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Compliance Monitoring and EnforcementProgramSERC Reliability Corporation2012 CMEP Implementation PlanNovember 1, 2012NOTE:ERO CMEP Implementation Plan and the 2012 ActivelyMonitored Reliability Standards List is posted at:http://www.nerc.com/commondocs.php?cd=3

Table of ContentsSERC Compliance Monitoring and Enforcement Program ............................................... 1Introduction ........................................................................................................................... 5SERC Compliance Monitoring and Enforcement Organization ........................................ 6Reliability Standards Subject to 2012 CMEP Implementation .......................................... 72012 CMEP Discovery Methods ........................................................................................... 81. Compliance Audits ................................................................................................ 8a. Audit Scope ................................................................................................. 8b. Annual Audit Plan and Long-Range Audit Plan ........................................... 8c. Audit Team Composition and Emphasis ..................................................... 92. Self-Certification .................................................................................................... 9a. CIP-002-3 through CIP-009-3 Reliability Standards .................................. 103. Spot Checks ........................................................................................................ 114. Periodic Data Submittals ..................................................................................... 115. Self-Report .......................................................................................................... 126. Exception Reporting ............................................................................................ 127. Complaint ............................................................................................................ 128. Compliance Investigation .................................................................................... 132012 Compliance Enforcement .......................................................................................... 141. Overall Process ......................................................................................... 142. Settlements ................................................................................................ 153. Mitigation Plans ......................................................................................... 154. Hearings .................................................................................................... 16Key CMEP Activities and Initiatives .................................................................................. 171. Efficiency Initiatives ............................................................................................. 172. Effectiveness/Quality Initiatives ........................................................................... 173. Outreach Activities .............................................................................................. 17Appendix 1 – Audit Schedule for 2012Appendix 2 – Long-Term Audit Schedule for 2012-2019Appendix 3 – Reliability Standards Included in the SERC 2012 Annual CMEPImplementation Plan and SERC Filing Due DatesRevision History

Section 1: SERC Compliance Monitoring and Enforcement ProgramSERC Compliance Monitoring and Enforcement ProgramReliability and accountability are basic tenets of the Compliance Monitoring and EnforcementProgram (CMEP). The objective of the North American Electric Reliability Corporation (NERC)and SERC Reliability Corporation (SERC) is to achieve reliability excellence in the planning,operation and security of the Bulk Power System. NERC and SERC are accountable to theFederal Energy Regulatory Commission (FERC) and to industry stakeholders. The CMEP iscritically important in supporting reliability and accountability, since effective compliance is anecessary, yet insufficient, activity for assuring reliability excellence. The CMEP covers not onlymonitoring and enforcement activities, but also education, training, and informational activitiesdesigned to assist the industry in achieving and sustaining effective compliance and enhancedreliability. NERC and the Regional Entities continue to refine and improve the annual CMEP andActively Monitored List (AML) by focusing efforts and resources on those areas that pose thegreatest risk to reliability of the Bulk Power System. This Risk Based Compliance Monitoringapproach is discussed in detail in the ERO Compliance Monitoring and Enforcement Program2012 Implementation Plan document posted on the NERC website.While NERC and SERC are implementing Risk Based Compliance Monitoring and a tieredapproach to establishing Reliability Standards and requirements to be actively monitored andaudited during 2012, all Registered Entities are reminded that NERC Rules of Procedure (ROP)state that all Bulk Power System users, owners, and operators are required to comply with allapplicable FERC-approved Reliability Standards at all times. Regional Reliability Standards andregional variances approved by NERC and FERC are enforceable and apply to all RegisteredEntities responsible for meeting those Reliability Standards within the Regional Entity boundaries,whether or not the Bulk Power System user, owner, or operator is a member of the RegionalEntity.The CMEP is developed under Section 215(c) of the Federal Power Act to establish and enforceReliability Standards for the Bulk Power System, subject to review by FERC and in generalaccordance with the “Principles for an Electric Reliability Organization that can Function on anInternational Basis.” The CMEP is designed to improve reliability through the effective and efficientenforcement of Reliability Standards.To help fulfill its responsibilities under its rules filed with FERC; NERC, as the ERO, has delegatedauthority to qualified Regional Entities to monitor and enforce compliance with ReliabilityStandards by users, owners, and operators of the Bulk Power System. This delegation isgoverned by Regional Delegation Agreements (RDA) that have been approved by FERC. NERCand these Regional Entities are responsible for carrying out the CMEP. Each Regional Entitysubmits its regional CMEP Implementation Plan to NERC for approval based on the requirementsof this document.SERC, as one of the eight Regional Entities with approved delegated authority to execute theCMEP pursuant to Section 215 of the Federal Power Act and the RDA between NERC and SERC,has adopted the CMEP, as set forth in Appendix 4C of the ROP, without exception. In addition,the ERO Compliance Monitoring and Enforcement Program 2012 Implementation Plan serves as aguidance and reference document for the development of the SERC 2012 CMEP ImplementationPlan.SERC Compliance Monitoring and Enforcement Program2012 CMEP Implementation PlanNovember 1, 2011 1

Section 1: SERC Compliance Monitoring and Enforcement ProgramA. MissionThe MISSION of SERC Reliability Corporation’s compliance organization is to effectively andefficiently monitor and enforce compliance with Reliability Standards among all users, owners, andoperators of the Bulk Power System within the SERC region. SERC’s implementation of theCMEP will be conducted with integrity, consistency, confidentiality, fairness, independence, andimpartiality.B. VisionThe VISION of SERC Reliability Corporation’s compliance organization is to optimize reliabilityacross the SERC region by fostering a culture of compliance among all users, owners, andoperators of the Bulk Power System.C. Key ObjectivesReliable and secure Bulk Power SystemPromote Registered Entity self-identification and aggressive mitigation of PossibleViolationsEffective and efficient staff processing of compliance actionsConsistency – intra and inter-regionallyTransparency of processes and results (within confidentiality constraints)D. SERC Compliance Monitoring and Enforcement ProgramSERC, through its compliance organization, adopts and implements the CMEP to monitor, assessand enforce compliance with Reliability Standards by the users, owners, and operators of the BulkPower System in SERC. In particular, SERC compliance staff is responsible for conductingmonitoring processes, assessment and disposition of all Possible Violations, includingdetermination of appropriate penalties and sanctions, and acceptance and verification ofcompletion of mitigation activities and actions to prevent recurrence.The CMEP defines eight monitoring (discovery) methods employed by the compliance staff toidentify Possible Violations: compliance audits, spot checks, self-reporting, complaint, selfcertification,exception reporting, periodic data submittal, and compliance violation investigations.These methods are further described in section 3.0 of this Annual Implementation Plan.Each Possible Violation identified through any of the discovery methods or through enforcementreview will be recorded by SERC and promptly reported to NERC and then further evaluated bySERC compliance enforcement staff. SERC compliance enforcement staff will determine theappropriate disposition of each Possible Violation. 1 In determining the appropriate disposition foreach identified Possible Violation, SERC compliance enforcement staff will rely on its collectivetechnical expertise, experience, and judgment to assess the facts and circumstances of thePossible Violation, the scope of the issue, the actual and potential risk to reliability of the Bulk1 The description of the enforcement processes described herein reflect the process for disposition of PossibleViolations through the normal CMEP provisions and filing with FERC of a Notice of Penalty. On September 30, 2011,NERC filed with FERC a Petition for Approval of New Enforcement Mechanisms and Initial Find Fix and TrackInformational Filing in Docket No. RC11-6-000, including a new process by which lesser risk issues will be found, fixed,tracked and reported to Regional Entities, NERC and FERC, instead of being processed in a Notice of Penalty asviolations subject to penalties or sanctions. SERC staff began implementing these processes in September 2011.SERC Compliance Monitoring and Enforcement Program2012 CMEP Implementation PlanNovember 1, 2011 2

Section 1: SERC Compliance Monitoring and Enforcement ProgramPower System posed by the issue, the relevant corrective and preventative actions, and theappropriate penalties and sanctions, if any. Additional information may be requested from theRegistered Entity to facilitate the assessment. If SERC compliance enforcement staff determinessufficient basis exists to allege a violation, then staff contacts the Registered Entity and overviewsthe bases, the potential daily penalty exposure, the status of any mitigation activities undertaken bythe Registered Entity, the proposed penalty given the facts and circumstances of the AllegedViolation, and the basic Registered Entity response options. Subsequently, staff will eithercommence settlement negotiations and/or issue a Notice of Alleged Violation and ProposedPenalty or Sanction (NAVAPS) to the Registered Entity. Upon completion of the settlementagreement or confirmation of the violation in accordance with applicable SERC procedures andprovisions of the CMEP, and approval by the SERC president, SERC staff will submit thesettlement agreement or Notice of Confirmed Violation (NOCV) to NERC for its approval. Uponapproval of the settlement or NOCV by NERC, a Notice of Penalty will be filed with FERC andsimultaneously served upon the Registered Entity and publicly posted pursuant to the ROP.SERC staff has developed and continues to refine an extensive set of compliance implementingprocedures. These procedures detail the actions and processes that SERC uses to conduct itscompliance monitoring and enforcement responsibilities. Procedures are aligned with and follow asimilar numbering scheme to the applicable sections of the CMEP to promote linkage. One ormore members of SERC compliance staff are assigned as subject matter experts (SMEs) for eachprocedure to ensure technical accuracy and to help coordinate revisions. New procedures andprocedure revisions are posted publicly for comment to promote transparency. The SERCCompliance Implementing Procedures are on the SERC website (www.serc1.org) under the“Compliance” tab.E. Board Compliance CommitteeThe SERC Board Compliance Committee, a balanced stakeholder committee of the SERC Boardof Directors, is responsible for oversight of SERC compliance staff and its implementation of theCMEP. The Board Compliance Committee, or a subset thereof, also acts as the hearing bodyresponsible for resolving any disputes related to either a finding of an Alleged Violation or asanction administered for an Alleged Violation.SERC compliance staff works independently to complete all of the steps in the Regional Entitycompliance monitoring and enforcement process. These steps conducted by staff includeevaluating whether sufficient basis exists to allege a violation of an approved Reliability Standard,issuing a Notice of Alleged Violation, confirming a violation, developing proposed sanctions andpenalties, negotiating settlements, and accepting mitigation plans.At the conclusion of the staff’s work, following the filing of a Notice of Penalty with FERC, thecompliance staff conducts a review of the enforcement action, including the approved penaltiesand sanctions, and mitigation plans with the Board Compliance Committee.F. Compliance StaffSERC compliance staff conducts compliance monitoring activities pursuant to the eight monitoringmethods set forth in the CMEP and enforces compliance with Reliability Standards throughassessment and determinations of Alleged Violations, imposition of appropriate penalties andsanctions in accordance with the CMEP and the Penalties and Sanctions Guidelines (Appendix 4Bof the NERC ROP), and approval and verification of completion of mitigation activities and actionsto prevent recurrence. To accomplish these activities, SERC’s compliance staff is further dividedSERC Compliance Monitoring and Enforcement Program2012 CMEP Implementation PlanNovember 1, 2011 3

