U.S. Department of Energy 

Office of Inspector General 

Office of Audit Services 

Audit Report 

Continuity of Operations at 

Bonneville Power Administration 

DOE/IG-0781 November 2007 
Department of Energy 

Washington, DC 20585 

November 6, 2007 

MEMORANDUM FOR THE ADMINISTRATOR, BONNEVILLE POWER 

ADMNISTRATION 

-2L ~;;KL&L~,;/ 

FROM: Grego d H. Friedman 

Inspector General 

SUBJECT: INFORMATION: Audit Report on "Continuity of Operations 

at Bonneville Power Administration" 

BACKGROUND 

'lhe Bonneville Power Administration (Bonneville) markets and delivers wholesale 

hydroelectric power. Currently, Bonneville provides about 40 percent of the power sold 

in the Pacific Northwest region of the U.S. and it operates over three-fourths of the 

region's high-voltage transmission facilities. 

In the event of a major disruption to its nonnal operations, Bonneville must be prepared 

to continue its essential functions, particularly its power scheduling, tra~lsmission 

scheduling, and system operations. In this regard, Bonneville is required to follow 

Federal Preparedness Circular 65 (FPC 65), as prescribed by the Department of 

Homeland Security's Federal Emergency Management Agency. Under FPC 65, agencies 

are to develop viable contingency plans. The Circular also provides a number of key 

steps that agencies should take for continuity of operations. Specifically, it recommends 

that each agency: (I) prepare alternate operating facilities; (2) establish a devolution plan 

to be implemented if it is incapable of performing essential functions from either its 

prlmary or alternate facility; and (3) test the capabilities of its continuity of operations 

program. The objective of the audit was to determine whether Bonrleville had a viable 

continuity of operations capability for its essential functions. 

RESULTS OF AUDIT 

We concluded that Bonneville's continuity of operations capability was not fully 

compliant with FPC 65 for all of its essential futlctions. Specifically: 

Bonneville's primary and alternate facilities for power scheduling were 

interdependent as well as in close proximity and, therefore, were s~~bject to the 

same hazards; and, 

Bonneville's plan to recover transmission scheduling from disruptions to its 

primary automated system relied in part on a manual process, rather than a fully 

automated system as required by FPC 65. 
Although initiatives were underway to reduce the possibility of power and transmission 

scheduling interruptions, additional actions are needed by Bonneville to improve 

continuity of operations planning. In addition, Bonneville did not have specific 

devolution plans for power scheduling, transmission scheduling, and system operations in 

the event that both primary and alternate facilities became inoperable. Finally, 

Bonneville could not provide us with sufficient evidence that the capabilities of its 

continuity of operations were periodically and fully tested or that lessons learned were 

identified and implemented. 

Bonneville did not have a consistent and sustained continuity of operations planning 

process. Since 2002, Bonneville has attempted at least three continuity of operations 

planning efforts. In July 2007, under its most recent initiative, Bonneville established a 

charter for its Business Resilience Project that combined continuity of operations 

planning with emergency management, crisis management, and asset riianagement 

planning. The charter for this project indicated that Bonneville will revise its approach 

and tinieline for continuity of operations planning and have continuity of operations plans 

in place for selected functions by March 2008. The reconimcndations in the attached 

report were provided to assist Bonneville in this and related efforts. 

MANAGEMENT REACTION 

Management concurred with the recommendations and indicated that it is either currently 

iniplementing or will soon implement the report's recommendations. Management 

emphasized that its current critical continuity of operations capability is operational, but 

improvenients are needed. Management's comments are included in their entirety in 

Appendix 3. 

