FERC STANDARDS OF CONDUCT POSTING OF NON-PUBLIC TRANSMISSION INFORMATION

During the course of an audit by FERC, KCPL discovered that certain non-public, transmission-related information was accessible to certain KCPL merchant function employees for a period of several months. Specifically, such information was in the form of a slide show that appeared on the Company’s intranet and information that was inadvertently included in a shared network folder that the accounting personnel of KCPL’s merchant function used to bill certain municipalities that until recently continued to receive bundled service.

The slide show contained historical transmission reliability and outage information that was not available to all customers, such as, System Average Interruption Duration Index (SAIDI), Transmission SAIDI, Reliability SAIDI, Transmission Line Contribution to SAIDI, Transmission Line Contribution to System Average Interruption Frequency Index (SAIFI), Reliability Performance Trends, Recordable Incident Rate - Transmission Lines, and Transmission Capital Budget 2000 - 2009.

The non-public transmission information inadvertently contained in the folder shared between merchant function and transmission function accounting personnel included operating letters containing megawatt values for transmission service schedules; information regarding transformers, transmission lines and breakers; and other non-public transmission information.

After FERC audit staff discovered the shared folder and slideshow, they interviewed PSS employees and inquired if the PSS employees had knowledge of the shared folder or slide show and if they accessed either. The employees interviewed said they did not know they had access to the folder or slide show, nor did they know either contained non-public transmission information. KCPL submit affidavits to FERC audit staff signed by all PSS employees stating they were not aware of the shared folder or slide show and their contents, and that they did not access transmission related data contained in the shared folder or slideshow.

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