Section 1: SERC Compliance Monitoring and Enforcement Programinto an audit branch, a CIP compliance monitoring branch, an enforcement branch, and aprograms branch; which includes registration and certification activities, outreach, andinvestigations.SERC significantly expanded and developed the competencies of its compliance staff from 2007through 2011 while continuing to engage the technical expertise and active participation of industryvolunteers as supporting members of audit teams. SERC’s compliance staff continues to developas a learning organization, working to improve processes and practices to enhance its ability toefficiently and effectively implement and administer the CMEP and promote a culture of reliabilityexcellence across the region.SERC Compliance Monitoring and Enforcement Program2012 CMEP Implementation PlanNovember 1, 2011 4

Section 2: IntroductionIntroductionThe ERO CMEP Implementation Plan is the operating plan for annual compliance monitoringand enforcement activities to ensure that NERC, as the international ERO, and its RegionalEntities fulfill their responsibilities under the legislation in the United States and other applicableobligations in other jurisdictions in Canada and Mexico.The compliance monitoring and enforcement activities are carried out by NERC and the eightRegional Entities based on the regulatory authority-approved uniform CMEP, the NERC ROP,and the respective RDA with the eight Regional Entities. The NERC CMEP ImplementationPlan outlines the implementation requirements to be followed by NERC and the eight RegionalEntities. Each Regional Entity submits its 2012 implementation plan by November 1, 2011 toNERC. NERC is responsible for approving the Regional Entity implementation plans.The ERO 2012 Implementation Plan includes a set of Reliability Standards that were selectedbased upon ERO-identified high-risk priorities and a three-tiered approach to complianceauditing. The implementation plan also requires Regional Entities to consider a registeredentity’s compliance history when determining the scope of compliance monitoring activities. Theobjectives of the Implementation Plan are to: Promote the reliability of the BPS through rigorous compliance monitoring andenforcement activities. Facilitate improved consistency of compliance activities throughout North America. Monitor all regulatory authority approved Reliability Standards by using the eight CMEPcompliance monitoring methods. Use risk-based and performance-based criteria for determining the scope for complianceaudits. Allow flexibility for the ERO and Regional Entities to investigate trends that may pose anear term risk to reliability either across the North American BPS, across anInterconnection, or within a Regional Entity boundary. Improve the compliance program by analyzing the compliance monitoring experienceacross North America and implementing necessary improvements.The Risk Based Compliance Monitoring Approach and the methodology employed by NERC inthe development of the implementation plan and actively monitored list of Reliability Standardsfor 2012 is described in detail in the ERO CMEP 2012 Implementation Plan.SERC Compliance Monitoring and Enforcement Program2012 CMEP Implementation PlanNovember 1, 2011 5

Section 4: Reliability Standards Subject to 2012 CMEP ImplementationReliability Standards Subject to 2012 CMEP ImplementationFERC-approved Reliability Standards and Requirements are monitored through at least one ofthe CMEP compliance monitoring methods. The development of the actively monitored list ofReliability Standards and requirements and three-tiered approach to audit scope determinationis discussed in detail in Chapter 3 - 2012 Implementation Plan Development Methodology andChapter 4 – Reliability Standards Subject to 2012 CMEP Implementation of the ERO CMEP2012 Implementation Plan.Regional Entities are authorized and obligated to implement the annual ERO ImplementationPlan. Regional Entity staff may increase the scope of compliance activities related to the EROprogram, as described above, but cannot reduce the scope of compliance activities withoutNERC consent. Where Regional Entities determine that a reduced scope is appropriate, theRegional Entity will submit the Regional Entity Request to Defer or Reduce the Scope of aCompliance Audit, which is located in Appendix 3 of the ERO CMEP 2012 Implementation Plan,to the NERC Compliance Operations department at least 90 days prior to the audit for approval.The overall monitoring scope of the 2012 Implementation Plan and AML is based on ReliabilityStandards that are anticipated to be in effect on January 1, 2012. To the extent new or revisedReliability Standards are adopted, approved by the regulatory authority or in effect during thecourse of 2012, NERC will work with the Regional Entities to determine whether the 2012program needs to be amended.All NERC Reliability Standards identified in the ERO CMEP 2012 Implementation Plan are listedin the 2012 CMEP Actively Monitored Reliability Standard list posted on the NERC website atthe following link: http://www.nerc.com/commondocs.php?cd=3The 2012 Actively Monitored Reliability Standards list includes several worksheets. Adescription of each is listed below: Summary Tab: Quick reference listing of the Reliability Standards identified forcompliance audits, self-certifications, and spot checks required by NERC in 2012,and mandatory effective dates for Reliability Standards. This tab is designed to givethe user a quick reference of the Implementation Plan lists. There are alsocomparisons of the number of Reliability Standards monitored in the 2007, 2008,2009, 2010, and 2011 programs. Requirements Detail Tab: A detailed list of the requirements included in the 2012Implementation Plan. Revision History: The revision history that will allow users, owners, and operatorsof the BPS to see all of the changes to the 2012 Actively Monitored ReliabilityStandards spreadsheets.Reliability Standards and requirements included in the SERC 2012 Annual CMEPImplementation Plan and associated filing due dates are listed in an attachment to thisdocument and are posted on the SERC website under the Compliance tab.While the 2012 CMEP Implementation Plan focuses on a subset of actively monitored ReliabilityStandards and requirements, all Registered Entities are reminded that all Bulk Power Systemusers, owners, and operators are required to comply with all applicable FERC-approvedReliability Standards at all times.SERC Compliance Monitoring and Enforcement Program2012 CMEP Implementation PlanNovember 1, 2011 7

Section 5: 2012 CMEP Discovery Methods2012 CMEP Discovery Methods1. Compliance Auditsa. Audit ScopeAll FERC-approved Reliability Standards applicable to the Registered Entity based onregistered functions are subject to audit. The default scope of review for compliance auditsconducted by SERC in 2012 will consist of the Tier 1 requirements plus the Modeling, Data, andAnalysis (MOD) Reliability Standards (MOD-001-1, 004-1, 008-1, 028-1, 029-1, and 030-2) forapplicable Registered Entities, pursuant to the requirement from FERC that this set ofStandards be audited during the first cycle of three-year audits following the effective date of theMOD Standards. In addition, for any Registered Entity that has not been previously audited bySERC, the scope will be expanded to include the Tier 2 requirements. Evidence supportingcompliance with Tier 2 or Tier 3 requirements may be needed to support evidence ofcompliance with a Tier 1 requirement (e.g., an audit of PRC-005-1 R2 will necessitate theauditor’s review of the Registered Entity’s program document required under PRC-005-1 R1 inorder to determine if the Registered Entity has met the requirements of PRC-005-1 R2.) Seethe NERC 2012 Actively Monitored Reliability Standards spreadsheet for the breakdown byrequirement of the scope for audits. SERC will provide to the Registered Entity the scope of thecompliance audit with the audit detail letter.Regional Entity audit teams are authorized and obligated to expand the scope of a complianceaudit to include Tier 2 and Tier 3 requirements and any other requirements they may deemnecessary based on the results of the Registered Entity Profile Assessment or the audit team’scollective professional judgment. Audit scope expansion can occur at any point during theprocess, from the initial review of the Registered Entity Profile Assessment through the close ofthe audit.In addition, the scope of compliance audits will include a review of all Mitigation Plans that areopen during the on-site audit, as discussed in the CMEP. Registered Entities must provide thecompliance audit team with the status, documentation, and evidence for all mitigation plans thatare to be reviewed. If a Registered Entity has certified a Mitigation Plan as being completedwithin 90 days of the audit start date, the audit team may verify satisfactory completion of theMitigation Plan during the compliance audit.To increase the efficiency of compliance audits in 2012, Regional Entity audit teams will havethe option of limiting the review of processes and procedures to the Registered Entity’s current,in-force documentation, and to the implementation of the Registered Entity’s internal complianceprogram. This approach allows the audit team to focus on the current reliability risk anddetermining compliance. In the event a finding of a Possible Violation is determined basedupon the current, in-force documents, the audit team will review previous versions of theprocess and procedure documentation to determine the full extent of the Possible Violation.Audit teams will have the flexibility to review historical information of the implementation ofactivities required by Reliability Standards, such as maintenance and testing records or operatorlogs/recordings, on an as needed basis.b. Annual Audit Plan and Long-Range Audit PlanThe schedule of audits for 2012 is attached as Appendix 1. A long range [eight (8) year] auditplan was developed to ensure that each entity registered within the SERC region receives acompliance audit on a prescribed schedule. Registered Entities that perform ReliabilityCoordinator (RC), Balancing Authority (BA), or Transmission Operator (TOP) functions will beSERC Compliance Monitoring and Enforcement Program2012 CMEP Implementation PlanNovember 1, 2011 8

Section 5: 2012 CMEP Discovery Methodsaudited on a three (3) year periodicity for those three functions plus any other functions forwhich the entity is registered. Entities that are not registered as RC, BA, or TOP will typically beaudited on a six (6) year periodicity. The long-range audit plan will be updated at least annuallyto account for changes in registration and other factors. See Appendix 2.c. Audit Team Composition and EmphasisEach SERC compliance audit will be led by a member of SERC compliance staff. The auditteam will be composed of SERC compliance staff and may include, upon approval of SERCcompliance management, other SERC staff members, SERC Registered Entity Industry SubjectMatter Experts (ISMEs), compliance staff members from other Regional Entities, and NERC andFERC personnel as applicable. All audit team members will operate under approved conflict ofinterest and non-disclosure agreements and will receive requisite training prior to the audit.Advance notifications will occur as required by the CMEP to allow for audited Registered Entityobjections to participation of selected team members. The SERC Director of Compliance willreview and act on such objections as appropriate.In 2012, as in previous years, SERC will continue a heavy focus toward “on-site” complianceaudits. In particular, those entities that have been more recently registered in the SERC region,or which have not previously been audited by SERC, will typically undergo an on-site audit asone means to promote communication of processes and expectations.2. Self-CertificationAll Registered Entities are required to participate in the annual self-certification each year perthe ERO Actively Monitored Reliability Standard list. Regional Entities, at their discretion, mayinclude additional Reliability Standards to include in the Regional 2012 Implementation Plan.Self-certification is an important component of the ERO Compliance Monitoring andEnforcement Program. It is one of the discovery methods that monitor a Registered Entity’scompliance with Reliability Standards, especially those that have not been included in auditscopes in recent years. Thirty-six Reliability Standards are designated for Self-Certification inthe ERO CMEP 2012 Implementation Plan with 13 additional Standards included in the SERC2012 Implementation Plan.Additional Standards Added to the Monitoring Scope for SERC Registered EntitiesConsistent with prior years’ SERC CMEP Annual Implementation Plans, SERC includes in theset of Reliability Standards subject to Self-Certification any Reliability Standard for whichPeriodic Data Submittal or Exception Reporting is required, if that Reliability Standard is notalready included in the Actively Monitored Reliability Standards set forth in the ERO CMEP2012 Implementation Plan, as described in the section above and listed in the worksheetsreferenced above. Thus, SERC will include in the set of Reliability Standards subject to Self-Certification for 2012, the following Reliability Standards:Standards for Which Periodic Data Submittal is Required: BAL-001-0.1a BAL-002-0 BAL-003-0.1b (Collected by Reliability Services) EOP-009-0 (Collected by Reliability Services) PRC-007-0 (Collected by Reliability Assessments) PRC-021-1 (Collected by Reliability Assessments) TPL-001-0.1SERC Compliance Monitoring and Enforcement Program2012 CMEP Implementation PlanNovember 1, 2011 9