Attachment 

cc: Deputy Secretary 

Under Secretary of Encrgy 

Chief of Staff 

Team Leader, Audit Liaison Team, CF-1.2 

Bonneville Power Administration Liaison Office 

Audit Liaison, Bonneville Power Administration 
REPORT ON CONTINUITY OF OPERATIONS AT BONNEVILLE POWER 

ADMINISTRATION 

TABLE OF 

CONTENTS 

Continuity of Operations at Bonneville Power Administration 

Details of Finding ......................................................................................................................... 1 

Recommendations ....................................................................................................................... 4 

Comments ..................................................................................................................................... 5 

Appendices 

1. Objective, Scope, and Methodology ................................................................................ ~J 

2. Prior Audit Reports .............................................................................................................. 8 

3. Management Comments ...................................................................................................... 9 
CONTINUITY OF OPERATIONS AT BONNEVILLE POWER 

ADMINISTRATION 

Continuity of Bonneville Power Administration (Bonneville) does not have a 

Operations viable contitluity of operations (COOP) capability as defined by 

Federal Preparedness Circular 65 (FPC 65) for all of its essential 

functions. Specifically, Bonneville: 

Needed to improve its alternate operating capabilities 

for power scheduling and transmission scheduling; 

Did not have specific devolution plans for power 

scheduling, transmission scheduling, and system 

operations; and, 

Could not always provide evidence that its COOP 

capabilities were periodically tested or that lessons 

learned were identified and implemented. 

Alternate Operating Strategies 

Bonneville needed to improve its alternate operating capabilities 

for power scheduling and transmission scheduling. For example, 

its primary and alternate facilities for power scheduling were 

interdependent and in close proximity. Specifically, the 

interdependent computer servers that support the power scheduling 

function's automated systems at the altemate power scheduling 

facility were dispersed between the primary and alternate facilities. 

Therefore, if an emergency rendered either of the facilities 

inoperable, power scheduling may be unable to continue 

operations. Further, its alternate operating facility was in close 

proximity and subject to some of the same hazards as the primary 

facility. For example, Bonneville personnel indicated that a major 

earthquake is one of its most significant risks that could impact 

both facilities. 

Additionally, Bonneville's COOP approach for recovering 

transmission scheduling relied in part on a manual process if the 

use of its primary automated system was disrupted during an 

emergency situation. Bonneville pointed out that the tools it 

currently has in place provide the basic continuity of operations for 

critical functions. However, we noted the use of a fully automated 

alternate operating system would increase its ability to continue 

transmission scheduling operations. Further, the manual part of 

the process did not meet the standard of FPC 65 that altemate 

operating facilities must provide computer equipment, software, 

and other automated data processing equipment necessary to carry 

out essential functions. 

Page 1 Details of Finding 
Bonneville noted that it has a number of information technology 

initiatives underway that will reduce the possibility of power and 

transmission scheduling interruptions. Specifically, for power 

scheduling Bonneville has two information technology projects 

planned that, once implemented, would reduce the risk of both 

primary and alternate facilities being rendered inoperable. 

Bonneville personnel indicated that the projects should be 

advanced enough by January 2008 to be able to rely on them in an 

emergency, although the estimated completion date for one of the 

projects is not until January 2009. Also, Bonneville is in the 

process of modernizing its transmission scheduling system to an 

Internet-based application that would allow transmission 

scheduling from any location with Internet access and eliminate 

reliance on a manual backup. Although the anticipated date of 

completion was November 2007, transmission officials have said 

that two schedule slippages that have occurred will postpone the 

completion date. Moreover, once the information technology 

initiatives are completed, Bonneville will need to update its COOP 

procedures to address the new capabilities to ensure that 

employees know the logistics of what to do and where to go if an 

emergency situation renders the primary facility unavailable. 

Devolution Plans 

Further, Bonneville's power scheduling, transmission scheduling, 

and system operations functions have not developed specific plans 

for devolving operations to another site in the event that both the 

primary and alternate facilities are rendered inoperable. Although 

Bonneville management stated that it does have current devolution 

plans, our review showed that these are beginning strategies rather 

than specific plans for devolution. For example, FPC 65 requires 

that devolution plans contain specific information such as a roster 

identifying the fully equipped and trained personnel at the 

designated devolution site that would have authority to perform 

essential functions and activities. However, the beginning 

strategies did not contain such information. Bonneville 

management acknowledged that these plans need to be improved 

to comply with FPC 65. Con~pleting specific devolutions plans is 

espccially important given the current situation in which primary 

and alternate facilities for power scheduling remain 

interdependent. 

