2013 reliabilityfirst cmep implementation plan - nerc

RReelliiaabbiilliittyyFFiirrsstt CCoommpplliiaannccee MMoonniittoorriinngg aanndd

EEnnffoorrcceemmeenntt PPrrooggrraamm 22001133 IImmpplleemmeennttaattiioonn PPllaann

January 1 2013 VVeerrssiioonn 0011

NOTE

CMEP Implementation Plan and the ReliabilityFirst 2013 Compliance Monitoring Schedule are posted at the following links httpswwwrfirstorgcompliancePagesCMEPImplementationPlansaspx httpswwwrfirstorgcompliancePagesSchedulesaspx

Table of Contents

2

TTaabbllee ooff CCoonntteennttss

ReliabilityFirst Compliance Monitoring and Enforcement Program 5

Introduction 7

2013 Executive Summary 9

ReliabilityFirst Compliance Monitoring and Enforcement Organization 11

Risk-Based Compliance Monitoring Approach 12

2013 Implementation Plan Development Methodology 13

ERO High-Risk Priorities 13

Southwest Blackout Report 13

FERC Order and Guidance 14

Violation Trend History 14

Input from Staff 14

Future Considerations 14

Three-Tiered Approach to Requirements Specification 14

Three-Tiered Approach to Audit Scope Determination 15

Audit Scope 16

Implementation Plan Summary 16

Reliability Standards Subject to 2013 CMEP Implementation 18

BAL ndash Resource and Demand Balancing 18

CIP ndash Critical Infrastructure Protection 18

COM ndash Communications 19

EOP ndash Emergency Preparedness and Operations 19

FAC ndash Facilities Design Connections and Maintenance 19

IRO ndash Interconnection Reliability Operations and Coordination 20

MOD ndash Modeling Data and Analysis 20

NUC ndash Nuclear 20

PER ndash Personnel Performance Training and Qualifications 21

PRC ndash Protection and Control 21

TOP ndash Transmission Operations 22

TPL ndash Transmission Planning 22

VAR ndash Voltage and Reactive 22

CMEP Discovery Methods 23

I Compliance Audits 23

Audit Focus or Scope 24

CIP Reliability Standards Compliance Audits 25

2013 Compliance Audit Schedule 25

Compliance Audit Reports 26

Reliability Standard Auditor Worksheets (RSAW) 27

Mitigation Plans 28

Table of Contents

3

II Self-Certification 28

CIP-002-3 through CIP-009-3 Reliability Standards 28

III Spot Checks 29

IV Periodic Data Submittals 29

V Self-Reporting 29

VI Exception-Reporting 30

VII Complaint 30

VIII Compliance Investigations 30

Key CMEP Activities and Initiatives 32

CMEP Transparency Elements 32

Outreach Efforts and Compliance Communications 33

Monthly Newsletter 33

Monthly Compliance Update Letter 33

ReliabilityFirst website 33

WorkshopsSeminarsWebinars 33

Compliance Data Management System (CDMS) 33

Periodic Reports 33

Open Compliance Calls 33

Assist Visits 34

Compliance Communication 34

Training and Self Improvement Activities 35

Compliance Auditors 35

Compliance Investigation (CI) Staff 35

Compliance Reviews of Events and Disturbances 35

Registered Entity Responsibilities 36

Regional Entity Responsibilities 36

Registration and Certification 37

Multi-Regional Registered Entities (MRRE) 37

Joint Registration Organization and Coordinated Functional Registration 37

Results of Abrupt or Forced Registration Changes 38

Enforcement Initiatives 38

Further Implementation of the CEI 38

ERO Guidance on COM-002-2 ndash Communication and Coordination 38

Approved Standards Which Reference Unapproved Standards 39

ReliabilityFirst CMEP Implementation Plan 41

Conclusion helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip 42

Document Change Revision History 43

Appendix 1 ndash Standards and Requirements Implicated System Events 44

Appendix 2 ndash Compliance Assessment Template 46

Appendix 3 ndash 2013 Regional Entity Request to Defer or Reduce the Scope of a Compliance Audit 50

Table of Contents

4

[Blank Page]

ReliabilityFirst Compliance Monitoring and Enforcement Program

2013 Implementation Plan

5


EEnnffoorrcceemmeenntt PPrrooggrraamm

The North American Electric Reliability Corporation (NERC) Compliance Monitoring

and Enforcement Program (CMEP) is developed under Section 215(c) of the Federal

Power Act1 to establish and enforce Reliability Standards for the Bulk Electric System

(BES) subject to review by the Federal Energy Regulatory Commission (FERC) and in

general accordance with the ldquoPrinciples for an Electric Reliability Organization that can

Function on an International Basisrdquo2 The CMEP is designed to improve reliability

through the effective and efficient enforcement of Reliability Standards

To help fulfill its responsibilities under its rules filed with regulatory authorities NERC

as the international Electric Reliability Organization (ERO) has delegated authority to

monitor and enforce compliance with Reliability Standards of owners operators and

users of the BES to qualified Regional Entities This delegation is governed by regional

delegation agreements (RDAs) that have been approved by the appropriate regulatory

authorities NERC and the Regional Entities are responsible for carrying out the CMEP

Under NERCrsquos oversight each Regional Entity submits to NERC for approval its regional

CMEP implementation plan that is based on this document

Reliability and accountability are basic tenants of the CMEP In concert with this

mutually agreed upon goal of NERC and the Regional Entities accountability is an

important characteristic of the collective endeavor NERC as the Federal Energy

Regulatory Commission (FERC) certified Electric Reliability Organization (ERO) along

with the Regional Entities are accountable to the regulators to fulfill this charge

Conducting a thorough risk based compliance program and appropriate enforcement

actions coupled with providing a continual education and information campaign to assist

the industry to achieve and sustain compliance will enhance reliability NERC in

conjunction with ReliabilityFirst and all of the Regional Entities continue to refine and

improve the annual CMEP Annual Implementation Plans and the Actively Monitored

List (AML) of standards with a goal that serves to enhance reliability not mandate a

single means of achieving it

Registered Entities are reminded that in the NERC Rules of Procedure (RoP)3 it states

that all Bulk Power System (BPS) users owners and operators are required to comply

with ALL applicable ERO governmental authority approved Reliability Standards at

ALL times Regional Reliability Standards and regional variances approved by NERC

and the applicable ERO governmental authority are enforceable and apply to all

Registered Entities responsible for meeting those Reliability Standards within the

Regional Entity boundaries whether or not the BPS user owner or operator is a member

of the Regional Entity

1 httpwwwnerccomfileUploadsFileAboutNERCHR6_Electricity_Titlepdf

2 Bilateral Electric Reliability Oversight Group August 3 2005 (the ldquoBilateral Principlesrdquo)

3 See Rules of Procedure Section 4012 at httpwwwnerccompagephpcid=1|8|169



6

ReliabilityFirst NERC and the other Regional Entities recognize that there are important

reliability matters that require prompt communication to industry NERC has used the

AlertsAdvisory process to rapidly inform the industry of such matters Through this

Implementation Plan we strongly encourage the applicable Registered Entities to

proactively address such communications as a way of demonstrating good utility practice

and a strong culture of compliance and reliability excellence

2013 Executive Summary

7

IInnttrroodduuccttiioonn

The objective of ReliabilityFirst as a Regional Entity is to preserve and enhance electric system

reliability and security for the interconnected electric systems within the ReliabilityFirst

geographic area To support this ReliabilityFirst through its role as outlined in the Regional

Delegation Agreement will monitor assess and enforce compliance with Regulatory Approved

Reliability Standards for each Registered Entity that has functional responsibilities as determined

by its organizationrsquos registration as posted on the NERC Compliance Registry ReliabilityFirst

will also monitor assess and enforce as applicable compliance to ReliabilityFirstrsquos Regulatory

Approved Reliability Standards ReliabilityFirst will verify compliance through one of the

monitoring methods described in the NERC Compliance Monitoring and Enforcement Program

(CMEP) as outlined in the Discovery Section of this implementation plan The ReliabilityFirst

2013 CMEP Implementation Plan closely mirrors the NERC CMEP Implementation Plan which

is the annual operating plan for compliance monitoring and enforcement activities

ReliabilityFirst will utilize the latest version of the NERC CMEP (Section 4C in the NERC

Rules of Procedure) filed and approved by FERC

The 2013 Implementation Plan includes a set of Reliability Standards that were selected for

monitoring based upon NERC identified high risk priorities with a three-tiered approach of

those standards to facilitate a more focused compliance monitoring effort The Implementation

Plan also requires consideration of a registered entityrsquos compliance history when determining the

scope of compliance monitoring activities

The objectives of the Implementation Plan are to

Promote the reliability of the BPS through rigorous compliance monitoring and

enforcement activities

Facilitate improved consistency of compliance activities throughout North America

Monitor all regulatory authority approved Reliability Standards by using the eight CMEP

compliance monitoring methods

Use risk-based and performance-based criteria for determining the scope for compliance

monitoring

Allow flexibility to investigate trends that may pose a near term risk to reliability by

implementing changes in the plan

The 2013 ReliabilityFirst CMEP Implementation Plan was developed considering the

requirements rules and information from the following

the ERO Annual Implementation Plan

the NERC RoP

the CMEP

the RDA

NERC Board of Trusteesrsquo actions including those of the


8

NERC Board of Trustees Compliance Committee

regulatory authority approved Reliability Standards


9

22001133 EExxeeccuuttiivvee SSuummmmaarryy

Noteworthy changes to the 2013 Implementation Plan include

1 Audit Scope and Periodicity Both audit scope and audit periodicity for a registered

entity starts with the tier one (1) requirements as the usual audit scope and can be

adjusted as described below with NERC oversight based on appropriate justification

a For entities registered as a Balancing Authority (BA) Reliability Coordinator

(RC) or Transmission Operator (TOP) scope can be modified however per the

current ROP they are still required to be audited every three years4

b For all other registered entities that were previously directed be audited on a six

year cycle there is flexibility to adjust the periodicity as well as scope again

with appropriate justification provided by ReliabilityFirst and with NERC

approval as outlined below and in Appendix 3

2 Registered Entity Compliance Assessments To support a strong culture of compliance

registered entities are encouraged to perform a compliance assessment in response to all

system events and disturbances Registered entities conducting compliance assessments

are encouraged to provide a compliance assessment report to ReliabilityFirst for system

events that fall in category 2 and above as outlined in the ERO events analysis process

document The Compliance Assessment Template as found in Appendix 5 should be

used when performing these assessments The use of rigorous compliance assessments

may reflect positively on a registered entityrsquos compliance program to self-identify and

address possible reliability issues demonstrate their effectiveness of their internal

controls and their commitment to their culture of compliance

3 Critical Infrastructure Protection (CIP) Standards and Tier Assignments Tier

assignments in the CIP standards have been reassigned so that each requirement along

with its sub-requirements is assigned a single tier

Where there is confidence in both an entities internal compliance program and their internal

controls monitoring their internal compliance effort both audit scopes and audit periodicity may

be specifically tailored to each registered entity In 2012 Tier 1 standards represented the

minimum audit scope If an entityrsquos compliance risk assessment performed by the Regional

Entity indicate a strong compliance program and effective internal and risk controls are in place

either its audit scope or its audit periodicity5 can be reduced

6 This reduction can allow for more

thorough compliance monitoring of entities potentially posing more risk to the reliability of the

Bulk Electric System (BES) which is the major benefit of performance-based monitoring In

contrast where there is a lack of confidence in the entity assessments the audit scope may be

4 Audit periodicity for entities registered as BAs RCs and TOPs must be every three years and cannot be reduced

per section 403111 of the NERC Rules of Procedure at

httpwwwnerccomfilesNERC_Rules_of_Procedure_EFFECTIVE_20110412pdf 5 Audit periodicity for entities registered as BAs RCs and TOPs must be every three years and cannot be reduced


httpwwwnerccomfilesNERC_Rules_of_Procedure_EFFECTIVE_20110412pdf 6 Using the form found in Appendix 3 of this document entitled ldquo2013 Regional Entity Request to Defer or Reduce

the Scope of a Compliance Auditrdquo


10

increased to include certain tier 2 and tier 3 requirements or more frequent monitoring could

occur

NERC ReliabilityFirst and the other Regional Entity staff continues to monitor recent activities

and major events such as the southwest cold weather event7 the southwest blackout event

