Pursuant to 18 CFR Section 358.7(e)(2)
Building and Building Services - Pursuant to Section 358.7(e)(2) of the Commissions Regulations, the following is a complete list of the employee-staffed facilities (excluding facilities where individuals do not typically transact business) shared by any Transmission Function Employees (TFEs) for Northwest and Marketing Function Employees.
The following employee-staffed facilities are shared by certain Transmission Function Employees for Northwest and Marketing Function Employees:
One Williams Center
The Marketing Function Employees (MFEs) reside in an office space that is separated from the locations of the Transmission Function Employees for Northwest.
Northwest’s main office facility is located in Houston, Texas. No Marketing Function Employees share this facility. A card key is required to access the office space that Transmission Function Employees of Northwest occupy in its main facilities in Houston. The card key access system prohibits access by a Marketing Function Employee to Northwest’s Houston facilities. Marketing Function Employees, as with non-affiliated visitors, may enter Northwest’s office space after registering with a receptionist and providing identification, but no card key is provided and they must be escorted by Northwest personnel.
Computer Systems - Northwest TFEs and MFEs share a Wide Area Network, and share access to servers on which corporate support-related systems reside, such as the human resources system, and the financial enterprise resource planning system (which supports finance, accounting, planning and forecasting, and reporting functions). Access to any Transmission Function Information (including non-affiliated shipper information) on those shared resources is restricted by organizational roles and the use of access control mechanisms (such as user ids, passwords) to ensure that MFEs do not have access to that information.
SharePoint sites with possible Transmission Function Information are marked as such. MFE system access is regularly reviewed by the FERC Compliance group.
The remaining servers where Transmission Function Information is maintained are not shared with Marketing Function Employees. Access to those servers is restricted by access control mechanisms (such as user ids, passwords, FERC deny flag for Windows servers, visibility restriction of FERC IT components in the access control system). Additionally, a firewall separates the MFE office area from the rest of Williams. This firewall operates in a deny-by-default manner where MFE access is only allowed for specifically approved share resources.
Northwest follows the Williams Access Control process under which Northwest ensures that Marketing Function Employees do not have preferential computer access to non-public Transmission Function InformationMFE system access is regularly reviewed by the FERC Compliance group. Any transfer by a Transmission Function Employee to a Marketing Function position is treated as a termination for access purposes, where old access is revoked prior to granting any new access.