Page 2 Details of Finding 
Periodic Testing 

Bonneville could not always provide evidence that COOP 

capabilities for power scheduling and transn~ission scheduling 

were periodically tested, deficiencies identified and lessons learned 

implemented. According to FPC 65, agencies must plan, conduct, 

and document periodic tests and identify deficicncics. 

Deficiencies and actions taken to correct them must also be 

documented. Formal testing procedures would ensure that tests are 

conducted on a regular basis, weaknesses are identified, corrective 

actioris are taken, and lessons learned are retained for the future. 

Although power and transmission scheduling personnel stated that 

their alternate operating strategies are tested, they could not always 

provide us with sufficient documentation to verify the existence or 

effectiveness of such tests. We judgmentally selected a number of 

transmission schedulers and contacted them to confirm that tests 

were conducted and were effective. However, three of thc eight 

transmission schedulers who responded indicated that they had not 

participated in any of the tests and three others had not participated 

for several years. Bonneville provided documentation of power 

scheduling employees participating in testing of the alternative 

facility, but was unable to document similar attendance by 

transmission scheduling employees. 

Process for After five years of effort, Bonneville had not developed a 

COOP Planning consistent process for COOP planning. Since 2002, Bonneville 

has attempted at least three separate COOP planning efforts. 

For example: 

In 2004, Bonneville directed its business functions, such 

as power and transmission scheduling, to develop COOP 

plans which Bonneville told us were based on templates 

provided by the Department of Homeland Security and 

the Fcderal Emergency Management Agency. Most 

business functions completed draft COOP plans by 

September 2005; however, Bonneville management did 

not adopt these plans because they found the individual 

plans were inconsistent in quality and lacked 

standardization that precluded integration of the plans 

into a Bonneville-wide plan. 

In early 2006, senior executives re-energized the COOP 

process for the purpose of creating comprehensive COOP 

plans. Although thc 2006 effort focused on nieeting the 

Page 3 Details of Finding 
Need for 

Preparedness 

requirements of FPC 65 and included a project plan with 

a milestone for completing plans by September 2007, 

executive management believed that the effort did not 

support its vision of a broader Pacific Northwest regional 

approach to COOP planning. 

Between December 2006 and March 2007, Bonneville 

initiated a Business Resilience Project that combined 

COOP planning with emergency management, crisis 

management, and asset management planning into what 

Bonneville told us will be a fully integrated planning 

process. However, Bonneville did not approve a charter 

for its Business Resilience Project until July 2007. 

Regarding COOP planning, the charter indicated that 

based on the results of a business impact analysis, 

Bonneville will revise its approach and timeline for 

COOP planning in October 2007 and have COOP plans 

for selected functions by March 2008. 

These planning efforts underscore the need for Bonneville to 

develop a more consistent planning process for consistency of 

operations. 

By taking further actions to achieve a viable COOP capability, 

Bonneville would improve its ability to continue all essential 

operations after an emergency that results in a significant 

disruption to its operations. Although it pointed out that the 

loss of certain functions does not mean the loss of its ability to 

service customers, be concluded that continuation of essential 

operations is important since Bonneville provides a significant 

amount of electric power to the Pacific Northwest region. In 

fact, a Bonneville official told us that it is likely that a large 

scale emergency would affect other regional utilities as well as 

Bonneville. The possibility of a region-wide impact 

underscores the importance of Bonneville being prepared to 

take a leadership role in restoring power and transmission 

services and in minimizing disruption to the region. 