8 as

well as the progress of the Find Fix Track and Report (FFT) mechanism of the Compliance

Enforcement Initiative (CEI) As a result of the Southwest Blackout9 report by FERC and

NERC ReliabilityFirst will review and include when applicable critical standards that include

aspects of situational awareness including both planning and coordination in its audit and self-

certification programs for 2013 Additionally ReliabilityFirst will broadly consider the themes

of the Southwest Blackout Report communication coordination planning and modeling A list

of these standards is provided in Appendix 1 of this report

The impact of currently known new or revised standards that will come into effect in 2013

include the introduction of the following

New CIP Tier reassignments effective 112013

FAC‐008‐3 effective 112013 (no effect on the Actively Monitored List (AML))

PER-005-1 effective 412013

EOP-001-2b EOP-005-2 EOP-006-2 and EOP-008-1 effective 712013

Specifics of the changes can be found in the ldquo2013 High-Risk Priority Standards and Tier 1

Requirementsrdquo section of this report and in the 2013 AML

7 Report from NERC and FERC httpwwwnerccomfilesSW_Cold_Weather_Event_Final_Reportpdf 8 Report from NERC and FERC httpwwwnerccomfileUploadsFileNewsPR_AZOutage01MAY12pdf 9 httpwwwnerccomfileUploadsFileNewsPR_AZOutage01MAY12pdf

ReliabilityFirst Compliance Monitoring and Enforcement Organization

11


EEnnffoorrcceemmeenntt OOrrggaanniizzaattiioonn

The ReliabilityFirst Compliance Monitoring and Enforcement Organization is comprised

of four functional groups that interact and work to improve the reliability of the Bulk

Electric System (BES) The table below highlights the present reporting relationship and

functional responsibilities of the Compliance and Enforcement Organization

Designates expected staffing levels by the end of 2013

Risk-Based Compliance Monitoring Approach

12

RRiisskk--BBaasseedd CCoommpplliiaannccee MMoonniittoorriinngg AApppprrooaacchh

The premise of risk-based compliance monitoring is that a registered entity receives

compliance monitoring commensurate with the risk it poses to the reliability of the BPS

Risk is not to be considered as a negative in any way simply as a consideration of the

complex nature of the industry Risk is neither uniform across the diverse industry that is

responsible for the reliability of the BPS nor is it consistent over time

Compliance monitoring encompasses a range of activities including spot checks self-

certifications audits and personal correspondence to an entity from ReliabilityFirst For

entities that do not pose a significant reliability risk the activities specifically prescribed

in this Implementation Plan may suffice For entities that do pose a significant risk to

reliability it may be necessary for those entities to undergo additional compliance

monitoring such as additional focused spot checks a greater number of self-certifications

investigations or broader and deeper audits of greater frequency etc

One of the key components of an effective risk-based audit approach is performance-

based auditing Audits according to the United States Government Accountability

Office10

are defined as engagements that provide assurance or conclusions based on an

evaluation of sufficient appropriate evidence against stated criteria such as specific

requirements measures or defined business practices A second component includes a

more detailed review and testing of the registered entityrsquos programs and procedures to

assure actual implementation of the stated programs rather than relying solely on

documentation

Registered entities are responsible for compliance with all regulatory approved

Reliability Standards and Requirements in effect per their registered function at all times

regardless of what a registered entityrsquos risk profile may indicate Regional Entities have

the authority and responsibility to expand the scope of an audit spot check or any other

compliance monitoring process as necessary when evaluating the compliance of a

registered entity

10

See United States Government Accountability Office ndash Government Auditing Standards (GAGAS) at

Chapter 1 Use and Application of GAGAS at Section 125 httpwwwgaogovnewitemsd07731gpdf

2013 Implementation Plan Development Methodology

13

22001133 IImmpplleemmeennttaattiioonn PPllaann DDeevveellooppmmeenntt

MMeetthhooddoollooggyy

As part of an overall compliance plan NERC ReliabilityFirst and the other Regional

Entities developed the NERC Actively Monitored List (AML) of Reliability Standards

for 2013 based on the methodology outlined in this section

The 2013 NERC and ReliabilityFirst Implementation Plans and the 2013 ReliabilityFirst

Compliance Monitoring Schedule (CMS) were developed and designed to recognize risk-

based approaches for ReliabilityFirst programs and initiatives that help sustain and

improve overall reliability Achieving these objectives will be accomplished through the

development maintenance and implementation of a list of the highest priority Reliability

Standards The Reliability Standards and associated Requirements populating this list

will be determined through an annual and ongoing review of the following

ERO High-Risk Priorities

FERC Orders Guidance and Reports (ie Southwest Blackout Report)

Compliance History and Culture

Input from Staff

Future Considerations


This focus identifies and uses a set of priorities in order to move our auditing away from

processes for ldquoadministrative and documentation related violationsrdquo and instead focuses

on Reliability Standards and Requirements deemed the most critical to the reliability of

the BPS The determination is made using a set of risk-based criteria as a priority and is

explained in further detail in Appendix 1 of the 2013 ERO High-Risk Priorities with High

Value Associated Reliability Standards found in the NERC 2013 Implementation Plan

httpwwwnerccomcommondocsphpcd=3

Southwest Blackout Report

The joint FERCNERC report on the southwest blackout of September 201111

was

released on May 1 2012 Areas of continuing concern are situational awareness

communication coordination planning and modeling Many of these concerns are

already addressed by the AML and will be bolstered by the release of EOP-005-2

effective July 1 2013

11 httpwwwnerccomfileUploadsFileNewsAZOutage_Report_01MAY12pdf


14

FERC Order and Guidance

The Reliability Standards MOD-001 MOD-004 and MOD-008 associated with a recent

FERC Orders 729 729-A and 729-B will be integrated into the 2013 Implementation

Plan and will be actively monitored as part of the 2013 Implementation Plan

Violation Trend History

An analysis of the compliance violation history of Reliability Standards found in the

2013 NERC Implementation Plan will continue and report on the most violated standards

will continue to be identified and be included as part of the annual compliance review

process

Input from Staff

Insight provided by the compliance staff of all eight Regional Entities in terms of their

subject matter expertise and experience while performing their role and responsibilities

as the Compliance Enforcement Authority was also considered and provided as input

into NERCrsquos development of their 2013 Actively Monitored List (AML) of Standards


Future considerations refer to those reliability standards that are not yet enforceable but

are implicated by the 2013 ERO high-risk priorities as referenced in Appendix 1 of the

2013 ERO High-Risk Priorities with High Value Associated Reliability Standards found

in the NERC 2013 Implementation Plan httpwwwnerccomcommondocsphpcd=3

Thus these suggested reliability standards should immediately be considered for

incorporation into the AML and the ReliabilityFirst Compliance Monitoring Schedule

(CMS) following FERC approval As indicated by the NERC Standards group the

applicable reliability standards subject to future enforcement12

for 2013 include EOP-

001-2b EOP-005-2 EOP-006-2 EOP-008-1 FAC-008-3 FAC-013-2 and most

requirements of PER-005-1

Three-Tiered Approach to Requirements Specification

The three-tiered approach for identifying the Requirements of the Actively Monitored

List and individual Regional Entity plans is described below For further information

regarding the NERC Implementation Plan methodology as referenced here Registered

Entities are asked to refer to Appendix 1 ndash 2013 ERO High-Risk Priorities with High

Value Associated Reliability Standards httpwwwnerccomcommondocsphpcd=3

Tier 1 Requirements are those that are deemed to be the most critical to the purpose and

intent of the standard of which they are a part Additionally the ability of a registered

entity to demonstrate compliance with Tier 1 Requirements will provide guidance to

12 See the NERC site for the latest information regarding in-effect dates for Reliability Standards

httpwwwnercnetstandardsreportsstandardssummaryaspx


15

audit teams on the necessity to investigate further and broaden an auditrsquos scope in

additional Requirements andor Reliability Standards

Tier 2 Requirements are also critical to the purpose of a standard but Tier 2

Requirements do not address the ERO high-risk priorities as does Tier 1 Tier 2 also does

not pose as severe a risk as Tier 1 This is not to say that compliance with Tier 2

Requirements is not mandatory Instead Tier 2 Requirements represent an additional

level of inquiry that may be undertaken when a registered entity does not display clear

compliance with those most critical Requirements of Tier 1 In the process of this added

level of monitoring it may become necessary to branch off into other Reliability

Standards that were not identified as relating directly to an ERO priority or the initial

scope of the monitoring process invoked

Tier 3 Requirements are those that while still contributing to BPS reliability do not

represent the purpose of a Reliability Standard directly or are not representative of ERO

priorities based upon the criteria listed above The exploration of an audit team into the

compliance of a registered entity with Tier 3 Requirements will be initiated through

registered entity responses and between the identified deficiencies in Tier 1 and 2

Requirements and those of Tier 3

The NERC and ReliabilityFirst CMEP Implementation Plan for 2013 will use Tier 1

Requirements as the NERC AML and ReliabilityFirst CMS of Reliability Standards

The basis for the requirements of the high-risk priority Reliability Standards in the Tier 1

classification is covered in the following section

Three-Tiered Approach to Audit Scope Determination

Audit teams are authorized and obligated to expand the scope of a compliance audit to

include Tier 2 and Tier 3 Requirements (all inclusively or separately) and any other

requirements they may deem necessary based on the results of the Regional Entityrsquos Risk

Profile Assessment of the Registered Entity or the audit teamrsquos collective professional

judgment Audit scope expansion can occur at any point during the process from the

initial review of the Registered Entity Risk Profile Assessment through the close of the

audit

Tier 1 Requirements are identified in the 2013 NERC AML and 2013 ReliabilityFirst

CMS and represent the minimum scope of most compliance audits The potential

expansion or reduction of an audit from Tier 1 or an expansion into Tier 2 and Tier 3

Requirements will be determined by ReliabilityFirst

When ReliabilityFirst determines that a change in audit scope is necessary based on a

risk-based compliance monitoring approach ReliabilityFirst will notify the registered

entity of the change in audit scope This notification shall include the Reliability

Standards and Requirements that are excluded or included in the revised audit scope as

well as the justification for the change in scope This notification shall be part of the

audit notification package when it is determined early enough in the process When

ReliabilityFirst determines that a change in audit scope is necessary after the notification


16

package is sent or while the audit is in progress (eg either on-site or off-site) then

ReliabilityFirst shall notify the registered entity of the change as soon as possible

If notification is provided ahead of the start of the audit ReliabilityFirst is anticipating

review of the additional evidence during the course of the audit If the notification is

provided once the audit has begun the Registered Entities will work with the Audit Team

Lead to determine the appropriate time frame to review the added

standardsrequirements However entities are expected to be compliant to all

standardsrequirements 100 of the time and therefore it is ReliabilityFirstrsquos expectation

that all material even those standardsrequirements from tier 2 and 3 that are added

during the course of the audit will be reviewed during the time of the scheduled audit

Acquiring additional evidence for few additional standardsrequirements in a timely

fashion is a reflection upon the rigor placed on compliance by entities Internal

Compliance Program (ICP)

Registered Entities must recognize that the audit scope for registered entities that are

registered to perform identical ldquofunctionsrdquo may vary and be slightly different even

amongst Registered Entities within ReliabilityFirst

Audit Scope

ReliabilityFirst will determine the Registered Entityrsquos specific audit scope based upon

the 2013 AML and assessments performed above As a matter of course all Registered

Entities subject to audit in 2013 shall be monitored to the standardsrequirements

identified in Tier 1 which may be adjusted based upon the risk assessment performed by

ReliabilityFirst Registered Entities will be advised of the audit scope when they receive

the formal audit notification package Compliance information and data archived by

ReliabilityFirst from the implementation of previous monitoring methods will be utilized

in the development of a Registered Entityrsquos audit scope including but not limited to

previous audits self-certifications demonstrated behavior during system events

exhibited culture of compliance and previous or current enforcement actions

ReliabilityFirst staff may change the scope and frequency of compliance audits based on

the results of the Risk Based Entity Profile Assessment At this time ReliabilityFirst

cannot reduce the scope of an audit without NERC consent

Implementation Plan Summary

Registered Entities must be in compliance with all Reliability Standards at all times

