200810264               NCR05156            5/25/2007          2/5/2008        Flathead did not document its Protection System              PRC-005-1                    1         High        WECC determined that the                   6/18/2007              7/16/2008           $0      The violation was self-reported, it was a          MIT-07-     7/16/2008     7/16/2008       9/15/2008      Self-Report                        Yes
                                    Inc                                                                                                                               Maintenance and Testing Program.                                                                                violation did not constitute a                                                                documentation issue, it was the first               0856
                                                                                                                                                                                                                                                                                      serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                      bulk power system because                                                                     by Flathead and it did not constitute a
                                                                                                                                                                                                                                                                                      Flathead was performing                                                                       serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                      maintenance and testing of its                                                                system. However, the Mitigation Plan for
                                                                                                                                                                                                                                                                                      Protection Systems.                                                                           the related pre-June 18 violation
                                                                                                                                                                                                                                                                                                                                                                                    (WECC200701980) was not completed on
                                                                                                                                                                                                                                                                                                                                                                                    time, which resulted in this post-June 18
                                                                                                                                                                                                                                                                                                                                                                                    violation. WECC considered these factors
                                                                                                                                                                                                                                                                                                                                                                                    and determined that, notwithstanding the
                                                                                                                                                                                                                                                                                                                                                                                    late completion of the Mitigation Plan, a
                                                                                                                                                                                                                                                                                                                                                                                    zero dollar penalty was appropriate for this
96                                                                                                                                                                                                                                                                                                                                                                                  violation.
           WECC           Flathead Electric Coop.,              NOC-0303           WECC200810265               NCR05156            5/25/2007          2/5/2008        Flathead did not document its Protection System              PRC-005-1                    2        Lower        WECC determined that the                   6/18/2007              7/16/2008           $0      The violation was self-reported, it was a          MIT-07-     7/16/2008     7/16/2008       9/15/2008      Self-Report                        Yes
                                    Inc                                                                                                                               maintenance and testing program.                                                                                violation did not constitute a                                                                documentation issue, it was the first               0856
                                                                                                                                                                                                                                                                                      serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                      bulk power system because                                                                     by Flathead and it did not constitute a
                                                                                                                                                                                                                                                                                      Flathead was performing                                                                       serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                      maintenance and testing of its                                                                system. However, the Mitigation Plan for
                                                                                                                                                                                                                                                                                      Protection Systems.                                                                           the related pre-June 18 violation
                                                                                                                                                                                                                                                                                                                                                                                    (WECC200702064) was not completed on
                                                                                                                                                                                                                                                                                                                                                                                    time, which resulted in this post-June 18
                                                                                                                                                                                                                                                                                                                                                                                    violation. WECC considered these factors
                                                                                                                                                                                                                                                                                                                                                                                    and determined that, notwithstanding the
                                                                                                                                                                                                                                                                                                                                                                                    late completion of the Mitigation Plan, a
                                                                                                                                                                                                                                                                                                                                                                                    zero dollar penalty was appropriate for this
97                                                                                                                                                                                                                                                                                                                                                                                  violation.