RECOMMENDATIONS In order for Bonneville to have assurance that it can continue all 

essential operations after an emergency, we recommend that the 

Bonneville Administrator ensure that Bonneville: 

1. Finalizes an approach to COOP planning that includes 

milestones for developing and approving a Bonnevillewide COOP plan. 

Page 4 Recommendations 
2. Develops and tnaintains viable business function COOP 

plans in accordance with FPC 65 that include: 

a) Strategies that ensure independent alternate 

operating facilities which are not subject to the 

same hazards as the primary facilities; 

b) Devolution plans to ensure COOP in the event 

that both the primary and alternate facilities are 

rendered inoperable; and, 

c) Fonnal testing of the alternate operating facilities 

and devolution plans, including documenting the 

results and implementing corrective actions when 

necessary. 

3. Integrates the business function COOP plans into a 

Bonneville-wide COOP plan that meets FPC 65 

requirements. 

4. Ensures timely completion of its information technology 

initiatives for power and transmission scheduling systems 

and that the new capabilities are reflected in business 

function COOP plans. 

MANAGEMENT Management concurred with the recommendations and 

REACTION indicated that it is either currently implementing or will soon 

implement the recommendations to ensure a viable COOP 

capability for critical functions at Bonneville. Bonneville pointed 

out that it currently has workable elements of COOP measures. 

However, Bonneville acknowledged that improvements are needed 

in its COOP measures. Bonneville management also indicated that 

it has a number of statutory and regulatory obligations, and if a 

conflict arose between those obligations and FPC 65, Bonneville 

would comply with its statutory and regulatory obligations. 

Additionally, Bonneville wanted to emphasize that its current 

critical functions COOP capability is operational, but needs to be 

improved. 

To develop an integrated and comprehensive set of COOP 

measures to address the deficiencies and implement the 

recommendations in the report, Bonneville has initiated a strategic 

approach to COOP planning called the Business Resilience 

Program, which has been final since July 2007. Bonneville stated 

that by October 2007, it will update implementation details for its 

Page 5 Comments 
AUDITOR 

COMMENTS 

approach. Bonneville has started its COOP planning for its most 

critical functions and COOP planning for its lower priority 

functions will follow. Specifically, COOP plans for its most 

critical functions will be completed by the end of fiscal year 2008 

and lower priority functions COOP plans will be completed in 

fiscal year 2009. These plans will be integrated into an industry 

standard COOP planning database. In addition, infortnation 

technology initiatives for transmission scheduling and power 

scheduling are underway and will be completed at the end of fiscal 

year 2008 and January 2009, respectively. 

Management comments are generally responsive to our 

recommendations and its planned corrective actions, when fully 

implemented, will help Bonneville strengthen its COOP planning. 

While the July 2007 charter was a positive step in COOP planning 

and identified the approach that Bonneville will take, it did not 

contain specific and measurable activities and milestones to ensure 

the program's success. 

Page 6 Comments 
Appendix I 

0B.IECTlVE The objective of this audit was to determine whether the 

Bonneville Power Administration (Bonneville) has a viable 

continuity of operations (COOP) capability for its essential 

functions. 

SCOPE The audit was performed from November 2006 to August 2007. 

The scope of the audit included COOP efforts for Bonneville's 

power scheduling, transmission scheduling, and system operations 

functions. 

METHODOLOGY To accomplish the audit objective, we: 

a Reviewed Bonneville's COOP planning efforts; 

a Reviewed laws, regulations, policies, and procedurcs for 

COOP; 

a Interviewed personnel responsible for COOP; and, 

Reviewed prior Office of Inspector General and 

Government Accountability Office reports, and other 

related reports. 