NERC and ReliabilityFirst encourage comprehensive self-assessments and self-reporting

of noncompliance by Registered Entities Registered Entities are further encouraged to

draft mitigation plans upon identification and self-reporting of possible violations prior to

the required submission timeline per the CMEP Mitigation plans are not an admission

of a violation and are treated as voluntary corrective action Mitigation plans duly

prepared and promptly submitted to the ReliabilityFirst will be used to demonstrate a

positive proactive culture of compliance in any potential enforcement action


17

The overall monitoring scope of the 2013 implementation program is based on Reliability

Standards that are anticipated to be in effect in 2013 or as of the date on which this plan

is approved To the extent new or revised Reliability Standards are adopted approved by

the regulatory authority or in effect during the course of 2013 ReliabilityFirst and NERC

will work with the other Regional Entities to determine whether the 2013 program needs

to be amended to include them

All NERC Reliability Standards identified in the 2013 implementation program are

included in the ReliabilityFirst 2013 Compliance Monitoring Schedule which is posted

on the ReliabilityFirst Web site at the following link

httpswwwrfirstorgcompliancePagesSchedulesaspx

The ReliabilityFirst 2013 Compliance Monitoring Schedule (CMS) is a list of standards

that includes several worksheets a description of each is provided below

STDs Monitored for Compliance Tab a quick reference listings of the Tier 1

Reliability Standards identified for compliance monitoring the monitoring

methods being used (ie audits data submittals self-certifications spot checks

etc) applicable functions the reporting period and applicable due dates

STDS not on 2013 AML Tab FERC approved standards that were not included

on the 2013 NERC AML As a reminder because these are FERC approved they

could be subject to review by ReliabilityFirst in 2013

Tier and VRF Rating Tab a list of standards that show the standards and the

tiers that they were placed in (ie Tier 1 2 and 3) for 2013 The standards are

accompanied by their respective Violation Risk Factors (VRF)

Revision History Tab provides the revision history that will allow

ReliabilityFirst Registered Entities to see all of the changes to the 2013

Compliance Monitoring Schedule spreadsheets

Reliability Standards Subject to 2013 CMEP Implementation

18

RReelliiaabbiilliittyy SSttaannddaarrddss SSuubbjjeecctt ttoo 22001133 CCMMEEPP

IImmpplleemmeennttaattiioonn

Given the considerations of the ERO-identified high-risk priorities which includes compliance

history and violation trend analysis the number of high priority Reliability Standards is 57 This

group of Reliability Standards was further reviewed to determine and rank the specific

Requirements of each standard that best represent the core purpose of that standard to ensure the

reliability of the BPS The further refined list of Requirements has been taken as the

ReliabilityFirst 2013 Compliance Monitoring Schedule (CMS) which at a minimum mirrors by

Standard the NERC 2013 AML

BAL ndash Resource and Demand Balancing

BAL-002-0 and BAL-003-01b have been identified as high priority Reliability Standards The

performance aspect of BAL-002 is reviewed quarterly through periodic data submittals but

recent winter weather events have shown that contingency reserve is a critical issue such that

special attention should be given here BAL-003-01b has been subject to spot checks in the

past but technical issues discovered through its enforcement have yet to be addressed Until

additional guidance is provided through interpretations revisions or otherwise the

Requirements of BAL-003 will be treated as Tier 2 Requirements

CIP ndash Critical Infrastructure Protection

CIP-001-2 CIP-002-3 CIP-003-3 CIP-004-3 CIP-005-3 CIP-006-3 CIP-007-3 CIP-008-3

and CIP-009-3 have been identified as high priority standards CIP-001 has an important role as

BPS personnel become aware of and properly report sabotage events Preparedness for

reporting as well as procedures to determine to whom reports should be issued is critical in

mitigating the occurrence of any such event CIP-002 through CIP-009 and FERC Order 706

cybersecurity Standards are fundamental to the reliability of the BPS in terms of security

Additionally the CIP Reliability Standards represent eight of the ten most violated Reliability

Standards most violated over the past year and seven of the Top 10 for all time indicating that

registered entities are having difficulty and confusion with CIP compliance issues Several

groups including NERC FERC and the Regional Entities have provided insight into the

various Requirements through guidelines and industry webinars in support of the CIP Standards

Selected requirements from these standards have been selected by the ERO and identified as high

priority standards CIP-002 through CIP-009 or 706 Reliability Standards are fundamental to the

reliability of the BPS in terms of cyber security The primary difference from this yearrsquos list is

that tier assignments have been reassigned so that each CIP requirement along with its sub-

requirements shares a single tier The anticipated effect of this change is to make it easier for a

registered entity to prepare for its audit

ReliabilityFirst has elected to add CIP-001-2a R1 to the tier 1 requirements for audit Based

upon an assessment of risk ReliabilityFirst believes this requirement in the standard is critical to

reliability of the BES This requirement builds the foundation of having an entityrsquos operating


19

personnel to have the knowledge and training to recognize sabotage events ReliabilityFirst will

audit this requirement in 2013

COM ndash Communications

COM-001-11 and COM-002-2 have been identified as high priority Reliability Standards

COM-001 details and mandates the adequacy of telecommunication facilities thus supporting

nearly every function and is critical to normal and emergency operations COM-002 has some

similar coverage as COM-001 but goes above and beyond with three-part communication and a

methodology for formulating directives Also COM-002 is the seventh-most-violated 693

standard in 2011

EOP ndash Emergency Preparedness and Operations

On July 1 2013 the introduction of EOP-001-2b EOP-005-2 EOP-006-2 and EOP-008-1

replacing previous standards will add five requirements to the AML for generator operator

(GOP) and four for the Reliability Coordinator (RC) while reducing the requirements of the

AML by two for TOP and three for BA The introduction of EOP-003-2 on October 1 2013

does not affect the AML as that standard is not tiered as discussed below

EOP-001-0 EOP-002-21 EOP-003-1 EOP-004-1 EOP-005-1 EOP-006-1 and EOP-008-0

have been identified as high priority reliability standards EOP-001 is critical in terms of Energy

Emergency Alerts (EEAs) which were important for mitigating impacts from winter weather

events taking place during early 2011 EOP-002 complements EOP-001 by assuring the

performance of mitigating actions for the both the RC and the BA EOP-003 designates load-

shedding as a suitable action for maintaining the reliability of the BPS but its action is implied in

EOP-001 and therefore the requirements of EOP-003 are not considered Tier 1 requirements

EOP-004 is critical in terms of EA and helping with the process of mitigating future events and

it is vital that the disturbance reports do not stay within a region but are shared with NERC for

dissemination across North America EOP-005 sets the foundation for system restoration if

actions identified in other EOP reliability standards fail and the testing and confirmation of a

blackstart capability process is engaged EOP-006 ensures that the RC takes the lead role in

system restoration initiated through EOP-005 such that coordination in these efforts is not an

oversight EOP-008 accounts for loss of a primary control center and many Requirements not

accounted for in any other standard so this is vital to include

FAC ndash Facilities Design Connections and Maintenance

The introduction of FAC-008-3 on January 1 2013 does not change the AML since all

associated requirements have been identified as Tier 2 or Tier 3 The introduction of FAC-013-2

on April 1 2013 also does not affect the AML as that standard is not tiered

FAC-001-0 FAC-002-0 FAC-003-1 FAC-008-1 and FAC-009-1 have been identified as high

priority Reliability Standards FAC-001 designates connections requirements for facilities

which is especially critical in terms of protection and construction of new facilities With these

facilities properly coordinated and accounted for existing system performance will improve

FAC-002 expands on FAC-001 by requiring that assessments for facilities be undertaken and


20

results coordinated FAC-003 concerns vegetation management which is a primary initiator of

many events and points to the necessity of an effective vegetation management program

FAC-008-3 is replacing Reliability Standards FAC-008-1 and FAC-009-1 which historically are

both considered heavily violated standards R6 and R7 of FAC-008-3 have been designated with

a Tier 1 priority level having the greatest potential risk and impact relationship to the reliability

of the BPS Due to the violation history of FAC-008-1 and FAC-009-1 and the tier designation

given to FAC-008-3 FAC-008-3 will be included in the 2013 Compliance Monitoring Schedule

for Self-Certification

IRO ndash Interconnection Reliability Operations and Coordination

The introduction of IRO-006-TRE-1 on October 1 2013 does not change the AML since this

regional standard is not tiered

IRO-002-2 IRO-004-2 IRO-005-3a and IRO-006-5 have been identified as high priority

Reliability Standards IRO-002 determines the sufficiency of tools needed for the RC to perform

its role in maintaining the reliability of the BPS which becomes increasingly imperative when

emergency situations arise and Balancing Authorities and Transmission Operators require

oversight IRO-004 covers the planning the Reliability Coordinators must perform and ensures

preparations are properly made for seen and unseen emergency events in the operation horizon

IRO-005 contains the only Tier 1 Requirement applicable to the PSE function It is expected that

the Regional Entities will ensure all PSEs are audited according to a six year interval cycle

including those PSEs which were removed from the 2011 audit schedule For audits of PSEs

Regional Entities will provide a complete audit report regardless of audit scope IRO-006

discusses the process of transmission load relief (TLR) and while this is an important topic

performance is covered in IRO-005 and therefore the Requirements of IRO-006 are not

considered Tier 1 Requirements

MOD ndash Modeling Data and Analysis

MOD-001-1a MOD-004-1 and MOD-008-1 have been identified as high priority Reliability

Standards These three Reliability Standards determine the procedure by which Available

Transmission Capability (ATC) is to be calculated by Transmission Service Providers The

proper setting of ATC is vital so facilities are not overloaded which could lead to possible

system emergencies FERC has mandated that this standard be audited following regulatory

approval of the Reliability Standard

NUC ndash Nuclear

NUC-001-2 has been identified as a high priority Reliability Standard The Nuclear Plant

Interface Requirements (NPIRs) in NPIR agreements are essential components of NUC-001-2

NERC strongly recommends that generation and transmission entities carefully review their

respective obligations under these agreements including coordinated communication to ensure

that parties share a clear and precise understanding of their obligations under these agreements


21

PER ndash Personnel Performance Training and Qualifications

The introduction of PER-005-1 on April 1 2013 will add four requirements (R13 R2 R21 and

R3) to the AML for functions BA RC and TOP However functions BA and TOP will have a

net reduction of four requirements due to the retirement of PER-002-0 PER-001-01 and PER-

002-0 have been identified as high priority reliability standards PER-001 speaks to the authority

of operating personnel to operate independently and in a reliable manner However this

authority is established in other reliability standards with more specific language based upon the

function considered and therefore the requirements of PER-001 are not considered Tier 1

Requirements PER-002 encompasses the development of training as well as the training itself

of all operating personnel responsible for ensuring reliability of the BPS Training especially in

preparedness and real time mitigation of emergency events is essential As such several of the

requirements supporting this training within PER-002 are considered to be Tier 1 Requirements

In anticipation of a number of the requirements of PER-005-1 regarding operator training

coming into effect April 1 2013 and retiring PER-002-0 in 2013 many of the requirements of

PER-005 are also considered to be high priority and are identified with Tier 1

PRC ndash Protection and Control

The introduction of PRC-006-2 on October 1 2013 also does not affect the AML as that standard

is not tiered

PRC-001-1 PRC-004-1 PRC-005-1 PRC-007-0 PRC-008-0 PRC-011-0 and PRC-023-1 have

been identified as high priority Reliability Standards PRC-001 promotes understanding of the

limitations and performance of protection systems which is especially important from an

operational standpoint such that protection systems are not overloaded and the system cannot be

controlled PRC-004 is a particularly important standard as it applies to misoperations analysis

and reporting As significant protection system misoperations are considered disturbance events

those misoperations for which BPS reliability is affected that are always addressed in PRC-004

are captured by EOP-004 R3 as well and therefore the Requirements of PRC-004 are not

considered Tier 1 Requirements Significant misoperations are those that result in such actions as

modifications to operating procedures or equipment and identification of lessons learned as

identified by Attachment 1 to EOP-004

PRC-005 is the most violated standard of all time and its mission to organize and implement

protection system maintenance is especially critical for ensuring system reliability PRC-007

and PRC-008 deal with underfrequency load-shedding (UFLS) while PRC-011-0 involves

undervoltage load-shedding (UVLS) Both UFLS and UVLS protection systems are important

but the level of compliance of a registered entity with PRC-005 will be most telling for

compliance with these Reliability Standards As a result the Requirements of PRC-007 PRC-