Section 5: 2012 CMEP Discovery Methods TPL-002-0a TPL-003-0a TPL-004-0Standards Requiring Exception Reporting: PER-003-0 TOP-005-1.1 TOP-007-0Since there is no specific form or template for Exception Reporting, RegisteredEntities should self-report, as Possible Violations, any “exceptions” to the ReliabilityStandard requirements designated for monitored through Exception Reporting, usingthe SERC Portal Self-Report form. Submittal by Registered Entities of selfcertificationsfor these Standards indicating the Registered Entity is “Compliant” willserve as a declaration by the Registered Entity that it has had no exceptions to thedesignated Reliability Standard requirements during the reporting period (a zeroexceptionreport).Within SERC, all requirements of the Actively Monitored Reliability Standards must be selfcertifiedto by applicable Registered Entities, not just the requirements included in theRequirements Detail Tab of the NERC Actively Monitored Reliability Standards spreadsheet.SERC has two major filings for annual self-certifications targeted for June 1 and October 1. Forthe June 1 and October 1 annual self-certification filings, the associated forms are “posted” tothe Portal approximately two months ahead of the scheduled due date. For the calendar yearself-certifications (CIP-002 through CIP-009, IRO-004, TOP-007, PER-002, PER-003) and theannual self-certifications of monthly and quarterly data submittals, forms are posted afterDecember 31. SERC requires at least one individual from each Registered Entity to beidentified as an authorized signatory. The authorized signatory is a role which should be givento the representative(s) who will be certifying to compliance submittals. Self-certification mustbe approved by the Registered Entity’s authorized signatory prior to being accepted by SERC.A systematic notification process to the Registered Entity’s primary compliance contact, withpossible escalation of notices to the primary compliance officer or CEO contact, will be initiatedfor any late submittals.A reporting period will be defined for each Reliability Standard monitored by self-certification.The reporting period is a 12 month period of time prior to posting of the form. The selfcertificationwill be an attestation by the Registered Entity for all FERC-approved versions of theReliability Standard in effect during the defined reporting period. The response to thecertification should accurately reflect the Registered Entity's compliance status for the entirereporting period and is subject to validation by SERC through spot check or any othercompliance monitoring method.The scheduled filing dates for self-certifications are listed in Appendix 3.a. CIP-002-3 through CIP-009-3 Reliability StandardsAnnual self-certifications for the CIP-002-3 through CIP-009-3 Reliability Standards (CIPStandards) for the 2011 CMEP will be conducted by SERC in January 2012 and willcover the period from October 1, 2010 through the earlier of December 31, 2011 or thedate Version 3 of the CIP Standards is superseded. Self-certifications of the CIPSERC Compliance Monitoring and Enforcement Program2012 CMEP Implementation PlanNovember 1, 2011 10

Section 5: 2012 CMEP Discovery MethodsStandards for the 2012 CMEP will be conducted by SERC in January 2013 and willcover the period fromJanuary 1, 2012 through the earlier of December 31, 2012 or the date Version 3 of theCIP Standards is superseded. However, self-certification of CIP Standards may expandto include CIP supplemental questionnaires as directed by NERC or FERC.Registered Entities to which the CIP Standards apply are required to self-certify to allrequirements of the CIP Standards, even if the applicable Registered Entity has noCritical Assets. CIP-002-3 R4 requires all entities to annually approve their risk-basedassessment methodology, the list of Critical Assets, and the list of Critical Cyber Assets;even if such lists are null, and CIP-003-3 R2 requires all entities to assign a single seniormanager with overall responsibility and authority for leading and managing the entity’simplementation of, and adherence to the CIP Standards, even if the entity hasdetermined that it has no Critical Cyber Assets. Thus, in its self-certifications for CIP-002-3 R4 and CIP-003-3 R2, Registered Entities must affirmatively respond “Compliant”or “Not Compliant”, and should not indicate “Not Applicable”, even if they havedetermined, based on their risk-based assessment methodology, that they have noCritical Assets. Registered Entities that have determined that they have no CriticalAssets should then indicate “Not Applicable” to all other requirements of CIP-003-3through CIP-009-3.3. Spot ChecksNERC and the Regional Entities have the authority to conduct additional spot checks of anyregulatory approved Reliability Standards. Spot checks of individual Registered Entities andselected Reliability Standards will be authorized by the SERC Director of Compliance and willinvolve notice to the applicable Registered Entity(s) in accordance with CMEP requirements. Allspot checks will require non-public spot check reports. Spot checks of operating and planningstandards will also require public spot check reports. The standard audit or spot check templateprovided by NERC will be utilized and submitted to NERC for all spot checks.4. Periodic Data SubmittalsFourteen Reliability Standards are designated for Periodic Data Submittal in the ERO CMEP2012 Implementation Plan with two additional Standards included in the SERC 2012Implementation Plan (PRC-015-0, collected by SERC Reliability Assessments, and PRC-016-0.1, collected by SERC Reliability Services). The Reliability Standards subject to Periodic DataSubmittal and the respective filing frequency (monthly, quarterly, bi-annual, or annual) aredefined in Appendix 3. The “Notes” column specifies the Standards for which Periodic DataSubmittals will be collected by Reliability Services or Reliability Assessments.SERC uses Periodic Data Submittals to obtain information from Registered Entities such asmodeling, studies, analyses, documents, procedures, methodologies, or operating data neededto demonstrate compliance with certain Reliability Standards.For each FERC-approved Reliability Standard requirement that is designated for Periodic DataSubmittal in the ERO CMEP 2012 Implementation Plan, SERC will also monitor the associatedReliability Standard through self-certification. The additional self-certification requirementsassociated with required Periodic Data Submittal are highlighted in the Self-Certification sectionand in Appendix 3.SERC Compliance Monitoring and Enforcement Program2012 CMEP Implementation PlanNovember 1, 2011 11

Section 5: 2012 CMEP Discovery Methods5. Self-ReportRegistered Entities are strongly encouraged to self-report Possible Violations of applicableReliability Standards and initiate mitigating actions as soon as they become aware of such acondition. Self-reports are submitted by Registered Entities through the SERC Portal.Mitigation Plans to address the conditions that gave rise to the Registered Entity’s self-reportmay be submitted via the SERC Portal as soon as receipt of the self-report has beenacknowledged by SERC staff.SERC staff will review and validate the submitted information. Registered Entities areencouraged to conduct a prompt and thorough review of the circumstances associated with theself-report to accurately identify relevant scope and underlying causes. Strong considerationwill be given to reduce associated sanctions and penalties for violations that are promptly andcomprehensively self-reported.6. Exception ReportingTwelve Reliability Standards are designated for Exception Reporting in the ERO CMEP 2012Implementation Plan. Therefore, Registered Entities are required to promptly report anyexceptions to the designated Reliability Standard requirements. Since there is no specific formor template for Exception Reporting, Registered Entities should self-report, as PossibleViolations, any “exceptions” to the Reliability Standard requirements designated for monitoringthrough Exception Reporting, using the SERC Portal Self-Report form. Ror ReliabilityStandards requiring Exception Reporting, submittal by Registered Entities of self-certificationsindicating the Registered Entity is “Compliant” will serve as a declaration by the RegisteredEntity that it has had no exceptions to the designated Reliability Standard requirements duringthe reporting period (a zero-exception report). The Reliability Standards subject to ExceptionReporting are defined in the 2012 CMEP Actively Monitored Reliability Standard list posted onthe NERC Web site at http://www.nerc.com/commondocs.php?cd=3 and in Appendix 3.7. ComplaintAll regulatory authority-approved Reliability Standards or requirements can be the subject of acomplaint regarding a compliance violation by a Registered Entity. Complaints, if validated, caninitiate one of the other compliance monitoring methods in order to determine the full extent ofpotential non-compliance.Complaints may be submitted to SERC using the Complaint Form found on the SERC web site.In addition, NERC maintains a Compliance Hotline that is administered by the Event Analysis &Investigation (EA&I) group. Any person may submit a complaint to report a possible violation ofa Reliability Standard by calling 404-446-2575, sending an e-mail directly to hotline@nerc.net orcompleting the form on https://www.nerc.net/hotline/. Unless specifically authorized by thecomplainant, NERC and Regional Entity staff will withhold the name of the complainant in anycommunications with the violating entity. All information provided will be held as confidential inaccordance with the NERC ROP. EA&I will informally seek additional information regarding thepotential violation of Reliability Standards from the submitter and others, as appropriate. EA&Imay refer the matter for further investigation by NERC or the appropriate Regional Entity.Note: The NERC Compliance Hotline is for reporting complaints or possible complianceviolations of Reliability Standards by an entity. For other questions regarding the NERC CMEPor Reliability Standards, please send an email to compliancefeedback@nerc.net.SERC Compliance Monitoring and Enforcement Program2012 CMEP Implementation PlanNovember 1, 2011 12

Section 5: 2012 CMEP Discovery Methods8. Compliance InvestigationA Compliance Investigation may be initiated at any time by the NERC or the Regions inresponse to a system disturbance, Complaint, or the Possible Violation of a Reliability Standardidentified by any other means. Compliance Investigations are confidential, unless FERC directsotherwise and are generally led by the Regional Entity’s staff. NERC reserves the right toassume the leadership of a Compliance Investigation.The Compliance Enforcement Authority reviews information to determine compliance with theReliability Standards. The Compliance Enforcement Authority may request additional dataand/or information as necessary through formal Requests for Information, site visits, swornstatements, etc. to perform its assessment.SERC Compliance Monitoring and Enforcement Program2012 CMEP Implementation PlanNovember 1, 2011 13

