EUCI is authorized by IACET to offer 0.6 CEUs for the course

COURSE

March 13, 2018Courtyard by Marriott PortlandPortland, OR

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FERC ELECTRICITY 101March 12, 2018 | Portland, OR

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FERC COMPLIANCE AND ENFORCEMENT

FERC COMPLIANCE AND ENFORCEMENTPortland, OR | March 13, 2018

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OVERVIEWThis course looks at many of the substantive requirements with which utilities – and in some cases, other participants in the electricity markets – must comply. In addition, it addresses steps that can be taken before FERC initiates an investigation or audit, describes what happens if FERC decides to act and when and what an organization should do in that case, and reviews the array of penalties that could be imposed when a violation occurs.

LEARNING OUTCOMES• Identify the substantive requirements involved in ensuring compliance with FERC regulations• Discuss the FERC organization and describe the divisions that are responsible for enforcement of FERC requirements• Describe the essential elements of protecting an organization by establishing proactive measures focused on

maintaining compliance• Explain what makes an internal compliance and audit program effective• Define the purpose of the FERC hotline• Examine various scenarios of actions that can be taken by FERC and consider organizational responses• Recognize penalties that can be imposed by FERC• Consider mitigating factors that may apply to FERC actions and their benefits

WHO SHOULD ATTEND• Engineers• Utility project managers• Transmission and distribution personnel• Members of the financial community • Attorneys• Regulators and regulatory affairs personnel for utilities• Governmental agencies interested in FERC compliance rules

“Very insightful for people new to the FERC/NERC world!”

FERC Compliance Analyst, Entergy

FERC COMPLIANCE AND ENFORCEMENTPortland, OR | March 13, 2018

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AGENDATUESDAY, MARCH 13, 2018

8:00 – 8:30 am Registration and Continental Breakfast

8:30 – 8:40 am Welcome, Introduction, and Overview

8:40 – 9:25 am Introduction to Electric Reliability: Mandatory and Enforceable Reliability Regime• Reliability History• Federal Power Act and Energy Policy Act of 2005• NERC

9:25 – 10:15 am Current Threats and Emerging Issues • Use of FERC’s Top-Down Authority• Scope of Emerging and Evolving Challenges

10:15 – 10:30 am Morning Break

10:30 – 11:15 am Transition to Risk-Based Monitoring and Enforcement • Monitoring and Enforcement Processes• Risk-Based Enforcement

11:15 am – 12:30 pm Reliability Compliance Best Practices• Understanding Regulatory Context• Cultivating Internal Structure• Conducting Compliance Reviews• Engaging in ERO CMEP Activities

12:30 – 1:30 pm Group Luncheon

1:30 – 2:45 pm Introduction to Market Manipulation • FERC Enforcement Background• Historical Development of FERC Enforcement o Prior to FERC: 1930s – 1970s o Non-FERC Agency Enforcement Regimes o Initial FERC Regime: 1977 – 2005• Current FERC Regime: 2005 – Present o Order No. 670 o Typical Enforcement Issues o Examples of Prohibited Actions o Case Studies

2:45 – 3:00 pm Afternoon Break

“Great for those new to the industry.”

Regulatory Consultant, AEP

FERC COMPLIANCE AND ENFORCEMENTPortland, OR | March 13, 2018

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TUESDAY, MARCH 13, 2018 (CONTINUED)

3:00 – 4:00 pm FERC Enforcement Process and Audits• How Enforcement Investigations Undertaken• Settlement Procedures• Orders to Show Cause• Appeal Routes• Penalties• Guidance Letters• Audits o How conducted o Recent Examples

4:00 – 4:30 pm Enforcement Penalties and Best Practices• FERC Penalty Guidelines• Best Practices for Handling the FERC Enforcement Process

4:30 – 5:30 pm Questions and Discussion

COURSE INSTRUCTORSTyler MansholtSenior Associate, Duncan, Weinberg, Genzer & Pembroke, P.C.

Tyler is a senior associate in the firm with a practice focused on matters before the FERC, as well as other Federal and state agencies, involving the electric, natural gas, and hydropower industries. With regard to electric regulation, Tyler has advised clients on a wide range of Federal matters associ-ated with wholesale markets, mergers and acquisitions, transmission incentives, and formula rates. In addition, he has assisted clients on matters before state utility commissions, including interconnection procedures, distributed generation, and integrated resource planning. In the area of natural gas, Tyler has advised clients regarding the Federal implications associated with the development of pipeline infrastructure, particularly as it regards compliance with environmental requirements. Tyler’s hydropower practice at the firm has also counseled clients on jurisdictional issues, permitting requirements, and preference power conditions.Prior to joining the firm, Tyler was employed at the FERC as an Attorney-Advisor in the Office of Gener-al Counsel. While at FERC, Tyler provided council on natural gas matters, including market-based rate and jurisdictional determinations, and applications for the construction of pipeline facilities, storage facilities, liquid natural gas facilities, presidential permits, and abandonment. Tyler also provided legal and policy advice on a wide range of hydropower matters, including preliminary permits, exemptions, licenses, relicenses, and surrenders.

AGENDA

FERC COMPLIANCE AND ENFORCEMENTPortland, OR | March 13, 2018

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Kristen Connolly McCulloughPartner, Duncan, Weinberg, Genzer & Pembroke, P.C.

