Coordinated Oversight of MRREs Process Development and Implementation Program The ERO Enterprise has identified over 40 groups Multi-Regional Registered Entities totaling over 150 individual registered entities to begin the Coordinated Oversight Program. In the initial implementation, the option of coordinated oversight will be offered to these 150 entities beginning in January 2015 with full implementation scheduled in June 2015. Background The program development would cover all components identified in the Regional Entity Coordinated Oversight Memorandum of Understanding. This could include the selection of risk elements through the IRA and ICE (if applicable) and determination and implementation of a monitoring oversight plan (audit, spot-check etc.). The program development also would cover coordinated enforcement-related processes. Procedures for sharing and storing relevant data would also be developed. Development of the program with the staged approach will provide useful input to the preparations for the 2016 budget and the 2016 CMEP Implementation Plans. Initial Implementation Notification Letter Distribution NERC will send the ERO EMG-approved notification letter to each of the MRRE candidate groups. NERC will send to the key compliance contact for each of the above described MRRE groups an email with the notification letter attached and copy the primary compliance contact by email for each registered entity included in the MRRE group. The email will instruct the MRRE group entity primary contact to respond with the group position regarding coordinated oversight to NERC. NERC will then send responses to the ECEMG for accumulation of status and distribution. Full Implementation In June 2015 full implementation will occur. All registered entities may notify each Regional Entity with which they are registered of their interest in Coordinated Oversight. The Regional Entities will work together and with the registered entities to seek to transition to Coordinated Oversight in a timely manner. In certain cases, it may be appropriate for the MRREs to receive Coordinated Oversight such that the MRREs might transition from having 8 Regional Entities conducting oversight to 2. 1 Implementation Schedule Initial Implementation 10/24/14 ERO EMG approval of program development proposal and MRRE initial implementation candidates. 11/17/14 Begin sending of notification letters to Initial Implementation approved MRRE candidate groups. 12/15/14 Responses to “Opt In” are due back from the initial MRREs. Coordinated Oversight is expected to begin in approximately two months, by mid-February 2015. 1/16/15 REMG selection of Lead Regions for each MRRE group that returned a positive “Opt In” response. 1/30/15 Signed MRRE MOU among affected regions. 1/30/15 Notification to initial MRREs of assigned LRE. 3/15/15 Inclusion in 2016 budgets for all affected LREs and AREs. May 2015 Report to NERC BOTCC on progress of Initial Implementation and announcement of Full Implementation Plans. 1/1/15 – 5/30/15 Formalization of processes and tools. Full Implementation 6/1/15 All Registered Entities may notify each Regional Entity with which they are registered of their interest in Coordinated Oversight. 6/30/15 Requests for Coordinated Oversight for 2016 cycle are due. 7/30/15 Regional Entities collaborate with each other and the MRREs to determine the specifics of Coordinated Oversight participation. 8/15/15 ERO EMG selection of Lead Regions for each MRRE. 8/30/15 Signed MRRE MOU among affected regions. 8/30/15 Notification to MRREs of assigned LRE. 10/1/15 Inclusion of coordinated oversight in 2016 CMEP Implementation Plan. 2 Multi-Regional Registered Entity (MRRE) Coordinated Oversight FAQ November 10, 2014 1. What is a MRRE? Response: A Multi-Regional Registered Entity (MRRE) is a registered entity that has a single NERC Compliance Registry (NCR) number in more than one region or affiliated registered entities in multiple regions with multiple NCR numbers. 2. What is a Lead Regional Entity (LRE)? Response: A LRE is the regional entity selected to lead efforts related to coordinating the compliance monitoring and enforcement oversight of a MRRE. 3. What is an Affected Regional Entity (ARE)? Response: An ARE is the Regional Entity, other than the Lead Regional Entity, in which the MRRE is registered for various NERC functional responsibilities. 