Section 6: 2012 Program Implementation - Enforcement2. SettlementsSettlements are viewed as an expedient and efficient method to address Alleged Violations.The settlement process is conducted as described by the NERC CMEP and SERCimplementing procedures. Some key points include:Staff details the basis for determining one or more Alleged Violations occurredStaff details what the penalties could have been, the negotiated penalties and sanctionsarrived at, and the attendant considerationsRegistered Entities are allowed to either admit that a violation occurred or indicate theyneither admit nor deny that the facts constitute a violation of the Reliability StandardRegistered Entities can provide a statement within the settlement providing theirperspective on the issuesThe settlement provides for correction of the violation and actions to prevent recurrence.Approved Mitigation Plans, the Registered Entity’s certification of completion of theMitigation Plan, and SERC staff’s verification of completion of the Mitigation Plan will beappended as an appendix to settlement documents.Among other factors, SERC staff may take the following into account when determining theproposed penalty: whether the Alleged Violation was self-reported, whether the entity admits theviolation, the level of cooperation received from the entity during the investigation, and thestrength of the entity’s compliance program.3. Mitigation PlansAggressive and thorough Registered Entity mitigation of any Possible Violation is stronglyencouraged. Although submittal of a Mitigation Plan is not required under the CMEP until aviolation has been confirmed after issuance of a NAVAPS, prompt initiation of corrective actionsand early submittal of Mitigation Plans documenting the corrective actions taken and to be takenis also strongly encouraged to reduce risk to the reliability of the Bulk Power System and todemonstrate prompt action by the Registered Entity to remedy the identified gap. MitigationPlans are submitted to SERC via direct-entry forms on the SERC Portal.Submission of a Mitigation Plan is NOT an admission by the Registered Entity that a violationhas occurred. Compliance staff reviews submitted Mitigation Plans and provides the RegisteredEntity feedback on any modifications required to support approval. Mitigation Plans mustspecifically address the Alleged Violations in question and describe specific actions to remedythe violation and prevent recurrence aimed at the root cause of the violations. Regionallyaccepted Mitigation Plans are subsequently forwarded to NERC and then to FERC.SERC staff monitors the Registered Entity’s progress toward completion of its Mitigation Plansin accordance with Section 6.0 of the uniform CMEP. Pursuant to the CMEP, RegisteredEntities are required to establish implementation milestones no more than three (3) monthsapart. SERC staff solicits quarterly reports from all Registered Entities with open MitigationPlans to monitor the progress on completion of milestones. SERC staff also produces andreviews Mitigation Plan status reports highlighting Mitigation Plans that are nearing thescheduled completion date. If the Registered Entity fails to complete its Mitigation Planaccording to schedule, appropriate additional enforcement action is initiated to assurecompliance is attained.Registered Entities are required to certify completion of the Mitigation Plan and to providesupporting evidence. Compliance staff reviews supplied evidence to determine whether theapproved Mitigation Plan has been implemented as agreed upon. Staff will initiate newSERC Compliance Monitoring and Enforcement Program2012 CMEP Implementation PlanNovember 1, 2011 15

Section 6: 2012 Program Implementation - Enforcementenforcement action in those cases where a Registered Entity does not complete Mitigation Planactions on time or cannot demonstrate current compliance through evidence.4. HearingsIn those cases where a Registered Entity chooses to contest the Alleged Violation, proposedpenalty, remedial action directive, or the region’s rejection of a Mitigation Plan, the RegisteredEntity can request a hearing. Requirements regarding staff and Registered Entity actions andassociated timing are detailed in the NERC CMEP and associated implementing procedures.The Board Compliance Committee or a subset of the Board Compliance Committee will serveas the hearing body.SERC Compliance Monitoring and Enforcement Program2012 CMEP Implementation PlanNovember 1, 2011 16

Section 7: Key CMEP Activities and InitiativesKey CMEP Activities and InitiativesSERC is committed to continuous improvement of its implementation of the CMEP. To that end,SERC solicits feedback from Registered Entities, NERC staff, the Board ComplianceCommittee, and other stakeholders seeking suggestions for improvements to SERC’sprocesses. During 2012, SERC compliance staff focus will be efficiency, effectiveness/quality,and outreach.1. Efficiency InitiativesSERC will continue to develop and enhance the systems it uses to implement the CMEP. TheCompliance Issues Tracking System (CITS), launched in 2010, is a Regional Entity applicationthat incorporates all aspects of violation tracking including reporting, determination, mitigation,penalties, and settlement. Registered Entities interface with the CITS application through theSERC Portal by submitting self- certification, self-report, complaint, and mitigation forms. Themitigation forms include milestone updates, extensions, and certification of closure.Standards, registration, and violations data are transferred electronically between SERC andNERC. This electronic exchange of data promotes uniformity, improves data quality, andsupports timely reporting. As SERC staff gains more experience with the CITS system, thequality and efficiency of the processing of Possible Violations will continue to improve.SERC staff will also continue its efforts with NERC to develop streamlined approaches toviolation processing. Such activities will require the support and assistance from RegisteredEntities, particularly in the development of a comprehensive determination of the scope of anyviolations and the potential risk to reliability of the violation.2. Effectiveness/Quality InitiativesSERC staff has initiated a multi-faceted plan to improve the rate at which it processesenforcement actions, while maintaining a high level of quality of enforcement actions. The planincludes process and productivity improvements, enhancements to tools and methods forcollecting and managing data, and additional staffing.3. Outreach ActivitiesOutreach is an important element of SERC’s compliance mission. It serves to enhanceawareness, improve transparency of compliance processes and promote reliability excellence.Focus areas for SERC outreach activities will include information on CMEP processes,Reliability Standards education materials, compliance application of Standards, lessons learned,guidance on developing a culture of compliance, preparation for audits, use of the SERC Portal,and sharing of experiences and good practices among Registered Entities.SERC has scheduled four (4) compliance seminars during 2012. Each of the seminars will bespecifically tailored to focus on current events of interest and compliance themes.SERC will also conduct quarterly “Open Forum” web conferences to convey key messages andallow for Registered Entity questions and feedback.During 2010, SERC compliance staff facilitated the creation of a Registered Entity-directedforum, the Registered Entities’ Forum (REF), to serve as a formal platform for RegisteredEntities to discuss reliability and compliance issues, exchange information, lessons learned,SERC Compliance Monitoring and Enforcement Program2012 CMEP Implementation PlanNovember 1, 2011 17

Section 7: Key CMEP Activities and Initiativesgood practices, and success stories; and generate concerns and questions for the SERC staff.The mission of the REF is to promote compliance excellence, elevate the collective complianceculture and strengthen reliability among all SERC Registered Entities.Generic lessons learned regarding in-process and completed compliance actions will becompiled and posted to provide Registered Entities timely feedback and promote transparency.Currently statistics on in-process violations are updated monthly and posted on the SERC publicweb site.SERC Compliance Monitoring and Enforcement Program2012 CMEP Implementation PlanNovember 1, 2011 18

Appendix 1 – Audit Schedule for 2012SERC Compliance Monitoring and Enforcement Program2012 Implementation PlanNovember 1, 2011

SERC 2012 Annual Audit Schedule (based on NERC Compliance Registry 4/26/11)NERC ID Registered Entity Audit Type Start Date End Date LocationNCR00026 Florida Reliability Coordinating Council, Inc. CIP On-Site 1/23/12 2/10/12 Miami, FLNCR00026 Florida Reliability Coordinating Council, Inc. Medium On-Site 1/23/12 2/3/12 Tampa, FLNCR01223 LG&E and KU Services Company Large On-Site 2/13/12 2/17/12 Louisville, KYNCR01315 South Mississippi Electric Power Association CIP On-Site 2/27/12 3/16/12 Hattiesburg, MSNCR01309 Seneca Light and Water Medium On-Site 3/5/12 3/7/12 Scenaca, SCNCR09026 Town of Culpeper Light & Power Small Off-Site 3/6/12 3/8/12 Charlotte, NCNCR01293 Piedmont Municipal Power Agny Medium On-Site 3/7/12 3/9/12 Greer, SCNCR01225 East Kentucky Power Cooperative Large On-Site 3/19/12 3/23/12 Winchester, KYNCR01328 City of Springfield, IL - CWLP CIP Off-Site 3/26/12 4/6/12 Charlotte, NCNCR08081 City of Troy, Alabama CIP Off-Site 3/26/12 4/6/12 Charlotte, NCNCR11016 Northeast Louisiana Power Cooperative Inc. CIP Off-Site 3/26/12 4/6/12 Charlotte, NCNCR11002 Princeton Electric Plant Board CIP Off-Site 3/26/12 4/6/12 Charlotte, NCNCR01309 Seneca Light and Water CIP Off-Site 3/26/12 4/6/12 Charlotte, NCNCR11002 Princeton Electric Plant Board Small Off-Site 4/2/12 4/4/12 Charlotte, NCNCR08081 City of Troy, Alabama Medium On-Site 4/3/12 4/5/12 Troy, ALNCR00128 ExxonMobil Corp - Baton Rouge CIP Off-Site 4/16/12 4/27/12 Charlotte, NCNCR01292 Piedmont Electric Membership Corporation CIP Off-Site 4/16/12 4/27/12 Charlotte, NCNCR01293 Piedmont Municipal Power Agny CIP Off-Site 4/16/12 4/27/12 Charlotte, NCNCR00070 Southeastern Power Administration CIP Off-Site 4/16/12 4/27/12 Charlotte, NCNCR01348 Town of Sharpsburg CIP Off-Site 4/16/12 4/27/12 Charlotte, NCNCR01350 Town of Waynesville CIP Off-Site 4/16/12 4/27/12 Charlotte, NCNCR01352 Town of Winterville CIP Off-Site 4/16/12 4/27/12 Charlotte, NCNCR01328 City of Springfield, IL - CWLP Large On-Site 4/16/12 4/20/12 Springfield, ILNCR01359 USACE - Mobile District Large On-Site 4/30/12 5/4/12 Mobile, ALNCR01234 Entergy CIP On-Site 5/7/12 5/25/12 New Orleans, LANCR01151 Tennessee Valley Authority Large On-Site 5/14/12 5/18/12 Chattanooga, TNNCR01359 USACE - Mobile District CIP On-Site 6/11/12 6/29/12 Mobile, ALNCR01319 Southern Company Services, Inc. - Gen Large On-Site 6/11/12 6/15/12 Birmingham, ALNCR01320 Southern Company Services, Inc. - Trans Large On-Site 6/11/12 6/15/12 Birmingham, ALNCR01348 Town of Sharpsburg Medium On-Site 6/25/12 6/27/12 Sharpsburg, NCNCR01356 USACE - Charleston District Medium On-Site 6/26/12 6/28/12 Grapevine, TXNCR01352 Town of Winterville Medium On-Site 6/27/12 6/29/12 Winterville, NCNCR01225 East Kentucky Power Cooperative CIP On-Site 7/16/12 8/3/12 Winchester, KYNCR10317 NextEra Energy Power Marketing, LLC (SERC Lead) Small Off-Site 7/16/12 7/20/12 Charlotte, NCNCR09036 RRI Energy Services, Inc. Small Off-Site 7/16/12 7/20/12 Charlotte, NCNCR00128 ExxonMobil Corp - Baton Rouge Medium On-Site 7/17/12 7/19/12 Baton Rouge, LANCR01315 South Mississippi Electric Power Association Large On-Site 8/6/12 8/10/12 Hattiesburg, MSNCR01151 Tennessee Valley Authority CIP On-Site 8/13/12 8/31/12 Chattanooga, TNNCR01292 Piedmont Electric Membership Corporation Medium On-Site 8/21/12 8/23/12 Hillsboro, NCNCR01350 Town of Waynesville Medium On-Site 8/21/12 8/23/12 Waynesville, NCNCR00070 Southeastern Power Administration Large On-Site 9/10/12 9/14/12 Elberton, GANCR00693 BlueStar Energy Services, Inc. (RFC Lead) Small-Off-Site 9/10/12 9/21/12 Akron, OHNCR01223 LG&E and KU Services Company CIP On-Site 10/1/12 10/19/12 Louisville, KYNCR01361 USACE - Savannah District Large On-Site 10/1/12 10/5/12 Savannah, GANCR11016 Northeast Louisiana Power Cooperative Inc. Medium On-Site 10/9/12 10/11/12 Winnsboro, LANCR01360 USACE - Nashville District Medium On-Site 10/9/12 10/11/12 Nashville, TNNCR01234 Entergy Large On-Site 10/22/12 10/26/12 New Orleans, LANCR01319 Southern Company Services, Inc. - Gen CIP On-Site 10/29/12 11/16/12 Birmingham, ALNCR01320 Southern Company Services, Inc. - Trans CIP On-Site 10/29/12 11/16/12 Birmingham, ALNCR00826 Midwest Independent Transmission System Operator Inc. (RFC Lead) CIP On-Site 11/5/12 11/9/12 Carmel, INNCR00826 Midwest Independent Transmission System Operator Inc. (RFC Lead) Large On-Site 11/5/12 11/9/12 Carmel, INNCR01312 South Carolina Public Service Authority Large On-Site 11/12/12 11/16/12 Moncks Corner, SCNCR01312 South Carolina Public Service Authority CIP On-Site 11/26/12 12/14/12 Moncks Corner, SCNCR11109 USACE - Fort Worth CIP Off-Site 11/26/12 12/7/12 Charlotte, NCNCR01356 USACE - Charleston District CIP Off-Site 11/26/12 12/7/12 Charlotte, NCNCR01360 USACE - Nashville District CIP Off-Site 11/26/12 12/7/12 Charlotte, NCNCR01361 USACE - Savannah District CIP Off-Site 11/26/12 12/7/12 Charlotte, NCNCR01364 USACE - Wilmington District CIP Off-Site 11/26/12 12/7/12 Charlotte, NCNCR11109 USACE - Fort Worth Medium On-Site 11/27/12 11/29/12 Charleston, SCNCR01364 USACE - Wilmington District Medium On-Site 11/27/12 11/29/12 Wilmington, NCNCR08044 ConocoPhillips Company (SPP RE Lead) TBD TBD TBD TBDNCR05326 Powerex Corp. (WECC Lead) TBD TBD TBD TBDNCR00635 Tenaska Power Services Co. (MRO Lead) TBD TBD TBD TBD