Since 2012, Kristen Connolly McCullough has been a Partner with Duncan, Weinberg, Genzer, & Pem-broke, P.C. Her practice generally consists of energy law, administrative law and regulatory matters. She represents and advises municipal utilities, municipal joint action agencies, electric cooperatives, and national trade associations on a variety of issues, including matters pertaining to North American Electric Reliability Corporation (NERC) and Regional Entity proceedings, rate and tariff filings before the Federal Energy Regulatory Commission (FERC) and state utility commissions, rulemaking proceedings, legislation, compliance and enforcement, and settlement negotiations. In addition, she handles appeals of FERC cases before the US Court of Appeals for the DC Circuit and the US Court of Appeals for the Ninth Circuit.

With the increased national focus on cyber attacks generally, there have been a multitude of executive actions and legislative initiatives intended to maintain national security, economic prosperity, and civil liberties by reducing threats to the nation’s critical assets, including the bulk electric system, via cyber attacks. These initiatives are intended to supplement or supersede the NERC Critical Infrastructure Protection (CIP) Reliability Standards. Accordingly, Ms. Connolly McCullough actively monitors these activities, advocates her clients’ positions, and advises clients regarding best practices, trends, and potential regulation arising from these legislative and executive initiatives with respect to addressing potential vulnerabilities of the bulk power system. She participated in NIST’s development process of its Cybersecurity Framework, a framework consisting of standards, guidelines, and practices (not specific to the electric sector) designed to protect critical infrastructure by minimizing any cybersecurity-related risk, on behalf of her clients.

With respect to reliability, Ms. Connolly McCullough regularly advises clients on the full panoply of issues stemming from the mandatory and enforceable Reliability Standards, including with respect to navigating their way through the NERC and Regional Entity Compliance Monitoring and Enforcement Programs, e.g., compliance audits, NOAVs, data submittals, self-reporting and self certifications, as well as audit preparation for subject matter experts and assisting with the compilation of compliance evidence and RSAWs. She has negotiated numerous settlements with the relevant Regional Entities on behalf of her clients regarding alleged violations of Reliability Standards and proposed penalties. Ms. Connolly McCullough routinely updates clients on developments pertaining to the NERC Reliability Standards at both the NERC industry stakeholder level through ballots and initiatives and the FERC level through NERC filings. She also routinely counsels clients through the development of internal compli-ance programs, document retention policies, and compliance trainings, and drafts formal and informal delegation agreements pertaining to the performance of the Reliability Standards.

COURSE INSTRUCTORS

FERC COMPLIANCE AND ENFORCEMENTPortland, OR | March 13, 2018

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REQUIREMENTS FOR A SUCCESSFUL COMPLETION OF PROGRAMParticipants must sign in/out each day and be in attendance for the entirety of the course to be eligible for continuing education credit.

INSTRUCTIONAL METHODSThis program will use PowerPoint presentations, group discussions, as well as active participation.

EVENT LOCATIONA room block has been reserved at the Courtyard by Marriott Portland, 550 SW Oak St, Portland, OR 97204, for the nights of March 11-12, 2018. Room rates are $169 plus applicable tax. Call 1- 503-505-5000 for reservations and mention the EUCI event to get the group rate. The cutoff date to receive the group rate is February 11, 2018 but as there are a limited number of rooms available at this rate, the room block may close sooner. Please make your reservations early.

IACET CREDITSEUCI has been accredited as an Authorized Provider by the International Association for Continuing Education and Training (IACET). In obtaining this accreditation, EUCI has demonstrated that it complies with the ANSI/IACET Standard which is recognized internationally as a standard of good practice. As a result of their Authorized Provider status, EUCI is authorized to offer IACET CEUs for its programs that qualify under the ANSI/IACET Standard.

EUCI is authorized by IACET to offer 0.6 CEUs for this course.

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PLEASE REGISTER

WWW.EUCI.COMp: 303-770-8800f: 303-741-0849

A room block has been reserved at the Courtyard by Marriott Portland, 550 SW Oak St, Portland, OR 97204, for the nights of March 11-12, 2018. Room rates are $169 plus applicable tax. Call 1- 503-505-5000 for reservations and mention the EUCI event to get the group rate. The cutoff date to receive the group rate is February 11, 2018 but as there are a limited number of rooms available at this rate, the room block may close sooner. Please make your reservations early.

BOTH FERC ELECTRICITY 101 AND FERC COMPLIANCE AND ENFORCEMENT COURSES: MARCH 12-13 2018: US $1895EARLY BIRD on or before February 23, 2018: US $1695

FERC COMPLIANCE AND ENFORCEMENT COURSE ONLY: MARCH 13, 2018: US $995, EARLY BIRD on or before February 23, 2018: US $895

EVENT LOCATION

Substitutions & CancellationsYour registration may be transferred to a member of your organization up to 24 hours in advance of the event. Cancellations must be received on or before February 9, 2018 in order to be refunded and will be subject to a US $195.00 processing fee per registrant. No refunds will be made after this date. Cancellations received after this date will create a credit of the tuition (less processing fee) good toward any other EUCI event. This credit will be good for six months from the cancellation date. In the event of non-attendance, all registration fees will be forfeited. In case of course cancellation, EUCI’s liability is limited to refund of the event registration fee only. For more information regarding administrative policies, such as complaints and refunds, please contact our offices at 303-770-8800. EUCI reserves the right to alter this program without prior notice.

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