4. Why have coordinated oversight of a MRRE? Response: Coordinated oversight can provide a structure for improving both efficiency to registered entity in responding to compliance oversight and consistency in the compliance oversight procedures, tools, communication, and interfaces affecting the registered entity. 5. How does a registered entity benefit from coordinated oversight of a MRRE? Response: Coordinated oversight can potentially reduce administrative burden and improve consistency. 6. How can a registered entity participate in MRRE coordinated oversight? Response: Initial Implementation will involve NERC sending letters to 43 groups of MRREs (over 150 individual registered entities). These registered entities will be requested to respond if they are interested in coordinated oversight. At Full Implementation, scheduled for June 2015, registered entities may contact their regional entities or a subset of their regional entities to request coordinated oversight or to request additional related information. 1 7. Is it mandatory that each registered entity that meets the definition of a MRRE participate in coordinated oversight? Response: No, participation by a MRRE in coordinated oversight will be voluntary for the registered entity. However, the registered entity is encouraged to consider the benefits of coordinated oversight if offered by the regional entity. 8. Can a registered entity or affiliates participate in coordinated oversight for some regions and not for others? Response: Possibly. Separating a MRRE for coordinated oversight into additional MRREs will be considered by the affected regional entities and may be acceptable if regional entities’ obligations for oversight can be appropriately met. 9. Can a Registered Entity agree to participate as a MRRE with coordinated oversight and later opt out of this coordinated oversight? Response: Yes, however there will likely be resource impacts on the affected regions in initiating the coordinating oversight as well as obligations to ensure continued compliance that must be considered in the timing and approach to ending a coordinated oversight. 10. How will the affected regions determine each of their coordinated oversight responsibilities associated with a MRRE? Response: The regional entities will consider each coordinated oversight and clearly assign compliance monitoring and enforcement activity responsibility to each region involved in the coordinated oversight. 11. How is the lead region for MRRE coordinated oversight determined? Response: The affected regional entities will consider each coordinated oversight and determine which region will be identified and obligated to be the lead region. 12. Does the MRRE have a choice of the lead region for coordinated oversight? Response: No. To ensure fulfilment of each region’s delegated responsibilities, the management of affected regions will decide who the lead region will be for each coordinated oversight. 13. Will there always be only one lead region? Response: No. In a few instances, the most appropriate Coordinated Oversight may result in more than 1 Lead Region, for example transitioning oversight from 8 Regional Entities to 2. 14. Does the coordinated oversight of a MRRE include activities other than compliance monitoring and enforcement? 2 Response: In addition to activities identified in the Compliance Monitoring and Enforcement Program (CMEP) there may be other reliability related activities for which coordination is beneficial to the registered entity and possibly the regional entity as well. Examples of such may include processing entity responses to NERC Alerts. 15. Will a MRRE involved in coordinated oversight have an identical possible violation (i.e same standard/requirement/instance/root cause/risk) numbered and reported to NERC from multiple regions? Response: A possible violation that is identical to those discovered in other regions would only be reported and processed once in coordinated oversight. To ensure any possible violations are identical, the affected regions must review and agree. 16. Will a MRRE involved in coordinated oversight be required to participate in enforcement actions such as a settlement in multiple regions? Response: Settlements and other related enforcement actions will be coordinated as well to avoid redundancy and improve efficiency. 17. If a registered entity has coordinated oversight will it become registered in just one region? Response: Participating in coordinated oversight does not change registration. It is expected that an entity would remain registered within each region in which BPS reliability functions are performed. 