           WECC           Flathead Electric Coop.,              NOC-0303           WECC200710266               NCR05156            5/25/2007         11/28/2007 Flathead was working with BPA to achieve compliance to             PRC-008-0                    2       Medium        WECC determined that the                   6/18/2007              9/17/2008           $0      The violation was self-reported, it was the        MIT-07-     9/17/2008     9/17/2008       9/17/2008      Self-Report                        Yes
                                    Inc                                                                                                                         this standard. BPA had a UFLS equipment maintenance                                                                   violation did not constitute a                                                                first violation of this Reliability Standard        1595
                                                                                                                                                                and testing program and was conducting testing for                                                                    serious or substantial risk to the                                                            incurred by Flathead and it did not
                                                                                                                                                                Flathead. However, Flathead had not memorialized                                                                      bulk power system because BPA                                                                 constitute a serious or substantial risk to
                                                                                                                                                                BPA's program as its own, so Flathead could not                                                                       has completed the maintenance                                                                 the bulk power system. However, the
                                                                                                                                                                implement its UFLS equipment maintenance and testing                                                                  and testing on the majority of the                                                            Mitigation Plan for the related pre-June 18
                                                                                                                                                                program as required by the standard.                                                                                  underfrequency relays on                                                                      violation (WECC200701887) was not
                                                                                                                                                                                                                                                                                      schedule.                                                                                     completed on time, which resulted in this
                                                                                                                                                                                                                                                                                                                                                                                    post-June 18 violation. WECC considered
                                                                                                                                                                                                                                                                                                                                                                                    these factors and determined that,
                                                                                                                                                                                                                                                                                                                                                                                    notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                                                                                                                    Mitigation Plan, a zero dollar penalty was
98                                                                                                                                                                                                                                                                                                                                                                                  appropriate for this violation.
           WECC              Front Range Power                  NOC-0105           WECC200700077               NCR05166                               6/18/2007       Front Range did not document its Facility Ratings          FAC-008-1                      1        Lower        WECC determined that the                   6/18/2007              9/7/2007            $0      The violation was self-reported, it was the        MIT-07-      9/7/2007      9/7/2007       2/12/2008      Self-Report                  Auto-accepted
                               Company, LLC                                                                                                                           Methodology for developing its generator facility ratings.                                                      violation did not constitute a                                                                first violation of this Reliability Standard        0313
                                                                                                                                                                      Additionally, Front Range's Facility Ratings Methodology                                                        serious or substantial risk to the                                                            incurred by Front Range and it did not
                                                                                                                                                                      did not include transmissions conductors, transformers,                                                         bulk power system because Front                                                               constitute a serious or substantial risk to
                                                                                                                                                                      relay protective devices, terminal equipment, and series                                                        Range had established generator                                                               the bulk power system.
99                                                                                                                                                                    and shunt compensation devices.                                                                                 facility ratings.
           WECC              Front Range Power                  NOC-0105           WECC200700080               NCR05166                               6/18/2007       Because Front Range had not documented its Facility        FAC-009-1                      1       Medium        WECC determined that the                   6/18/2007              9/7/2007            $0      The violation was self-reported, it was a          MIT-07-      9/7/2007      9/7/2007       12/4/2008      Self-Report                  Auto-accepted
                               Company, LLC                                                                                                                           Ratings Methodology as required by FAC-008-1 R1, it had                                                         violation did not constitute a                                                                documentation issue, it was the first               0314
                                                                                                                                                                      a violation of FAC-009-1 R1.                                                                                    serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                      bulk power system because Front                                                               by Front Range and it did not constitute a
                                                                                                                                                                                                                                                                                      Range's facilities had Facility                                                               serious or substantial risk to the bulk power
100                                                                                                                                                                                                                                                                                   Ratings.                                                                                      system.




                                                                                                                                                                                                                                                                                            WECC
      1
          Date of Verification of Completion is the WECC RSAW date, if complete. Otherwise, it is date of the Verification letter sent by WECC to the Registered Entity.                                                                                                                                                                                                                                                                                                                                                       Page 32 of 80
                                                                                                                                                                                                                                                                               10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                                                                                                                          PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                                                                                                                        CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                                                                                                                        HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.