Appendix 2 – Long-Term Audit Schedule for 2012-2019SERC Compliance Monitoring and Enforcement Program2012 Implementation PlanNovember 1, 2011

SERC 2012-2020 Audit ScheduleNERC ID#Registered Entities to be Audited (based onNERC Compliance Registry as of 9/27/11) 2012 2013 2014 2015 2016 2017 2018 2019 2020NCR11050 AL Sandersville, LLC XNCR01165 Alabama Municipal Electric Authority X XNCR01166 Alabama Power Company XNCR01168 Alcoa Power Generating, Inc. - Tapoco Division X X XNCR01169 Alcoa Power Generating, Inc. - Yadkin Division X X XNCR00667 Alcoa Power Generating, Inc. (RFC Lead) XNCR01170 Alcoa Power Marketing LLC (RFC Lead) XNCR00678 Ameren Energy Marketing Company X X XNCR10309 Ameren Energy Resources X X XNCR10248 Ameren Missouri X X XNCR01175 Ameren Services Company X X XNCR00683 American Municipal Power Inc. XNCR10081 ArcLight Energy Marketing, LLC (SERC Lead) X XNCR03049 Arlington Valley, LLC (WECC) (SERC Lead) X X XNCR01177 Associated Electric Cooperative, Inc. X X XNCR01178 Baconton Power LLC X XNCR09030 Barclays Bank PLC (NPCC Lead) XNCR01179 Batesville Balancing Authority 1 X X XNCR01180 Big Rivers Electric Corporation X X XNCR01181 Birchwood Power Partners LP XNCR01182 Black Warrior Electric Membership Corporation XNCR01183 Blue Ridge Electric Membership Corporation XNCR03033 Bluegrass Generation Company, LLC XNCR00693 BlueStar Energy Services, Inc. (RFC Lead) X XNCR05160 BNP Paribas Energy Trading GP (SERC Lead) X XNCR00005 BP Energy Company (FRCC Lead) XNCR01186 Brazos Electric Power Cooperative, Inc. XNCR00006 Calpine Corporation X XNCR01189 Calpine Energy Services X XNCR08080 CAMS - Mackinaw Power X XNCR11086 CAMS Bainbridge, LLC X XNCR11085 CAMS Discover, LLC X XNCR01066 Cargill Power Markets, LLC (MRO Lead) XNCR09001 Catalyst Old River Hydroelectric Limited Partnership XNCR01191 Central Electric Power Cooperative Inc. XNCR10390 CER Generation LLC XNCR10207 Choctaw Gas Generation, LLC X XNCR10206 Choctaw Generation Limited Partnership X XNCR10055 Citigroup Energy Inc. (WECC Lead) XNCR01192 Citizens Electric Corporation XNCR01193 City of Benton 1 X X XNCR01195 City of Camden XNCR01196 City of Columbia, MO X X XNCR01197 City of Concord XNCR01198 City of Conway 5 X X XNCR01199 City of Dalton d/b/a Dalton Utilities X XNCR09002 City of Manassas XNCR11091 City of North Little Rock, AR (DP, LSE) X XNCR01201 City of North Little Rock, AR 5 X X XNCR01202 City of Orangeburg Department of Public Utilities XNCR10383 City of Osceola 1 X X XNCR01203 City of Ruston, LA (DERS) 1 X X XNCR01328 City of Springfield, IL - CWLP X X XNCR08081 City of Troy, Alabama X XNCR11100 City of West Memphis (DP, LSE) XNCR01204 City of West Memphis 5 X X XNCR00499 Claiborne Electric Cooperative, Inc. XNCR08044 ConocoPhillips Company (SPP RE Lead) X XPage 1 of 5

SERC 2012-2020 Audit ScheduleNERC ID#Registered Entities to be Audited (based onNERC Compliance Registry as of 9/27/11) 2012 2013 2014 2015 2016 2017 2018 2019 2020NCR00015Constellation Energy Commodities Group, Inc. (RFCLead)XNCR00180 Constellation NewEnergy, Inc. (RFC Lead) XNCR11092 Conway Corporation X XNCR01210 Cottonwood Energy, LP X XNCR01211 Covanta, Fairfax, Inc. XNCR09021 CPI USA North Carolina, LLC (Roxboro) X XNCR09020 CPI USA North Carolina, LLC (Southport) X XNCR01212 Craven County Wood Energy Limited Partnership X XNCR00749 DB Energy Trading, LLC (RFC Lead) XNCR09003 DC Energy Mid-Atlantic, LLC (MRO Lead) X XNCR09004 DC Energy Midwest, LLC (MRO Lead) X XNCR09005 DC Energy, LLC (MRO Lead) X XNCR00443 Direct Energy Business, LLC (NPCC Lead) XNCR00416 Dixie Electric Membership Corporation XNCR00335 Dow Pipeline Company XNCR01216 Doyle l, LLC X XNCR11026 DTE Energy Supply, Inc. X XNCR00760 DTE Energy Trading, Inc. (NPCC Lead) XNCR01219 Duke Energy Carolinas X X XNCR09007 Duke Energy Generation Services, Inc. XNCR00200 Dynegy Midwest Generation, LLC (SERC Lead) X XNCR00201 Dynegy Power Marketing, Inc. (NPCC Lead) XNCR09008 E. I. du Pont de Nemours and Company XNCR01225 East Kentucky Power Cooperative X X XNCR01226 East Mississippi Electric Power Association XNCR01227 East Texas Electric Cooperative Inc. (SERC Lead) XNCR00551 EDF Trading North America, LLC (TexasRE Lead) X XNCR01228 Edgecombe Genco, LLC XNCR01229 Edgecombe Operating Services, LLC XNCR01230 Electric Energy, Inc. X X XNCR08084 Elizabethtown Energy XNCR00505 Endure Energy, LLC NPCC Lead) XNCR01232 EnergyUnited Electric Membership Corporation XNCR01234 Entergy X X XNCR11167 Entergy - Fossil & Hydroelectric Generation X X XNCR11166 Entergy - Nuclear X X XNCR00776 Exelon Energy Company (SERC Lead) XNCR01095 Exelon Generation Company LLC (RFC Lead) X XNCR00778 Exelon Generation Company, LLC - Exelon Nuclear X XNCR00128 ExxonMobil Corp - Baton Rouge X XNCR01239 ExxonMobil Oil Corporation - Beaumont Refinery XNCR01240 Fayetteville Public Works Commission XNCR01241 Florida Power & Light Company XNCR00026 Florida Reliability Coordinating Council, Inc. X X X XNCR01244 French Broad Electric Membership Corporation XGDF SUEZ Energy Marketing NA, Inc. (WECCNCR00626 Lead)XNCR11059 GDF SUEZ Energy Resources NA, Inc. X XNCR00396 GenOn Wholesale Generation (SERC Lead) X XNCR01247 Georgia Power Company XNCR01248 Georgia System Operations Corporation X X XNCR01249 Georgia Transmission Corporation X XNCR05169 Gila River Power (WECC) (SERC Lead) X X XNCR01250 Greenwood Commissioners of Public Works XNCR01251 Greenwood Utilities Commission XNCR03050 Griffith Energy, LLC (WECC) (SERC Lead) X X XPage 2 of 5

