OUR MISSION: To provide our customers with high-quality, efficient and reliable water, power and sewer services in a manner that values environmental and community interests and sustains the resources entrusted to our care.
PO Box 160
Moccasin, CA 95347
T: 209-989.2000
F: 209.989.2104
Junction of Hwy 49 and Hwy 120
April 15, 2024
TO: Tim Paulson, Commission President
Anthony Rivera, Commission Vice President
Newsha K. Ajami, Commissioner
Sophie Maxwell, Commissioner
Kate H. Stacy, Commissioner
THROUGH: Dennis J. Herrera, General Manager
FROM: Steven R. Ritchie, Assistant General Manager, Water Margaret A. Hannaford, SFPUC NERC Compliance Officer
RE: 2023 Annual Electric Reliability Compliance Pr ogram Report
The San Francisco Public Utilities Commission (SFPUC) Electric Power Reliability Compliance Program (Compliance Program) requires SFPUC Executive Staff to report to the Commission annually on the progress of the Compliance Program. This is the report for calendar year 2023.
EXECUTIVE SUMMARY
The North American Electric Reliability Corporation (NERC), subject to Federal Energy Regulatory Commission (FERC) jurisdiction, establishes and enforces mandatory Reliability Standards to protect the bulk electric transmission system. NERC works through regional entities, including the Western Electricity Coordinating Council (WECC) which manages utilities in the west. Utilities must register with NERC to identify the functions they perform and are subject to particular rules for each function.
Functional Registrations: We are registered with NERC as a Generator Owner, Generator Operator, Transmission Owner, Transmission Operator, and Transmission Planner. During 2023, through meetings with WECC, we determined that the current asset ownership and related configurations of the substations supporting the airport will not require us to register as a Distribution Provider for the anticipated demand growth at San Francisco International Airport (SFO Airport).
Funding: Actual expenditures for FY 2022-2023 were $5.24 million. We are budgeted for $4.449 million in FY 2023-2024.
Personnel: We hired a Power Regulatory Compliance Manager in December 2023. We will continue to recruit for Engineering personnel and Operations and Transmission Planning personnel to fill vacancies incurred since 2021 that support WECC/NERC compliance.
Compliance Program: During 2023 we made non-substantive modifications to our Compliance Program.
Enforcement Actions: We self-reported 2 violations during calendar year 2023; while two other self-reports remain open (one from 2021 and one from 2020).
2023 WECC Compliance Audit: During June 2023, WECC completed its NERC Compliance Audit. The audit resulted in No Findings, one Recommendation, and two Positive Observations. A copy of the HHWP’s 2023 Public Audit Report from WECC is included as Attachment A.
Self-Certification: In December 2023, WECC confirmed that we would not be required to complete the Annual WECC Self-Certification process for calendar year 2023.
Accordingly, we did not self-certify to any O&P or CIP Reliability Standard Requirements related to calendar year 2023. However, each quarter WECC selects entities to complete a self-certification through the WECC Guided Certification process. If notified, we will timely complete the certification.
Procedure Review: We reviewed and updated 31 of our 38 O&P and CIP procedures during 2023. Modifications were made to reflect new or revised Reliability Standards that went into effect in 2023.
Reliability Standard Audit Worksheets (RSAWs): RSAW templates are developed by NERC and are utilized during audits and other regulatory reviews to summarize a utility’s compliance procedures, supporting compliance evidence and related internal controls. In 2023 we performed maintenance on certain RSAWs, updating them for new or revised Reliability Standards or Requirements applicable to SFPUC, and ensured they reflect current business processes.
Internal Controls: Internal Controls are used to demonstrate how an entity prevents, detects and/or corrects potential noncompliance. During 2023, we updated various components of our internal controls documentation.
Line Clearance Issues: In conformance with a 2010 NERC Alert, we were required to identify discrepancies between transmission line design clearances and actual field condition clearances (e.g., hard clearances, ground, streetlights, wires). We have determined that in certain instances, we have multiple detections across single spans; and after further review, separate remediation activities may be required. Accordingly, we have adjusted the identified number of clearances to 231. To date, we have remediated a total of 98 transmission line clearance discrepancies, completing 33 projects in 2023.
Regulatory Update:
• New, updated, or modified Reliability Standards continue to be approved by the Federal Energy Regulatory Commission (FERC). For 2024 enforcement, as of the date of this report, four revised applicable Reliability Standards have gone into effect, and there are 11 approved as “Subject to Future Enforcement” with various effective dates between 2024 and 2025.