               A                         B                            C                       D                       E                   F                G                                        H                                     I             J         K           L                          M                              N                     O               P                              Q                              R            S              T               U              V            W                X
                                                                                                                                    Date                 Date
                                                                                                                                 Identified or                                                                                                                           Violation                                                                                                                                                                                 Registered       Regional
                                                                                                                                                     Identified or                                                                                                                                                                                                          Total
                                                                                                                                  Received                                                                                                                                 Risk                                                                                                                                                                                      Entity          Entity
                                                                                                                                                       Received                                                                                    Regional                                                                                                                Penalty                                                      Mitigation   Mitigation                                                  Separate
                                                                                  NERC Violation ID                               (Pre-June                                                                                          Reliability                          Factor*                                              Violation Start Date                                                 Additional Factors                                            Certification   Verification    Discovery                    Signed
           Region              Registered Entity                  NOC-ID                                         NCR_ID                               (Post-June                      Description of the Violation                                 Reliability   Req.                            Risk Assessment                                      Violation End Date      or                                                          Plan         Plan                                                     Settlement
                                                                                         #                                            18                                                                                             Standard                                                                                 (Post-June 18, 2007)                                               for the Basis of Penalty                                         of Mitigation   of Mitigation    Method                  Disposition Letter
                                                                                                                                                     18 Violation)                                                                                 Standard                                                                                                                Sanction                                                      Number      Completed                                                  Agreement
                                                                                                                                  Violation)*                                                                                                                                *See                                                                                                                                                                                     Plan            Plan
                                                                                                                                                                                                                                                                                                                                                                             ($)
                                                                                                                                                                                                                                                                         Attachment C                                                                                                                                                                              Completion     Completion1
1                                                                                                                                   *if applicable

           WECC            Gila River Power, LP -               NOC-0305           WECC200800854               NCR05170                               6/3/2008        Gila River's Facility Rating Methodology did not specify       FAC-008-1                    1        Lower        WECC determined that the                   6/18/2007             10/31/2007           $0      The violation was self-reported, it was            MIT-08-     10/31/2007     6/5/2008       8/29/2008      Self-Report                      Yes
                                GO/GOP/PSE                                                                                                                            the most limiting element or the normal and emergency                                                             violation did not constitute a                                                                documentation issue, it was the first               1711
                                                                                                                                                                      ratings.                                                                                                          serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                        bulk power system because it was                                                              by Gila River and it did not constitute a
                                                                                                                                                                                                                                                                                        a documentation issue and the                                                                 serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                        facility had 100% redundant                                                                   system.
                                                                                                                                                                                                                                                                                        capability and therefore the
                                                                                                                                                                                                                                                                                        'normal' rating equaled the
101                                                                                                                                                                                                                                                                                     'emergency rating.'
           WECC                Glacier Electric                 NOC-0306           WECC200800998               NCR05171                               7/21/2008       GEC did not document its Protection System                     PRC-005-1                    1         High        WECC determined that the                   6/18/2007              1/8/2009            $0      The violation was self-reported, it was a          MIT-08-      1/8/2009      1/8/2009       1/12/2009      Self-Report                      Yes
                               Cooperative, Inc.                                                                                                                      maintenance and testing program.                                                                                  violation did not constitute a                                                                documentation issue, it was the first               0952
                                                                                                                                                                                                                                                                                        serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                        bulk power system because GEC                                                                 by GEC and it did not constitute a serious
                                                                                                                                                                                                                                                                                        was performing maintenance and                                                                or substantial risk to the bulk power system.
102                                                                                                                                                                                                                                                                                     testing.
           WECC                Glacier Electric                 NOC-0306           WECC200800999               NCR05171                               7/21/2008       Although GEC was performing maintenance and testing, PRC-005-1                              2        Lower        WECC determined that the                   6/18/2007              1/8/2009            $0      The violation was self-reported, it was a          MIT-08-      1/8/2009      1/8/2009       1/12/2009      Self-Report                      Yes
                               Cooperative, Inc.                                                                                                                      it did not have records evidencing that Protection System                                                         violation did not constitute a                                                                documentation issue, it was the first               0952
                                                                                                                                                                      maintenance and testing were taking place as required by                                                          serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                      the standard.                                                                                                     bulk power system because GEC                                                                 by GEC and it did not constitute a serious
                                                                                                                                                                                                                                                                                        was performing maintenance and                                                                or substantial risk to the bulk power system.