SERC 2012-2020 Audit ScheduleNERC ID#Registered Entities to be Audited (based onNERC Compliance Registry as of 9/27/11) 2012 2013 2014 2015 2016 2017 2018 2019 2020NCR01252 Gulf Power Company XNCR09032 Harrisonburg Electric Commission XNCR10293 Haywood Electric Membership Corporation XNCR01254 Henderson Municipal Power & Light X XNCR01255 Holland Energy, LLC XNCR00794 Hoosier Energy REC, Inc. XNCR01256 Hopewell Cogeneration, L.P. X XNCR11155 Hopewell Operating Services, LLC X XNCR01257 Hot Spring Power Company, LLC X XNCR00795 Illinois Municipal Electric Agency (RFC Lead) X XNCR00255 Integrys Energy Services, Inc. (NPCC Lead) XNCR00256 J. Aron & Company (MRO Lead) XNCR10263J.P. Morgan Ventures Energy Corporation(TexasRE Lead) X XNCR01262 James River Genco, LLC X XNCR10379 Kansas Energy, LLC (NPCC Lead) XNCR11015 Kentucky Municipal Power Agency XNCR09011 KGen Hinds LLC XNCR09012 KGen Hot Spring LLC XNCR09013 KGen Murray I and II LLC XNCR01223 LG&E and KU Services Company X X XNCR11154 Lively Grove Energy Partners, LLC XNCR11131 Lockhart Power Company XNCR11052 Lost Creek Wind, LLC X XNCR01265 Louisiana Generating, LLC X X XNCR01266 LSP Energy Limited Partnership X XNCR08085 Lumberton Energy, LLC XNCR08082 Mackinaw Power, LLC X XNCR11066 Memphis Light, Gas and Water Division X XNCR02800 Merrill Lynch Commodities, Inc. (SERC Lead) XNCR00167 Mid Georgia Cogen L.P. XNCR08083 MidAmerican Energy Company - Retail X XNCR00824 MidAmerican Energy Company (MRO Lead) X XNCR00826Midwest Independent Transmission SystemOperator Inc. 2 (RFC Lead) X X XNCR03044MISO - MBHydro Contingency Reserve SharingGroup (MRO Lead)XNCR01273 Mississippi Power Company XNCR00050 Morgan Stanley Capital Group, Inc. (FRCC Lead) XNCR01277 Mt. Carmel Public Utility Co. XNCR01278 Municipal Electric Authority of Georgia XNCR01283 NAES - Holland XNCR08086 NAES - Magnolia XNCR09018 NAES Corporation - Cottonwood X XNCR11012 NAES Corporation - Hinds XNCR11013 NAES Corporation - Hot Spring XNCR03032 NAES Corporation - Plum Point X XNCR11077 Nashville Electric Service XNCR10395 NaturEner Power Watch (WECC) (SERC Lead) X X XNCR09017 Nelson Industrial Steam Company XNCR02552 New Harquahala (WECC) (SERC Lead) X X XNCR10317NextEra Energy Power Marketing, LLC (SERCLead) X XNCR01243 NextEra Energy Resources, LLC X XNCR05385Noble American Energy Solutions, LLC (WECCLead)XNCR11019 Noble Americas Gas & Power Corp. (NPCC ?) XNCR01284 North Carolina Eastern Municipal Power Agency XNCR01279 North Carolina Electric Membership Corporation X XPage 3 of 5

SERC 2012-2020 Audit ScheduleNERC ID#Registered Entities to be Audited (based onNERC Compliance Registry as of 9/27/11) 2012 2013 2014 2015 2016 2017 2018 2019 2020NCR01285North Carolina Municipal Power Agency Number1(SERC Lead)XNCR11132 North Carolina State University XNCR11016 Northeast Louisiana Power Cooperative Inc. X XNCR10281 Northern Virginia Electric Cooperative XNCR09019 Occidental Chemical Corporation X XNCR10100 Occidental Power Services, Inc. (MRO Lead) XNCR01287 Oglethorpe Power Corporation X XNCR00859 Old Dominion Electric Cooperative (SERC Lead) X XNCR01290 Owensboro, KY Municipal Utilities X XNCR03041 Paducah Power System XNCR01292 Piedmont Electric Membership Corporation X XNCR01293 Piedmont Municipal Power Agny X XNCR00879 PJM Interconnection, LLC 2 (RFC Lead) X X XNCR10384 Plum Point Energy Associates (PPEA), LLC - BA 1 X X XNCR10385 Plum Point Energy Associates (PPEA), LLC - GO XNCR01206 Portsmouth Genco, LLC XNCR10294 Portsmouth Operating Services, LLC XNCR05326 Powerex Corp. (WECC Lead) X XNCR10203 PowerSouth Energy Cooperative X X XNCR09034 PPG Industries, Inc. XNCR00371 PPL EnergyPlus, LLC (RFC Lead) XNCR09035 Prairie Power, Inc. XNCR01296 Prairieland Energy Incorporated XNCR11002 Princeton Electric Plant Board X XNCR01298 Progress Energy Carolinas X X XNCR09036 RRI Energy Services, Inc. X XNCR00396 RRI Energy Wholesale Generation, LLC X XNCR01303 Rutherford Electric Membership Corporation XNCR01305 Sabine River Authority of TX/LA XNCR01307 Sam Rayburn G&T Electric Cooperative Inc. XNCR01309 Seneca Light and Water X XNCR11135 Settlers Trail Wind Farm LLC XShell Energy North America (US), L.P. (TexasRENCR05118 Lead) X XNCR00915 South Carolina Electric & Gas Company X X XNCR01312 South Carolina Public Service Authority X X XNCR01313 South Eastern Electric Development Corporation X XNCR01314 South Eastern Generating Corporation X XNCR00163 South Louisiana Electric Cooperative Association XNCR01315 South Mississippi Electric Power Association X X XNCR00070 Southeastern Power Administration X X XNCR01319 Southern Company Services, Inc. - Gen X X XNCR01320 Southern Company Services, Inc. - Trans X X XNCR01321 Southern Illinois Power Cooperative X X XNCR01322 Southern Power Company XSouthwest Louisiana Electric MembershipNCR10328 CorporationXNCR01143 Southwest Power Pool 4 (SERC lead) X X XNCR01323 Southwest Power Pool, Inc. - ICTE 4 X X XNCR01324 Southwestern Electric Cooperative, Inc. X XNCR01325 SOWEGA Power LLC X XNCR01329 Spruance Genco, LLC X XNCR01330 Spruance Operating Services, LLC X XNCR03043 TEE Contingency Reserve Sharing Group XNCR01334 Tenaska Alabama II Partners, L.P. X XPage 4 of 5

SERC 2012-2020 Audit ScheduleNERC ID#Registered Entities to be Audited (based onNERC Compliance Registry as of 9/27/11) 2012 2013 2014 2015 2016 2017 2018 2019 2020NCR01335 Tenaska Alabama Partners, L.P. X XNCR00632 Tenaska Frontier Partners, Ltd XNCR01337 Tenaska Georgia Partners, L.P. XNCR00635 Tenaska Power Services Co. (MRO Lead) X XNCR01339 Tenaska Virginia Partners, L.P. XNCR01151 Tennessee Valley Authority X X XNCR01341 Tennessee Valley Authority - TVAM XNCR01342Tex-La Electric Cooperative of Texas, Inc. (SERCLead)XNCR09037 The Dow Chemical Company X XNCR00076 The Energy Authority, Inc. (RFC Lead) XNCR11014 Tilton Energy, LLC XNCR09026 Town of Culpeper Light & Power X XNCR01348 Town of Sharpsburg X XNCR01349 Town of Stantonsburg XNCR01350 Town of Waynesville X XNCR01352 Town of Winterville X XNCR08074 TransAlta Energy Marketing (U.S) Inc. (RFC Lead) XNCR11108 Twin Eagle Resource Management, LLC XNCR01354 Union Power Partners, L.P. X XNCR01355 Union Power Partners, L.P. (PUPP) 1 X X XNCR01356 USACE - Charleston District X XNCR11109 USACE - Fort Worth Distric X XNCR01359 USACE - Mobile District X XNCR01360 USACE - Nashville District X XNCR01361 USACE - Savannah District X XNCR01364 USACE - Wilmington District X XNCR01365 VACAR South X X XVirginia Electric & Power Company (PSE) (SERCNCR00938 Lead) X XNCR09028Virginia Electric and Power Company – Fossil andHydro (GO, GOP) X XNCR09006Virginia Electric and Power Company – Nuclear(GO, GOP) X XNCR01214Virginia Electric and Power Company (DP, LSE, TO,TP) X XNCR00940 Wabash Valley Power Association, Inc. (RFC Lead) X XNCR11101 Wells Fargo Commodities, LLCNCR00658 Westar Energy, Inc. (SPP Lead) XNCR01370 Westmoreland Partners X XNCR10386 WGPPS Hardin County Peaking Facility XNCR10387 WGPPS San Jacinto County Peaking Facility XFootnotes:1. Constellation - All entities will be audited at thesame time.2. All functions audited by RFC with SERCparticipation.3. All functions audited by MRO with SERCparticipation.4. Audited by SERC with MRO participation.5. Audited with LAGenLegendMRRE or potential MRRE- all functions audited by adesignated region for all appplicable regionsPage 5 of 5

Appendix 3 – Reliability Standards Included in the SERC 2012Annual CMEP Implementation Plan and SERC Filing Due DatesSERC Compliance Monitoring and Enforcement Program2012 Implementation PlanNovember 1, 2011

Reliability Standards Included in the NERC & SERC 2012 CMEP (Revised 1-17-12)Audit 1Tier 1Audit 1Tier 2Audit 1Tier 3StandardNumber Title Applicable Function(s)Resource and Demand BalancingBAL-001-0.1a Real Power Balancing Control PerformanceBA √ MBAL-002-0BAL-003-0.1bBAL-004-0BAL-006-2CommunicationsCOM-001-1.1COM-002-2Critical Infrastructure ProtectionCIP-001-2aCIP-002-3CIP-003-3CIP-004-3CIP-005-3aCIP-006-3cCIP-007-3CIP-008-3CIP-009-3Disturbance Control PerformanceFrequency Response and BiasTime Error CorrectionInadvertent InterchangeTelecommunicationsCommunications and CoordinationSabotage ReportingCritical Cyber Asset IdentificationSecurity Management ControlsPersonnel & TrainingElectronic Security Perimeter(s)Physical Security of Critical Cyber AssetsSystems Security ManagementIncident Reporting and Response PlanningRecovery Plans for Critical Cyber AssetsEmergency Preparedness and OperationsEOP-001-0EOP-002-3Emergency Operations PlanningCapacity and Energy EmergenciesSelf-Certification 2Periodic Data Submittal(M: Monthly, Q: Quarterly,B: Bi-Annual, A: Annual)BA, RSG √ √ √ QBA √ √ A √BA, RCBA M √BA, RC, TOP √ √ √ √BA, GOP, RC, TOP √ √ √BA, GOP, LSE, RC, TOP √ √ √BA, GO, GOP, IA, LSE, RC,RE, TO, TOP, TSP √ √ √BA, GO, GOP, IA, LSE, RC,RE, TO, TOP, TSP √ √ √ √BA, GO, GOP, IA, LSE, RC,RE, TO, TOP, TSP √ √BA, GO, GOP, IA, LSE, RC,RE, TO, TOP, TSP √ √ √BA, GO, GOP, IA, LSE, RC,RE, TO, TOP, TSP √ √ √BA, GO, GOP, IA, LSE, RC,RE, TO, TOP, TSP √ √ √BA, GO, GOP, IA, LSE, RC,RE, TO, TOP, TSP √ √ √BA, GO, GOP, IA, LSE, RC,RE, TO, TOP, TSP √ √ √BA, TOP √ √ √ √BA, LSE, RC √ √ √Exception Reporting 3√Spot Check 1NotesPeriodic Data Submittal collected by ReliabilityServices department.Periodic Data Submittal collected by ReliabilityServices department.Page 1 of 5

