Enforcement 101 Rachael Ferrin Associate Process Analyst

Agenda Possible Violation Information – Submittal and review process for possible violations – Submittal and review process for Mitigation Plans 2

What is a violation? A violation is a failure to demonstrate compliance pursuant to an applicable NERC Reliability Standard Requirement – Possible Violation (PV) The identification by the Compliance Enforcement Authority of a possible failure by a Registered Entity to comply with a Reliability Standard that is applicable to the Registered Entity. NERC Rules of Procedure, Appendix 2 (March 19, 2015). 3

Discovery Methods Self-Reports Self-Certifications New possible violation Change in scope Compliance Audits Spot Checks Compliance Investigations Periodic Data Submittals Complaints Self-Logging 4

Possible Violation Submittal Submit Self-Reports and Self-Certifications via webCDMS Self Report/Self Certification Content Checklist 5

Possible Violation Review WECC Subject Matter Experts (SME) review the “possible violation” Analyze facts and circumstances Data Requests/conference call if necessary Technical assessment – Facts and Timelines – Risk Assessment Recommendation of Dismissal or Acceptance to Enforcement Analysts 6

Entity’s next step after reporting a Possible Violation Mitigating Activities Submit Mitigation Plan or Mitigating Activities – Notice of Alleged Violation triggers Mitigation Plan due date – Timely Mitigation is encouraged – Not an admission of violation 7 Every violation goes through the same process.

Mitigation Plan Submittal Submit via webCDMS – One violation per plan Eight Steps to Prevention and Mitigation Mitigation Plan Content Checklist 8

Mitigation Plan Review WECC Subject Matter Experts (SME) conduct reviews Review the mitigation plan – Actions (Corrective, Detective and Preventive) – Duration Data Requests/conference call if necessary Notice of Acceptance or Rejection via auto notification or EFT server 9

Mitigation Plan Extensions Extension Requests – Accepted Mitigation Plan completion date = date Completion Certification and evidence submitted to WECC – Five business days prior to completion date 10

CMP Submittal Submit Completion Certification and evidence via webCDMS CMP Content Checklist 11

Mitigation Plan Completion Review WECC Subject Matter Experts (SME) conduct reviews Analyze Evidence – Were all actions outlined in the plan completed? – Has both procedural and implementation evidence been submitted? Data Requests/conference call if necessary Notice of Acceptance or Rejection via auto notification or EFT Server 12

Summary Violation life cycle – Submitting violations and mitigation plans – WECC’s review of violations and mitigation plans 13