103                                                                                                                                                                                                                                                                                     testing.
           WECC         Grays Harbor County PUD                 NOC-0307           WECC200700042               NCR05172                               6/18/2007       Grays Harbor did not have procedures for the recognition       CIP-001-1                    1       Medium        WECC determined that the                   6/18/2007              9/28/2007           $0      The violation was self-reported, it was the        MIT-07-     9/28/2007     9/30/2007       2/13/2008      Self-Report                      Yes
                                                                                                                                                                      of and for making its operating personnel aware of                                                                violation did not constitute a                                                                first violation of this Reliability Standard        0300
                                                                                                                                                                      sabotage events on its facilities.                                                                                serious or substantial risk to the                                                            incurred by Grays Harbor and it did not
                                                                                                                                                                                                                                                                                        bulk power system because of the                                                              constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                        nature and the location of Grays                                                              the bulk power system.
104                                                                                                                                                                                                                                                                                     Harbor's assets.
           WECC         Grays Harbor County PUD                 NOC-0307           WECC200700043               NCR05172                               6/18/2007       Grays Harbor did not have procedures for the                   CIP-001-1                    2       Medium        WECC determined that the                   6/18/2007              9/28/2007           $0      The violation was self-reported, it was the        MIT-07-     9/28/2007     9/30/2007       2/13/2008      Self-Report                      Yes
                                                                                                                                                                      communication of information concerning sabotage                                                                  violation did not constitute a                                                                first violation of this Reliability Standard        0300
                                                                                                                                                                      events to appropriate parties in the Interconnection.                                                             serious or substantial risk to the                                                            incurred by Grays Harbor and it did not
                                                                                                                                                                                                                                                                                        bulk power system because of the                                                              constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                        nature and the location of Grays                                                              the bulk power system.
105                                                                                                                                                                                                                                                                                     Harbor's assets.
           WECC         Grays Harbor County PUD                 NOC-0307           WECC200700044               NCR05172                               6/18/2007       Grays Harbor did not provide its operating personnel with      CIP-001-1                    3       Medium        WECC determined that the                   6/18/2007              3/31/2009           $0      The violation was self-reported, it was the        MIT-07-     3/31/2009      4/1/2009       4/23/2009      Self-Report                      Yes
                                                                                                                                                                      sabotage response guidelines, including personnel to                                                              violation did not constitute a                                                                first violation of this Reliability Standard        0300
                                                                                                                                                                      contact, for reporting disturbances due to sabotage                                                               serious or substantial risk to the                                                            incurred by Grays Harbor and it did not
                                                                                                                                                                      events.                                                                                                           bulk power system because of the                                                              constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                        nature and the location of Grays                                                              the bulk power system.
106                                                                                                                                                                                                                                                                                     Harbor's assets.
           WECC         Grays Harbor County PUD                 NOC-0307           WECC200700045               NCR05172                               6/18/2007       Grays Harbor did not establish communications contacts,        CIP-001-1                    4       Medium        WECC determined that the                   6/18/2007              9/28/2007           $0      The violation was self-reported, it was the        MIT-07-     9/28/2007     9/30/2007       2/13/2008      Self-Report                      Yes
                                                                                                                                                                      as applicable, with local Federal Bureau of Investigation                                                         violation did not constitute a                                                                first violation of this Reliability Standard        0300
                                                                                                                                                                      (FBI) officials and develop reporting procedures as                                                               serious or substantial risk to the                                                            incurred by Grays Harbor and it did not
                                                                                                                                                                      appropriate to the circumstances.                                                                                 bulk power system because of the                                                              constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                        nature and the location of Grays                                                              the bulk power system.
107                                                                                                                                                                                                                                                                                     Harbor's assets.
