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Corporate compliance is key to our success

Maintaining the highest professional standards for honest and ethical conduct helps the ISO meet its core values and drives our reputation as a transparent and trustworthy organization.  This requires constant vigilance from all ISO employees to ensure adherence to the principles that underpin the ISO’s integrity, our policies and procedures and the numerous laws and regulations that apply to the organization.

 

Corporate compliance program overview

The ISO Corporate Compliance department helps the ISO exercise sound judgment, make the right choices and take the right actions.  They assess, monitor and investigate ISO compliance with the NERC compliance monitoring and enforcement program, internal investigations and ISO policies, procedures and tariff. 

The Compliance Committee reports directly to executive management and works independently of other business units to ensure compliance activities are free from undue influence by those with responsibilities for adherence to reliability standards and other regulatory requirements.  Our board appointed Chief Compliance Officer has direct access to the CEO and Board of Governors to ensure appropriate communication of compliance concerns to the highest levels within the ISO.

Compliance hotline​

The ISO is committed to developing and maintaining a culture in which our personnel feel free to report illegal or improper conduct through appropriate internal channels. We do not tolerate retaliation for any report submitted in good faith.  The ISO uses EthicsPoint, an independent reporting service, for reporting any illegal or improper conduct.  All reports submitted through EthicsPoint are confidential and can be made anonymously.

 

 Tariff compliance

 
As required by the Federal Power Act of 1935, the ISO operates under the terms and conditions of its FERC approved tariff, which contains the rates, terms and conditions governing all areas of the ISO business, including:
  • Requirements for participating in the ISO’s energy and ancillary services markets
  • Rules for determining the prices paid to providers of electricity and ancillary services and how these charges are allocated
  • Transmission access charges
  • The ISO’s grid management charge
  • Processes for generation interconnection and transmission planning. 
     
The ISO FERC-approved tariff is modified, amended, supplemented or restated as needed.  If a provision of an existing ISO contract, business practice manual or operating procedure conflicts with it, the tariff will prevail to the extent of the inconsistency.

Find a complete list of ISO Tariff, compliance and informational filings in our regulatory library.
 

 NERC reliability standards and registration

 

The Energy Policy Act of 2005 requires that FERC approve and enforce standards to protect and improve the reliability of the nation’s bulk power system.  The North American Electric Reliability Corporation (NERC) develops, revises and implements standards under this statutory framework and delegates compliance monitoring and enforcement authority to various regional councils, such as the Western Electricity Coordinating Council (WECC). NERC also develops and approves regional reliability standards, which are more stringent than a continent-wide reliability standard and may address a regional difference in the bulk power system.
The ISO must comply with all requirements of FERC-approved reliability standards applicable to its current registered reliability functions, as follows:
  • Balancing authority
  • Planning coordinator
  • Transmission operator
  • Transmission service provider
 

 Coordinated functional registration

 

A Coordinated Functional Registration (CFR) is where two or more entities agree in writing upon a division of compliance responsibility for one or more reliability standards, requirements or sub-requirements applicable to a particular function (see the NERC Rules of Procedure, section 508, appendix 5A)
 
The ISO has 5 CFR agreements that identify the reliability standards compliance responsibilities for each party registered under the transmission operator function for the transmission facilities within the ISO balancing authority.  These agreements are filed with the WECC and posted on both the NERC web site under the registration section, and on the ISO web at the below links.

ISO and VEA Coordinated Functional Registration Agreement

ISO and PG&E Reliability Standards Agreement

ISO and SCE Reliability Standards Agreement

ISO and SDG&E Reliability Standards Agreement

ISO and TBC Reliability Standards Agreement

 

For compliance questions, please contact Corporate Compliance at compliance@caiso.com