008 and PRC-011 are not considered Tier 1 Requirements PRC-023 as with all Reliability

Standards has the chief purpose of promoting reliability in the BPS and in this case it relates to

transmission relay protection settings The concerns surrounding these settings are that they are

proper for detecting and protecting against fault conditions As with UFLS and UVLS

maintenance programs the compliance performance of a registered entity with PRC-005 is a

good guide as to how well protection systems at that entity are maintained and tested which is

applicable to PRC-023 as an indicator of the due diligence of an entity in properly setting relays


22

and reviewing transmission system protection schemes Also significant misoperations resulting

from improper relay settings are addressed through EOP-004 which would allow for a complete

review of Requirements in PRC-023 in response to any such event For those reasons listed the

Requirements of PRC-023 are not considered Tier 1 Requirements

TOP ndash Transmission Operations

TOP-001-1 TOP-002-2a TOP-003-0 TOP-004-2 TOP-006-1 and TOP-008-1 have been

identified as high priority reliability standards TOP-001 sets down operation authority for the

TOP function and in so doing re-iterates language from the EOPs and IROs addressing this

same issue In an event where it can be demonstrated that an operator was not aware of his

authority to act this standard will be important for an entity to be audited on However as the

authority of system operators is generally well understood and therefore the Requirements of

TOP-001 are not considered Tier 1 Requirements TOP-002 deals with normal operations

planning and one of the key concepts to this standard is communications The outage

coordination that is discussed in TOP-003 is implied by TOP-002 in normal operations planning

and therefore the Requirements of TOP-003 are not considered Tier 1 Requirements TOP-004

addresses operating in an unknown state and points to insufficient or faulty equipment

processes planning etc and should be considered a high priority issue especially in terms of

preparedness for emergencies TOP-006 the monitoring of reliability parameters can be gauged

from compliance with TOP-008 which complements IRO-005 but this time for the TOP

function The Requirements of TOP-006 will not be considered Tier 1 Requirements while

TOP-008 will be

TPL ndash Transmission Planning

TPL-003-0a and TPL-004-0 have been identified as high priority reliability standards TPL -003

accounts for the loss of two or more BPS elements and TPL-004 addresses extreme events both

of which go hand-in-hand with minimizing the impact of emergency events affecting the BES

VAR ndash Voltage and Reactive

ReliabilityFirst has elected to add VAR-001-2 R4 and VAR-002-11b R2 and the R2 sub-

requirement tier 1 requirement for audit ReliabilityFirst believes these requirements in these

standards are critical to reliability of the BES These requirements establish and specify voltage

andor Reactive Power schedules require entities to maintain the voltage andor Reactive Power

schedules that have been established and or notify appropriate entities if the established

schedules cannot be maintained Based upon feedback from our audit teams ReliabilityFirst

continues to see entity difficulty in understanding and applying these requirements within our

region ReliabilityFirst will audit these in 2013

CMEP Discovery Methods

23

CCMMEEPP DDiissccoovveerryy MMeetthhooddss

I Compliance Audits

The Reliability Standards were selected for compliance audit are determined based on the

2013 NERC Implementation Plan Methodology ReliabilityFirst will provide to the

registered entity the scope of the compliance audit with the audit notification letter The

intervals for compliance audits is three years for entities registered as a Reliability

Coordinator Balancing Authority or Transmission Operator and is six years for entities

registered for all other functions13

Registered Entities may be audited more or less

frequently per the RoP -Appendix 4C audit cycle based upon the results of the risk and

performance based assessment as well as the facts and circumstances surrounding those

entities

ReliabilityFirst audit teams are authorized and obligated to expand the scope of a

compliance audit to include Tier 2 andor Tier 3 Requirements and any requirements they

may deem necessary based on the results of the Risk Based Entity Profile Assessment or

the audit teamrsquos collective professional judgment Audit scope expansion can occur at

any point during a monitoring process from the initial review of the Registered Entity

Profile Assessment through the close of the monitoring process

ReliabilityFirst has the authority to expand an audit but cannot reduce the scope without

NERCrsquos consent ReliabilityFirst shall consider past performance including historical

violation trends across the Region and those specific to the registered entity and changes

to compliance responsibility resulting from mergers acquisitions corporate re-

organizations open investigations and other factors that in the judgment of the

ReliabilityFirst audit staff should be considered as part of the normal planning required

for a compliance audit and consistent with generally accepted audit practices

The scope of the registered entitiesrsquo compliance audits will include a review of all open

mitigation plans remedial action directives and technical feasibility exceptions14

during

the pre-audit field-audit or post-audit phases as discussed in the CMEP ReliabilityFirst

must provide the compliance audit team with the status documentation and evidence for

all mitigation plans that are to be reviewed

Should an expanded scope be required based upon significant issues discovered during

the on-site portion of the audit process the audit team will have the discretion to address

and expand the scope as deemed appropriate in coordination with the registered entity

ReliabilityFirst may at its discretion expand the scope of process monitoring perform a

spot check or unscheduled audit or other monitoring process to follow-up the registered

entityrsquos compliance with the Reliability Standards andor Requirements in question

13

See Rules of Procedure Section 403111 at

httpwwwnerccomfilesNERC_Rules_of_Procedure_EFFECTIVE_20110412pdf 14

See Appendix 4C of the NERC RoP at Sections 3143 and 66

httpwwwnerccomfilesAppendix4C_Uniform_CMEP_20110101pdf


24

Registered entities will not be expected to provide evidence outside of the current audit

time period for compliance purposes unless that evidence is required in accordance with

the processes and procedures of the registered entity or it is required by the standard For

example a registered entity is expected to provide evidence outside of the current audit

period for substantiating long range plans that are longer than an audit period such as

Protection System maintenance and testing intervals For those reliability standards that

do not involve long-range plans an audit team will not be able to request information that

is outside of the bounds of the current audit either three or six years nor can it identify

possible non-compliance outside of this audit period In other words the completion of

an audit closes one audit period and initiates another excluding future audit teams from

reviewing a registered entityrsquos compliance during past audit periods This exclusion does

not apply to ERO enforcement investigations or events analysis Generally speaking

spot checks periodic data submittals and self-certifications will not require evidence that

proceeds the current audit period

Audit Focus or Scope

To maintain a focus on risk the audits scopes monitor the current relevant documentation

as of the date of the 90 day notification letter Auditors at their option can look back to

the beginning of the time period identified in the audit scope to determine extent of

violations The audit teams will have the flexibility to review historical information on

an as needed basis This approach will allow the audit team to focus on determining

current reliability risk and compliance of a registered entity In the event a finding of a

possible violation is determined based upon the current in-force documents the audit

team may review previous versions of the process and procedure documentation to

determine the full extent of the possible violation

In 2013 the audit period being the range of time for which a registered entity is audited

will be unique to each entity based upon several factors Depending upon a registered

entityrsquos particular situation the start date for the audit period may be one of several

possibilities

I the day after the prior audit review or

II the date when monitoring activity by the Compliance Enforcement Authority

ended or

III the later of June 18 2007 or the Registered Entityrsquos date of registration if the

Registered Entity has not previously been subject to a Compliance Audit

or

IV (For CIP Audits Only) for entities registered before April 2008 the date

established as the ldquoC-Compliantrdquo date in either Table 1 2 or 3 of the (Revised)

Implementation Plan for Cyber Security Standards CIP-002-1 through CIP-009-

115

as applicable to the registered entity based on its registered functions

For entities registered in April 2008 and thereafter the Implementation Plan for

Newly Identified Critical Cyber Assets and Newly Registered Entities16

defines the

15

httpwwwnerccomfilesGuidance_on_CIP_Standardspdf - 16

httpwwwnerccomdocsstandardssarImp-

Plan_Newly_Identified_CCA_RE_clean_last_approval_2009Nov19pdf


25

schedule for Compliance with the CIP Version 2 or Version 3 requirements for (a)

newly Registered Entities and (b) newly identified Critical Cyber Assets by an

existing Registered Entity after the Registered Entityrsquos applicable Compliant

milestone date has already passed

The end date for the period of time to be covered during compliance audits in 2013 will be

the end date for the compliance audits as outlined in the current CMEP Section 3142

CIP Reliability Standards Compliance Audits

Registered entities are subject to audits for compliance with all Requirements of CIP-

002-3 through CIP-009-3 which took effect October 1 2010 If there are indications of

possible non-compliance auditors are authorized and obligated to review an entityrsquos

compliance throughout the entire audit period per the criteria documented in the above

Audit Scope section which includes previous versions of CIP Reliability Standards in

order to determine the extent of possible violations

If a responsible entity has active Technical Feasibility Exceptions (TFEs) Section 8 of

NERC RoP - Appendix 4D17

Procedure for Requesting and Receiving TFEs to NERC

CIP Standards requires that

81 Following approval of a Responsible Entityrsquos TFE Request subsequent

Compliance Audits of the Responsible Entity conducted prior to the Expiration Date

shall include audit of (i) the Responsible Entityrsquos implementation and maintenance of

the compensating measures or mitigating measures or both specified in the approved

TFE in accordance with the time schedule set forth in the approved TFE and (ii) the

Responsible Entityrsquos implementation of steps and conduct of research and analyses

towards achieving Strict Compliance with the Applicable Requirement in accordance

with the time schedule set forth in the approved TFE These topics shall be included

in such Compliance Audits regardless of whether a Compliance Audit was otherwise

scheduled to include the CIP Standard that includes the Applicable Requirement

2013 Compliance Audit Schedule

The 2013 ERO compliance audit schedule which is a compilation of all regional

schedules will be posted on the Compliance Resource page on the NERC website18

This posted schedule is updated at least quarterly allowing the Registered Entities to

have access to the schedule for the upcoming year as soon as possible

The compliance audits listed on the schedule are labeled as on-site audits or off-site

audits This distinction is only relevant to the location of the audit activities not the rigor

of the audits Both on-site and off-site audits are compliance audits and are performed

using the same Reliability Standards Audit Worksheets (RSAW) and other audit tools

and processes The major difference is that on-site audits would entail physical access to

17

httpwwwnerccomfilesAppendix_4D_ProcedureRequestingAndReceivingTFEs_20120131pdf 18



26

the audited entityrsquos premises A large portion of the pre-audit work associated with an

on-site audit will actually occur off-site

Certain types of audits must contain an on-site component because of the nature or

functions of the Registered Entity For example Reliability Coordinator Balancing

Authority and Transmission Operator functions must be audited on-site For other BPS

users owners and operators on the NERC Compliance Registry the Regions and NERC

can use discretion on the location and the conduct of the audit In either case

ReliabilityFirst will plan the audit to assure proper scope and rigor

In 2012 and continuing in 2013 ReliabilityFirst has been auditing our registered entities

based upon their registered functions on their three (3) year and six (6) year cycles In

the past when ReliabilityFirst performed an audit the audit combined all the registered

functions into a single audit If an entity was registered as a Transmission Operator

(TOP) and Generation Owner (GO) where one function was to be audited on a three year

cycle and the second on a six year cycle that entityrsquos audit was conducted on both

functions every three years ReliabilityFirst will only cover the three year standards on a

three year cycle and those on the six year basis on a six year cycle

Regarding the audits of entities registered for the PSE function it is being proposed by

NERC that ReliabilityFirst ensure all PSEs are audited according to a six year cycle

including those PSEs which were removed from the 2011 audit schedule ReliabilityFirst

will work with NERC and execute a plan to address and fulfill the requirement for these

audits in 2013

All ReliabilityFirst Registered Entities scheduled for audit in 2013 are included in the

2013 CIP and Operations and Planning audit schedules which are posted on the

ReliabilityFirst Web site at the following link


Compliance Audit Reports

ReliabilityFirst is obligated to provide written audit reports for all compliance audits and

spot checks in accordance with NERC Compliance Process Directive 2010-CAG-001 -

Regional Entity Compliance Audit Report Processing19

NERC posts all public versions

of the ReliabilityFirst compliance audit reports of registered entities on the NERC

website to satisfy requirements of the CMEP ReliabilityFirst submits two audit reports

for each Operations amp Planning (OampP) compliance audit of a Registered Entity a public

report and a non-public report CIP compliance audits only submit a non-public report

due to the sensitive nature of the included information The Operations amp Planning

public report does not contain critical energy infrastructure information or any other

information deemed confidential The OampP public report does not include a description

of how the audit team determined its findings rather it includes a listing of the findings

