February 6, 2004
Magalie Roman Salas, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Dockets Room, Room 1A
Washington, D.C. 20426
RE: Docket No. RM01-10-000
Kansas City Power & Light Company
Dear
Ms. Salas:
In
conformance with the Commission’s Order 2004 in Docket No. RM01-10-000, Kansas
City Power & Light Company (KCPL) files its Order 2004 Compliance Plan and
Schedule and KCPL’s Estimate of Compliance Cost.
The
following information is submitted by KCPL:
APPENDIX A: KCPL’s Order 2004 Compliance Plan
and Schedule dated February 6, 2004.
APPENDIX B: KCPL’s Estimate of Compliance Costs
dated February 6, 2004.
APPENDIX C: A Form of Notice suitable for
publication in the Federal Register in accordance with Section 35.8 of the
Commission's Regulations.
If you have any questions about this filing, please call me at (816) 556-2483.
Respectfully
submitted,
Michael
A. Rump
Senior
Attorney
Great Plains Energy Services
1201 Walnut
Kansas City, MO
64106-2124
Attorney for Kansas City Power & Light
Company
Kansas
City Power & Light’s
Order
2004 Compliance Plan and Schedule
In order to be in compliance with Order 2004 by June 1, 2004,
KCPL intends to accomplish the following major actions by the indicated
dates. The indicated actions and dates
are subject to change as KCPL refines its planning and implements its plan, and
may change in response to FERC clarification or rehearing of Order 2004.
Major Actions
|
Activities
|
Start Date
|
End Date
|
|
|
|
|
|
|
1. File compliance
plan and schedule and estimate of compliance costs |
n
Establish
project team. n
Analyze
Order 2004. n
Identify
actions. n
Develop cost
estimates. n
Establish
deadlines. n
Document,
file and post. |
|
February 9, 2004 |
|
|
|
|
|
|
2. Revise current standards
of conduct procedures in accordance with Order 2004 |
n
Compare
current standards of conduct procedures to Order 2004. n
Draft
revised standards of conduct procedures. n
Review
revised standards of conduct procedures with project team and affected functions. n
Obtain
corporate approval of revised standards of conduct procedures. |
January 2, 2004 |
April 1, 2004 |
|
|
|
|
|
|
3. Dissemination of
revised standards of conduct procedures |
n
Print and
distribute revised standards of conduct procedures. n
Post revised
standards of conduct procedures on corporate intranet n
Obtain
verification of receipt of revised standards of conduct procedures. n
Establish
procedure to distribute revised standards of conduct procedures to new
employees. |
April 1, 2004 |
April 9, 2004 |
|
|
|
|
|
|
4. Training |
n
Identify
persons to be trained. n
Discuss
affidavits with bargaining unit business agents. n
Create
training materials. n
Schedule
training classes. n
Deliver
training. n
Collect and
retain affidavits. n
Establish
procedures and schedules to train new employees and to provide refresher
training. |
February 2, 2004 |
May 31, 2004 |
|
|
|
|
|
|
5. Organization
charts and position descriptions. |
n
Determine
Order 2004 requirements. n
Establish
procedures for the creation and updating of organization charts. n
Establish
procedures for the creation and maintenance of position descriptions. n
Establish
procedures for the posting of organization charts, position descriptions and
position transfers. n
Post
organization charts and position descriptions. |
February 2, 2004 |
May 31, 2004 |
|
|
|
|
|
|
6. Chief Compliance
Officer |
n
Corporate
action to designate officer. n
Creation of
position description. n
Establish
procedures for officer to carry out functions established by Order 2004. |
February 2, 2004 |
May 31, 2004 |
|
|
|
|
|
|
7. Monitoring,
auditing and controls |
n
Establish
controls and monitoring and auditing processes in revised standards of
conduct procedures. n
Establish
procedures to carry out monitoring and auditing processes. |
February 2, 2004 |
May 31, 2004 |
|
|
|
|
|
|
8. Compliance |
n
Monitor and
audit compliance with Revised Standards. n
Post Revised
Standards. n
Post updates
to organization chart and position descriptions. n
Post notices
of employee transfers. n
Train new
employees on Revised Standards. n
Periodic
refresher training. |
June 1, 2004 |
ongoing |
Kansas
City Power & Light’s
Estimate
of Compliance Costs
The industry has requested that FERC clarify on re-hearing if training
is required of all employees of the Transmission Provider (all employees) or
for just those employees in the Transmission Provider’s transmission system
operations, wholesale marketing and sales departments and support staff
(relevant employees). Since this issue
has not yet been clarified, KCPL has provided cost estimate for both scenarios.
Cost estimates for
2004:
Ongoing Cost
estimates:
UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
KANSAS CITY POWER & LIGHT COMPANY ) Docket No. RM01-10-000
NOTICE OF FILING
Take
notice that on ___________, 2004, Kansas City Power & Light Company
("KCPL") tendered for filing its Order 2004 Compliance Plan and its
Estimate of Compliance Cost in conformance with the Commission’s Order 2004 in
Docket No. RM01-10-000.
Any person desiring to be heard or to protest
this filing should file a petition to intervene or protest with the Federal
Energy Regulatory Commission, 825 North Capitol Street N.E., Washington, D.C.
20426, in accordance with Sections 1.8 and 1.10 of the Commission's Rules of
Practice and Procedure (18 CFR 1.8, 1.10).
All such petitions or protests should be filed on or before
_________________, 2004. Protests will
be considered by the Commission in determining the appropriate action to be
taken, but will not serve to make protestants parties to the proceeding. Any person wishing to become a party must
file a petition to intervene. Copies of
this filing are on file with the Commission and are available for public
inspection.
Secretary