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Board of Directors Meeting September 2010

Board of Directors Meeting September 2010. Enforcement Process Update Robert K. Wargo Manager of Enforcement. Enforcement Process. Initial Risk Mitigated. Scope/Breadth Of Violation(s). Filed With NERC. Go Forward. Penalty Proposed. Step 1 Receipt Of Violation. Step 2

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Board of Directors Meeting September 2010

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  1. Board of Directors MeetingSeptember 2010 Enforcement Process Update Robert K. Wargo Manager of Enforcement

  2. Enforcement Process Initial Risk Mitigated Scope/Breadth Of Violation(s) Filed With NERC Go Forward Penalty Proposed Step 1 Receipt Of Violation Step 2 Initial Reliability Assessment Step 3 Initial Information Developed Step 4 Detailed Information Developed Step 5 Settlement Or NAVAP/NOCV Mitigation Plan Submittal, Review, Acceptance, Tracking & Verification 0 to 90Days 10 to 90 Days 0 to 21Days 1 to 3 Days 1 Day Typical Durations In Calendar Days Actual processing times from receipt to filing of settlement with NERC has ranged from30 Days [Simple/Already Fixed Matters] to 300 Days [Complex/Controversial Matters]

  3. Enforcement Efficiency Initiatives • Enforcement Staff Generated 51 Efficiency Improvement Ideas During Brainstorming Session • Fully Implemented 23 Ideas • Partially Implemented 6 Ideas • Tabled 7 Ideas • Rejected 15 Ideas • Adopted a “Reengineered” Enforcement Process • Immediate “Triage” of Violations – Identification of Low Effort/Rapid Filing Candidates • Immediate Issuance of “Stock” Request For Information Documents • Assignment of Appropriate Personnel by Skill Level/Experience to Specific Tasks • Synchronization Established Between Mitigation Plan Review & Verification Activities & Anticipated Filing Dates • Elimination of Some Internal Documents [3 Documents Combined Into 1] • Institution of Weekly Docket Lists & Projections • Elimination of Multiple Layers of Review & Sign Off

  4. Enforcement Staff2010 PREVIOUS 2010 ADDS Jason Blake Vimarie Luna STARTED AUGUST 23 Kristina Sims David Rosenfeldt Amanda Fried Theresa Cunniff

  5. Enforcement NEW Initiatives & Developments • NERC led Streamlining Initiative • Activities in Compliance Monitoring & Lessons Learned to reduce # of violations • Providing a path for less serious violations to be processed at Regional level with only minimal reporting to NERC and FERC • Specific handling options for CIP violations • Developments in Opposition to Streamlining • FERC directed analysis and treatment of repeat violations • FERC and NERC directed corporate affiliate analysis • Continued increase in violation volume • Increase in FERC activity in extending review of NOPs in order to ask Regions questions • CIP matters are still matters of “first impression”

  6. As of August 30, 2010

  7. Questions?

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