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2011 SERC CMEP Implementation Plan - SERC Home Page

2011 SERC CMEP Implementation Plan - SERC Home Page

Section 7:

Section 7: 2011 Program Implementation - EnforcementRegistered Entities are required to certify completion of the Mitigation Plan and toprovide supporting evidence. Compliance staff reviews supplied evidence to determinewhether the approved Mitigation Plan has been implemented as agreed upon and hasrestored compliance. Staff will initiate new enforcement action in those cases where aRegistered Entity does not complete Mitigation Plan actions on time or cannotdemonstrate current compliance through evidence.4. HearingsIn those cases where a Registered Entity chooses to contest the alleged violation,proposed penalty, remedial action directive, or the region’s rejection of a Mitigation Plan,the Registered Entity can request a hearing. Requirements regarding staff andRegistered Entity actions and associated timing are detailed in the NERC CMEP andassociated implementing procedures. The Board Compliance Committee or a subset ofthe Board Compliance Committee will serve as the hearing body.SERC Compliance Monitoring and Enforcement Program2011 Implementation PlanDecember 1, 2010 (Rev. December 10, 2010) 21

Section 8: Key CMEP Activities and InitiativesKey CMEP Activities and InitiativesSERC is committed to continuous improvement of the CMEP implementation. To thatend, SERC solicits feedback from Registered Entities, NERC staff, the BoardCompliance Committee, and other stakeholders seeking suggestions for improvementsto SERC’s processes. During 2011, 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 theCMEP. The Compliance Issues Tracking System (CITS), launched in 2010, is aRegional Entity application that incorporates all aspects of violation tracking includingreporting, determination, mitigation, penalties, and settlement. Registered Entitiesinterface with the CITS application through the SERC Portal by submitting selfcertification, self report, complaint, and mitigation forms. The mitigation forms includemilestone updates, extensions, and certification of closure.Standards, registration, and violations data are transferred electronically between SERCand NERC. This electronic exchange of data promotes uniformity, improves dataquality, and supports timely reporting. As SERC staff gains more experience with theCITS system, the quality and efficiency of the processing of possible violations willcontinue 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 fromRegistered Entities, particularly in the development of a comprehensive determination ofthe scope of any violations and the potential risk to reliability of the violation.2. Effectiveness/Quality InitiativesSERC staff will undertake a review of its key compliance processes to identifyopportunities for improvements in the effectiveness and quality of the processes. Theseactivities will be targeted towards identification of deficiencies and enhancements,relevant performance measures, and the development of appropriate improvementplans. SERC staff will initiate and/or build on previously initiated self-improvementactivities through additional benchmarking activities to indentify best practices that canbe deployed. Benchmarking will be focused on techniques in use by other regions onkey processes.3. Outreach ActivitiesOutreach is an important element of SERC’s compliance mission. It serves to enhanceawareness, improve transparency of compliance processes and promote reliabilityexcellence. Focus areas for SERC outreach activities will include information on CMEPprocesses, Reliability Standards education materials, compliance application ofStandards, lessons learned, guidance on developing a culture of compliance,preparation for audits, use of the SERC Portal, and sharing of experiences and goodpractices among Registered Entities.SERC Compliance Monitoring and Enforcement Program2011 Implementation PlanDecember 1, 2010 (Rev. December 10, 2010) 22

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