• Securing the grid against cyber and physical attacks, effectively preparing for and responding to extreme weather events (e.g., snow, floods, heat, wind, storms, etc.), maximizing the capacity of the grid, and the growing dependency on renewable/inverter-based resources were important regulatory issues in 2022 that will continue into the future.
2023 REPORT
Functional Registrations: We are currently registered with NERC as a Generator Owner, Generator Operator, Transmission Owner, Transmission Operator, and Transmission Planner under the name Hetch Hetchy Water and Power (HHWP). In 2023, Power Enterprise continued work associated with increasing its footprint [e.g., Bay Corridor Transmission Distribution Project (BCTD) and substations that feed San Francisco International Airport (SFO Subs)]; and we continued coordinating with Power Enterprise to evaluate the facilities’ impact to our required functional registrations. Based upon our review and discussions with WECC, we have determined that no changes in our NERC functional registrations are required at this time.
During 2023, BCTD closed-in service, but was subsequently taken off-line due to protection system issues. BCTD is anticipated to go back in service during Q1/Q2 2024.
Based on our interconnection agreement with PG&E for BCTD, there may be a need to register as a Distribution Provider, Under Frequency Load Shedding only. However, PG&E has not requested we install Under Frequency Load Shedding equipment at this time, therefore there is no need to register. We continue to monitor the status of BCTD.
During 2023, in conjunction with WECC, we determined that due to the current configurations, asset ownership, and operational protocols related to the SFO Subs, the SFPUC assets qualify for a BES radial exclusion. As such, we will not need to register as a Distribution Provider at this time. However, should the current configurations, asset ownership, and/or operational protocols change in the future, we will be required to reassess whether the BES radial exclusion still applies and whether registration as a Distribution Provider is required.
Funding:
The SFPUC’s NERC Compliance Program is funded through a NERC Compliance line item and other parts of the HHWP operating budget. Our 2023 compliance efforts have focused on maintaining our program to meet current and upcoming Standards, updating internal controls consistent with new tools and expectations from our regulators, and preparing documentation associated with completing a successful 2023 WECC Compliance Audit. Total expenditures for FY 2022-23 were $5.24 million, and we are budgeted for $4.449 million in FY 2023-24.
The Commission-approved NERC Compliance line item for the FY 2024-25 budget at $5.5 million. In 2024, in addition to maintaining our program, our focus will also include implementing processes and procedures to comply with new extreme weather Requirements, supporting compliance obligations associated with Power Enterprise expansion projects, and implementing processes and procedures to comply with FERC Order 881 (Ambient Adjusted Ratings for transmission lines).
Personnel: Registered Entities must designate a NERC Compliance Officer and a CIP Senior Manager. The HHWP Division Manager has been assigned these roles.
During 2023, the Compliance Program continued to be staffed by consultants. One consultant is acting as the NERC Compliance Manager and O&P Specialist; the second is the CIP Specialist; and the third is the Compliance Administrator. During 2023, the HHWP Division Manager oversaw the NERC Compliance Manager. In December 2023, a Power Regulatory Compliance Manager was hired reporting to the Division Manager. In 2024, in addition to other responsibilities, the Power Regulatory Compliance Manager will oversee the NERC Compliance Manager. Due to the budget, the hours for these consultants remained reduced; and all consultants except for the Compliance Administrator have worked 100% remotely. During 2024, HHWP will be recruiting to fill a one compliance support staff position.
Historically, Subject Matter Experts (SMEs) were personnel working in HHWP Operations, Engineering, and Information Technology, with some exceptions. Due to staff turnover since 2021, electrical engineering SMEs supporting Engineering and Operation functions are now being supported by consultants. We have 1.75 full-time equivalent (FTE) electrical engineering consultants, and 1.5 FTE transmission planning engineer consultants serving as SMEs. We consider these staff positions as vital to reliability and compliance and are aggressively recruiting for electrical engineering positions as our division’s highest priority.
Limited SME responsibilities extend to 525 Golden Gate with support from Emergency Planning and Security and Information Technology staff who manage physical access to specific HHWP and SFPUC data centers. During 2023, turnover in this area also occurred.
The SMEs’ responsibilities are currently reassigned to existing staff.