18. Does the Lead Regional Entity make the final decisions on compliance & enforcement? Response: In coordinated oversight each affected region will have the right and opportunity to be involved in all compliance monitoring and enforcement decisions that are related to the reliability functions of registered entities within their region. This will be coordinated among the affected regions and the MRRE will interface with the Lead Regional Entity. 19. Does the oversight authority of the affected regions terminate once an entity is a MRRE? Response: No. Each affected region in the coordinated oversight retains responsibility and authority to ensure compliance with the approved reliability standards. Coordinated oversight can improve the consistency and efficiency to the registered entity of implementing this regional responsibility. 3 NOTIFICATION TEMPLATE [DATE] Via Electronic Mail [Registered Entity Contact Name, Contact Title] [Registered Entity Name] [Street Address] [City, State Zip Code] [Contact’s email address] Subject: Notice of Regional Entity Coordinated Oversight Dear Mr./Mrs./Ms. [NAME]: The purpose of this letter is to notify [Registered Entity] of its eligibility for Coordinated Oversight and to summarize the protocols of the affected Regional Entities will utilize to assure coordination of delegated functions (e.g. compliance monitoring and enforcement, event analysis etc.). This coordinated regulatory oversight between the Regional Entities is intended to streamline risk assessment, compliance monitoring and enforcement, and event analysis activities. [Registered Entity] may choose to participate in Coordinated Oversight by providing written notification to NERC by December 15, 2014. We would expect the Coordinated Oversight to begin approximately two (2) months after we receive your notification. If [Registered Entity] does not desire Coordinated Oversight, the Regional Entities will continue to separately address their respective risk assessment, compliance monitoring and enforcement and event analysis activities for [Registered Entity]. Lead Regional Entity If [Registered Entity] elects to participate in Coordinated Oversight, the Regional Entities will identify a Lead Regional Entity (LRE) for [Registered Entity]. The LRE will notify you when the identification has been agreed upon. The affected Regional Entities will periodically review the Coordinated Oversight activities to ensure efficiencies are preserved. The LRE may be changed from time to time, as agreed upon by the affected Regional Entities. In the event of a change in LRE, the affected Regional Entities will notify [Registered Entity]. In addition to those roles listed below, the LRE, will: 1) include [Registered Entity] in LRE’s annual implementation plan; 2) maintain adequate resources with regard to oversight activities pertaining to the compliance monitoring and enforcement of [Registered Entity]’s matters and coordinate with Affected Regional Entity(s) (ARE) regarding the use of ARE’s resources for compliance monitoring and enforcement activities; 3) provide ARE with the opportunity to participate in any compliance monitoring and enforcement activity; 4) ensure NERC Rules of Procedure are followed during Coordinated Oversight 5) select the oversight approach for [Registered Entity], including timing and frequency of such activities, after coordinating and receiving input from ARE; 6) compose reports related to coordinated compliance monitoring and enforcement activities and provide such reports to ARE for review and comment, prior to the issuance of the report;1 and 7) perform all risk and internal controls evaluation(s) of [Registered Entity] in coordination with ARE. Self-Reports [Registered Entity] will self-report all potential instances of noncompliance to LRE. If [Registered Entity] has any concerns about unnecessary duplication of effort on any future selfreported potential violations, please contact the LRE staff. Compliance Audits LRE will lead the scheduling and execution of the compliance audits conducted of [Registered Entity] with participation from ARE staff. Self-Certifications [Registered Entity] will submit self-certifications to LRE in accordance with LRE’s Implementation Plan for the NERC CMEP. Should ARE identify a self-certification