We conducted this performance audit in accordance with gcneral ly 

accepted Government auditing standards. Those standards require 

that we plan and perform the audit to obtain sufficient, appropriate 

evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objective. We believe that the 

evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objective. The audit included tests 

of controls and compliance with laws and regulations related to 

Bonneville's COOP. Because our review was limited, it would not 

necessarily have disclosed all internal control deficiencies that may 

have existed at the time of our audit. Also, we examined the 

establishment of perfomlance measures in accordance with the 

Government Performance and Results Act of 1993, as it related to 

the audit objective. We concluded that Bonneville had not 

established specific performance measures to ensure COOP in an 

emergency. However, our recommendations, when fully 

implemented, will assist Bonneville in ensuring the continuation of 

essential functions in emergency situations. Finally, we did not 

rely on computer processed data; therefore, we did not conduct 

reliability assessments on the data. 

We held an exit conference with Bonneville officials on 

October 10. 2007. 

Page 7 Objective, Scope, and Methodology 
Appendix 2 

PRIOR AUDIT REPORTS 

The Department of Ener~'s Use of the Str~ztegic Petroleum Reserve in Response to 

Hurricunes Kutrinu und Rita (DOE/IG-0747, December 2006). The report identified an 

opportunity to provide greater assurance that Strategic Petroleum Reserve (Reserve) 

operations could continue in future emergency situations. Specifically, the audit report 

stated that as a result of hurricanes Katrina and Rita, the Reserve's business recovery 

capabilities were impaired when mission-essential computer networks at both the primary 

and alternate sites were rendered inoperable. The Reserve's primary and secondary sites 

are located within 55 miles of each other. Katrina's far-reaching impact proved that the 

proximity of the alternate site to the primary facilities was less than optimal. The report 

also noted that the Reserve had not performed an all-hazards risk assessment when trying 

to determine the location of its alternate operating facility, as required by Federal 

Preparedness Circular 65. 

The Deportment's Continuity Plunning and Emergency Preparedness (DOE/IG-065 7, 

August 2004). The report found that five sites did not develop comprehensive plans to 

continue essential functions during an emergency and had not corrected a number of 

weaknesses identified during prior emergency preparedness exercises. Specifically, the 

sites had not fully identified essential functions or alternate operating facilities in case of 

an emergency. Additionally, the Department of Energy (Department) did not have 

specific requirements for sites to validate the effectiveness of corrective actions 

addressing recognized preparedness weaknesses or to share complex-wide lessons 

learned about common problems. The Department had recently created the Corrective 

Action Management Program as a means to validate corrective actions identified during 

emergency preparedness testing. Also, the Department had recently developed the 

Society for Effective Lessons Learned Sharing to centrally track and share lessons 

learned from emergency preparedness test exercises. As a result of these findings, the 

Department may face increased risks to operations, employees, and surrounding 

communities during an emergency situation. 

Page 8 Prior Audit Reports 
Appendix 3 

DOE F 19?5 t3e k!ec::v,t>,,'F,,!,;: A!q~:ovc(J Ljy Fur!',> t,fqt ! 04 ;:I ?I106 

(.I8 89: 

United States Government Department of Energy 

memorandum I%onncvillc I'owcr Administration 

REPLY TO 

AlTNOF lG-3'7 (A0711N057) 

SUBJECT: Ho~~~ic\illc PO\VCI. ~\(l~lli~lis~~.;r~io~i Co11inic111s on [lie 1C Discusslo11 Ill-aft I<cport on lllc "Audit ol 

('oillirli~ity 01 Opcr;~iions ar Uonncv~llc I'cnvcr Admin~srrai~on" diitcd /\i~girbt 20, 7007 

TO. (icorgc ('olI:~r~l. /\ssist:1111 IIII>'~I~I. C'Iener;~I for Pcriorniiince Audit5 

Ol'licc ol rhc 1nsl)ector Gcnc~al 

Tl~ir~lh yo11 1'01 alloi\ing the Son~lc.\~illc Power Aclmiriistraiio~l tBPA or Borirlr\,illc) io comnicnl 

(III youi- auclit ol' BPA's Conirnuiry of Oper;~rior,s Planriing (C001'). BPA accepts the IG's 

rccom~~~cndario~is. 131'A is cill~e~~currcntly in~plcrncnting or \\ill so011 i~nl,lcrllcnt the I(; 

r.ccommcndntions to ensure ;I viitble (:OOP cap:ibility for critical functio~is ;it BPA. 

