Arrow LeftEnergy and Utilities COMPLIANCE CHECKLIST

Compliance Checklist for Energy and Utilities Sector: Pennsylvania

Use this state-specific checklist to ensure your energy and utilities operations meet necessary compliance requirements in Pennsylvania.

Pennsylvania

Pennsylvania

1. Federal Energy Regulatory Commission (FERC) Compliance:
The utility complies with all applicable FERC regulations, including tariffs, market rules, and reporting requirements.
YesNoNA

Regularly review FERC regulations and ensure ongoing compliance with updates. Maintain open communication with FERC and prepare for audits or inquiries.

Identify specific areas of non-compliance and take corrective action immediately. Develop and submit any required reports or filings to FERC, and update internal procedures to prevent future issues.

2. North American Electric Reliability Corporation (NERC) Reliability Standards:
The utility adheres to NERC reliability standards, including those related to grid security, resource adequacy, and operational performance.
YesNoNA

Conduct regular audits and assessments to ensure continued compliance with NERC standards. Stay updated on any changes to reliability standards and adjust operations as needed.

Identify the gaps in compliance and develop a corrective action plan. Implement necessary changes to meet NERC standards and prepare for potential penalties or enforcement actions.

3. Environmental Protection Agency (EPA) Compliance:
The utility complies with EPA regulations related to air emissions, water discharges, and waste management, including the Clean Air Act, Resource Conversation & Recovery Act and Clean Water Act.
YesNoNA

Maintain accurate records of emissions, discharges, and waste management practices. Regularly review and update compliance strategies in line with EPA guidelines.

Identify the areas of non-compliance and take corrective measures immediately. Develop a mitigation plan, update operations as needed, and submit any required reports to the EPA.

4. Occupational Safety and Health Administration (OSHA) Compliance:
The utility adheres to OSHA regulations for workplace safety, including hazard communication, safety training, and reporting of workplace incidents.
YesNoNA

Regularly review and update workplace safety protocols. Conduct ongoing safety training for employees and ensure that all incidents are properly documented and reported.

Assess current safety practices and identify areas of non-compliance. Implement necessary safety measures, provide additional training, and ensure all incidents are reported to OSHA.

5. Federal Communications Commission (FCC) Compliance:
If applicable, the utility complies with FCC regulations related to communications infrastructure, including pole attachments and radio frequency (RF) emissions.
YesNoNA

Ensure all communications infrastructure is regularly inspected and maintained in compliance with FCC regulations. Keep records of all FCC-related activities and filings.

Identify areas where compliance is lacking, such as unapproved attachments or RF emissions above limits. Take immediate action to rectify the situation and update internal procedures to ensure future compliance.

6. Department of Energy (DOE) Reporting Requirements:
The utility submits required reports to the DOE, including those related to energy production, consumption, and efficiency programs.
YesNoNA

Maintain accurate and timely reporting practices to the DOE. Review and update reporting procedures as needed to ensure ongoing compliance.

Identify missed reporting obligations and submit the necessary reports promptly. Review internal processes to ensure that future DOE reporting requirements are met.

7. Pipeline and Hazardous Materials Safety Administration (PHMSA) Compliance:
If applicable, the utility complies with PHMSA regulations related to pipeline safety and the transportation of hazardous materials.
YesNoNA

Conduct regular safety inspections and audits of pipeline infrastructure. Ensure that all hazardous materials are handled and transported according to PHMSA regulations.

Identify any deficiencies in pipeline safety or hazardous materials handling. Take immediate corrective actions and implement ongoing monitoring to ensure compliance.

8. Federal Trade Commission (FTC) Consumer Protection Compliance:
The utility adheres to FTC regulations regarding consumer protection, including transparency in billing practices and marketing communications.
YesNoNA

Ensure that all customer-facing communications and billing practices are clear, accurate, and compliant with FTC regulations. Review marketing strategies regularly to avoid misleading claims.

Review and revise billing and communication practices to meet FTC standards. Provide additional training for customer service and marketing teams to ensure compliance.

9. Sarbanes-Oxley Act (SOX) Compliance (for publicly traded utilities):
If publicly traded, the utility complies with SOX requirements, including financial reporting and internal control assessments.
YesNoNA

Regularly audit financial controls and reporting processes to ensure they meet SOX standards. Maintain thorough documentation and prepare for external audits.

Conduct a comprehensive review of financial reporting and internal controls. Implement necessary changes to achieve SOX compliance and prepare for potential audits or reviews.

10. Federal Energy Efficiency Requirements:
The utility complies with federal energy efficiency standards and participates in federally mandated efficiency programs.
YesNoNA

Monitor energy efficiency initiatives and report progress to relevant federal agencies. Adjust programs as needed to maintain compliance and achieve efficiency targets.