The names of the ReliabilityFirst personnel and registered entity personnel participating

in the audit are excluded from the public report and all participants are identified by title

19

httpwwwnerccompagephpcid=3|22


27

In accordance with FERC expectations20

the non-public report shall document all areas

of concern related to situations that do not appear to involve a current or ongoing

violation of a Reliability Standard requirement but instead represent an area of concern

that could become a violation The non-public report contains confidential information

and detailed evidence that supports the audit findings The names and titles of all

ReliabilityFirst personnel and all registered entity personnel participating in the audit are

included in the non-public report

Public and non-public compliance audit reports that do not contain possible violations are

completed by ReliabilityFirst and are submitted to NERC at the same time Upon receipt

of the reports NERC posts the public reports on its website and submits the non-public

audit reports to the applicable regulatory authority

Public and non-public audit reports that contain possible violations are submitted to

NERC at different times The non-public compliance audit reports are completed by the

ReliabilityFirst as soon as practical after the last day of the audit and are then submitted

to NERC Upon receipt of the non-public reports NERC submits them to the Applicable

Governmental Authority The public reports that contain possible violations are

completed by redacting all confidential information in the non-public reports The

Regional Entities retain the public version of compliance audit reports that contains

possible violations until all violations are processed through the NERC CMEP Due

process is considered complete when all possible violations are dismissed or when a

violation is confirmed or a settlement is reached and a decision has been rendered if

applicable by the regulatory authority (eg Notice of Penalty (NOP) has been issued in

the United States) Upon completion of due process the Regional Entities submit the

public version of the compliance audit reports to the registered entities for review and

comment prior to submitting them to NERC Upon receipt of the public reports NERC

posts them on the NERC website21

Reliability Standard Auditor Worksheets (RSAW)

The RSAWs are designed to add clarity and consistency to the assessment of compliance

with Reliability Standards The RSAWs are used for multiple compliance monitoring

methods Comments on these and any of the EROrsquos auditor resources are welcome and

can be directed to the Audit Compliance Managers22

The RSAWs are posted on the NERC public website23

and provide information to the

industry about expectations of the ERO compliance auditors when evaluating compliance

with a Reliability Standard NERC works in close coordination with the Regional

Entities to ensure the information in existing RSAWs is updated with the latest regulatory

authority language and guidance and new RSAWs are developed as Reliability Standards

20

Compliance with Mandatory Reliability Standardscedil ldquoGuidance Order on Compliance Audits Conducted

by the Electric Reliability Organization and Regional Entitiesrdquo 126 FERC para 61038 (2009) at P13

httpwwwnerccomfilesGuidanceOrderOnComplianceAudits-01152009pdf 21

Public audit reports can be found at httpwwwnerccompagephpcid=3|26|246 22

Information concerning Regional Entity programs is available at

httpwwwnerccompagephpcid=3|23 23



28

are approved It is recommended that Regional Entities and registered entities check the

NERC website regularly to ensure the latest available versions of RSAWs are being used

The Registered Entity sections of the RSAWs that they are required to fill out must be

submitted by the date specified in the notification letters

Mitigation Plans

ReliabilityFirst encourages aggressive self-assessments and analysis and self-reporting of

noncompliance by registered entities Registered entities are further encouraged to draft

mitigation plans upon identification and self-reporting of possible violations prior to the

required submission timeline per the CMEP Mitigation plans are not an admission of a

violation and are treated as voluntary corrective action However mitigation plans duly

prepared and promptly submitted to ReliabilityFirst will be used to demonstrate a

positive proactive culture of compliance in any potential enforcement action Open

mitigation plans are also examined as part of the compliance audit process during the pre-

audit field-audit or post-audit phases as discussed in the CMEP and as agreed to

between ReliabilityFirst Compliance and Enforcement staff

II Self-Certification

All registered entities are required to participate in the annual self-certification each year

based upon the ReliabilityFirst CMS It is one of the discovery methods that monitor a

Registered Entityrsquos compliance with Reliability Standards especially those that have not

been included in audit scopes in recent years

ReliabilityFirst will continue in 2013 to have all of our Registered Entities self-certify to

all of the applicable Reliability Standards that NERC included in their 2013 Actively

Monitored List as outlined in the ReliabilityFirst Compliance Monitoring Schedule

All NERC Reliability Standards identified for self-certification in the 2013

implementation program are included in the ReliabilityFirst 2013 Compliance

Monitoring Schedule which is posted on the ReliabilityFirst Web site at the following

link httpswwwrfirstorgcompliancePagesSchedulesaspx

CIP-002-3 through CIP-009-3 Reliability Standards

Registered entities are also required to self-certify once per year as scheduled by

ReliabilityFirst to the suite of CIP standards It should also be understood that self-

certification may be expanded to include CIP supplemental questionnaires as directed by

NERC or an Applicable Governmental Authority

Some unique characteristics of the CIP Standards as they pertain to self-certification

include CIP-002-3 R4 requires all entities to annually approve their risk-based

assessment methodology the list of Critical Assets and the list of Critical Cyber Assets

even if such lists are null Thus all entities will need to submit self-certification for CIP-

002-3 even if they conclude they have no Critical Assets Similarly a registered entity

must self-certify to CIP-003-3 R2 even if they do not have any CCAs


29

The requirements for Self-Certification differ from the reporting requirements for

approved TFEs TFE reporting requirements for Responsible Entities are described in

Section 6 of NERC RoP - Appendix 4D Procedure for Requesting and Receiving TFEs

to NERC CIP Standards

III Spot Checks

Spot checks are compliance audits with a much narrower focus but are performed with

the same rigor as a compliance audit ldquoSpot Checkingrdquo means a process in which the

Compliance Enforcement Authority requests a Registered Entity to provide information

(1) to support the Registered Entityrsquos Self-Certification Self-Reporting or Periodic Data

Submittal and to assess whether the Registered Entity complies with Reliability

Standards or (2) as a random check or (3) in response to events as described in the

Reliability Standards or based on operating problems or system events

ReliabilityFirst has the authority to conduct spot checks of any regulatory approved

Reliability Standards ReliabilityFirst has the option to expand the list of Reliability

Standards and Requirements that NERC has designated for spot checks within the

Region ReliabilityFirst will at a minimum satisfy all the spot check requirements in the

NERC 2013 Implementation Plan and AML

Both Operations amp Planning and CIP spot checks will require the appropriate reports per

the RoP CMEP and NERC Compliance Process Directive 2010-CAG-001 - Regional

Entity Compliance Audit Report Processing24

The standard audit report template and

procedure provided in NERC Compliance Process Directive 2010-CAG-001 will be

used by ReliabilityFirst for all spot check reports

IV Periodic Data Submittals

Specific Reliability Standards and Requirements have been identified for periodic data

submittals The periodic data submittals for 2013 are as shown on the Requirements Tab

of the 2013 Actively Monitored Reliability Standards list ReliabilityFirst will distribute

specific guidance on each periodic data request it initiates

V Self-Reporting

Registered Entities are encouraged to self-report compliance violations with any

approved Reliability Standard Self-reports of compliance violations are provided to

ReliabilityFirst Registered Entities are encouraged to report violations of Reliability

Standards as soon as possible to minimize any ongoing risk to the BPS and ensure that

the entity receives any potential cooperation credit25

or self-reporting credit26

24


North American Electric Reliability Corporation ldquoOrder on Review of Notice of Penaltyrdquo 134 FERC para

61209 (2011) at P 13 httpwwwfercgovwhats-newcomm-meet2011031711E-3pdf


30

VI Exception-Reporting

Specific Reliability Standards and Requirements in the 2013 Actively Monitored

Reliability Standards list have been identified for exception reporting ReliabilityFirst

will distribute specific guidance and request our registered entities to self-certify by

exception to these standards

As noted in the NERC 2013 Implementation Plan in May of 2012 NERC filed proposed

revisions with FERC to Appendix 4C CMEP (and other ROP provisions) that would

remove exception reporting as one of the compliance monitoring methods As the filing

states ldquoException Reporting will no longer be considered one of the compliance

reporting processes as Exception Reports are triggered by Requirements of particular

reliability standards and not on the initiative of the CEArdquo It is important to note that

exception reporting will remain as a compliance monitoring method until these proposed

revisions are accepted by FERC

VII Complaint

All approved Reliability Standards or Requirements can be the subject of a complaint

regarding a compliance violation by a Registered Entity Complaints if validated can

initiate one of the other compliance monitoring methods in order to determine the full

extent of potential non-compliance

Registered Entities may submit to ReliabilityFirst a complaint in any form of media that

they desire Complaints may be made by an individual or anonymously Each complaint

will be reviewed and discussed with the entity that the allegation is made against A

determination will be made based upon these discussions whether an additional

compliance monitoring process will be implemented

NERC also maintains a Compliance Hotline that is administered by the Reliability Risk

Management (RRM) group Any person may submit a complaint to report a possible

violation of a Reliability Standard by calling 404-446-2575 sending an e-mail directly to

hotlinenercnet or completing the form at httpswwwnercnethotline Unless

specifically authorized by the complainant NERC and ReliabilityFirst staff will withhold

the name of the complainant in any communications with the violating entity

All information provided will be held as confidential in accordance with the NERC Rules

of Procedure NERC and or ReliabilityFirst will seek additional information regarding

the potential violation of Reliability Standards from the submitter and others as

appropriate A determination will be made based upon this information whether an

additional compliance monitoring process will be implemented

VIII Compliance Investigations

A Compliance Investigation may be initiated at any time by NERC or ReliabilityFirst in

response to a system disturbance Complaint or the possible violation of a Reliability

26

Guidance o Filing Reliability Notices of Penalty North American Electric Reliability Corporation

ldquoOrder on Review of Notice of Penaltyrdquo 124 FERC para 61015 (2008) at P 32

httpwwwfercgovEventCalendarFiles20080703131349-AD08-10-000pdf


31

Standard identified by any other means Compliance Investigations are confidential

unless FERC directs otherwise and are generally led by ReliabilityFirst staff

The Compliance Enforcement Authority reviews information to determine compliance

with the Reliability Standards The Compliance Enforcement Authority may request

additional data andor information as necessary through formal Requests for Information

site visits sworn statements etc to perform its assessment

Key CMEP Activities and Initiatives

32

KKeeyy CCMMEEPP AAccttiivviittiieess aanndd IInniittiiaattiivveess ReliabilityFirst NERC and the Regional Entities receive CMEP implementation

feedback from the Members Representative Committee (MRC) Compliance and

Certification Committee (CCC) and other stakeholders through the use of audited entity

feedback forms All feedback and input from these groups among others are reviewed

on a continual basis for opportunities for improvement ReliabilityFirst NERC and the

Regional Entities are committed to continuous improvement of the CMEP

implementation

CMEP Transparency Elements

NERC ReliabilityFirst and the Regional Entities continuously balance the request from

the industry to improve transparency with the confidential nature of the CMEP processes

Figure 1 is a pictorial view of the compliance process and it shows how most of the

processes in the CMEP fall under a window of confidentiality NERC ReliabilityFirst

and the Regional Entities are continuously identifying and implementing innovative ways

to share CMEP process information while honoring confidentiality Additional initiatives

are underway to increase transparency of CMEP elements in 2013 They are discussed

later in this Chapter

Figure 1 Compliance Process

ReliabilityFirst works with NERC Compliance Operations to continue to review and

publicly post CMEP implementation and process information in the form of public

notices27

in order to increase transparency of the CMEP application to registered entities

27

Public notices are available at httpwwwnerccompagephpcid=3|22

Region notifies NERC (amp entity) of alleged violation within 2-5 days ndash NERC notifies govrsquot authority

Region continues review and evaluation

CONF I DEN T I A

L

Dismissed Notice of alleged violation amp proposed penalty sent to responsible entity

