Vermont Transco sets forth below its Compliance Plan for implementing the Federal Energy Regulatory Commission’s (the “Commission”) Order 2004 Standards of Conduct for Transmission Providers.VT Transco is an electric transmission company operating under the laws of the State of Vermont. VT Tranco through its manager, VELCO, serves the distribution utilities and other eligible customers in the State of Vermont. The headquarters is located at 366 Pinnacle Ridge Rd, Rutland, Vermont 05701.
VT Transco does not own any generation assets; it is a “wires only” company. VT Transco does not sell any retail electric energy to its customers.[1] VT Transco does not have an Energy Trading function, but does have a Power Accounting department. This department is responsible for administration of the settlement contracts for a few of the distribution utilities. The Power accounting department is involved in the settlement only portion of the markets. It does not provide market advice or transmission-related information to the Vermont distribution utilities.VT Transco has complied fully with the requirements of all FERC Orders governing the Standards of Conduct. 888/889. The plan below describes steps VT Transco will take in order to maintain compliance. 1. VT Transco shall train all officers, directors,[2] and employees with access to Transmission information or information concerning electric purchases, sale or Marketing functions.
2. All of the personnel listed above signed affidavits affirming that they will not be a conduit for sharing
transmission or customer information with any Marketing, Sales or Brokering Employees, or to any of our
Energy Affiliates.
3. VT Transco will maintain logs of employees that have participated in the training and copies of signed
affidavits of the employees that have participated in the training.
1. VT Transco will continue to prohibit disclosure of restricted transmission system information to Marketing,
Sales or Brokering Employees and Energy Affiliates unless such information is made available by posting on OASIS
or the Company’s Web site, or is otherwise available to the general public without restriction.
2. The company names and addresses of Energy Affiliates will be posted on OASIS or the Company Web site.
3. Employee transfers between the Transmission Function and any of VT Transco’s Energy Affiliates will be
posted on the OASIS or the Company’s Web site for 90 days.
4. VT Transco will post information concerning potential merger partners as affiliates within seven days after the merger is announced.
5. VT Transco will post written procedures implementing the standards of conduct.
6. VT Transco will post on the OASIS or Company’s web site, comprehensive organization charts identifying all Transmission function employees. VT Transco will post comprehensive organizational chart showing: (1) The organizational structure of the corporation with the relative position of the Transmission Function employees. For VT Transco, the job titles and descriptions, and chain of command for all employees in the Transmission Function, and Officers and Directors, with the exception of clerical, maintenance, and field positions. The job
titles and descriptions will include the employee's title, the employee's duties, whether the employee is
involvedin transmission or sales, and the name of the supervisory employees who manage non-clerical
employees involved in transmission or sales.
VT Transco will designate a Chief Compliance Officer who will:
(1) Ensure that VT Transco is in compliance with the Standards of Conduct.
(2) Ensure that Standards of Conduct training for new and existing employees is carried out.
[1] VT Transco sells a portion of the output of Vermont Yankee, a nuclear power plant in Vernon, Vermont to certain of the Vermont Distribution utilities. These are pass-through transactions in which, for administrative convenience, VT Transco acts as an intermediary between Vermont Yankee and the ultimate wholesale customers. VT Transco recovers from those customers only the amounts it pays to Vermont Yankee, with no mark-up, even for administrative expenses. VT Transco has no role in deciding prices, schedules or any other term or condition of the sales in question.
[2] For purposes of this Plan, the term, “Directors”, refers to individuals managing particular business functions on a day-to-day basis. It does not include members of VT Transco’s Board of Directors.
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