SC Self Audit Attestation & SQMD Plan Affirmation Elaine Siegel Market Services Policy Lead Stakeholder Web Conference August 23, 2018 1:00 PM – 2:00 PM (PDT) CAISO Public CAISO Public
SC Self Audit Attestation & SQMD Plan Affirmation Agenda Differences between the SC Self Audit Attestation and the SQMD Plan Affirmation Similarities between the SC Self Audit Attestation and the SQMD Plan Affirmation SC Self Audit Attestation Process Overview SQMD Plan Affirmation Process Overview Next Steps CAISO Public Page 2
SC Self Audit Attestation vs. SQMD Plan Affirmation Differences SC Self Audit Attestation SQMD Plan Affirmation • ISO Tariff Section 10.3.10.1 • ISO Tariff Section 10.3.7.5 (10.3.7.1) • Effective since 1999 • Effective since April 10, 2017 • Bi-Annual activity (every even year) • Annual activity • Audit of the processes for creating and • Self assessment and affirmation that submitting SQMD and adherence to the Scheduling Coordinator has the Scheduling Coordinator’s Local implemented and continues to comply Regulatory Authority with the approved SQMD plan on file • Includes SCME and PDR/RDRR • Includes SCME with approved SQMD Plan, NO PDR/RDRR CAISO Public Page 3
SC Self Audit Attestation vs. SQMD Plan Affirmation Similarities • For Scheduling Coordinator Metered Entities • Executed through a digital signature process, initiated by the CAISO Due on October 31 st of the applicable year • Where October 31 st lands on a weekend, due date will be the next business • day CAISO Public Page 4
SC Self Audit Attestation Process Overview • The SC Self Audit activity is for Scheduling Coordinators who submit Meter Data to the ISO, including entities who participate in Demand Response • ISO Tariff 10.3.10.1 “At least every two years, each scheduling coordinator shall (or engage an independent, qualified entity to conduct) audit and test the Metering Facilities of the Scheduling Coordinator Metered Entities that it represents and the Meter Data provided to the Scheduling Coordinator in order to ensure compliance with all applicable requirements of any relevant Local Regulatory Authority….” • Auditor must be independent of the processes relating to the collection of meter data, the Validating, Estimating and Editing process and data submission to the CAISO. • Audit Period: follow your normal audit schedule or perform a 1 year lookback. CAISO Public Page 5
SC Self Audit Attestation Process Overview • No template for audit content – Evaluate process flow of Meter Data • Collecting meter data • Validation, Editing and Estimation process • Submission process (through Actual SQMD) • Audit Report should be able to provide your management the assurance that your processes are: • Complete • Accurate • Timely • Meet your Local Regulatory Authority requirements • Content of Audit Report is no longer required by the CAISO • CAISO Tariff 10.3.10.2 Audit and Testing by CAISO CAISO Public Page 6
SC Self Audit Attestation Process Overview • Attestation Due to CAISO on 10/31 of applicable year – Digital Signature process will begin mid October • CAISO will provide the SC Self Audit Attestation • Management signature is required • Identify the time period reviewed during the audit • Name, Title and Company of Auditor • List of auditors findings with corrective actions • CAISO Tariff 37.6.3.2, Rules of Conduct penalties apply to all late SC Self Audit Attestations CAISO Public Page 7
SQMD Plan Affirmation Process Overview • Effective April 10, 2017 all Scheduling Coordinators who have a CAISO approved SQMD Plan, must annually submit an SQMD Plan Affirmation. • Any Scheduling Coordinator participating before April 10, 2017 is not required to have a SQMD Plan, unless the Scheduling Coordinator is: • Repowering • Modifying their meter data interval • Adding generator capacity • Adding a new resource • The SQMD Plan Affirmation process does not apply to PDR and RDRR resources. (ISO Tariff 10.3.7.1 is applicable) CAISO Public Page 8
SQMD Plan Affirmation Process Overview • ISO Tariff 10.3.7.5 “….on an annual basis the Scheduling Coordinator Metered Entity must perform a self assessment and affirm to the CAISO, in writing, that it has implemented and continues to comply with its SQMD Plan….” • Affirmation is due to CAISO on 10/31 of applicable year – Digital Signature process will begin mid October • CAISO will provide the SQMD Plan Affirmation • Management signature is required • Scheduling Coordinator will attach a list of resources that are applicable to the plan • CAISO Tariff 37.6.1 Rules of Conduct penalties apply to all late SQMD Plan Affirmations CAISO Public Page 9
Next Steps SC Self Audit Attestation Process • CAISO will reach out by phone to confirm contacts • CAISO will email Scheduling Coordinators who have been identified as a SC Metered Entity • If you have not received an email by 9/17/18, and you feel you are an SC Metered Entity, please email EDAS@caiso.com • Scheduling Coordinators should be working on their audit report • CAISO will initiate digital signature process mid-October, 2018. CAISO Public Page 10
Next Steps SQMD Plan Affirmation Process • CAISO will email Scheduling Coordinators who have been identified as a SC Metered Entity • Scheduling Coordinators should be working on their self assessment • CAISO will initiate digital signature process mid October CAISO Public Page 11
Questions? • Please send all inquiries to EDAS@caiso.com. Thank you! CAISO Public Page 12
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