Entity accepts violation ndash submits Mitigation Plan Entity Contests

Notice of confirmed violation sent to NERC amp responsible entity

Mitigation Plan Region Review

NERC Review

Govrsquot Review

NERC BOTCC reviews amp approves regionrsquos proposed penalty

Notice of penalty or settlement sent to FERC in US amp posted to NERC website (Processes differ in Canada)

5 DAY WAITING PERIOD

Settlement negotiations

Settlement Reached Regional Hearing

Appeals Process Settlement Approved

by BOTCC

Compliance Violation

Investigation

Self-Report

Audits Spot Check

Exception Self-

certification Periodic Reports


33

Outreach Efforts and Compliance Communications

ReliabilityFirst continues to reach out to its Registered Entities to further enhance the

communication between the region and our Registered Entities Below are several

methods that are used to communicate with the Registered Entities

Monthly Newsletter

The ReliabilityFirst Newsletter provides entities with news and information relating to

reliability activities

Monthly Compliance Update Letter

The ReliabilityFirst Monthly Compliance Update Letter provides the Registered Entities

with any changes made to the Compliance Monitoring Schedule and the notification due

dates of submittals necessary to satisfy compliance for monitoring activities of all of the

Reliability Standards

ReliabilityFirst website

The ReliabilityFirst website provides compliance and technical materials needed to

support compliance program implementation

WorkshopsSeminarsWebinars

ReliabilityFirst Compliance workshopsseminars or webinars which will include NERC

and FERC related initiatives will be scheduled to assist the Registered Entities in the

understanding of their responsibilities to satisfy compliance to all Reliability Standards

throughout the year

Compliance Data Management System (CDMS)

ReliabilityFirst allows our Registered Entities to report compliance via an internet based

application The home page provides informational announcements updates and news

worthy items of interest to the Registered Entities

Periodic Reports

ReliabilityFirst will provide Periodic Reports to its Registered Entities of its performance

compliance activities and as well areas of compliance that the Registered Entities

continue to struggle with These reports will be posted on the ReliabilityFirst website

Open Compliance Calls

ReliabilityFirst has implemented and is facilitating a conference call currently on a

monthly basis which is an open forum for our Registered Entities to call and voice

concerns ask questions and to be informed about upcoming compliance items


34

Assist Visits

ReliabilityFirst has implemented a program whereby an entity may request a one on one

or a small group meeting where guidance on compliance related activities can be

provided These Assist Visits can be in the form of a conference call web meeting or

on-site visit Topics can range from helping an entity become more familiar with

compliance related material and activities too special guidance and education when either

the Registered Entity or ReliabilityFirst believes the entity needs special attention or

additional help

Compliance Communication

The NERC Compliance Operations Program and ReliabilityFirst are working toward

common goals related to improving consistency increasing transparency and creating

more efficiency in compliance processes Past field experience is an important part of

meeting the goal to provide clarity on particular items and state the proper expectations

ReliabilityFirst and NERC provide transparency information in various formats

depending on the scope of the matter and relevance to the particular functions within the

BPS These include the following as well as other means as NERC and ReliabilityFirst

deem necessary

CANs ndash Compliance Application Notices28

The CANs focus on current and future auditable compliance applications

CANs provide continued compliance and enforcement guidance as a

means to facilitate information to industry while Reliability Standards are

revised and improved as discussed in FERC Order No 693 and 706

CARs ndash Compliance Analysis Reports29

CARS are a historical look at compliance trends for individual Reliability

Standards and will include addendums when the information is updated

Case Notes30

Case Notes provide examples of mitigation plans for recent possible

violations that have been accepted and in most cases complete Case notes

do not identify the Registered Entity

Bulletins31

Bulletins provide general information or clarification on current and future

issues

Lessons Learned32

Lessons Learned may result from an event analysis or other compliance or

engineering related activity They provide examples of how a problem

occurred and was identified and the corrective action taken

28

httpwwwnerccompagephpcid=3|22|354 29






35

Annual CMEP Reports33

Annual CMEP Reports are assessments of the previous yearrsquos CMEP and

are used in the planning and development of future yearsrsquo annual CMEP

Implementation Plans

Training and Self Improvement Activities

Compliance Auditors

The NERC compliance auditor training is based in part on generally accepted auditing

practices found in documents such as the Government Accounting Office (GAO)

Generally Accepted Government Auditing Standards (GAGAS) and is revised as

necessary Continuing education will provide training on specific auditing issues to

promote consistency and increased reliability

In 2013 NERC Compliance Operations will continue to improve processes and practices

which includes broader implementation of the Compliance Enforcement Initiative

Effective training is an important part of delivering consistency across NERC and the

Regions

In addition NERC sponsors seminars on specific matters as a way to provide continuous

education to ERO staff Two such seminars took place in 2012 and two are scheduled

for 2013

Specialized training for CIP auditors will continue in 2013 to address technical issues

unique to the CIP Standards environment and increase the skills of CIP auditor staff CIP

Standards Training will be conducted in 2013 ReliabilityFirst CIP audit staff has

attended at least one of those sessions during 2012 and will attend at least one in 2013

NERC encourages the CIP audit staff to have requisite experience training and

credentials in cyber security and IT auditing

Compliance Investigation (CI) Staff

A ldquoFundamentals of CIrdquo courseseminar has been conducted for NERC and Regional

Entity staff by NERC over the last two years The training is scheduled to be conducted

twice annually and is revised as necessary ReliabilityFirst staff will participate in this

training as required

Compliance Reviews of Events and Disturbances

Through the events analysis process the ERO strives to develop a culture of reliability

excellence that promotes aggressive critical self-review and analysis of operations

planning and critical infrastructure protection performance This self-critical focus is

ongoing and registered entities are linked together by their individual and collective

33



36

performances Focusing on critical self-review and analysis is the basis of understanding

the root cause of events and in turn avoiding similar or repeated events by the timely

identification and correction of their causes and by sharing lessons learned As an

important component of the EROrsquos risk-based approach to compliance monitoring

compliance assessments conducted after events and disturbances further enhances the

overall strength of the ERO and the industry Both Registered Entities and

ReliabilityFirst have responsibilities in this area to facilitate continued learning and

demonstration of accountability to overall Bulk Power System (BPS)

Registered Entity Responsibilities

To support a strong culture of compliance registered entities are encouraged to perform a

compliance assessment in response to all system events and disturbances Registered

Entities conducting compliance assessments are encouraged to provide a compliance

assessment report to ReliabilityFirst for system events that fall in category 2 and above as

outlined in the ERO events analysis process document The Compliance Assessment

Template as found in Appendix 2 should be used when performing these assessments

Registered Entities that utilize compliance assessments to self-identify and address

possible reliability issues demonstrate their effectiveness of their internal controls and

their commitment to their culture of compliance Registered Entities that are able to

demonstrate strong internal controls and a robust culture of compliance that mitigate risk

may be afforded some recognition in consideration of reduced levels and frequency of

compliance monitoring activities At a minimum the entity is typically given credit for

these actions in the enforcement of a self-reported possible violation(s) and non-

compliance issue(s) Deference will be provided the Registered Entity for comprehensive

compliance assessments that clearly demonstrate a review of applicable standards and as

appropriate self-reporting

Regional Entity Responsibilities

ReliabilityFirst will review all system event reports and all compliance assessment

reports provided by registered entities and may utilize a risk based approach to

prioritizing these reviews The scope and depth of compliance review and the manner in

which the Regional Entities and NERC evaluate respond and process these reviews is

intended to reflect the significance of the event and the thoroughness of the compliance

assessment performed by the registered entity Compliance reviews are an area that

may also produce lessons learned to be shared at compliance workshops or compliance

newsletters to facilitate improvement in industry compliance programs These

compliance lessons learned and the results of these reviews will be shared with NERC

In the case that a registered entity does not provide a compliance assessment or if

ReliabilityFirst determines the assessment was insufficient ReliabilityFirst may perform

an independent compliance assessment ReliabilityFirst may also request additional

information from the registered entity These compliance assessments can impact future

compliance monitoring activity


37

Registration and Certification

The purpose of the Organization Registration Program is to clearly identify those entities

that are responsible for compliance with the regulatory approved Reliability Standards

and is described in the NERC Rules of Procedure Appendix 5A Organization

Registration and Certification Manual As described in the NERC Statement of

Compliance Registry Criteria NERC will include in its compliance registry each entity

that the ERO concludes can materially impact the reliability of the BPS ReliabilityFirst

and NERC are obligated to identify all organizations to be listed in the NERC compliance

registry Identifying these organizations is necessary and prudent for the purpose of

determining resource needs both at the NERC and ReliabilityFirst level and to begin the

process of communication with these entities regarding their potential responsibilities and

obligations

Multi-Regional Registered Entities (MRRE)

There are several activities related to registration compliance monitoring and

enforcement involving registered entities that are registered and operate andor conduct

business in multiple regions The purpose of the MRRE process is to describe the

coordinated CMEP processes that will be used by NERC and the Regional Entities for a

subset of registered entities that are registered in multiple regions on a voluntary basis

The MRRE process allows these entities the ability to request to be accountable to one

Compliance Enforcement Authority (CEA) This coordinated process provides for

increased efficiencies in compliance resource allocation for NERC the Regional Entities

and the Registered Entities while maintaining the reliability of the BPS

Until the MRRE gets approved and put in place ReliabilityFirst will continue to

participate on Joint Audits for the PSE functions and those entities previously agreed

upon with other regions This effort helps to reduce the resources required to meet the

regional schedules and is intended to reduce some of the burden of those Registered

Entities across multiple Regions

Joint Registration Organization and Coordinated Functional Registration

Joint Registration Organization (JRO)34

In addition to registering as the entity

responsible for all functions that it performs itself an entity may register as a JRO on

behalf of one or more of its members or related entities for one or more functions for

which such members or related entities would otherwise be required to register and

thereby accept on behalf of such members or related entities all compliance responsibility

for that function or those functions including all reporting requirements

Coordinated Functional Registration (CFR)35

In addition to registering as an entity

responsible for all functions that it performs itself multiple entities may each register

using a CFR for one or more reliability standard andor for one or more

34

Section 507 of the NERC RoP



httpwwwnerccomfilesNERC_Rules_of_Procedure_EFFECTIVE_20110412pdf


38

requirementssub-requirements within particular reliability standards applicable to a

specific function The CFR submission must include a written agreement that governs

itself and clearly specifies the entitiesrsquo respective compliance responsibilities The

registration of the CFR is the complete registration for each entity Additionally each

entity shall take full compliance responsibility for those Reliability Standards andor

requirementssub-requirements it has registered for in the CFR Due to abrupt or forced

registration changes as described below this form of registration may become more

common in 2013

Results of Abrupt or Forced Registration Changes

NERC and ReliabilityFirst will continue to work together in the development of

appropriate actions to efficiently manage the compliance issues resulting from abrupt and

forced registration changes

Enforcement Initiatives

In 2013 ReliabilityFirst NERC and the other Regional Entitiesrsquo will continue to

develop enhancements to enforcement processing to achieve efficient and timely

compliance outcomes including streamlined procedures for lesser risk violations and

improved workflow and tools This will result in an increased focus of compliance

enforcement resources on the cases that have the most significant impact on the reliability

of the BPS Compliance Enforcement staff has realized significant efficiencies and

expects to gain efficiencies through better utilization of existing resources in the future

In September 2011 NERC made its initial Compliance Enforcement Initiative (CEI)

filing with the Federal Energy Regulatory Commission (FERC) that introduced the

streamlined spreadsheet Notice of Penalty (NOP) and the FFT approaches The CEI has

received significant support from the Regional Entities and industry On March 15 2012

FERC approved the FFT approach with certain proscribed conditions NERC anticipates

the FFT process will enable better alignment and substantially greater resources and

attention to be devoted to matters that pose a more serious risk to the reliability of the