Reliability Standards Included in the NERC & SERC 2012 CMEP (Revised 1-17-12)StandardNumber Title Applicable Function(s)EOP-003-1EOP-004-1EOP-005-1EOP-006-1EOP-008-0Load Shedding PlansDisturbance ReportingSystem Restoration PlansReliability Coordination - System RestorationPlans for Loss of Control Center FunctionalityAudit 1Tier 1Audit 1Tier 2Audit 1Tier 3BA, TOP √ √Self-Certification 2Periodic Data Submittal(M: Monthly, Q: Quarterly,B: Bi-Annual, A: Annual)BA, GOP, LSE, RC, TOP √ √ √BA, TOP √ √ √ √RC √ √ √BA, RC, TOP √ √ √ √EOP-009-0 Documentation of Blackstart Generating Unit Test Results GO, GOP √ AFacilities Design, Connections, and MaintenanceFAC-001-0FAC-002-1FAC-003-1FAC-008-1FAC-009-1Facility Connection RequirementsTO √ √ √Coordination of Plans For New Generation, Transmission,and End-User Facilities DP, GO, LSE, PA, TO, TP √ √ √Transmission Vegetation Management ProgramFacility Ratings MethodologyEstablish and Communicate Facility RatingsInterchange Scheduling and CoordinationINT-001-3INT-003-3Interchange InformationInterchange Transaction ImplementationInterconnection Reliability Operations and CoordinationIRO-002-2IRO-004-2IRO-005-3aReliability Coordination — FacilitiesReliability Coordination - Operations PlanningReliability Coordination – Current-Day OperationsTO √ √ √ QGO, TO √ √ √GO, TO √ √BA, PSEBARC √ √ √BA, TOP, TSP √ √ √BA, GOP, LSE, PSE, RC, TOP,TSP √ √ √ √IRO-006-5 Reliability Coordination - Transmission Loading Relief (TLR) BA, RC √Exception Reporting 3√√Spot Check 1NotesPeriodic Data Submittal collected by ReliabilityServices department.IRO-009-1Reliability Coordinator Actions to Operate Within IROLsRC √ √Page 2 of 5

Reliability Standards Included in the NERC & SERC 2012 CMEP (Revised 1-17-12)StandardNumber Title Applicable Function(s)Audit 1Tier 1Audit 1Tier 2Audit 1Tier 3Procedures, Processes, or Plans to Support CoordinationIRO-014-1Between Reliability Coordinators RC √ √Modeling, Data, and AnalysisMOD-001-1aMOD-004-1MOD-008-1MOD-010-0MOD-012-0MOD-024-1MOD-025-1MOD-028-1MOD-029-1aMOD-030-2Available Transmission System CapabilityCapacity Benefit MarginTransmission Reliability Margin Calculation MethodologySteady-State Data for Modeling and Simulation of theInterconnected Transmission SystemTOP, TSP √ √BA, LSE, RP, TP, TSP √ √TOP √ √GO, RP, TO, TPSelf-Certification 2Periodic Data Submittal(M: Monthly, Q: Quarterly,B: Bi-Annual, A: Annual)Dynamics Data for Modeling and Simulation of theInterconnected Transmission SystemGO, RP, TO, TPAVerification of Generator Gross and Net Real PowerCapability GO AVerification of Generator Gross and Net Reactive PowerCapability GO AArea Interchange MethodologyRated System Path MethodologyFlowgate MethodologyPersonnel Performance, Training, and QualificationsNUC-001-2Nuclear Plant Interface CoordinationPersonnel Performance, Training, and QualificationsPER-001-0.1PER-002-0PER-003-0PER-005-1Protection and ControlOperating Personnel Responsibility and AuthorityOperating Personnel TrainingOperating Personnel CredentialsSystem Personnel TrainingTOP, TSPTOP, TSPTOP, TSPBA, DP, GO, GOP, LSE, PA,RC, TO, TOP, TP, TSP √ √ √BA, TOPBA, TOP √ √ √BA, RC, TOP √ √BA, RC, TOP√√√√√AException Reporting 3Spot Check 1NotesCollected by Regional studies groups andReliability Assessments staff pursuant to theSystem Modeling Data RequirementsRegional Criteria.Collected by Regional studies groups andReliability Assessments staff pursuant to theSystem Modeling Data RequirementsRegional Criteria.Periodic Data Submittal collected by ReliabilityAssessments department.Periodic Data Submittal collected by ReliabilityAssessments department.Page 3 of 5

Reliability Standards Included in the NERC & SERC 2012 CMEP (Revised 1-17-12)StandardNumber Title Applicable Function(s)PRC-001-1PRC-004-1PRC-005-1PRC-007-0PRC-008-0PRC-011-0PRC-015-0PRC-016-0.1PRC-017-0PRC-018-1PRC-021-1PRC-023-1Transmission OperationsTOP-001-1TOP-002-2aTOP-004-2TOP-005-2aTOP-007-0TOP-008-1Audit 1Tier 1Audit 1Tier 2Audit 1Tier 3System Protection CoordinationBA, GOP, TOP √ √ √Analysis and Mitigation of Transmission and GenerationProtection System Misoperations DP, GO, TO √ √Transmission and Generation Protection SystemMaintenance and Testing DP, GO, TO √ √ √Assuring Consistency with Regional UFLS ProgramRequirements DP, LSE, TO, TOP √Underfrequency Load Shedding Equipment MaintenancePrograms DP, TO √ √Undervoltage Load Shedding System Maintenance andTesting DP, TO √ √Special Protection System Data and DocumentationSpecial Protection System MisoperationsSpecial Protection System Maintenance and TestingDisturbance Monitoring Equipment Installation and DataReportingUnder-Voltage Load Shedding Program DataTransmission Relay LoadabilityReliability Responsibilities and AuthoritiesNormal Operations PlanningTransmission OperationsOperational Reliability InformationReporting SOL and IROL ViolationsResponse to Transmission Limit ViolationsDP, GO, TODP, GO, TODP, GO, TO √ √GO, TODP, TODP, GO, PA, TO √ √ √BA, DP, GOP, LSE, TOPBA, GOP, LSE, TOP, TSP √ √ √TOP √ √ √ √Self-Certification 2√Periodic Data Submittal(M: Monthly, Q: Quarterly,B: Bi-Annual, A: Annual)BA, PSE, TOP √ √RC, TOP √ √ √ √TOP√√BAAAAAException Reporting 3√Spot Check 1NotesPeriodic Data Submittal collected by ReliabilityServices department.Periodic Data Submittal collected by ReliabilityAssessments department.Periodic Data Submittal collected by ReliabilityAssessments department.Periodic Data Submittal collected by ReliabilityServices department.Periodic Data Submittal collected by ReliabilityServices department.Periodic Data Submittal collected by ReliabilityAssessments department.Page 4 of 5

Reliability Standards Included in the NERC & SERC 2012 CMEP (Revised 1-17-12)StandardNumber Title Applicable Function(s)Transmission PlanningAudit 1Tier 1Audit 1Tier 2Audit 1Tier 3Self-Certification 2Periodic Data Submittal(M: Monthly, Q: Quarterly,B: Bi-Annual, A: Annual)Exception Reporting 3Spot Check 1NotesTPL-001-0.1TPL-002-0aTPL-003-0aSystem Performance Under Normal ConditionsPA, TPASystem Performance Following Loss of a Single BESElement PA, TP √ √ ASystem Performance Following Loss of Two or More BESElements PA, TP √ √ √ ATPL-004-0Voltage and ReactiveSystem Performance Following Extreme BES EventsPA, TP √ √ AVAR-001-2VAR-002-1.1bVoltage and Reactive ControlLSE, PSE, TOP √ √ √Generator Operation for Maintaining Network VoltageSchedules GO, GOP √ √ √Additional monitoring by SERC1 The scope of audits and spot checks will be on a requirement basis as set forth in the 2012Actively Monitored Reliability Standards spreadsheet posted with the NERC implementationplan. Regional Entity audit teams are authorized and obligated to expand the scope of acompliance audit to include Tier 2 and Tier 3 Requirements and any other requirements theymay deem necessary based on the results of the Registered Entity Profile Assessment or theaudit team’s collective professional judgment.2 Self-Certifications cover all requirements applicable to the Registered Entity.3 There is no specific form or template for Exception Reporting. Registered Entities shouldself report, using the portal Self-Report form, any possible violations of Reliability Standardsmonitored through Exception Reporting. Submittal by Registered Entities of self-certificationsfor these standards indicating the Registered Entity is “Compliant” will serve as a declarationby the Registered Entity that it has had no exceptions to the designated Reliability StandardRequirements during the reporting period (a zero-exception report).Added Self CertificationAdded Periodic Data SubmittalPage 5 of 5

SERC Filing Due Dates (Revised 1-17-12)SERC Filing Due Dates2011 Compliance Program for Self-Certifications (filing deadlines in 2012)StandardApplicable Function(s)***Number Title Due Date* Reporting Period** Reqt's BA DP GO GOP IA LSE PA PSE RC RP RSG TO TOP TP TSPCritical Infrastructure ProtectionCIP-002-3CIP-003-3CIP-004-3CIP-005-3CIP-006-3aCIP-007-3CIP-008-3Critical Cyber Asset IdentificationSecurity Management ControlsPersonnel & TrainingElectronic Security Perimeter(s)Physical Security of Critical Cyber AssetsSystems Security ManagementIncident Reporting and Response Planning1/31/2012 10/1/2010 - 12/31/2011 All BA GO GOP IA LSE RC TO TOP TSP1/31/2012 10/1/2010 - 12/31/2011 All BA GO GOP IA LSE RC TO TOP TSP1/31/2012 10/1/2010 - 12/31/2011 All BA GO GOP IA LSE RC TO TOP TSP1/31/2012 10/1/2010 - 2/1/2011 All BA GO GOP IA LSE RC TO TOP TSP1/31/2012 10/1/2010 - 5/18/2011 All BA GO GOP IA LSE RC TO TOP TSP1/31/2012 10/1/2010 - 12/31/2011 All BA GO GOP IA LSE RC TO TOP TSP1/31/2012 10/1/2010 - 12/31/2011 All BA GO GOP IA LSE RC TO TOP TSPCIP-009-3Recovery Plans for Critical Cyber AssetsPersonnel Performance, Training, and Qualifications1/31/2012 10/1/2010 - 12/31/2011 All BA GO GOP IA LSE RC TO TOP TSPPER-002-0Operating Personnel Training1/31/2012 1/1/2011 - 12/31/2011 All BA TOPPER-004-1Reliability Coordination – Staffing1/31/2012 1/1/2011 - 3/31/2011 All RCAnnual Self-Certification of Monthly and Quarterly Data SubmittalsBAL-001-0.1aBAL-002-0IRO-004-2PER-003-0TOP-007-0Real Power Balancing Control PerformanceDisturbance Control PerformanceReliability Coordination - Operations PlanningOperating Personnel CredentialsReporting SOL and IROL Violations1/31/2012 1/1/2011 - 12/31/2011 All BA1/31/2012 1/1/2011 - 12/31/2011 All BA RSG1/31/2012 1/1/2011 - 12/31/2011 All BA TOP TSP1/31/2012 1/1/2011 - 12/31/2011 All BA RC TOP1/31/2012 1/1/2011 - 12/31/2011 All RC TOPPage 1 of 4

