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2011 SERC CMEP Implementation Plan - SERC Home Page

2011 SERC CMEP Implementation Plan - SERC Home Page

Section 1:

Section 1: SERC Compliance Monitoring and Enforcement Program• Transparency of processes and results (within confidentiality constraints)D. SERC Compliance Monitoring and Enforcement ProgramAs a regional entity, SERC Reliability Corporation (SERC), through its complianceorganization, adopts and implements the NERC Compliance Monitoring andEnforcement Program (CMEP) (Appendix 4C to the NERC Rules of Procedure) tomonitor, assess and enforce compliance with Reliability Standards by the users, owners,and operators of the bulk power system in SERC. In particular, SERC compliance staffis responsible for conducting monitoring processes, assessment of all possibleviolations, and recommending confirmation or dismissal of violations and recommendingpenalties and sanctions.The CMEP defines eight monitoring (discovery) methods employed by the compliancestaff to identify possible violations: compliance audits, spot checks, self reporting,complaint, self certification, exception reporting, periodic data submittal, and complianceviolation investigations. These methods are further described in section 3.0 of this plan.Each possible violation will be promptly reported to NERC and then further evaluated bySERC compliance staff. If, after comprehensive evaluation of the facts andcircumstances of the possible violation, SERC compliance staff determines sufficientbasis exists to allege a violation, then staff contacts the Registered Entity and overviewsthe bases, the potential daily penalty exposure, the proposed penalty given the facts andcircumstances of the alleged violation, and the basic Registered Entity response options.Subsequently, staff will either commence settlement negotiations and/or issue a Noticeof Alleged Violation and Proposed Penalty or Sanction (NAVAPS) to the RegisteredEntity. Upon completion of the settlement agreement or confirmation of the violation inaccordance with applicable SERC procedures and provisions of the CMEP, SERCcompliance staff will submit the settlement agreement or Notice of Confirmed Violation(NOCV) to NERC for its approval. Upon approval of the settlement or NOCV by NERC,a Notice of Penalty (NOP) will be filed with FERC and simultaneously served upon theRegistered Entity and publicly posted pursuant to the Rules of Procedure.SERC staff has developed and continues to refine an extensive set of complianceimplementing procedures. These procedures detail the actions and processes thatSERC uses to conduct its compliance monitoring and enforcement responsibilities.Procedures are aligned with and follow a similar numbering scheme to the applicablesections of the CMEP to promote linkage. One or more members of SERC compliancestaff are assigned as subject matter experts (SMEs) for each procedure to ensuretechnical accuracy and to help coordinate revisions. New procedures and procedurerevisions are posted publicly for comment to promote transparency. The SERCCompliance Implementing Procedures are on the SERC website ( underthe “Compliance” tab.E. Board Compliance CommitteeThe SERC Board Compliance Committee, a balanced stakeholder committee of theSERC Board of Directors, is responsible for oversight of the SERC ComplianceMonitoring and Enforcement Program. The Board Compliance Committee, or a subsetSERC Compliance Monitoring and Enforcement Program2011 Implementation PlanDecember 1, 2010 (Rev. December 10, 2010) 3

Section 1: SERC Compliance Monitoring and Enforcement Programthereof, also acts as the hearing body responsible for resolving any disputes related toeither a finding of an alleged violation or a sanction administered for an alleged violation.SERC compliance staff works independently to complete all of the steps in the regionalentity compliance process. These steps conducted by staff include evaluating whether asufficient basis exists for a possible violation, issuing a Notice of Alleged Violation,confirming a violation, developing proposed sanctions and penalties, negotiatingsettlements, and accepting mitigation plans.At the conclusion of the staff’s work, following the filing of a Notice of Penalty with FERC,the compliance staff conducts a review of the enforcement action, including theapproved penalties and sanctions, and mitigation plans with the Board ComplianceCommittee.F. Compliance StaffSERC compliance staff implements the Compliance Monitoring and EnforcementProgram. The SERC compliance staff makes determinations of alleged violations andproposes appropriate penalties and sanctions in accordance with the CMEP and thePenalties and Sanctions Guidelines (Appendix 4B of the NERC Rules of Procedure). Toaccomplish these activities, SERC’s compliance staff is further divided into anenforcement branch, an audit branch, and a programs branch; which includes CIPcompliance monitoring, registration and certification activities, and investigations.SERC significantly expanded and developed the competencies of its compliance stafffrom 2007 through 2010, while continuing to engage the technical expertise and activeparticipation of industry volunteers as supporting members of audit teams. SERC’scompliance staff continues to develop as a learning organization, working to improveprocesses and practices to enhance its ability to efficiently and effectively implement andadminister the CMEP and promote a culture of reliability excellence across the region.SERC Compliance Monitoring and Enforcement Program2011 Implementation PlanDecember 1, 2010 (Rev. December 10, 2010) 4

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