needed from [Registered Entity], ARE will coordinate the self-certification request with LRE. Periodic Data Submittals [Registered Entity] will submit periodic data submittals to LRE in accordance with the LRE periodic data submittal schedule. Should ARE identify a “periodic data submittal” needed from [Registered Entity], ARE will coordinate the data submittal request with LRE. Compliance Investigations LRE will perform any Compliance Investigations of [Registered Entity]. LRE will notify ARE of the conduct of a compliance investigation and seek assistance from ARE as needed. If there is a reason for ARE to initiate and conduct a compliance investigation of [Registered Entity], ARE will notify LRE and coordinate the performance of such compliance investigation of [Registered Entity] with LRE. Complaints Both LRE and ARE may receive complaints regarding allegations of [Registered Entity]’s violation(s) of FERC approved Reliability Standards or requirements. If ARE receives a complaint against [Registered Entity], ARE will notify and coordinate with LRE to review and resolve the complaint. In any case, LRE and ARE will inform each other of the issuance of a complaint, result of the review and the proposed resolution of the matter. Spot Checks LRE will notify and coordinate the performance of any Spot Checks of [Registered Entity] with ARE. Should there be a reason why ARE may need to conduct a Spot Check of [Registered Entity], ARE will notify LRE and coordinate the performance of such Spot Check of [Registered Entity] with LRE. Technical Feasibility Exceptions (TFEs) LRE will be responsible for handling all TFE’s submitted by [Registered Entity], regardless of where they may apply within [Registered Entity]’s operations. [Registered Entity] will only need to request TFE approvals and amendments from LRE, but will clearly note any TFEs for covered assets that reside within the ARE footprint. LRE will then consult and coordinate with ARE on the TFE’s specific to facilities within the ARE footprint. Any required quarterly or annual TFE update reports will be submitted by [Registered Entity] to LRE. Pending Violations Pending violations which are duplicative or redundant and currently open in the LRE and ARE Regions will be handled and processed by LRE. ARE will issue a Notice of Transfer to LRE and a Notice of Dismissal to [Registered Entity] for any open NERC tracking IDs within ARE’s footprint. Mitigation Plan Review and Verification LRE will coordinate the review and acceptance of any mitigating activities or a mitigation plan with ARE prior to acceptance. LRE will lead and coordinate verification of all completion of any mitigating activities or mitigation plans with ARE. Enforcement Coordination LRE will provide periodic updates to ARE throughout the enforcement process. LRE will copy ARE during the issuance of notices, draft settlement agreements, and final settlement agreements to [Registered Entity]. Retention and Disposal of Confidential Compliance Monitoring and Enforcement Data LRE will be responsible for the secure transfer and storage of all data and evidence associated with all coordinated oversight activities. LRE will be responsible for retention and disposal timing as required by NERC rules and regulations. In the event that [Registered Entity] is no longer considered a MRRE, then ARE will resume responsibility for the retention and disposal of any new data from the effective date of the transition. System Events LRE will review system events or disturbances related to [Registered Entity]’s facilities exclusively in the LRE footprint including reviews of [Registered Entity]’s compliance selfassessments of an event. LRE will provide any reports to ARE. For system events or disturbances which may exclusively involve facilities within the ARE footprint, the ARE will lead the coordination and review of the event analysis and will provide any reports to the LRE. For system events or disturbances related to [Registered Entity’s] facilities that impact both LRE and ARE footprints, LRE will notify and coordinate with the ARE to complete an adequate analysis. NERC Alerts LRE is designated to handle responses from [Registered Entity] regarding NERC Alerts. Any required status updates associated with NERC Alerts should be submitted to LRE. LRE will consult and coordinate with ARE regarding assets located within the ARE footprint which are subject to the NERC Alert. This