           WECC         Grays Harbor County PUD                 NOC-0307           WECC200700121               NCR05172                               6/18/2007       Grays Harbor did not document, maintain or publish             FAC-001-0                    1       Medium        WECC determined that the                   6/18/2007             12/14/2007           $0      The violation was self-reported, it was a          MIT-07-     12/14/2007   12/14/2007       8/28/2008      Self-Report                      Yes
                                                                                                                                                                      facility connection requirements.                                                                                 violation did not constitute a                                                                documentation issue, it was the first               0332
                                                                                                                                                                                                                                                                                        serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                        bulk power system because Grays                                                               by Grays Harbor and it did not constitute a
                                                                                                                                                                                                                                                                                        Harbor was utilizing its Balancing                                                            serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                        Authority's requirements, even                                                                system.
                                                                                                                                                                                                                                                                                        though it had failed to memorialize
                                                                                                                                                                                                                                                                                        the requirements into its own
108                                                                                                                                                                                                                                                                                     policy.
           WECC         Grays Harbor County PUD                 NOC-0307           WECC200700122               NCR05172                               6/18/2007       Grays Harbor did not document, maintain or publish             FAC-001-0                    2       Medium        WECC determined that the                   6/18/2007             12/14/2007           $0      The violation was self-reported, it was a          MIT-07-     12/14/2007   12/14/2007       8/28/2008      Self-Report                      Yes
                                                                                                                                                                      facility connection requirements, so it could not address                                                         violation did not constitute a                                                                documentation issue, it was the first               0332
                                                                                                                                                                      the requirements of R2.                                                                                           serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                        bulk power system because Grays                                                               by Grays Harbor and it did not constitute a
                                                                                                                                                                                                                                                                                        Harbor was utilizing its Balancing                                                            serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                        Authority's requirements, even                                                                system.
                                                                                                                                                                                                                                                                                        though it had failed to memorialize
                                                                                                                                                                                                                                                                                        the requirements into its own
109                                                                                                                                                                                                                                                                                     policy.
           WECC         Grays Harbor County PUD                 NOC-0307           WECC200700123               NCR05172                               6/18/2007       Grays Harbor did not document, maintain or publish             FAC-001-0                    3       Medium        WECC determined that the                   6/18/2007             12/14/2007           $0      The violation was self-reported, it was a          MIT-07-     12/14/2007   12/14/2007       3/17/2008      Self-Report                      Yes
                                                                                                                                                                      facility connection requirements, so it could not update its                                                      violation did not constitute a                                                                documentation issue, it was the first               0332
                                                                                                                                                                      requirements or provide the requirements upon request.                                                            serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                        bulk power system because Grays                                                               by Grays Harbor and it did not constitute a
                                                                                                                                                                                                                                                                                        Harbor was utilizing its Balancing                                                            serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                        Authority's requirements, even                                                                system.
                                                                                                                                                                                                                                                                                        though it had failed to memorialize
                                                                                                                                                                                                                                                                                        the requirements into its own
110                                                                                                                                                                                                                                                                                     policy.
           WECC         Grays Harbor County PUD                 NOC-0307           WECC200700127               NCR05172                               6/18/2007       Grays Harbor had not documented its Facility Ratings           FAC-008-1                    1        Lower        WECC determined that the                   6/18/2007             12/10/2008           $0      The violation was self-reported, it was the        MIT-07-     12/10/2008   12/10/2008       6/19/2009      Self-Report                      Yes
                                                                                                                                                                      Methodology.                                                                                                      violation did not constitute a                                                                first violation of this Reliability Standard        0334
                                                                                                                                                                                                                                                                                        serious or substantial risk to the                                                            incurred by Grays Harbor and it did not
                                                                                                                                                                                                                                                                                        bulk power system because Grays                                                               constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                        Harbor had facility ratings and had                                                           the bulk power system.
                                                                                                                                                                                                                                                                                        been providing the ratings upon
111                                                                                                                                                                                                                                                                                     request.