SERC Filing Due Dates (Revised 1-17-12)SERC Filing Due Dates2012 Compliance Program for Self-Certifications (filing deadlines in 2012)StandardNumber Title Due Date* Reporting Period**Resource and Demand BalancingApplicable Function(s)***Reqt's BA DP GO GOP IA LSE PA PSE RC RP RSG TO TOP TP TSPBAL-003-0.1bCommunicationsCOM-001-1.1Frequency Response and BiasTelecommunications10/1/2012 8/1/2011 - 7/31/2012 All BA10/1/2012 8/1/2011 - 7/31/2012 All BA RC TOPCOM-002-2Communications and CoordinationCritical Infrastructure ProtectionCIP-001-2aSabotage ReportingEmergency Preparedness and Operations10/1/2012 8/1/2011 - 7/31/2012 All BA GOP RC TOP10/1/2012 10/1/2011 - 7/31/2012 All BA GOP LSE RC TOPEOP-001-0EOP-005-1Emergency Operations PlanningSystem Restoration Plans10/1/2012 8/1/2011 - 7/31/2012 All BA TOP10/1/2012 8/1/2011 - 7/31/2012 All BA TOPEOP-008-0 Plans for Loss of Control Center FunctionalityEOP-009-0 Documentation of Blackstart Generating Unit Test ResultsFacilities Design, Connections, and Maintenance10/1/2012 8/1/2011 - 7/31/2012 All BA RC TOP10/1/2012 8/1/2011 - 7/31/2012 All GO GOPFAC-003-1FAC-008-1Vegetation Management ProgramFacility Ratings Methodology6/1/2012 4/1/2011 - 3/31/2012 All TO6/1/2012 4/1/2011 - 3/31/2012 All GO TOFAC-009-1Establish and Communicate Facility RatingsInterconnection Reliability Operations and Coordination6/1/2012 4/1/2011 - 3/31/2012 All GO TOIRO-004-2Reliability Coordination - Operations Planning10/1/2012 10/1/2011 - 7/31/2012 All BA TOP TSPIRO-005-3aModeling, Data, and AnalysisReliability Coordination - Current-Day Operations10/1/2012 10/1/2011 - 7/31/2012 All BA GOP LSE PSE RC TOP TSPMOD-001-1aAvailable Transmission System Capability10/1/2012 8/1/2011 - 7/31/2012 All TOP TSPMOD-004-1Capacity Benefit Margin10/1/2012 8/1/2011 - 7/31/2012 All BA LSE RP TP TSPTransmission Reliability Margin CalculationMOD-008-1Methodology 10/1/2012 8/1/2011 - 7/31/2012 All TOPProtection and ControlPRC-001-1PRC-004-1PRC-005-1PRC-007-0PRC-008-0PRC-011-0System Protection Coordination6/1/2012 4/1/2011 - 3/31/2012 All BA GOP TOPAnalysis and Mitigation of Transmission andGeneration Protection System Misoperations 6/1/2012 4/1/2011 - 3/31/2012 All DP GO TOTransmission and Generation Protection SystemMaintenance and Testing 6/1/2012 4/1/2011 - 3/31/2012 All DP GO TOAssuring Consistency with Regional UFLS ProgramRequirements 6/1/2012 4/1/2011 - 3/31/2012 All DP LSE TO TOPUnderfrequency Load Shedding EquipmentMaintenance Programs 6/1/2012 4/1/2011 - 3/31/2012 All DP TOUndervoltage Load Shedding System Maintenanceand Testing 6/1/2012 4/1/2011 - 3/31/2012 All DP TOPRC-017-0PRC-021-1Special Protection System Maintenance and TestingUnder-Voltage Load Shedding Program Data6/1/2012 4/1/2011 - 3/31/2012 All DP GO TO6/1/2012 4/1/2011 - 3/31/2012 All DP TOPRC-023-1Transmission OperationsTransmission Relay Loadability6/1/2012 4/1/2011 - 3/31/2012 All DP GO TOTOP-002-2aTOP-004-2Transmission PlanningNormal Operations PlanningTransmission Operations10/1/2012 8/1/2011 - 7/31/2012 All BA GOP LSE TOP TSP10/1/2012 8/1/2011 - 7/31/2012 All TOPTPL-001-0.1TPL-002-0aTPL-003-0aSystem Performance Under Normal Conditions6/1/2012 4/1/2011 - 3/31/2012 All PA TPSystem Performance Following Loss of a Single BESElement 6/1/2012 4/1/2011 - 3/31/2012 All PA TPSystem Performance Following Loss of Two or MoreBES Elements 6/1/2012 4/1/2011 - 3/31/2012 All PA TPTPL-004-0Voltage and ReactiveSystem Performance Following Extreme BES Events6/1/2012 4/1/2011 - 3/31/2012 All PA TPVAR-001-2VAR-002-1.1bVoltage and Reactive Control10/1/2012 10/1/2011 - 7/31/2012 All PSE TOPGenerator Operation for Maintaining NetworkVoltage Schedules 10/1/2012 10/1/2011 - 7/31/2012 All GO GOPPage 2 of 4

Resource and Demand BalancingSERC Filing Due Dates (Revised 1-17-12)SERC Filing Due Dates2012 Compliance Program for Data Submittals (filing deadlines in 2012)BAL-001-0.1aReal Power Balancing Control PerformanceMonthly Previous Month All BABAL-002-0Disturbance Control PerformanceFacilities Design, Connections, and MaintenanceFAC-003-1Vegetation Management ProgramTransmission PlanningQuarterly Previous Quarter All BA RSGQuarterly Previous Quarter 3 TOTPL-001-0.1TPL-002-0aTPL-003-0aSystem Performance Under Normal Conditions6/1/2012 4/1/2011 - 3/31/2012 3 PA TPSystem Performance Following Loss of a Single BESElement 6/1/2012 4/1/2011 - 3/31/2012 3 PA TPSystem Performance Following Loss of Two or MoreBES Elements 6/1/2012 4/1/2011 - 3/31/2012 3 PA TPTPL-004-0 System Performance Following Extreme BES Events6/1/2012 4/1/2011 - 3/31/2012 2 PA TPCritical Infrastructure Protection2012 Compliance Program for Self-Certifications (filing deadlines in 2013)CIP-002-3CIP-003-3CIP-004-3CIP-005-3aCIP-006-3cCIP-007-3CIP-008-3Critical Cyber Asset IdentificationSecurity Management ControlsPersonnel & TrainingElectronic Security Perimeter(s)Physical Security of Critical Cyber AssetsSystems Security ManagementIncident Reporting and Response Planning1/31/2013 1/1/2012 - 12/31/2012 All BA GO GOP IA LSE RC TO TOP TSP1/31/2013 1/1/2012 - 12/31/2012 All BA GO GOP IA LSE RC TO TOP TSP1/31/2013 1/1/2012 - 12/31/2012 All BA GO GOP IA LSE RC TO TOP TSP1/31/2013 2/2/2011 - 12/31/2012 All BA GO GOP IA LSE RC TO TOP TSP1/31/2013 5/19/2011 - 12/31/2012 All BA GO GOP IA LSE RC TO TOP TSP1/31/2013 1/1/2012 - 12/31/2012 All BA GO GOP IA LSE RC TO TOP TSP1/31/2013 1/1/2012 - 12/31/2012 All BA GO GOP IA LSE RC TO TOP TSPCIP-009-3Recovery Plans for Critical Cyber Assets1/31/2013 1/1/2012 - 12/31/2012 All BA GO GOP IA LSE RC TO TOP TSPInterconnection Reliability Operations and Coordination and Transmission OperationsIRO-004-2Reliability Coordination - Operations Planning1/31/2013 1/1/2012 - 12/31/2012 All BA TOP TSPTOP-007-0Reporting SOL and IROL ViolationsPersonnel Performance, Training, and Qualifications1/31/2013 1/1/2012 - 12/31/2012 All RC TOPPER-002-0Operating Personnel Training1/31/2013 1/1/2012 - 12/31/2012 All BA TOPPER-003-0Operating Personnel Credentials1/31/2013 1/1/2012 - 12/31/2012 All BA RC TOPAnnual Self-Certification of Monthly and Quarterly Data SubmittalsBAL-001-0.1aBAL-002-0Real Power Balancing Control PerformanceDisturbance Control Performance1/31/2013 1/1/2012 - 12/31/2012 All BA1/31/2013 1/1/2012 - 12/31/2012 All BA RSGPage 3 of 4

Resource and Demand BalancingSERC Filing Due Dates (Revised 1-17-12)SERC Filing Due DatesData Submittal Reporting Requirements(will be posted to the portal by Reliability Services or Reliability Assessments)2012 Program (filing deadlines in 2012)BAL-003-0.1bEOP-009-0MOD-010-0Form: Frequency ResponseEmergency Preparedness and OperationsModeling, Data, and AnalysisMOD-012-0Form: BlackstartSteady-State Data for for Modeling and Simulationof the Interconnected Transmission SystemDynamics Data for for Modeling and Simulation ofthe Interconnected Transmission System12/15/2012 --- All BA10/1/2012 --- All GO GOPSee System Modeling Data RequirementsRegional Criteria document for dates andsubmittal requirements.See System Modeling Data RequirementsRegional Criteria document for dates andsubmittal requirements.All GO RP TO TPAll GO RP TO TPMOD-024-1Form: Generator Testing, Real6/1/2012 --- All GOMOD-025-1Protection and ControlForm: Generator Testing, Reactive6/1/2012 --- All GOPRC-004-1Form: Protection System Misoperations2/28/20125/31/20128/31/201211/30/2012before 12/31/20111/1/2012 – 4/30/20125/1/2012 – 6/30/20127/1/2012 – 9/30/2012DP GO TOPRC-007-0Form: UFLS6/1/2012 --- All DP LSE TO TOPPRC-015-0 Form: SPS Summary 6/1/2012 --- DP GO TOPRC-016-0.1 Form: SPS Misoperations 6/1/2012 --- DP GO TOPRC-018-1 Form: Disturbance Monitoriing Equipment 6/1/2012 --- GO TOPRC-021-1Reliability AssessmentsForm: UVLS6/1/2012 --- All DP TOLong Term Reliability Assessments Data 2/17/2012 2011-2022 BA GOP LSE TO TOPSummer Assessment Data 2/17/2012 6/1/2012 - 9/30/2012 BA GOP LSE TO TOPWinter Assessment Data8/17/2012(tentative)12/1/2012 - 2/28/2013 BA GOP LSE TO TOP* Due dates are subject to change with advance notice provided by SERC to registered entities.** Period of time covered by the self-certification or data submittal. The end date of the reporting periodis subject to change if a new version of the standard is approved by FERC.*** The listing of applicable functions is provided as a convenience. The applicability section of the reliability standardsets forth the function types for which the standard applies.Page 4 of 4

Revision HistoryRevision HistoryRevisionNumber Date Description0 10/7/2011 Initial draft version – sent to NERC for approval.1 11/1/2011 Final version – posted on SERC website.2 1/17/2012Revised Appendix 3 to correct description of datacollection for MOD-010 and MOD-012 and to includeIRO-009-1 in the Audit Tier 2 and Tier 3 category.SERC Compliance Monitoring and Enforcement Program2012 Implementation PlanNovember 1, 2011