During 2024, preparing for the implementation of FERC Order 881’s Ambient Adjusted Ratings will be a large lift for both the NERC Compliance Officer, and the consultants that support the SFPUC’s NERC Compliance Program. Additionally, as the Power Enterprise distribution footprint expands, their compliance obligations may increase.
Compliance Program: In 2023, we reviewed our Compliance Program document, the guiding document for our program. We made non-substantive modifications (e.g., updating terms/capitalizations and modifying the distribution list due to personnel changes) and modifications to incorporate newly developed/modified programs (e.g., NERC Risk and Internal Controls Program, NERC Corrective Action Plan Program, etc.) that further support our Compliance Program.
Staff and consultants committed significant resources to maintaining the NERC Compliance Program including:
• NERC Compliance Team Meetings: The NERC Compliance Team met monthly to discuss status of projects outlined in the 2023 Annual Work Plan, enforcement actions, and other key issues impacting compliance.
• Regulatory Reports: The Regulatory Report is prepared every other month, summarizing significant compliance activities and progress achieved during the respective reporting period. Distribution includes the Compliance and Executive teams.
• Executive Team Biannual Briefing: The NERC Compliance Officer briefed SFPUC Executive Staff on March 7, 2023, July 11, 2023, and January17, 2024. The December 2022 briefing was moved to March 7, 2023, due to winter storms which caused scheduling conflicts; and the December 2023 briefing was scheduled for and held on January 17, 2024. The briefings included status updates of 2023 and 2024 Work Plans; high priority projects; open enforcement actions; upcoming changes to the Reliability Standards; and potential changes to functional registration. • Regulatory Assessments/Surveys: During 2023, FERC and NERC issued various data requests, surveys and alerts (e.g., Internal Network Security Monitoring, Cold Weather Preparations for Extreme Weather Events Essential Action Alert III, Section 800 Reliability Assessment Request, etc.) which required review, research, and responses by specified dates. We timely responded to each.
Enforcement Actions: Two O&P-related enforcement actions self-reported in 2020 and 2021, and two CIP-related enforcement actions self-reported in 2023, currently remain open. WECC Enforcement previously indicated that resolution of one of the self-reports would be handled during the 2023 WECC Compliance Audit. However, prior to the audit, WECC removed the Requirement associated with our 2020 enforcement action from the audit scope. Accordingly, this enforcement action remains open. With respect to all of the open enforcement actions, at this time we are not aware of any additional mitigation actions required. Penalties may be assessed by WECC.
2023 WECC Compliance Audit: During June 2023, the 2023 WECC Compliance Audit was performed. The audit scope included fourteen Requirements from four CIP and five O&P Reliability Standards. The audit concluded with No Findings, one Recommendation, and two Positive Observations. We have completed the implementation of the Recommendation. A copy of the Public version of the audit report can be found in Attachment A.
Self-Certification: In December 2023, we were notified by WECC that we would not be required to complete the Annual WECC Self-Certification process for the 2023 calendar year. However, WECC could request that we perform a guided self-certification at some point during the calendar year. Guided self-certification notices are sent to the respective entities quarterly.
Procedure Review: Our program includes 39 O&P and CIP operational procedures used by our staff. We reviewed and updated 31 of our 39 procedures in 2023: 19 O&P procedures and 12 CIP procedures. These procedures are a component of the controls utilized to mitigate risk of non-compliance. Accordingly, the procedure reviews included ensuring the documented processes support compliance with each of the over 1,500 Reliability Requirements and related parts/sub requirements applicable to us. The procedures that were not reviewed in 2023 will be completed in 2024 based upon our procedure review schedule. Additionally, we will identify which procedures require review again in 2024 based on a priority of: 1) Annual reviews required by the Reliability Standards; 2) Effective date of new or modified Reliability Standards; 3) Materiality of the of updates or revisions to Reliability Standards; 4) Operational changes within the business;
5) Procedures related to completion of mitigation plans; and 6) Biennial review based on good business practice procedures.
Reliability Standard Audit Worksheets (RSAWs): RSAW templates are developed by NERC and are utilized during audits and other regulatory reviews to summarize the entity’s compliance procedures, supporting compliance evidence and related internal controls. We have approximately 90 RSAWs. During 2023, we updated our RSAWs for new or revised Reliability Standards or Requirements, and ensured they reflected current business processes. The RSAWs to be reviewed/updated will be based on: 1) New or modified Reliability Standards effective during the year; 2) Materiality of the of updates or revisions to Reliability Standards; 3) Operational changes within the business; and 4) Modifications related to completion of mitigation plans.
