Multi-Region Registered Entity Coordinated Oversight Program
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1 Multi-Region Registered Entity Coordinated Oversight Program Ken McIntyre, Vice President and Director of Standards and Compliance Compliance Committee Open Meeting February 7, 2018
2 Coordinated Oversight The Coordinated Oversight Program (Program) is designed to streamline Electric Reliability Organization (ERO) Enterprise activities for the registered entities that use, own, or operate assets in areas covering more than one Regional Entity s (RE s) territory. The intention is to increase efficiency and eliminate unnecessary duplication of administrative tasks. Lead REs (LREs) and Affected REs collaborate toward effective, consistent, and efficient implementation of the Program. 2
3 Participation 47 Multi-Region Registered Entity (MRRE) Groups in Coordinated Oversight (231 registered entities) WECC, 5 MRO, 10 Texas RE, 10 NPCC, 1 SPP RE, 6 RF, 11 SERC, 4 Distribution of 47 MRRE Groups by LRE 3
4 2016 Survey Results 2016 MRRE survey for registered entities in Coordinated Oversight Support and encouragement for program success o 97 percent overall program satisfaction Opportunities o Establish expectations o Coordination and communication 4
5 2016 and 2017 Key Activities ERO Enterprise Guide for MRREs in Coordinated Oversight Templates MRRE Spot-Check and Audit Notification Letter MRRE Spot-Check and Audit Report Periodic data submittal schedule MRRE monitoring engagement schedule 2017 follow-up survey Outreach 2017 Standards and Compliance Workshop Frequently Asked Questions 5
6 2017 Survey Results Appreciation for the increased coordinating efforts 98 percent overall program satisfaction Opportunities Inherent Risk Assessment coordination Coordinated, seamless data submittal o Self-Report o Periodic data submittals Stakeholder communications and education 6
7 Next Steps Public posting of Coordinated Oversight procedure Continued training for ERO Enterprise staff Include MRRE-specific questions in post-audit feedback survey Industry outreach NERC Oversight 7
8 8
9 2017 Compliance Monitoring and Enforcement Program Annual Report Andrea Koch, Senior Director of Reliability Assurance Sonia Mendonca, Vice President, Acting General Counsel and Corporate Secretary, and Director of Enforcement Compliance Committee Open Meeting February 7, 2018
10 Compliance Monitoring Highlights Inherent Risk Assessment (IRA) Regional Entities (REs) completed IRAs for 80 percent of all registered entities. IRAs are complete for all Reliability Coordinators, Balancing Authorities, and Transmission Operators. Internal Controls Enhanced Internal Controls Guide Standardized approach for documenting reviews Outreach 2
11 Compliance Monitoring Highlights 2018 Compliance Monitoring and Enforcement Program (CMEP) Implementation Plan (IP) Eight risk elements CMEP IP posted in September Regional IPs posted in November 2019 CMEP IP enhancements Program Alignment Issues and Recommendations Tracking Regional Program Information Matrix Consistency Reporting Tool Outreach 3
12 Compliance Guidance Implementation Guidance 20 Endorsed, 10 Non-endorsed, 1 Retired, and 10 Open New Pre-qualified Organization request Legacy Guidance Documents Outreach 4
13 2018 Priorities Electric Reliability Organization (ERO) Enterprise Program Alignment Process Coordinated Oversight of Multi-Region Registered Entities (MRREs) Internal Controls CMEP IP CMEP Technology Project 5
14 Self Identification of Noncompliance Remains Strong 6
15 Continued Progress in Mitigation 7
16 Serious Risk Violations Remain a Small Percentage of the Total 8
17 Compliance Severity Risk Index 9
18 Compliance Severity Risk Index 10
19 Repeat Violations Trended Down 11
20 Trends to Watch: Increase in New Noncompliance 12
21 Trends to Watch: Most Violated Standards 13
22 Trends to Watch: Vegetation Contacts 14
23 15
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