Develop and implement energy efficiency programs to meet federal standards. Submit required reports and documentation to federal agencies and monitor ongoing performance.

11. Nuclear Regulatory Commission (NRC) Regulations:
The utility complies with NRC regulations regarding the operation, maintenance, and decommissioning of nuclear facilities.
YesNoNA

Maintain ongoing communication with the NRC to ensure compliance. Regularly review and update safety protocols, emergency preparedness plans, and staff training.

Identify areas of non-compliance and develop a corrective action plan. Submit required documentation and reports to the NRC to achieve compliance.

12. National Environmental Policy Act (NEPA):
The utility conducts environmental impact assessments as required by NEPA for new projects or significant modifications.
YesNoNA

Ensure thorough documentation of all environmental assessments and public involvement processes. Stay updated on any changes in NEPA requirements.

Initiate the NEPA review process immediately. Prepare and submit environmental assessments or impact statements as required.

13. Energy Policy Act (EPAct):
The utility adheres to the mandates of the EPAct, including energy efficiency standards and renewable energy incentives.
YesNoNA

Regularly monitor energy efficiency initiatives and renewable energy procurement to ensure compliance. Take advantage of available incentives and rebates.

Develop a plan to align operations with EPAct requirements. Seek out available resources to support compliance efforts.

14. Spill Prevention, Control, and Countermeasure (SPCC):
The utility has an SPCC plan in place and complies with EPA requirements for spill prevention and response.
YesNoNA

Regularly review and update the SPCC plan. Conduct periodic training and drills for spill response teams to ensure readiness.

Develop and implement an SPCC plan immediately. Ensure all required spill prevention measures and response protocols are in place and compliant with EPA regulations.

15. Department of Transportation (DOT) – Safety and Hazardous Materials Transport:
The utility complies with DOT regulations for the safe transport of hazardous materials, including proper labeling, packaging, and training.
YesNoNA

Continuously review and update transport safety procedures. Ensure all staff involved in the transport of hazardous materials are adequately trained and certified.

Identify gaps in transport safety protocols and implement necessary changes. Provide required training to staff and ensure proper documentation.

16. Equal Employment Opportunity Commission (EEOC):
The utility adheres to EEOC regulations concerning non-discriminatory employment practices, including hiring, promotions, and workplace conduct.
YesNoNA

Regularly review HR policies to ensure compliance with EEOC guidelines. Provide ongoing training to staff on diversity, equity, and inclusion practices.

Update HR policies and practices to align with EEOC regulations. Address any identified issues of non-compliance and provide necessary staff training.

17. Patent and Trademark Regulations (Intellectual Property):
The utility complies with federal patent and trademark regulations regarding the protection and use of intellectual property related to energy technologies.
YesNoNA

Maintain accurate records of all intellectual property and ensure compliance with patent and trademark regulations. Regularly review IP portfolios and update filings as necessary.

Conduct an audit of intellectual property to identify areas of non-compliance. File or update patent and trademark applications as needed to protect IP assets.

1. Pennsylvania Public Utility Commission (PUC) Compliance:
The utility files all required documents and reports with the Pennsylvania PUC, including rate cases, safety plans, and service quality reports.
Yes No NA

Regularly review filed documents to ensure accuracy and compliance. Stay updated on PUC guidelines and prepare for potential audits.

Identify missing filings and prioritize their submission. Implement corrective actions to prevent future non-compliance.

2. Alternative Energy Portfolio Standards (AEPS) Compliance:
The utility meets Pennsylvania’s AEPS requirements by procuring the mandated percentage of electricity from alternative energy sources.
Yes No NA

Monitor ongoing compliance with AEPS and adjust procurement strategies based on regulatory changes.

Develop a plan to meet AEPS targets by increasing alternative energy procurement or partnerships. Review current contracts and explore new sources.

3. Environmental Protection Compliance:
The utility adheres to Pennsylvania Department of Environmental Protection (DEP) regulations, including emissions and water quality standards.
Yes No NA

Maintain ongoing monitoring and reporting of environmental data. Ensure compliance with DEP requirements and prepare for updates or inspections.

Identify areas of non-compliance and implement mitigation strategies. Submit required reports and coordinate with DEP for resolution.

4. Electricity Generation Customer Choice and Competition Act Compliance:
The utility complies with Pennsylvania’s rules on customer choice and competition, ensuring fair and transparent practices.
Yes No NA

Regularly review customer choice policies to ensure they align with state laws. Train staff to maintain transparency in customer interactions.

Update internal procedures to comply with the act. Address any complaints or issues related to customer choice promptly.

5. Energy Efficiency and Conservation Program Implementation:
The utility implements energy efficiency and conservation programs as mandated by the Pennsylvania PUC.
Yes No NA

Regularly assess program effectiveness and report outcomes to the PUC. Update programs based on customer feedback and regulatory changes.