Self-Logging Program: During 2023, we submitted an application to participate in WECC’s Self-Logging Program. The self-logging program is designed to allow registered entities to report low risk non-compliance matters as self-logs which can be reviewed and resolved in an expedited manner.
Internal Controls: Internal Controls are used to demonstrate how an entity prevents, detects and/or corrects potential noncompliance. Internal Controls have been become one of WECC’s primary focuses with respect to ensuring the reliability of the Bulk Electric System (BES). During 2023, we developed a NERC Corrective Action Plan Program to better document our corrective action processes that support our Compliance Program. We also made minor updates to our existing internal controls and program documentation to incorporate the corrective actions identified in the corrective action program. These documents, among others, are used by WECC to assess the maturity of an entity’s compliance program and determine an entity’s potential risk to the BES.
New or Revised Reliability Standards: HHWP is responsible for approximately 70 Reliability Standards (representing over 1,500 Reliability Requirements and related parts/sub requirements). In 2023, four new or revised applicable O&P Reliability Standards, with 174 requirements, went into effect. We implemented processes and procedures to timely meet compliance for each of the new or revised Reliability Standards. No new or revised CIP Reliability Standards became effective in 2023.
In addition, work was required in 2023 to meet new or revised Reliability Standards coming into effect on January 1, 2024. This included two new or revised applicable O&P Reliability Standards and two new or revised applicable CIP Reliability Standards.
Additionally, we timely completed implementation of three applicable O&P Reliability Standards whose phase-in periods ended on January 1, 2024. We will continue implementation work associated with other new or revised applicable Reliability Standards that become effective throughout 2024.
Line Clearance Issues: We own and operate almost 324 miles of 115 kV and 230 kV transmission lines within 134 miles of right-of-way corridor. As part of a 2010 NERC Alert, we were required to identify discrepancies between transmission line design
clearances and actual field condition clearances. We identified a total of 231 discrepancies that required mitigation.1 We have limited access to these conditions by installing fencing and posting signs. We remediated 33 discrepancies in 2023. Since the project’s inception, we have remediated 42 percent of the identified discrepancies (98 discrepancies with 133 remaining). In 2022, we modified our capital program request to expedite remediation of these clearance issues. The revised request was approved by the Commission in early 2023.
Based on the pace of work and the status of work currently in process, our expectation is that we will remediate the remaining clearance issues by 2028 (in advance of the previously planned 2040 date).
NERC also requires Transmission Owners to implement a program for avoiding transmission line contacts with vegetation. We use a combination of LiDAR information and visual inspections to manage this program.
We maintain a Transmission Vegetation Management Pro
gram to proactively manage
vegetation within and outside our transmission right of way. As of December 31, 2023, within our right of way, there were:
• Zero “high risk” grow-in trees, i.e., trees that are within 6 feet of the transmission lines; • Zero “critical grow-ins,” i.e., trees that could become a “high risk” tree within a growing season or two; and
• Zero “potential grow-ins,” i.e., trees that could become “critical grow-ins” within a growing season or two.
We continue to monitor tree growth and work jointly with the farmers to address trees within our right of way.
There are trees outside of our right of way, that could fall into, or grow into, our transmission lines, causing damage to our infrastructure or starting fires. These trees are on federal lands or private property. As of December 31, 2023, outside our right of way, there were:
• T
rees outside of right of way that could affect our transmission lines • Category 1 (grow-in trees)
o 0 high risk grow-in trees that are within 6 feet of our transmission lines. o 23 critical grow-in trees that are within 13 feet of our transmission lines. All of the trees are almond trees located on private orchards and are pruned, as needed, to maintain compliance.
o 35 potential grow-in trees that are within 19 feet of our transmission lines. All of the trees are almond trees located on private orchards and are pruned, as needed, to maintain compliance.
• Category 2 (fall-in trees offset less than 40 feet from our right of way) o 0 critical fall-in trees.
o 0 potential fall-in trees.
1 A discrepancy is defined as a location where the clearance between the conductor and a hard object do not meet either the National Electric Safety Code or the CPUC, General Order 95, minimum safety clearance criteria. A hard object can be the ground, a building, other electrical wires, etc.