notice is being sent to a limited group of MRREs. It is part of an initial effort to refine and implement the processes and tools necessary to support coordinated oversight of MRREs. In about six months, coordinated oversight will be opened more broadly to address requests from other MRREs. Also, entities that received this notice but choose not to participate will have future opportunity to express an interest in coordinated oversight. We trust that this notice will inform [Registered Entity] as to LRE’s and ARE’s protocols for coordinating their compliance monitoring and enforcement processes for [Registered Entity]. Please contact us should you have questions or require additional information regarding the Coordinated Oversight protocols discussed above. Please send your notification to Brooke Thornton ([email protected]) requesting participation in this Coordinated Oversight program by December 15, 2014. Coordinated Oversight - MRRE Initial Notification List 11/17/2014 Item # 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 NCR ID# NCR05002 NCR03039 NCR00663 NCR05004 NCR11178 NCR05007 NCR01055 NCR00666 NCR00667 NCR01168 NCR01169 NCR11249 NCR11027 NCR00961 NCR10337 NCR 00962 NCR00685 NCR00685 NCR00769 NCR00769 NCR00769 NCR00769 NCR00769 NCR04015 NCR01186 NCR10371 NCR11341 NCR11202 NCR11094 NCR00743 NCR00744 NCR10007 NCR00017 NCR10009 NCR10010 NCR00018 NCR10389 NCR10011 NCR11009 Entity Name AES Alamitos, LLC AES Armenia Mountain Wind, LLC AES Beaver Valley L.L.C AES Huntington Beach, LLC AES Laurel Mountain, LLC AES Redondo Beach LLC AES Shady Point, LLC AES Warrior Run Alcoa Power Generating, Inc. Alcoa Power Generating, Inc. - Tapoco Division Alcoa Power Generating, Inc. - Yadkin Division Algonquin Power Sanger LLC Algonquin Power Windsor Locks, LLC Alliant Energy - East Alliant Energy - East Alliant Energy - West American Transmission Co., LLC American Transmission Co., LLC Boston Energy Trading and Marketing LLC Boston Energy Trading and Marketing LLC Boston Energy Trading and Marketing LLC Boston Energy Trading and Marketing LLC Boston Energy Trading and Marketing LLC Brazos Electric Power Co Op, Inc. Brazos Electric Power Cooperative, Inc. CCI Rensselaer LLC CCI Roseton LLC CCI Signal Hill LLC Coolidge Power LLC Covanta Delaware Covanta Essex Covanta Hennepin Energy Resource Co. Covanta Lee Covanta Niagara LP Covanta Onondaga LP Covanta Pasco Inc. Covanta Plymouth Renewable Energy, LLC. Covanta SEMASS LLC Covanta Southeastern Florida Renewable Energy (SEFLOR), LT Sheet 1 of 4 Regional Compliance Enforcement Authority WECC RFC RFC WECC RFC WECC SPP RFC RFC SERC SERC WECC NPCC MRO RFC MRO MRO RFC MRO RFC SPP TRE WECC TRE SERC NPCC NPCC TRE WECC RFC RFC MRO FRCC NPCC NPCC FRCC RFC NPCC FRCC Item # 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 NCR ID# NCR10298 NCR10388 NCR01211 NCR07061 NCR07065 NCR01219 NCR00761 NCR00063 NCR10264 NCR11032 NCR11241 NCR01298 NCR11187 NCR00200 NCR00200 NCR00200 NCR01234 NCR11167 NCR11166 NCR07071 NCR07072 NCR07073 NCR07074 NCR08052 NCR07075 NCR11200 NCR00374 NCR00540 NCR00212 NCR00251 NCR00780 NCR10331 NCR10331 NCR00794 NCR00794 NCR00795 NCR00795 NCR10400 NCR10192 NCR00803 NCR01113 NCR04088 NCR00168 Entity Name Covanta West Enfield Covanta York Renewable Energy, LLC. Covanta, Fairfax, Inc. Dominion Energy Manchester Street, Inc. Dominion Nuclear Connecticut, Inc. Duke Energy Carolinas Duke Energy Corporation Duke Energy Florida, Inc. Duke Energy Generation Services, Inc. Duke Energy Generation Services, Inc. Duke Energy Generation Services, Inc. Duke Energy Progress, Inc. Dynegy Midwest Generation, LLC Dynegy Power, LLC Dynegy Power, LLC Dynegy Power, LLC Entergy Entergy - Fossil & Hydroelectric Generation Entergy - Nuclear Entergy Nuclear Fitzpatrick, LLC Entergy Nuclear Generation Company Entergy Nuclear Indian Point 2, LLC Entergy Nuclear Indian Point 3, LLC Entergy Nuclear Palisades, LLC Entergy Nuclear Vermont Yankee, LLC Entergy Rhode Island State Energy LP Essential Power Massachusetts, LLC Essential Power Newington, LLC Essential Power OPP, LLC Essential Power Rock Springs, LLC Fairless Energy, LLC First Wind O&M, LLC First Wind O&M, LLC Hoosier Energy REC, Inc. Hoosier Energy REC, Inc. Illinois Municipal Electric Agency Illinois Municipal Electric Agency ITC Great Plains, LLC ITC Midwest ITC Transmission Kiowa Power Partners, LLC Kiowa Power Partners, LLC Lakewood Cogeneration, LP Sheet 2 of 4 Regional Compliance