BPS ReliabilityFirst NERC and the other Regional Entities will continue to work

collaboratively to continue to implement and improve the CEI

Further Implementation of the CEI

As the FFT implementation matures auditors will be able to recommend FFT treatment

for certain audit findings but ultimately the decision to afford FFT treatment to a specific

issue resides with the ReliabilityFirst enforcement staff NERC will provide a series of

webinars and workshops to guide compliance and enforcement staff at all levels on the

application of FFT to possible violations

ERO Guidance on COM-002-2 ndash Communication and Coordination

Compliance monitoring for COM-002 will be based on the NERC BOT approved

interpretation effective as approved by the BOT on February 9 2012 Background and

further information is provided below


39

In December of 2011 a recirculation ballot was approved by the ballot pool regarding an

interpretation36

to COM-002-2 regarding the use and associated circumstances of three-

part communication for directives Specifically the interpretation states that

COM-002-2 R2 does not specify the conditions under which a directive is issued

nor does it define directive It only provides that the requirements be followed

when a directive is issued to address a real-time emergency Routine operating

instructions during normal operations would not require the communications

protocols for repeat backs as specified in R2

Following the recirculation ballot this interpretation was presented and subsequently

approved by the NERC Board of Trustees (BOT) in February 2012 This interpretation

has designated that COM-002-237

R2 is applicable to the use of directives in addressing

real-time emergencies and with BOT approval now represents NERC guidance on the

use of directives

To ensure consistency throughout the ERO for COM-002-2 NERC Compliance

Operations is utilizing a strategy based upon the following four components

1) NERC staff will develop an enhanced COM-002 RSAW that provides the

appropriate compliance guidance and relates industry best practices

2) NERC and the Regional Entity staffs will work with the NERC Operating

Committee (OC) and Standards Committee (SC) to develop and provide guidance

regarding good utility practice on the use of three-part communication for real-

time operations

3) NERC staff was assigned and will work with the NERC SC to expedite the

completion and FERC approval of Standards Project 2007-02 ― Operating

Personnel Communications Protocols ― COM-00338

that addresses real-time

communication protocols

Approved Standards Which Reference Unapproved Standards

There are several approved reliability standards that reference or rely on not yet approved

reliability standards

In Order No 693 the Commission determined it could neither approve nor remand

certain proposed reliability standards based on information provided

The ERO only enforces those standards that have been approved by FERC In Order No

693 the Commission did state however that the ERO has the authority to obtain

36

See Standards Project 2009-22 - Interpretation of COM-002-2 mdash Communications and Coordination R2

for the ISORTO Council at

httpwwwnerccomfilezstandardsProject2009-22_RFI_COM-002-2_R2_IRChtml 37

See the BOT approved revision to the COM-002-2 that includes the interpretation at

httpwwwnerccomfilesCOM-002-2apdf 38

See Standards Project 2007-02 ― Operating Personnel Communications Protocols ― COM-003 at

httpwwwnerccomfilezstandardsOp_Comm_Protocol_Project_2007-02html


40

necessary information through the Commissionrsquos regulations In addition the

Commission stated that

ldquoThe fact that a Reliability Standard simply references another pending Reliability

Standard one that is not being approved or remanded here does not alone justify not

approving the former Reliability Standardrdquo 39

Examples of these standards follow

Fill-in-the-blank standard Referenced in

MOD-011-0 filed 4406 awaiting

FERC action

MOD-010-0 R1 and R2 effective 61807


FERC action


PRC-002-1 filed 82806 awaiting

FERC action

PRC-018-1 R1 R2 R3 R4 and

(indirectly)R5 effective 61807

39 Mandatory Reliability Standards for the Bulk-Power System 72 FR 16416 (Apr 4 2007) FERC Stats amp

Regs para 31242 (2007) (Order No 693) P 300

Regional Entities CMEP Implementation Plans

41

RReelliiaabbiilliittyyFFiirrsstt CCMMEEPP IImmpplleemmeennttaattiioonn PPllaann The ReliabilityFirst 2013 CMEP Implementation Plan is an annual plan submitted to

NERC each year for their review approval and is done in accordance with NERC RoP

Section 4016 The NERC CMEP Implementation Plan identifies at a minimum that

each Regional Entity plan must address The ReliabilityFirst CMEP implementation

Plan identifies

1 All Reliability Standards identified by NERC in the 2013 CMEP Actively

Monitored Reliability Standards list The ReliabilityFirst2013 CMEP

Implementation Plan mirrors at a minimum by Standard the AML found

in the NERC 2013 Implementation Plan

2 Other Reliability Standards proposed for monitoring by ReliabilityFirst

these will include any regional Reliability Standards and additional NERC


3 The methods to be used for reporting monitoring evaluation and

assessment of performance criteria with each Reliability Standard

ReliabilityFirst will at a minimum perform the compliance monitoring

methods identified in the NERC 2013 Actively Monitored Reliability

Standards list When ReliabilityFirst determines that an increased audit

scope is necessary ReliabilityFirst shall notify the registered entity of the

increased audit scope This notification shall be part of the audit

notification package and shall include the Reliability Standards and

Requirements that are included in the increased scope as well as the

justification for the increased scope When ReliabilityFirst determines that

an increased audit scope is necessary after the notification package is sent

or while the audit is ongoing then ReliabilityFirst shall notify the

registered entity of the increased audit scope as soon as possible For

references to NERC guidance or Implementation Plans such as the CIP

Guidance links from the NERC are included in the ReliabilityFirst

Implementation Plan where applicable and instead of including the entire

document

4 The ReliabilityFirst Annual Implementation Plan should include a list of

registered entity names that are on the 2013 schedule NERC Compliance

Registration ID and the year they will be audited

5 The Regional Entityrsquos Annual Plan should address Key CMEP Activities

and Initiatives

Conclusion

42

CCoonncclluussiioonn The ERO CMEP Implementation Plan which is developed according to Section 215(c)

of the Federal Power Act is the operating plan for annual compliance monitoring and

enforcement activities NERC as the international ERO and ReliabilityFirst and the

other Regional Entities through their delegation agreements with NERC monitor and

enforce compliance of registered entities with all regulatory approved Reliability

Standards Registered entities include all BPS owners operators and users

While the actions of the ERO in accordance with the CMEP are critical to the reliability

of the BPS it is only one part of an overall plan to ensure system reliability The other

part consists of the actions of the registered entities and the electric power industry at

large and these are equally as critical to system reliability The registered entities must

participate in the educational informational and developmental efforts that are being

undertaken not only to maintain reliability but to enhance it as well The sharing of the

industryrsquos technical expertise experience and judgment as well as its participation in the

EROrsquos processes will help to further identify and remove reliability gaps and

shortcomings The ERO continuously seeks to improve the execution of its role in

ensuring system reliability as is the case with the advancements of the annual CMEP

Implementation Plan undertaken for 2013 but the industry must continue to participate

for the overall reliability plan to be successful

Revision History

43

DDooccuummeenntt CChhaannggee RReevviissiioonn HHiissttoorryy

Version Reason for Change Approved by Revision Date

0 2013 ReliabilityFirst CMEP Implementation Plan James A Uhrin January 1 2013

01 Remove all reference to the Entity Impact Evaluations

(EIE) until the process is beter defined and matures James A Uhrin January 1 2013

Appendix 1 ndash Standards and Requirements Implicated by the 2011 Southwest Blackout

44

AAppppeennddiixx 11 ndashndash SSttaannddaarrddss aanndd RReeqquuiirreemmeennttss

IImmpplliiccaatteedd SSyysstteemm EEvveennttss

NERC staff will continue to monitor recent events such as the southwest cold weather

event and the southwest blackout and the progress of the FFT compliance enforcement

initiative As a result of the recently released Southwest Blackout40

report by FERC and

NERC Regional Entities are encouraged to consider critical standards that include

aspects of situational awareness in their audit and self-certification programs for 2013

Situational Awareness

EOP-006-1 mdash Reliability Coordination mdash System Restoration

EOP-008-1 mdash Loss of Control Center Functionality

IRO-002-2 mdash Reliability Coordination mdash Facilities

IRO-005-3a mdash Reliability Coordination mdash Current Day Operations


IRO-006-EAST-1 mdash TLR Procedure for the Eastern Interconnection

MOD-001-1a mdash Available Transmission System Capability

TOP-002-2b mdash Normal Operations Planning


Regional Entities should also consider these other implicated standards by requirement

in scoping compliance monitoring activities for RCs BAs and TOPs This list is subject

to change as further data and analysis become available

40 httpwwwnerccomfileUploadsFileNewsPR_AZOutage01MAY12pdf

Standard Requirement Tier

COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1

FAC-011-2 R2 Not Tiered



IRO-002-2 R6 3

IRO-003-2 R2 Not Tiered

IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1

MOD-012-0 R1 Not Tiered

PER-004-2 R2 Not Tiered

PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1

PRC-009-0 R1 Not Tiered



PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3

TOP-006-2 R1 Not Tiered




TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2

Appendix 2 ndash Compliance Assessment Template

46

AAppppeennddiixx 22 ndashndash CCoommpplliiaannccee AAsssseessssmmeenntt TTeemmppllaattee

Events Analysis Process Compliance Assessment Template

The registered entity is encouraged to perform an initial compliance self-assessment

concurrent with the registered entityrsquos event review

A systematic and methodical compliance assessment (CA) process that would include the

following steps

1 Refer to the causes and contributing factors of the event as determined by the

registered entityrsquos events analysis process

2 Identify any applicable NERC Reliability Standard(s) requirement(s) that may

have been implicated by the causes and contributing factors of the event

3 After reviewing the facts and circumstances of the event develop conclusions

that are relevant to step 2 above as they apply to the applicable NERC

Reliability Standards requirements

4 On request by the Regional Entity or on its own accord the Registered Entity

will provide a copy of its CA report to the Regional Entity The report should

reference the separate events analysis report provided to ReliabilityFirst

5 Self-report any findings of non-compliance to the Regional Entity per the

CMEP procedures

Sample Template for Compliance Assessment Summary

Event causes or

contributing

factors

Applicable NERC


Details of Compliance

Assessment Effort Findings

Cause AAA-000-0 Requirement 1 Identify the process used

to assess compliance

with this requirement

Identify any evidence

that demonstrates

compliance


that suggests non-

compliance

Findings of possible

violations should be

identified

If there are no findings

of non-compliance that

should be noted

AAA-000-0 Requirement 2

Contributing factor BBB-000-0 Requirement 1

Category 1a Example Event causes or

contributing

factors

Applicable NERC Reliability

Standards


Assessment Effort

Findings

Equipment failure of

a high side

transformerndash cleared

TOP-002-2a

R6 Each BA and TOP shall plan to

meet unscheduled changes in system

Established transfer limits

were followed such that the

event did not result in

No findings of non-

compliance


47

along with two

transmission lines

configuration and generation

dispatch (at a minimum N-1

Contingency planning) in accordance

with NERC Regional Reliability

Organization sub-regional and local

reliability requirements

instability The limit for

operating across this internal

interface is established in the

RC

ldquoXYZ Interface All Lines In

Stability Guiderdquo (document

provided)


a high side


along with two

transmission lines

TOP-002-2a

R10 Each Balancing Authority and

Transmission Operator shall plan to

meet all System Operating Limits

(SOLs) and Interconnection

Reliability Operating Limits

(IROLs)