Ho\\c\.er. UI'.A, 1)) "1;1tuto1y clirccii\.c. IIILISI pro\,irlc po\vcr and rrirns~nission scr\,ices to its 

CLISI~I~C'I.~ ~II ;I I~~~si~~e~s-lih~ 111;1111icr while ilnplementing a nunibcr of organic stittntcs (including 

the 13o1~1~c~illr Project ,Icr. rhc Federal <:olumhin Ki\~c~~T~-a~~s~nissiorl Sybteln Act. and the 

I>itcit'rc NorrIl\\.csr I<lcctr~c I'o\vc~ Plitrin~ng i~nd C:onscr\:atiorl Acr), I-egulatory guidailcc (fiEI<C, 

NEICC. imcl M'E('(.' 1.cg111;~tions). intcr.nariona1 iscnlics, rcgional ol)cr.a~iorls a~rccincnts. ;lnd 

IX-LICICI~I ~ltili~y I>I.~IL.I~cc. In 11ie event of it conflict I>ct\vccrl FPC 65 and thc t\dminist~.aror's 

sta~uiory ~.csl>c~~~sil~ilities. UI'A \vill conil~ly with its st;~(~~tory and r-cgulatory obligations. 

More sl)cc~llcally. HPA's cu~.~-c~l(rit~cal f~~rlci~on COOP cupahility is opcratiorlal. I>ut nccds lo 

he irnpl-ovccl. DI'A has initiated the Husincss Resilience Prugl.ani to dcvclup an intcgl-atcd and 

comp~ulic~lsivc sr 01' COOP n~eas~u-es, ;IS \\ell as relatcd clncrgcncy, crisis, ancl assct 

~ni~rlagcriicrlt plans to address those def~cicrlcics and implement the I(i recomlnendations. HI'A 

11;ls st;rrtecl w1tI1 (lie IIIC)SI cr~tical furictic>~ls, all of \vhich arc r-clalcd to sustaining sale, rcliablc, 

~IIICI ;I~C~LILIIL' Ir.:rr1~1nlssion ;]nd generation. COOP planning for lo\i.er priority fu~lcriorls will 

1'c)lluu ill FY 2008 and FY 2009. 111 th~s proccss. BPA \\:ill idcntil'y any ;tspccts of busi~icss 

rcsilicncc that ~~ccd to he strengthened ancl schedule the p~.ojects. 

IJI'A ayrccs \virI~ Ilic ICi Report recommc~idations. Wc have ttdcletl some clarific;ttions and timclincs 

for a mo1.c coml>lcrc itndcrstanding of the 131'.4 appl-o~rch lo COOI' planniny. 

I<eco~nr~~er~datio~~ I. I'irlali~e arl approach to C001' planning tl~at inclutles milestones I'or 

tlevelol,ing ;inti al)provi~lg ;I Ilo~~nc~ille-\bide COOI' plall. 

I1 ['A's .;l~.;~tcg~c "appl-oath" 10 ('00[' ~>larlning has bccn Irnal si~lce Jill y 2007. UI'A has c~)nsolidatccl 

(~'001' olarl~li~~g w~th cnlcrgcllc!8 rnar1agcr1~crlr. crihi, 11iirn~1;cmcnt. anti asscl management planning. 

l'll~s o\cr;rll al)l>ro;tcli is called l3usiriess Kcsiliencr and is i~ltc~lclcil toproclucc ;r11 intcgrit~ccl anit 

co~~llxchcnsi\,c sc~ ot plans, c~lIi;r~lcc~nrnts. and skills lo allo\\, HPA to ct'l'ccrivcly rcspolld to 

dis~.lrl'ri\~e c\.cnts aftccrirlg. UI'A. 11s customers and stakcholdcr-s ill the I'acilic Noi-tl~\\.cst region. 