Enforcement Authority NPCC RFC SERC NPCC NPCC SERC RFC FRCC WECC TRE SPP SERC SERC NPCC RFC WECC SERC SERC SERC NPCC NPCC NPCC NPCC RFC NPCC NPCC NPCC NPCC RFC RFC RFC WECC NPCC SERC RFC RFC SERC SPP MRO RFC SPP TRE RFC Item # 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 NCR ID# NCR10226 NCR11107 NCR10022 NCR00817 NCR05235 NCR11273 NCR04097 NCR00820 NCR08023 NCR00826 NCR00826 NCR00826 NCR00826 NCR07142 NCR07143 NCR10394 NCR03044 NCR03044 NCR03044 NCR03044 NCR05247 NCR01015 NCR00303 NCR05256 NCR10366 NCR10271 NCR10367 NCR10272 NCR10273 NCR11070 NCR10368 NCR01019 NCR07182 NCR00859 NCR00859 NCR07186 NCR00879 NCR00879 NCR00893 NCR11239 NCR00895 NCR07201 NCR07202 Entity Name Llano Estacado Wind, LP LSP University Park, LLC LSP-Cottage Grove, LP LSP-Whitewater, LP Mesquite Power LLC Mesquite Solar 1, LLC Mesquite Wind LLC METC Michigan Electric Coordinated Systems Midcontinent Independent System Operator, Inc. Midcontinent Independent System Operator, Inc. Midcontinent Independent System Operator, Inc. Midcontinent Independent System Operator, Inc. Milford Power Company, LLC Milford Power, LLC Milford Wind Corridor Phase I, LLC MISO-MBHydro Contingency Reserve Sharing Group MISO-MBHydro Contingency Reserve Sharing Group MISO-MBHydro Contingency Reserve Sharing Group MISO-MBHydro Contingency Reserve Sharing Group Montana-Dakota Utilities Co., a Division of MDU Resources G Montana-Dakota Utilities Company Municipal Energy Agency Of Nebraska Municipal Energy Agency of Nebraska Noble Altona Windpark, LLC Noble Bliss Windpark, LLC Noble Chateaugay Windpark, LLC Noble Clinton Windpark, LLC Noble Ellenburg Windpark, LLC Noble Great Plains Windpark, LLC Noble Wethersfield Windpark, LLC Northern Iowa Wind Power 1, LLC Ocean State Power Old Dominion Electric Cooperative Old Dominion Electric Cooperative Orange and Rockland Utilities Inc. PJM Interconnection, LLC PJM Interconnection, LLC PSEG Fossil LLC PSEG New Haven LLC PSEG Nuclear LLC PSEG Power Connecticut LLC PSEG Power New York LLC Sheet 3 of 4 Regional Compliance Enforcement Authority SPP RFC MRO RFC WECC WECC TRE RFC RFC MRO RFC SERC SPP NPCC NPCC WECC MRO RFC SERC SPP WECC MRO MRO WECC NPCC NPCC NPCC NPCC NPCC SPP NPCC MRO NPCC RFC SERC NPCC RFC SERC RFC NPCC RFC NPCC NPCC Item # 126 127 128 129 130 131 132 133 134 135 136 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 157 158 159 160 161 162 163 164 165 166 NCR ID# NCR10026 NCR10026 NCR10314 NCR11207 NCR00863 NCR00071 NCR01322 NCR11221 NCR11396 NCR01143 NCR01143 NCR01143 NCR00543 NCR00088 NCR01342 NCR01342 NCR01342 NCR04146 NCR09037 NCR07220 NCR11071 NCR10102 NCR10030 NCR08034 NCR10032 NCR08036 NCR08037 NCR09028 NCR09006 NCR00940 NCR00940 NCR01160 NCR01160 NCR02923 NCR08077 NCR10172 NCR10185 NCR10184 NCR10033 NCR05546 NCR10221 Entity Name Purenergy Operating Services , LLC Purenergy Operating Services , LLC Quantum Auburndale Power, LP Quantum Choctaw Power, LLC Rockland Electric Company Southern Power Company Southern Power Company Southern Power Company Southern Power Company Southwest Power Pool Southwest Power Pool Southwest Power Pool TC Ravenswood LLC TC Ravenswood Services Corp. Tex-La Electric Cooperative of Texas, Inc. Tex-La Electric Cooperative of Texas, Inc. Tex-La Electric Cooperative of Texas, Inc. The Dow Chemical Co The Dow Chemical Company TransCanada Hydro Northeast Inc TransCanada Maine Wind Development Inc. Tri-State Generation And Transmission Association Inc. - Tran Tri-State Generation and Transmission Association, Inc. - Relia US Operating Services Company - Chambers US Operating Services Company - Indiantown US Operating Services Company - Logan US Operating Services Company - Scrubgrass Virginia Electric and Power Company - Fossil and Hydro (GO,G Virginia Electric and Power Company - Nuclear (GO,GOP) Wabash Valley Power Association, Inc. Wabash Valley Power Association, Inc. Western Farmers Electric Cooperative Western Farmers Electric Cooperative Wheelabrator Bridgeport, L.P. Wheelabrator Falls Inc. Wheelabrator Millbury Inc. Wheelabrator North Broward Wheelabrator S. Broward Wheelabrator Saugus J.V. Wheelabrator Spokane Inc. Wheelabrator Westchester Inc. Sheet 4 of 4 Regional Compliance Enforcement Authority NPCC RFC FRCC SERC RFC FRCC SERC TRE WECC MRO SERC SPP NPCC NPCC SERC SPP TRE TRE SERC NPCC NPCC MRO WECC RFC FRCC RFC RFC SERC SERC RFC SERC SPP TRE NPCC RFC NPCC FRCC FRCC NPCC WECC NPCC
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