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2011 SERC CMEP Implementation Plan - SERC Home Page

2011 SERC CMEP Implementation Plan - SERC Home Page

Section 5:

Section 5: 2011 CMEP Discovery Methods2011 CMEP Discovery MethodsReliability Standards included in the NERC 2011 Compliance Monitoring andEnforcement Program are approved by the appropriate regulatory authority and aresubject to the CMEP. NERC staff performed a detailed assessment of all of theapproved Reliability Standards to identify the risk-based Reliability Standards for NorthAmerica wide consideration based on the multiple inputs outlined in the criteria listedbelow:• High Violation Risk Factor; 4• NERC top ten list of most violated Reliability Standards;• Regional Entity’s top ten list;• History of past events and major reliability issues;• Violation Risk Index (top five);• Review of the Final Report on the August 14, 2003 Blackout;• A review of violation statistics and trends.NERC staff worked in close coordination with the Regions to further refine the list anddetermine appropriate monitoring methods for the Reliability Standards selected using arisk based approach.NERC and the Regional Entities have processes in place to implement each compliancemonitoring method as appropriate to a given set of facts and circumstances. In 2011,the compliance monitoring methods will be implemented as stated below:1. Compliance AuditsAll FERC-approved Reliability Standards applicable to the Registered Entity based onregistered functions are subject to audit. The subset of Reliability Standards /requirements designated for audit in the 2011 NERC CMEP Implementation Plan willserve as the default scope for SERC audits, in addition to any Reliability Standards forwhich a mitigation plan has been completed by the Registered Entity within the 12months prior to the date of the audit detail letter. See the NERC 2011 ActivelyMonitored Reliability Standards spreadsheet for the breakdown by requirement of thescope for audits. Additional applicable requirements may be added to audit scopebased on the risk-based and performance criteria set forth in the Reliability StandardsSubject to 2011 CMEP Implementation section above. If the audit scope differs from the4 “Each requirement set out within NERC’s Reliability Standards has been assigned a Violation Risk Factor(VRF) through the NERC Reliability Standards development process. The factors have been defined andapproved through the standards development process and are assigned to requirements to provide clear,concise and comparative association between the violation of a requirement and the expected or potentialimpact of the violation to the reliability of the bulk electric system. One of three defined levels of risk isassigned to each standards requirement: Lower Risk Factor, or; Medium Risk Factor, or; High Risk Factor.Definitions of the factors can be found in appropriate standards development process documentation.”Rules of Procedure Paragraph 4.1.1 the link:http://www.nerc.com/files/NERC_Rules_of_Procedure_EFFECTIVE_20090616.pdf#page=172.SERC Compliance Monitoring and Enforcement Program2011 Implementation PlanDecember 1, 2010 (Rev. December 10, 2010) 11

Section 5: 2011 CMEP Discovery MethodsActively Monitored Reliability Standards, SERC will provide to the Registered Entity thescope of the compliance audit with the audit detail letter, including SERC’s analysis of itsrisk and performance based approach which determined the additional audit scopeapplied to the Registered Entity being audited.If a Registered Entity has an open Mitigation Plan, the audit team will review MitigationPlan milestone completion during the compliance audit to verify that the milestones havebeen satisfactorily completed, ensuring that the plan is on schedule for timelycompletion.If an Entity has certified a Mitigation Plan as being completed within 90 days of the auditstart date, the audit team will verify satisfactory completion of the Mitigation Plan duringthe compliance audit.a. Modeling, Data, and Analysis (MOD) Reliability StandardsThe Modeling, Data, and Analysis (MOD) Reliability Standards (MOD-001-1, 004-1, 008-1, 028-1, 029-1, and 030-2) become effective April 1, 2011. For applicable RegisteredEntities, SERC will include MOD-001-1, MOD-004-1 and MOD-008-1 in the complianceaudit scope when the MOD Reliability Standards become effective.SERC will include MOD-028-1, MOD-029-1, and MOD-030-1 in the audit scope of allapplicable entities being audited in 2011. Because the number of requirements andsupporting requirements that must be evaluated during review of these standards isquite extensive, the audit team will typically include an additional sub-team dedicated tothe MOD standards and, perhaps, a few additional standards.b. PRC-023-1 Reliability StandardPRC-023-1 Reliability Standard was initially effective in July of 2010, but was notincluded in the compliance audit scope for 2010. Therefore, NERC and the RegionalEntities determined it is appropriate to include PRC-023-1, Requirement 1 in thecompliance audit monitoring program for 2011. The remaining requirements are subjectto other compliance monitoring methods at the Regional Entities’ discretion.SERC will typically only audit Requirement 1 of PRC-023-1. Once registration ofPlanning Coordinators has been completed and an approved criteria document forPlanning Coordinators to use in determining which of the facilities in its PlanningCoordinator area are critical to the reliability of the BES has been developed,Requirements 2 and 3 may be added to the audit scope.c. CIP Reliability Standards Compliance AuditsAt the end of 2010, all scheduled activities described in the “Implementation Plan forReliability Standards CIP-002-1 through CIP-009-1,” 5 will be complete and RegisteredEntities are subject to audits for compliance with all requirements of CIP-002-3 throughCIP-009-3 (CIP Standards). The 2011 CIP compliance audits will cover only the periodwhen version 3 was in effect (October 1, 2010 through the date of the compliance audit).5 http://www.nerc.com/files/Guidance_on_CIP_Standards.pdf.SERC Compliance Monitoring and Enforcement Program2011 Implementation PlanDecember 1, 2010 (Rev. December 10, 2010) 12

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