Irnl~lcr~tc~~l;~tio~~ clcta~ls \\.rll hc i~(?d:trcd rn 0ctol~1- 2007. I'ollo\\~ing o~rr Llus~r~css Inilx~ct i\nalysis 

Page 9 Management Comments 
Appendix 3 (Continued) 

(El:\ I \\ I1ii.h has iclcntrl'i~d IW.\'\ "core, outp~its." 111c Iligi~~~~t ~~riol.lr! pr.ocl~rcts and scr\ ~ccs the aycnc! 

rnlrht susla~n dul-in: ancl IoIIo\\ ing an cmcrscnc.!. all ot'\\I)rih ,\I-c ~-cl;~tccl ro sust;iinrng <ale. I.~II:II>Ic. 

:LI~LI atlccluatc ti.ansnilsiion and gcncr.:ikroll. As par-t ol rhc El.\. BI'.A \\ ill ~clcntil'y the i'i'rri~.al I'unirrons 

th,~t sublain thcse corc outpul.\. C'OOl' p1:rns for thcse li~ghcnr ~r.~~rlty-c'ritici~l ~UIICIIUI~~ \\rIl he 

cc~rnl>lc.tcd 115' khc cncl ol 1;) 2005. \\ ith sccoild pl.icll.it! t'unctlorl COOP p1:ins to I'ollo\\. iluriny 

I..) 2000. 

I<cco~l~lllcndatio~~ 2. I)c\clo~ and maintain 1 ial)le I)c~sint.as function COOI' [)l:trls in accortliince 

\\ it11 IiI'C' 65 tl~at include: 

(a) Strategies Illat ensure intlcpentlent alternate operating facilities which are not s~il~ject to Ihe 

same hazards as the prinlary facilities: 

(I)) 1)evolution plans to ensure COOIL in the event that botli tllc priniary and alternate lacilitics 

arc rc~ltlerctl inopera1)lc: and 

(c) Forrxlal testing of thc nltcrnatc ooerating facilities and devolutio~l plans. inclutling 

docunlcnting the res~rlts and inlplcrllc~lting corrcctii-e actions when necessar!. 

RP.-\ lntcnds to ha\c \ iablc huhincss i'unction ('OOP l>l:~rl.; in :ic.cordancc \vitl~ (a) ilncl IIJ) :~ho\c I>! the 

cricl 01' 1:). 2008 I'or ir.; niosl cl-lrrsal t'i~ncrlons, with orl1cr.l ro lollo\\. Addirional cllangcs in s!\rems 

;IIIC~ PI.OCCSSCS, ~ncl~~cii~iy lornn;ll resting dcscribcd In (c) aho\c. \\ill hc irnl>Ieinenked o\cr a fe\\ months 

ro \c\c~-al yciuh. dcpcnd~ng t)n iizcni! pr.ioi.~lics. ~ml)lcrncntatic)ri time and costs. 

:\.; pc)intctl OLII in 111' cornnlcnt\ rn tllc .-\p~cnd~s. and in 111~ 1G 1-cport I'111Cli1lgl;. U1'.4 di)~s ~UI~SCIIII! 

h;1\ L. \\ OI-~;II~IC ~ICIII~III.; or' i;i ). 11)). aid (c) ;L~o\.c. hut ;~ikn~\\.ledg~'s tll~lt i~nl)ro\c~~~cnts 3r.r nrzded 

I<ecotll~llc~ldatio~i 3. Integrates the I)usincss function COOP plsns into a Iionncvillc-\r ide C001' 

plan that nleets FI'C 65 rccluiremcnts. 

I3onnc\ 111~'s C'OOf' plans \\ill be ~ntcgl'arcd ro ensure rhar 11s prrorit> "corc oi~tputs" are rcbilicnr. 