• Category 3 (fall-in trees offset greater than 40 feet from our right of way) o During 2023, we identified an error in the reporting of Category 3 trees offset greater than 40 feet from our right of way. We previously reported a total of 288 Category 3 trees; however, due to density, there were more trees than previously seen via LiDAR. Accordingly, although 165 Category 3 trees were removed during 2023 (as of January 9, 2024), 176 Category 3 trees remain to be addressed.
o Trees are on private land between Ferretti Rd to Groveland. The majority of these trees will be removed in spring 2024.
Regulatory Update: New, updated, or modified Reliability Standards continue to be approved by FERC. For 2024 enforcement, as of the date of this report, four revised applicable Reliability Standards have gone into effect, and there are currently 11 new or revised applicable Reliability Standards approved as “Subject to Future Enforcement” with effective dates throughout 2024 and 2025. Additionally, there are five applicable Reliability Standards identified by NERC as “Filed and Pending Regulatory Approval.” We will monitor and adjust processes and procedures to meet the changing Requirements by the respective effective dates.
Securing the grid against cyber and physical attacks, effectively responding to extreme weather events (e.g., snow, floods, heat, wind, storms, etc.), maximizing the capacity of the grid, and the growing dependency on renewable/inverter-based resources were important regulatory issues in 2023. We expect these items to continue to be important focus areas in 2024. We regularly monitor these regulatory developments and will adjust our priorities accordingly.
NERC and WECC continue to review and adjust their oversight activities to reflect their own risk assessments and the degree of internal controls put into place by the regulated entities. Participation in Industry Forums and WECC sponsored workshops/conferences (e.g., Reliability and Security Workshop) aid in understanding any changes to NERC/WECC compliance philosophies or approaches. NERC’s 2024 Compliance Monitoring and Enforcement Program Implementation Plan spotlights a focus on the following Risk Elements: 1) Remote Connectivity, 2) Supply Chain, 3) Physical Security, 4) Incident Response, 5) Stability Studies, 6) Inverter-Based Resources, 7) Facility Ratings and 8) Extreme Weather. The changes from the 2023 Risk Elements include a new physical security risk element, and the expansion of the “cold” weather risk element to “extreme” weather, which includes cold and hot weather, as well as space weather events.
Attachment A
WECC Public Audit Report for HHWP’s 2023 Compliance Audit Date of 2023 Compliance Audit: June 20, 2023 – June 30, 2023 Date of Report: February 6, 2024
<Confidential>
NCR ID: NCR05182
Hetch Hetchy
Water & Power:
Hetch Hetchy Water & Power
HHWP:
HHWP
Reliability
Standards Scope:
Operations & Planning (FERC Order 693) Standards
Compliance
Monitoring
Process:
Compliance Audit
Distribution:
Public Version. Confidential Information Has Been
Removed, Including Privileged and Critical Energy
Infrastructure Information.
Regional Entity:
Western Electricity Coordinating Council (WECC)
Date of Opening
Presentation: June 20, 2023
Date of
Closing
Presentation:
June 30, 2023
Date of Report: February 6, 2024 IP Year: 2023
Potential
Noncompliance: None (zero)
Jurisdiction:
United States
Attachment A
(2023 Annual Electric Reliability Compliance Program Report) <Confidential>
Table of Contents
Executive Summary ................................................................................................................................................3 Compliance Audit Process ....................................................................................................................................4 Objectives .............................................................................................................................................................4 Scope ....................................................................................................................................................................4 Internal Compliance Program ...........................................................................................................................5 Controls ................................................................................................................................................................5 Confidentiality and Conflict of Interest ...........................................................................................................5 Methodology ........................................................................................................................................................5 Company Profile .................................................................................................................................................7 Compliance Audit Findings .................................................................................................................................7 Areas of Concern, Recommendations and Positive Observations ................................................................7 Compliance Culture ...............................................................................................................................................7 Appendix 1: Compliance Audit Participants .....................................................................................................8
Date of 2023 Compliance Audit: June 20, 2023 – June 30, 2023 Date of Report: February 6, 2024
<Confidential>
Executive Summary
WECC conducted an Operations & Planning Compliance Audit of Hetch Hetchy Water & Power (HHWP), NCR ID NCR05182 from June 20, 2023 to June 30, 2023.
At the time of the Compliance Audit, HHWP was registered for the functions of Generator Operator (GOP), Generator Owner (GO), Transmission Operator (TOP), Transmission Owner (TO), Transmission Planner (TP).
