American Transmission Company Standards of Conduct Information

Job Descriptions
ATC Transmission Function Employee Job Descriptions Updated: 4/19/2024

Written SOC procedures including compliance plan
American Transmission Company LLC FERC Standards of Conduct Compliance Plan Updated: 3/18/2024

03/14/2024: ATC has designated Ellen Nowak, Vice President State and Federal Affairs, as the FERC Standards of Conduct Chief Compliance Officer for ATC. Ms. Nowak may be reached at 262-506-6804.

1/10/17: Update to names and addresses of affiliates with marketing function employees
Alliant Energy
4902 North Biltmore Lane, Madison, WI 53707-1007

Wisconsin Electric Power Company
231 W. Michigan St., Milwaukee, WI 53203

Wisconsin Public Service Corp.
700 N Adams St, Green Bay, WI 54301

List of facilities, and their addresses, shared by ATC and its affiliates
None

3/12/06: As of 0400 CST, the emergency reported below was resolved and Standards of Conduct were reinstated.

3/10/06: ATC has suspended its Standards of Conduct associated with the Wausau, WI area transmission system as a result of forced outages to the in the Wausau area. These forced outages, in conjunction with other outages in the area, result in the need for effective load curtailment to maintain system reliability. This suspension is effective 23:04 CST.

1/16/06: As of 15:30 CST, the emergency reported below was resolved and Standards of Conduct were reinstated.

1/16/06: ATC has suspended their Standards of Conduct associated with the Wausau, WI area transmission system as a result of a forced outage to the Weston-Rocky Run 345 kV line. This forced outage, in conjunction with other outages in the area, result in the need for effective load curtailment to maintain system reliability. This suspension is effective 11:03 CST.

Incidents of disclosure of information

Posted on 11/6/20:
American Transmission Company LLC (ATC) has identified a prohibited disclosure of non-public transmission function information to a Marketing Function Employee (MFE) of an affiliated company. Specifically, on Wednesday, November 4, 2020, an affiliate employee contacted the Pewaukee System Operations Control Center requesting a status update for CROW ID 1-25950337. The ATC System Control Operator provided an update stating that the outage had been completed. Upon further investigation by ATC Real Time Operations, the affiliate contact was identified as an MFE. There is typically a one-hour delay before CROW information is posted on OASIS. Given the time between the call from the MFE and the MISO completion time, ATC Real Time Operations believes that non-public outage information was shared with the MFE approximately 30 minutes before that information was published to OASIS via CROW.

Posted on 5/16/18:
American Transmission Company LLC (ATC) has identified the possible disclosure of non-public transmission function information to a marketing function employee of an affiliated company. A transmission function employee at American Transmission Company LLC exchanged generator limit/restriction related information with employees of an Affiliate, which erroneously included a marketing function employee of the Affiliate. The information provided regarded a draft commissioning study for two planned facilities which identified operating restrictions for a generating station owned by the Affiliate. The subject limits information is considered non-public transmission function information and disclosure to a marketing function employee is contrary to the Standards of Conduct.

Posted on 4/5/2016:
American Transmission Company LLC (ATC) has identified the possible disclosure of Non-Public Transmission Function Information to Marketing Function Employees of an affiliated company. To aid in safe, secure and reliable operations, ATC routinely conducts meetings and/or teleconferences with staff at interconnected and/or affiliated companies to discuss upcoming scheduled transmission asset related outages. The need and frequency of the meetings and/or teleconferences to discuss scheduled transmission related outages is agreed to with each of ATC’s interconnected companies or affiliates, and is different for each company.

As relevant here, ATC conducts weekly outage update teleconference calls with staff members of one of ATC’s affiliated companies. Although the intent of the weekly teleconferences is to only discuss outages which have been publicly posted on the MISO CROW outage scheduler, ATC has prohibited Marketing Function Employees of the affiliated company from participating in the weekly teleconference calls as a precaution in the event that unanticipated discussions occur during the live teleconference. In addition, it has been ATC’s practice to distribute to this affiliated company, in advance of the weekly teleconference, a spreadsheet that lists applicable scheduled transmission outages expected to be discussed during the teleconference so as to support reliable operations. These outage summary spreadsheets were intended to only depict transmission outages which had been publicly posted on the MISO CROW scheduler and that were identified in advance as topics for the weekly teleconference. ATC emails these spreadsheets to relevant contacts at the affiliated company in advance of the teleconference, specifically including certain Marketing Function Employees.

While preparing the outage summary spreadsheet for March 31, 2016, ATC determined that the spreadsheet contained outages which had been submitted to ATC’s Transmission Outage Administration software, but had not yet been submitted to MISO’s public CROW outage scheduler or publicly posted on MISO’s OASIS. ATC therefore labeled this March 31, 2016 spreadsheet as “Non-Public Transmission Function Information.” Although the spreadsheet was appropriately labeled, the spreadsheet was issued to employees at the interconnected affiliated company using a standard email distribution list, which included Marketing Function Employees. This error was recognized and brought to the attention of ATC’s compliance staff on April 1, 2016. On April 4, 2016, ATC’s operations and outage coordination staff conducted a review of the content of the March 31, 2016 spreadsheet and determined that the spreadsheet provided to ATC’s affiliated company did disclose information regarding 1) certain additional transmission-related outages which, at the time the spreadsheet was distributed, did not have a corresponding MISO CROW outage schedule entry; or 2) that revised outage dates depicted in the spreadsheet had not yet been updated in the MISO CROW outage scheduler. In either case, such information was not publicly available.