UI'A 112s procu~.ed I.I>Kl'S (121\lng Dlsaatcr Rcco~cry Pl;inn~n~ S! srerii). an industry srandard COOP 

pl;11lning tor11 to assist Irl thrs rntesr.atio11. All busrncsj funcllo~l COOP plans \rill IJC inrc;ratcd ;rnd 

Iodycd in rhc I.DRPS dxra Ixise \\ hich ii cxpcctcd to lull!. Inect FPC 65 rc~lililr~rlerlt 1%tllcc'i~d of 

1-1. 700s. 

Keco~l~rllcndatioti 1. Ensures tinlcly co~nl~lction of its infonnation tech~lology initiatives for 

pwcr anti transnlission scllcduling systcn~s ant1 that the neb\ cnl~abilitics arc rctlectcd in 

I~usirlcss function (:001' ~)lans. 

Intc-)rnliitron rcctinol~v! init~;itr\-cs !(>I- Po\\.cr Schcd~iling and Transmission Schcd~ilillg S!.strm.; are 

~inclcr- \\a!. 'l'hc r.criic~tc sltc Intclncl sihcduling ca~>:ll~rlrry. lociitsd in \qinnc;lllc~lis. 31%. \\ill 1,c 

II~ t 1 I 01 I 0 '1-hc r.crnotc alrcr'narc I';lciliric.; sr~c for critical supl~ort t'linc.tic)n\ 

~n~.lucl~r~g 1'01-ccabtiny and sL.ticdullng at ~hc Munro Contr.ol C'cnicr. ('\ICC') in Sl~oh:une. \V:\. I.; 

~~\pc~~rccl 10 l>c Sinisliecl I>! .I;II~LI;LI.! 2009. 

Page 10 Management Comments 
Appendix 3 (Continued) 

BPA's r.eylonsc. [he Appendix, and olhcr docurncntation can hc found on the HPA weh\ire at 

h~lp\\www. bpa.~ov.co~.porale\abuut bpa\audits. 

Nalional Relations Manager 

LC. 

Mark Mickclscn - L)OL. Office of Inspcclur Gcncsal 

Page 11 Management Corr~ments 
IG Report No. DOEIIG-0781 

CUSTOMER RESPONSE FORM 

The Office of Inspector General has a continuing interest in improving the usefulness of its 

products. We wish to make our reports as responsive as possible to our customers' requirements, 

and, therefore, ask that you consider sharing your thoughts with us. On the back of this form, 

you may suggest improvements to enhance the effectiveness of future reports. Please include 

answers to the following questions if they are applicable to you: 

1. What additional background information about the selection, scheduling, scope, or 

procedures of the inspection would have been helpful to the reader in understanding this 

report'? 

2. What additional information related to findings and recommendations could have been 

included in the report to assist management in implementing corrective actions? 

3. What format, stylistic, or organizational changes might have made this report's overall 

message more clear to the reader? 

4. What additional actions could the Office of Inspector General have taken on the issues 

discussed in this report which would have been helpful? 

5. Please include your name and telephone number so that we may contact you should we have 

any questions about your comments. 

Name Date 

Telephone Organization 

When you have completed this form, you may telefax it to the Office of Inspector General at 

(202) 586-0948, or you may mail it to: 

Office of Inspector General (IG-1) 

Department of Energy 

Washington, DC 20585 

ATTN: Customer Relations 

If you wish to discuss this report or your comments with a staff member of the Office of 

Inspector General, please contact Judy Garland-Smith (202) 586-7828. 
The Office of Inspector General wants to make the distribution of its reports as customer friendly and cost 

effective as possible. Therefore, this report will be available electronically through the Internet at the 

following address: 

U.S. Department of Energy Office of Inspector General Home Page 

http://www.ig.energv.~ov 

Your comments would be appreciated and can be provided on the Customer Response Fornl 

attached to the report.