The Reliability Coordinator (RC), Balancing Authority (BA), Transmission Operator (TOP), Planning Authority (PA), Transmission Planner (TP), and Resource Planner (RP) for HHWP are as follows, respectively RC West, CAISO, HHWP, CAISO, HHWP, and RC West.
HHWP performs the functions of Transmission Planner (TP) for itself only (HHWP).
The Compliance Audit team (team) evaluated HHWP for compliance with seven (7) Operations and Planning requirements for the 2023 Electric Reliability Organization (ERO) Enterprise Compliance Monitoring and Enforcement Program (CMEP). The team assessed compliance with the NERC Reliability Standards for the period of May 12, 2020, to February 21, 2023.
HHWP submitted evidence for the team’s evaluation of compliance with requirements. The team reviewed and evaluated all evidence provided to assess compliance with Reliability Standards applicable to HHWP at this time.
Based on the evidence provided, no findings were noted for the Reliability Standards and applicable Requirements in scope for this engagement.
The team notified HHWP of one (1) recommendation.
The WECC Compliance Audit team lead certifies that the team adhered to all applicable requirements of the NERC Rules of Procedure (ROP) and Compliance Monitoring and Enforcement Program (CMEP).1
1This statement replaces the Regional Entity Self-Certification process.
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Compliance Audit Process
The Compliance Audit process steps are detailed in the NERC ROP. The CMEP generally conforms to the United States Government Auditing Standards and other generally accepted audit practices.
Objectives
All registered entities are subject to compliance assessments with all Reliability Standards applicable to the functions for which the registered entity is registered2 in the Region(s) performing the assessment.
The Compliance Audit objectives are designed to:
• Provide reasonable assurance of compliance to the identified applicable Reliability Standards. • Review compliance with applicable NERC Reliability Standards identified for 2023 ERO Enterprise CMEP.
• Review evidence of self-reported violations and previous self-certifications. • Review HHWP’s internal compliance program and controls.
Scope
The scope of this Compliance Audit considered the NERC Reliability Standards from the 2023 ERO Enterprise CMEP Implementation Plan, and the Inherent Risk Assessment (IRA) of HHWP completed by WECC. In addition, the scope of the Compliance Audit included a review of Mitigation Plans or Remedial Action Directives that were open during the Compliance Audit.
The Reliability Standards and Requirements in-scope for this Compliance Audit are illustrated in Table 2 Compliance Audit Scope:
Table 2: Compliance Audit Scope
Registered
Function Standards Requirement(s)
GO MOD-025-2 R1, R2.
GO, TO MOD-032-1 R3.
GOP PER-006-1 R1.
TO PRC-002-2 R1.
GO, TO PRC-024-3 R1, R2.
The team reduced the scope of the Compliance Audit from what was stated in the notification package.
2NERC ROP, Appendix 4C, Section 3.1, Compliance Audits.
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Table 2b: Compliance Audit Scope (Reduced)
Registered
Function Standards Requirement(s)
GO, TO FAC-008-5 R6.
Internal Compliance Program
Within the scope of the Compliance Audit, HHWP’s compliance program was not reviewed.
Assessment of HHWP’s internal compliance program will be performed by WECC on an as-needed basis.
Controls
The team reviewed HHWP’s related internal controls associated with NERC Reliability Standards in scope.
Confidentiality and Conflict of Interest
Confidentiality and conflict of interest of the team are governed under the Regional Delegation Agreements with NERC, and Section 1500 of the NERC ROP. 3 HHWP was informed of WECC’s obligations and responsibilities under the agreement and procedures. The work history for each team member was provided to HHWP, which was given an opportunity to object to a team member’s participation on the basis of a possible conflict of interest or the existence of other circumstances that could interfere with a team member’s impartial performance of duties. HHWP had not submitted any objections by the stated objection due date based on the ROP and accepted the team member participants without objection. There were no denials or access limitations placed upon this team by HHWP.