           WECC         Grays Harbor County PUD                 NOC-0307           WECC200700128               NCR05172                               6/18/2007       Because Grays Harbor had not documented its Facility      FAC-008-1                         2        Lower        WECC determined that the                   6/18/2007             12/10/2008           $0      The violation was self-reported, it was a          MIT-07-     12/10/2008   12/10/2008       6/19/2009      Self-Report                      Yes
                                                                                                                                                                      Ratings Methodology as required by R1, it was not able to                                                         violation did not constitute a                                                                documentation issue, it was the first               0334
                                                                                                                                                                      provide its Facility Ratings Methodology upon request.                                                            serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                                                                                                                                        bulk power system because Grays                                                               by Grays Harbor and it did not constitute a
                                                                                                                                                                                                                                                                                        Harbor had facility ratings and had                                                           serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                                        been providing the ratings upon                                                               system.
112                                                                                                                                                                                                                                                                                     request.




                                                                                                                                                                                                                                                                                              WECC
      1
          Date of Verification of Completion is the WECC RSAW date, if complete. Otherwise, it is date of the Verification letter sent by WECC to the Registered Entity.                                                                                                                                                                                                                                                                                                                                                       Page 33 of 80
                                                                                                                                                                                                                                                                              10/14/2009 Omnibus Public Spreadsheet
                                                                                                                                                                                                                                                                         PRIVILEGED AND CONFIDENTIAL INFORMATION
                                                                                                                                                                                                                                                                       CRITICAL ENERGY INFRASTRUCTURE INFORMATION
                                                                                                                                                                                                                                                                       HAVE BEEN REMOVED FROM THIS PUBLIC VERSION.




               A                         B                            C                       D                       E                   F                G                                        H                                    I             J         K           L                          M                              N                     O               P                              Q                              R            S              T               U               V             W                X
                                                                                                                                    Date                 Date
                                                                                                                                 Identified or                                                                                                                          Violation                                                                                                                                                                                 Registered       Regional
                                                                                                                                                     Identified or                                                                                                                                                                                                         Total
                                                                                                                                  Received                                                                                                                                Risk                                                                                                                                                                                      Entity          Entity
                                                                                                                                                       Received                                                                                   Regional                                                                                                                Penalty                                                      Mitigation   Mitigation                                                    Separate
                                                                                  NERC Violation ID                               (Pre-June                                                                                         Reliability                          Factor*                                              Violation Start Date                                                 Additional Factors                                            Certification   Verification    Discovery                      Signed
           Region              Registered Entity                  NOC-ID                                         NCR_ID                               (Post-June                      Description of the Violation                                Reliability   Req.                            Risk Assessment                                      Violation End Date      or                                                          Plan         Plan                                                       Settlement
                                                                                         #                                            18                                                                                            Standard                                                                                 (Post-June 18, 2007)                                               for the Basis of Penalty                                         of Mitigation   of Mitigation    Method                    Disposition Letter
                                                                                                                                                     18 Violation)                                                                                Standard                                                                                                                Sanction                                                      Number      Completed                                                    Agreement
                                                                                                                                  Violation)*                                                                                                                               *See                                                                                                                                                                                     Plan            Plan
                                                                                                                                                                                                                                                                                                                                                                            ($)
                                                                                                                                                                                                                                                                        Attachment C                                                                                                                                                                              Completion     Completion1
1                                                                                                                                   *if applicable

           WECC         Grays Harbor County PUD                 NOC-0307           WECC200700129               NCR05172                               6/18/2007       Because Grays Harbor had not documented its Facility      FAC-008-1                        3        Lower        WECC determined that the                   6/18/2007             12/10/2008           $0      The violation was self-reported, it was a          MIT-07-     12/10/2008   12/10/2008       6/19/2009      Self-Report                        Yes
                                                                                                                                                                      Ratings Methodology as required by R1, it was not able to                                                        violation did not constitute a                                                                documentation issue, it was the first               0334
                                                                                                                                                                      provide its Facility Ratings Methodology upon request,                                                           serious or substantial risk to the                                                            violation of this Reliability Standard incurred
                                                                                                                                                                      and therefore would not have been able to respond to                                                             bulk power system because Grays                                                               by Grays Harbor and it did not constitute a
                                                                                                                                                                      comments on its Facility Ratings Methodology as required                                                         Harbor had facility ratings and had                                                           serious or substantial risk to the bulk power
                                                                                                                                                                      by R3. However, Grays Harbor had been providing its                                                              been providing the ratings upon                                                               system.