Develop and launch required programs. Ensure proper documentation and submission of reports to the PUC.

6. Stormwater Management Compliance:
The utility adheres to Pennsylvania stormwater management regulations, including proper drainage and runoff control for facilities.
Yes No NA

Regularly inspect facilities for stormwater management compliance. Implement any necessary upgrades or changes.

Review stormwater regulations and address any deficiencies in current practices. Develop a plan for compliance and document all actions taken.

7. Infrastructure Safety and Maintenance:
The utility maintains compliance with PA state regulations on infrastructure safety, including routine maintenance, inspections, and timely repairs.
Yes No NA

Schedule regular safety inspections and maintenance activities. Document all actions taken to ensure compliance and prepare for potential regulatory reviews or inspections.

Identify areas of non-compliance and prioritize necessary repairs or maintenance. Develop a schedule to address deficiencies and ensure future compliance with safety regulations.

1. Corporate Governance and Ethics:
The utility has a code of conduct and corporate governance policies in place that are regularly reviewed and followed by all employees.
YesNoNA

Ensure continuous training for employees on governance and ethical standards. Regularly review and update the code of conduct to reflect evolving industry standards and regulations.

Develop and implement a code of conduct and corporate governance policies. Provide mandatory training for all employees and establish a review schedule to ensure ongoing adherence.

2. Risk Management Framework:
The utility has an established risk management framework that identifies, assesses, and mitigates operational and financial risks.
YesNoNA

Regularly review and update the risk management framework. Ensure that emerging risks are promptly addressed and that mitigation strategies are effective.

Develop a comprehensive risk management framework. Identify key risks, assign ownership, and implement mitigation strategies. Monitor the framework’s effectiveness and adjust as needed.

3. Cybersecurity Policies and Procedures:
The utility has robust cybersecurity policies and procedures in place to protect against cyber threats.
YesNoNA

Conduct regular cybersecurity audits and update security protocols. Provide ongoing cybersecurity training for employees and ensure incident response plans are in place.

Develop and implement cybersecurity policies and procedures. Train employees on cybersecurity best practices and establish an incident response team to handle potential breaches.

4. Employee Health and Safety Programs:
The utility has comprehensive health and safety programs to protect employees, including regular training and emergency preparedness drills.
YesNoNA

Maintain ongoing safety training programs and conduct regular emergency preparedness drills. Monitor and improve safety protocols based on feedback and incident reports.

Develop and implement health and safety programs. Provide mandatory safety training for employees and establish procedures for regular drills and safety audits.

5. Internal Audit and Compliance Monitoring:
The utility has an internal audit function that regularly monitors compliance with both internal policies and external regulations.
YesNoNA

Ensure the internal audit function has sufficient resources and authority to operate effectively. Regularly review audit findings and implement recommended corrective actions.

Establish an internal audit department or function. Define audit procedures, schedule regular audits, and ensure that compliance monitoring is thorough and actionable.

6. Data Management and Reporting Accuracy:
The utility has data management policies ensuring the accuracy and security of data used for reporting and decision-making.
YesNoNA

Regularly audit data management practices to ensure accuracy and security. Update data policies as needed to reflect technological advancements and regulatory changes.

Develop data management policies that include guidelines for data accuracy, security, and reporting. Train employees on these policies and establish regular audits to ensure compliance.

7. Customer Service Standards:
The utility has established customer service standards and regularly measures customer satisfaction against these standards.
YesNoNA

Continuously monitor customer feedback and satisfaction levels. Adjust customer service practices and standards as needed to improve service quality.

Define and implement customer service standards. Establish a system to monitor customer satisfaction and gather feedback. Use this data to improve service offerings.

8. Environmental and Sustainability Initiatives:
The utility has internal initiatives aimed at reducing its environmental impact and promoting sustainability.
YesNoNA

Monitor the effectiveness of environmental and sustainability initiatives. Report progress internally and externally, and make adjustments to meet evolving goals.

Develop and launch sustainability initiatives that align with industry standards and community expectations. Establish metrics to measure impact and report progress regularly.

9. Financial Controls and Accountability:
The utility has strong financial controls in place to ensure accurate financial reporting and accountability.
YesNoNA

Regularly review financial controls to ensure they remain robust and effective. Conduct internal audits and implement any necessary improvements based on audit findings.

Implement comprehensive financial controls and establish clear accountability measures. Train financial staff on these controls and conduct regular audits to ensure compliance.

10. Employee Development and Training:
The utility provides ongoing training and professional development opportunities for its employees.
YesNoNA

Regularly assess training programs to ensure they meet employee and organizational needs. Update training content to reflect new skills, technologies, and regulatory requirements.

Develop a training and development program that addresses the skills and knowledge gaps within the organization. Encourage continuous learning and professional growth for all employees.

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