ATC has taken the following actions to remedy this inadvertent disclosure of information to an affiliated Marketing Function Employee that may be Non-Public Transmission Function Information:

•ATC has revised the email distribution list to ensure that Marketing Function Employees of the relevant affiliated company will not receive emails containing weekly outage spreadsheets in the future. In addition, for all future interactions with any of ATC’s affiliated or interconnected companies done for the purposes of discussing scheduled outages to support reliable operations, ATC will take necessary steps to ensure that Non-Public Transmission Function Information is not distributed to Marketing Function Employees.
•ATC has updated the MISO CROW outage scheduler to publicly depict any outages, and to revise outage dates, that were listed in the March 31, 2016 outage spreadsheet but had not yet been processed through and publicly posted in the MISO CROW outage scheduler. The subject outages have been recorded on the MISO CROW outage scheduler with the following identifiers: CROW 1-08889386, CROW 1-09471332, and CROW 1-10434469.
•ATC has also reviewed the weekly outage spreadsheets which were issued to the affiliated company for the three weeks prior to March 31, 2016. Although it appears possible that similar inadvertent disclosures may have occurred in the past, ATC has determined that, given the passage of time, planned outages depicted in the prior three weekly outage spreadsheets (and any earlier spreadsheets) are currently correctly depicted and are publicly available in the MISO CROW outage scheduler.

If further information is required regarding this notice, please contact Doug Johnson in ATC’s Compliance Department at 262-506-6863.

Posted on 12/13/12:
American Transmission Company LLC (ATC) has identified the possible disclosure of non-public transmission function information to marketing function employees of an affiliated company. An interconnected, generator operator brought to ATC’s attention the need to take a generator outage. In coordinating the date of the generator outage, the generator operator requested guidance from ATC as to acceptable dates for the generator outage. ATC responded to this inquiry via an e-mail which identified dates during which the generator outage could not be scheduled due to planned transmission system outages. This e-mail was properly identified as non-public transmission function information, but the e-mail was erroneously copied to marketing function employees of an affiliated company of ATC. The planned transmission system outage had not yet been publicly posted on the MISO outage scheduler. The subject transmission outage information is considered non-public transmission function information, and disclosure to marketing function employees is contrary to the Standards of Conduct. ATC has entered the subject scheduled transmission system outages into the MISO CROW outage scheduler and the planned outages have been recorded with the following identifiers: CROW 1-03289647, CROW 1-03289678, and CROW 1-03289679.

Posted on 9/29/11:
An Affiliate has brought to the attention of American Transmission Company LLC the possible disclosure of non-public transmission function information to a marketing function employee. A transmission function employee at American Transmission Company LLC exchanged and discussed transmission and generator outage related information with an employee of an Affiliate who is not a marketing employee. The information provided regarded a planned substation outage scheduled for 2013 which would potentially constrain the output from a generating station owned by the Affiliate. The outage related information was subsequently discussed between additional employees at the Affiliate and it is believed the information was erroneously shared with a marketing function employee of the Affiliate. The subject outage information is considered non-public transmission function information and disclosure to a marketing function employee is contrary to the Standards of Conduct.

Posted on 9/26/11:
An Affiliate has brought to the attention of American Transmission Company LLC the possible disclosure of non-public transmission function information to a marketing function employee. A draft data request response associated with a rate proceeding filing, which was circulated internally at the Affiliate for review, was erroneously provided to a marketing function employee of the Affiliate. The draft data request response included a very brief summary of a MISO Operating Guide which defines how generating units at a specific power plant would be dispatched under certain transmission constraints. This information is considered non-public transmission function information and disclosure to a marketing function employee is contrary to the Standards of Conduct.

Posted on 2/18/11: at request of Integrys/Wisconsin Public Service:
On February 18, 2011 at approximately 3:30pm Central Time, there was an improper disclosure of non-public transmission function information by a transmission function employee to a marketing function employee. At a joint meeting that included the transmission function employee and the marketing function employee, the transmission function employee inadvertently disclosed the outage of a 138 kV transmission line located in the Western UPPCO service territory and indicated that the line was expected to return to service in about 1 hour. The transmission function employee’s disclosure was based on information received from American Transmission Company, LLC (ATC). After the disclosure occurred, the joint meeting was immediately concluded and Integrys investigated the disclosure. Integrys contacted ATC concerning the improper disclosure and completed this posting required by the Commission’s regulations.

American Transmission Company LLC's Supplemental Compliance Filing
ATCLLC will make available the EMS alarm data dating from January 1, 2001 through March 8, 2002 on a compact diskette to any entity that requests a copy. Any requests for this data should be made to
Keith Jonas at ATCLLC.
Phone: 262-506-6741
E-Mail: kjonas@atcllc.com

ATC Standards of Conduct postings

Voluntary consent to share transmission customer's non-public information with marketing function employees
Nothing to post at this time.

Potential merger partners

The following appeared in the third quarter Form 10-Q filed by Allete, Inc. with the U.S. Securities and Exchange Commission:

“ATC is a for-profit transmission-only company created by the transfer of transmission assets previously owned by several electric utilities serving the upper Midwest. In April 2003, the PSCW approved a transfer of interests in the Wausau-to-Duluth electric transmission line project to ATC. As a result, ATC has assumed primary responsibility for the overall management of the project and will own and operate the completed Wausau-to-Duluth line. We have a contractual opportunity related to ATC that, if exercised, would ultimately result in our having an equity investment in ATC. We intend, if approved by other parties, to invest $60 million in ATC by the end of 2006.”

Based on preliminary analysis, ATC Board approval of Allete's membership is required.

Employee transfers
None at this time

Affiliate employee transfers
None at this time

Other information
Alliant Energy-WPL extracts a subset of the following tables for month end processing from the American Transmission Company, LLC. Information is all related to tie-line data (WPL's interconnections) and is extracted for control area reporting (CAR). Information is only extracted after-the-fact. HS stands for historical.