ZL Reduces Risk by Meeting Compliance with FERC Order 717 Standards of Conduct
Published by: ZL Tech
Energy Market’s Needs Met by Archiving, Supervision, and Search Capabilities of ZL Unified Archive®
SAN JOSE, CA – Aug. 25, 2009ZL Technologies, Inc., the leader in e-mail and file archiving in large, complex environments, today unveiled recommended practices for complying with recently issued requirements set forth in FERC Order 717. Regulated firms face penalties of up to $1 million per day per violation. However, market research has shown that few firms know the benefits of implementing technology such as ZL Unified Archive® for compliance. These practices will guide regulated firms in establishing comprehensive and defensible procedures for minimizing regulatory risk.
The goal of Federal Energy Regulatory Commission (FERC) Order 717 is to protect consumers by ensuring that transmission providers do not treat customers on a preferential basis. FERC 717, which went into effect November 26, 2008, amends the Standards of Conduct for interstate natural gas pipelines and electric utilities (“Transmission Providers”), governing the relationship between transmission employees and marketing employees.
There are considerable benefits to demonstrating compliance with FERC Standards of Conduct. The regulation states that transmission providers who take steps to proactively engender a “culture of compliance” will, in the event of a violation, have their civil penalties reduced or eliminated. Organizations should go beyond the Standards of Conduct by taking ownership of their regulatory duties and fully integrating them with their core business operations.
Adherence to FERC 717’s requirements should include the following:
Transmission Providers must immediately respond to any intentional or unintentional FERC violations. This requires a solution that monitors communications in real-time to prevent prohibited exchanges and alert compliance officers of any violations. Since the Standards of Conduct distinguish between marketing and transmission employees, administrators must be able to apply policies and email controls at the departmental, user, or even message level. These internal safeguards will enable immediate response to all non-compliant messages.
Companies must archive all correspondence between marketing and transmission employees for five years. Therefore, companies should set up an archival system that ensures 100% capture of email between applicable employees. The archive of corporate data must also be quickly searchable in the event of audits. This requirement can be cost-effectively met by maintaining a unified, central repository to maximize storage savings and minimize search times.
A solution should be implemented that can apply policies based on email content. Furthermore, this solution should have strict access controls and a proven audit system. Administrators should be able to create policies based on flexible user groups to monitor inter-departmental communications. These safeguards allow firms to defend and demonstrate their compliance practices to any regulatory agency.
ZL’s recommended practices are featured in a set of regulation datasheets and a series of Webinars to guide transmission providers in FERC Order 717 compliance.