Methodology
The ERO Compliance Monitoring and Enforcement Manual (Manual)4 documents the ERO Enterprise’s current approaches used to assess a registered entity’s compliance with the NERC Reliability Standards. The ERO Enterprise uses, “to the extent possible, the Generally Accepted Auditing Standards (GAAS), the Generally Accepted Government Auditing Standards (GAGAS), and standards sanctioned by the Institute of Internal Auditors, as guidance for performing activities under the Compliance Monitoring and Enforcement Program (CMEP).”5 While the ERO Enterprise does not necessarily perform compliance monitoring activities that must be in accordance with these standards
3 See NERC ROP
4https://www.nerc.com/pa/comp/CAOneStopShop/ERO_Enterprise_Compliance%20Monitoring%20and%20Enforcement%20 Manual_v5.0.pdf
5NERC ROP, Section 1207 and 126 FERC 61,038, Paragraph 3 Distribution: Public Version. Confidential Information Has Been Removed, Including Privileged and Critical Energy Infrastructure Information. 6 <Confidential>
recognized in the United States, the ERO Enterprise uses these standards as framework to conduct compliance monitoring activities under the CMEP, and recognizes that these standards provide information used in oversight, accountability, transparency, and improvements in ERO Enterprise operations.
The WECC provided HHWP with a Compliance Audit notification package to commence the Compliance Audit. HHWP provided evidence at the time requested, or as agreed upon, by WECC. The team reviewed the evidence submitted by HHWP and assessed compliance with the requirements of the applicable Reliability Standards. Additional evidence could be submitted until the agreed-upon deadline prior to the exit briefing. After that date, only data or information that was relevant to the content of the report or its finding could be submitted with the agreement of the team lead.
The team reviewed documentation provided by HHWP and requested additional evidence and sought clarification from subject matter experts during the Compliance Audit. The evidence submitted in the form of policies, procedures, emails, logs, studies, data sheets, etc. were validated, substantiated, and cross-checked for accuracy as appropriate. Where sampling is applicable to a requirement, the sample set was determined by a statistical methodology, along with professional judgment as mentioned in the Manual.
The findings were based on the facts and documentation reviewed, the team’s knowledge of the Bulk Electric System (BES), the NERC Reliability Standards, and professional judgment. All findings were developed based upon the consensus of the team.
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Company Profile
Hetch Hetchy Water and Power (HHWP) is a division within the San Francisco Public Utilities Commission (SFPUC), which is a department of the City and County of San Francisco. The SFPUC is headed by the General Manager. A five-member commission (the Commission) provides policy direction to and undertakes general oversight of the SFPUC. The Division Manager of HHWP reports to an Assistant General Manager of the SFPUC and is responsible for the operation and maintenance of HHWP Bulk Electric System (BES) facilities.
HHWP owns and operates 385 MW of hydroelectric generation capacity (Holm, Kirkwood and Moccasin), and 160 miles of transmission lines (115kV and 230 kV).
Compliance Audit Findings
Based on the results of this Compliance Audit, no findings were noted for the Reliability Standards and applicable Requirements in scope for this engagement.
Areas of Concern, Recommendations and Positive Observations This information has been redacted.
Compliance Culture
HHWP’s compliance culture was not formally reviewed by the team as part of the compliance audit.
WECC Contact Information
Any questions regarding this Compliance Audit report can be directed to:
WECC
155 North 400 West, Suite 200
Salt Lake City, UT 84103
On behalf of WECC, this report was prepared and reviewed by:
Compliance Audit Team Lead Date
David Cronin, Compliance Auditor, Operations & Planning August 9, 2023 Management Rep Date
Phil O’Donnell, Interim Manager, Entity Monitoring, Operations & Planning August 14, 2023
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Appendix 1: Compliance Audit Participants
Appendix Table 1: Compliance Audit Team and Appendix Table 2: HHWP Participants list all personnel from the team and HHWP who were directly involved during the meetings and interviews.
Role Title Entity
Compliance (ATL) Compliance Auditor, Operations & Planning WECC Team Member Compliance Auditor, Operations & Planning WECC Team Member Compliance Auditor, Operations & Planning WECC Team Member Compliance Program Coordinator WECC
Observer Manager, Oversight Analysis & Administration WECC Observer Director, Entity Monitoring WECC
Observer Director Oversight Planning & Analysis WECC
Observer Interim Manager, Entity Monitoring,
Operations & Planning
WECC
Observer Compliance Auditor, Operations & Planning WECC
Title Entity
Power Generation and Transmission Manager HHWP
Security Specialist HHWP
Senior Consultant (OP Specialist) HHWP
Operations and Transmission Planning Engineer HHWP
NERC/WECC Compliance Administrator HHWP
Engineer HHWP
Compliance Engineer HHWP
NERC/WECC Compliance Manager HHWP