No SOLs were violated

There are no IROLs

associated with the loss of

equipment in this event See

the specific guide referenced

in the response to TOP-002-

2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2

R1 Each TOP shall operate within

the IROLs and SOLs

R2 Each TOP shall operate so that

instability uncontrolled separation

or cascading outages will not occur

as a result of the most severe single

contingency

The system was operated to

remain within transfer limits

across the ldquoXYZrdquo internal

interface established as a

result of stability studies as

delineated in the

Transmission Operating

Guide developed by RC See



2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001

R1 Each TOP BA and GOP shall be

familiar with the purpose and

limitations of protection system

schemes applied in its area

Both the RC and the TOPs

are trained on the


Guides as well as relaying

and SPSs on the BPS

Protection operated correctly

and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004

R1 The TOP and any Distribution

Provider that owns a transmission

Protection System shall each analyze

its transmission Protection System

Misoperations and shall develop and

implement a Corrective Action Plan

to avoid future Misoperations of a

similar nature according to the

Regional Entityrsquos procedures

System Protection engineers

evaluated the relay

operations and determined

that all relaying operated

correctly and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008

R1 The TOP experiencing or

contributing to an IROL or SOL

violation shall take immediate steps

to relieve the condition which may

include shedding firm load

R2 Each Transmission Operator

shall operate to prevent the

likelihood that a disturbance action

or inaction will result in an IROL or

SOL violation in its area or another

area of the Interconnection In

instances where there is a difference

in derived operating limits the TOP

R1 Operators used their

EMS-based tools to ensure

that there were no

SOLIROL violations

R2 by following the TOP

Guides developed by RC

violations do not occur

R3 no conditions occurred

that required disconnection



that there were no

SOLIROL violations

No findings of non-

compliance


48

shall always operate the BPS to the

most limiting parameter

R3 The TOP shall disconnect the

affected facility if the overload on a

transmission facility or abnormal

voltage or reactive condition persists

and equipment is endangered In

doing so the TOP shall notify its RC

and all neighboring TOPs impacted

by the disconnection prior to

switching if time permits otherwise

immediately thereafter

R4 The TOP shall have sufficient

information and analysis tools to

determine the cause(s) of SOL

violations This analysis shall be

conducted in all operating

timeframes The TOP shall use the

results of these analyses to

immediately mitigate the SOL

violation


a high side


along with two

transmission lines

TOP-006

R2 Each RC TOP and BA shall

monitor applicable transmission line

status real and reactive power flows

voltage load-tap-changer settings

and status of rotating and static

reactive resources

R5 Each RC TOP and BA shall use

monitoring equipment to bring to the

attention of operating personnel

important deviations in operating

conditions and to indicate if

appropriate the need for corrective

action

The EMSs at both the RC

and the TOP provide

operators with the

information needed to

evaluate system conditions

and notify operators when

conditions are off normal

EMS system visibility and

communications were not

lost during this event

No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-

assessment will result

in either a statement of

ldquoNo Findingsrdquo or that

of ldquoPossible Violation

(PV)rdquo

Should the latter be the

result the entity will be

given the opportunity to

self-report the PV to the

Regional Compliance

Enforcement

department in

accordance with the

existing procedures set

forth in the CMEP In

doing so the entity self-

reporting should inform

the Regional

Compliance

Enforcement

department that this has

been done consistent

with the event analysis

process and the

completion of a

compliance self-

assessment to obtain the

credit prescribed

Appendix 3 ndash 2013 Regional Entity Request to Defer or Reduce the Scope of a Compliance Audit

50

AAppppeennddiixx 33 ndashndash 22001133 RReeggiioonnaall EEnnttiittyy RReeqquueesstt ttoo

DDeeffeerr oorr RReedduuccee tthhee SSccooppee ooff aa CCoommpplliiaannccee

AAuuddiitt

Request to Reduce Scope or Deferment of a Compliance Audit41 This form should be submitted as both a Word and PDF file to NERC Compliance Operations at least 90 days prior to the audit for approval Email forms along with an entity risk assessment to JimHughesnercnet and ChariseWilsonnercnet

Requesting Regional Entity Information

Date

Name

Title

Region

State the basis for

Reduced Audit Scope or

Deferment of

Compliance Audit

State other methods used

for compliance

monitoring during period

of reduced scope or

deferment

State requested duration

of deferment if

applicable

State whether this is a

MRRE audit

Applicable Region(s) FRCC MRO NPCC RFC

SERC SPP RE TRE WECC

Registered Entity Information

Registered Entityrsquos Legal

Name

NCR ID Number

Date of Last Compliance

Audit

Date of Next

Compliance Audit

41 Audit periodicity for entities registered as BAs RCs and TOPs must be every three years and cannot be

reduced per section 403111 of the NERC Rules of Procedure at



51

Regional Entityrsquos Additional Information

Comments

Regional Entity Authorized Signature

ERO Analysis Results

State

information

reviewed and

basis for

determination

ERO Final Determination

Approved Declined

ERO Director of Compliance Operations

Table of Contents

2

TTaabbllee ooff CCoonntteennttss

ReliabilityFirst Compliance Monitoring and Enforcement Program 5

Introduction 7

2013 Executive Summary 9

ReliabilityFirst Compliance Monitoring and Enforcement Organization 11

Risk-Based Compliance Monitoring Approach 12

2013 Implementation Plan Development Methodology 13

ERO High-Risk Priorities 13

Southwest Blackout Report 13

FERC Order and Guidance 14

Violation Trend History 14

Input from Staff 14

Future Considerations 14

Three-Tiered Approach to Requirements Specification 14

Three-Tiered Approach to Audit Scope Determination 15

Audit Scope 16

Implementation Plan Summary 16

Reliability Standards Subject to 2013 CMEP Implementation 18

BAL ndash Resource and Demand Balancing 18

CIP ndash Critical Infrastructure Protection 18

COM ndash Communications 19

EOP ndash Emergency Preparedness and Operations 19

FAC ndash Facilities Design Connections and Maintenance 19

IRO ndash Interconnection Reliability Operations and Coordination 20

MOD ndash Modeling Data and Analysis 20

NUC ndash Nuclear 20

PER ndash Personnel Performance Training and Qualifications 21

PRC ndash Protection and Control 21

TOP ndash Transmission Operations 22

TPL ndash Transmission Planning 22

VAR ndash Voltage and Reactive 22

CMEP Discovery Methods 23

I Compliance Audits 23

Audit Focus or Scope 24

CIP Reliability Standards Compliance Audits 25

2013 Compliance Audit Schedule 25

Compliance Audit Reports 26

Reliability Standard Auditor Worksheets (RSAW) 27

Mitigation Plans 28

Table of Contents

3



III Spot Checks 29


V Self-Reporting 29


VII Complaint 30










Periodic Reports 33


Assist Visits 34






















Table of Contents

4

[Blank Page]



5











































6








7




























monitoring






the NERC RoP

the CMEP

the RDA



8




9











































10


occur



8 as


















11









12
















Office10






documentation






registered entity

10




13
















Input from Staff












was







14









process

Input from Staff





























15





























audit













16

















Audit Scope
























17



























18








































19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined


Table of Contents

3



III Spot Checks 29


V Self-Reporting 29


VII Complaint 30










Periodic Reports 33


Assist Visits 34






















Table of Contents

4

[Blank Page]



5











































6








7




























monitoring






the NERC RoP

the CMEP

the RDA



8




9











































10


occur



8 as


















11









12
















Office10






documentation






registered entity

10




13
















Input from Staff












was







14









process

Input from Staff





























15





























audit













16

















Audit Scope
























17



























18








































19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined


Table of Contents

4

[Blank Page]



5











































6








7




























monitoring






the NERC RoP

the CMEP

the RDA



8




9











































10


occur



8 as


















11









12
















Office10






documentation






registered entity

10




13
















Input from Staff












was







14









process

Input from Staff





























15





























audit













16

















Audit Scope
























17



























18








































19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined




5











































6








7




























monitoring






the NERC RoP

the CMEP

the RDA



8




9











































10


occur



8 as


















11









12
















Office10






documentation






registered entity

10




13
















Input from Staff












was







14









process

Input from Staff





























15





























audit













16

















Audit Scope
























17



























18








































19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined




6








7




























monitoring






the NERC RoP

the CMEP

the RDA



8




9











































10


occur



8 as


















11









12
















Office10






documentation






registered entity

10




13
















Input from Staff












was







14









process

Input from Staff





























15





























audit













16

















Audit Scope
























17



























18








































19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined



7




























monitoring






the NERC RoP

the CMEP

the RDA



8




9











































10


occur



8 as


















11









12
















Office10






documentation






registered entity

10




13
















Input from Staff












was







14









process

Input from Staff





























15





























audit













16

















Audit Scope
























17



























18








































19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined



8




9











































10


occur



8 as


















11









12
















Office10






documentation






registered entity

10




13
















Input from Staff












was







14









process

Input from Staff





























15





























audit













16

















Audit Scope
























17



























18








































19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined



9











































10


occur



8 as


















11









12
















Office10






documentation






registered entity

10




13
















Input from Staff












was







14









process

Input from Staff





























15





























audit













16

















Audit Scope
























17



























18








































19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined



10


occur



8 as


















11









12
















Office10






documentation






registered entity

10




13
















Input from Staff












was







14









process

Input from Staff





























15





























audit













16

















Audit Scope
























17



























18








































19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined



11









12
















Office10






documentation






registered entity

10




13
















Input from Staff












was







14









process

Input from Staff





























15





























audit













16

















Audit Scope
























17



























18








































19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined



12
















Office10






documentation






registered entity

10




13
















Input from Staff












was







14









process

Input from Staff





























15





























audit













16

















Audit Scope
























17



























18








































19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined



13
















Input from Staff












was







14









process

Input from Staff





























15





























audit













16

















Audit Scope
























17



























18








































19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined



14









process

Input from Staff





























15





























audit













16

















Audit Scope
























17



























18








































19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined



15





























audit













16

















Audit Scope
























17



























18








































19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined



16

















Audit Scope
























17



























18








































19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined



17



























18








































19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined



18








































19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined



19









standard in 2011
































20
































NUC ndash Nuclear







21


















is not tiered


























22





















TOP-008 will be















23


I Compliance Audits










entities
















during










13






24




























possibilities



ended or



or




115




defines the

15





25






































17




26





















audits in 2013




















19



27







































20









28





Mitigation Plans



































29





III Spot Checks
























V Self-Reporting







24





30














VII Complaint
























26





31








32







implementation













notices27


27




CONF I DEN T I A

L





NERC Review

Govrsquot Review







by BOTCC


Investigation

Self-Report

Audits Spot Check

Exception Self-



33





Monthly Newsletter















throughout the year





Periodic Reports









34

Assist Visits







additional help









deem necessary









Case Notes30




Bulletins31


issues

Lessons Learned32




28







35






Compliance Auditors









Regions



for 2013

















33



36










































37












obligations




























34






38








common in 2013

































39


interpretation36













use of directives








time operations













36









40









FERC action



FERC action



FERC action






41





Plan identifies
























document





and Initiatives

Conclusion

42



















Revision History

43







44






report by FERC and


















COM-002-2 R1 3

FAC-008-1 R1 2

FAC-009-1 R1 1




IRO-002-2 R6 3


IRO-004-2 R1 1

IRO-005-3a R4 2


45

IRO-005-3a R5 2

IRO-005-3a R6 1

IRO-005-3a R12 1



PRC-001-1 R1 1

PRC-001-1 R4 2

PRC-001-1 R5 2

PRC-005-1b R1 2

PRC-005-1b R2 1




PRC-023-2 R1 2

TOP-002-2b R4 2

TOP-002-2b R6 2

TOP-002-2b R10 2

TOP-002-2b R11 2

TOP-002-2b R19 2

TOP-004-2 R1 2

TOP-004-2 R2 2

TOP-004-2 R3 2

TOP-004-2 R4 1

TOP-004-2 R6 3





TOP-008-1 R1 2

TOP-008-1 R2 2

TOP-008-1 R4 2

TPL-002-0b R1 3

TPL-002-0b R2 3

TPL-003-0a R1 3

TPL-003-0a R2 2


46






following steps












CMEP procedures


Event causes or

contributing

factors

Applicable NERC








that demonstrates

compliance


that suggests non-

compliance



identified



should be noted




contributing

factors


Standards


Assessment Effort

Findings


a high side


TOP-002-2a






No findings of non-

compliance


47

along with two

transmission lines










RC



provided)


a high side


along with two

transmission lines

TOP-002-2a






(IROLs)


There are no IROLs





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

TOP-004-2


the IROLs and SOLs





contingency






delineated in the





2a R6

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-001






are trained on the



and SPSs on the BPS


and as planned

No findings of non-

compliance


a high side


along with two

transmission lines

PRC-004











evaluated the relay




No findings of non-

compliance


a high side


along with two

transmission lines

TOP-008
















that there were no

SOLIROL violations








that there were no

SOLIROL violations

No findings of non-

compliance


48





















violation


a high side


along with two

transmission lines

TOP-006






reactive resources







action


and the TOP provide

operators with the








No findings of non-

compliance


49

Findings as the

outcome of a

compliance self-





(PV)rdquo





Regional Compliance

Enforcement

department in

accordance with the





the Regional

Compliance

Enforcement




process and the

completion of a

compliance self-


credit prescribed


50



AAuuddiitt



Date

Name

Title

Region

State the basis for


Deferment of

Compliance Audit


for compliance


of reduced scope or

deferment


of deferment if

applicable


MRRE audit





Name

NCR ID Number


Audit

Date of Next

Compliance Audit





51


Comments



State

information

reviewed and

basis for

determination


Approved Declined


2013 reliabilityfirst cmep implementation plan - nerc

Documents