                                                                                                                                                                      facility ratings upon request.                                                                                   request.
113
           WECC         Grays Harbor County PUD                 NOC-0307           WECC200700017               NCR05172                               6/18/2007       Grays Harbor did not have a written policy in place to tell   IRO-001-1                    8         High        WECC determined that the                   6/18/2007             12/20/2007           $0      The violation was self-reported, it was the       MIT-07-      12/20/2007   12/20/2007        3/4/2008      Self-Report                        Yes
                                                                                                                                                                      the Reliability Coordinator when it could not follow                                                             violation did not constitute a                                                                first violation of this Reliability Standard       0291
                                                                                                                                                                      directives, as required by the standard.                                                                         serious or substantial risk to the                                                            incurred by Grays Harbor and it did not
                                                                                                                                                                                                                                                                                       bulk power system because of the                                                              constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                       nature and location of Grays                                                                  the bulk power system. Grays Harbor
                                                                                                                                                                                                                                                                                       Harbor's assets and because this                                                              completed its mitigation plan over 3.5
                                                                                                                                                                                                                                                                                       was a documentation issue.                                                                    months after its approved completion date
                                                                                                                                                                                                                                                                                                                                                                                     of 9/1/2007. WECC considered these
                                                                                                                                                                                                                                                                                                                                                                                     factors and determined that,
                                                                                                                                                                                                                                                                                                                                                                                     notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                                                                                                                     Mitigation Plan, a zero dollar penalty was
114                                                                                                                                                                                                                                                                                                                                                                                  appropriate for this violation.
           WECC         Grays Harbor County PUD                 NOC-0307           WECC200700018               NCR05172                               6/18/2007       Grays Harbor did not provide evidence that it was             IRO-004-1                    4         High        WECC determined that the                   6/18/2007             12/20/2007           $0      The violation was self-reported, it was the       MIT-07-      12/20/2007   12/20/2007       3/17/2008      Self-Report                        Yes
                                                                                                                                                                      providing information required for system studies, such                                                          violation did not constitute a                                                                first violation of this Reliability Standard       0292
                                                                                                                                                                      as critical facility status, Load, generation, operating                                                         serious or substantial risk to the                                                            incurred by Grays Harbor and it did not
                                                                                                                                                                      reserve projections, and known Interchange                                                                       bulk power system because the                                                                 constitute a serious or substantial risk to
                                                                                                                                                                      Transactions. Specifically, Grays Harbor had delegated                                                           information was being provided by                                                             the bulk power system. Grays Harbor
                                                                                                                                                                      the responsibility for providing the information to another                                                      another entity on Grays Harbor's                                                              completed its mitigation plan over 3.5
                                                                                                                                                                      entity and was not able to provide a formal delegation                                                           behalf and due to the nature and                                                              months after its approved completion date
                                                                                                                                                                      agreement. Grays Harbor is able to provide the                                                                   location of Grays Harbor's assets.                                                            of 9/1/2007. WECC considered these
                                                                                                                                                                      information directly in the event that the delegated entity                                                                                                                                                    factors and determined that,
                                                                                                                                                                      does not perform the requirement.                                                                                                                                                                              notwithstanding the late completion of the
                                                                                                                                                                                                                                                                                                                                                                                     Mitigation Plan, a zero dollar penalty was
115