agenda compliance and certification committee highlights and... · 2019. 6. 13. · agenda...

Agenda Compliance and Certification Committee June 18 2019 | 100 pm ndash 500 pm Central June 19 2019 | 800 am ndash 1100 am Central

Exelon Corporation Offices 10 S Dearborn St 48th Floor Chicago IL 60603

Introduction and Chairrsquos Remarks

Welcome ndash Jennifer Sterling ndash Vice President ndash NERC Compliance and Security Exelon

Opening Remarks ndash Mechelle Thomas ndash Vice President and Chief Compliance Officer NERC

NERC Antitrust Compliance Guidelines and Public Announcement

Agenda Items

1 Administrative ndash Secretary and Jennifer Flandermeyer

2 Committee Business

a Consent Agenda ndash (Review) ndash Jennifer Flandermeyer

i Meeting Agenda ndash (Approve)

ii CCC March 2019 Meeting Minutes ndash (Approve)

3 Action Plan Updates

a Work Plan Spotlight ndash Scott Tomashefsky

b Effectiveness and Efficiency Summary with Action Items ndash Jennifer Flandermeyer

c Communication Package ndash Ryan Stewart and Jennifer Flandermeyer

d Extranet Site ndash Chris Boyd-Witherspoon

4 CCC Action Items and Work Plan Status ndash (Discuss) ndash Scott Tomashefsky

5 Subcommittee Updates

a Nominating Subcommittee ndash (Inform) ndash Daniela Cismaru

b ORCS ndash (Inform) ndash Greg Campoli

c EROMS ndash (Inform) ndash Ted Hobson

i New EROMS Scope Document - (Approve)

Agenda ndashCompliance and Certification Committee - June 18-19 2019 2

ii CCCPP-001 (Monitoring Program for NERCrsquos Adherence to NERCrsquos Rules of Procedure forCompliance Enforcement) ndash (Approve)

iii CCCPP-011 (Procedure to Become a Prequalified Organization Eligible to SubmitImplementation Guidance to the ERO) ndash (Approve)

iv NERC 2019 CCC Self Certification SPM

v CCCPP-010 (Criteria for Annual Regional Entity Program Evaluation)

vi Compliance Monitoring and Enforcement Program Organization Registration andCertification Program Audit

d Alignment Working Group ndash (Inform) ndash Martha Henson

e Standing Committee Coordination Group (SCCG) ndash (Update) ndash Scott Tomashefsky

6 Focused Discussion ndash (Discuss) ndash Jennifer Flandermeyer

a Application of Risk Principles

i Inherent Risk

ii Residual Risk

iii Risk-based CMEP

b Risk Identification and Valuation

c Risk Tolerance

d Committee Risk Activities

7 NERC Internal Audit (IA) Risk Process ndash (Update) ndash Matt Gibbons

8 ERO CMEP ndash (Update) ndash Steve Noess Ed Kichline

9 CORES Rollout ndash (Update) - Ryan Stewart

10 ALIGN Project ndash (Discuss) ndash Andy Rodriquez

11 NERC Board of Trustees Enterprise-wide Risk Committee ndash (Update) ndash Jennifer Flandermeyer

12 NERC Board of Trustees and Members Representative Committee (MRC) May 2019 Meetings -(Update) ndash Scott Tomashefsky

13 Standard Efficiency Review Phase II (Evidence Retention) ndash (Update) ndash John Allen

14 RISC Reliability Risk Report ndash (Discuss) ndash Patti Metro

15 Review of Action Items ndash (Review) ndash Scott Tomashefsky

16 Future Meeting Dates ndash (Inform)

a Confirmed 2019 Dates

i September 17-18 2019 Kansas City MO (KCPampL Offices)


ii November 19-20 2019 Rosemead CA (SCE Offices)

b Tentative 2020 Dates

i March 10-11 2020 TBD

ii June 9-10 2020 Cleveland OH (ReliabilityFirst)

iii September 23-24 2020 Salt Lake City UT (WECC Offices)

iv November 17-18 2020 Tentative Atlanta GA (NERC Offices)

Background materials included

Antitrust Compliance Guidelines I General It is NERCrsquos policy and practice to obey the antitrust laws and to avoid all conduct that unreasonably restrains competition This policy requires the avoidance of any conduct that violates or that might appear to violate the antitrust laws Among other things the antitrust laws forbid any agreement between or among competitors regarding prices availability of service product design terms of sale division of markets allocation of customers or any other activity that unreasonably restrains competition It is the responsibility of every NERC participant and employee who may in any way affect NERCrsquos compliance with the antitrust laws to carry out this commitment Antitrust laws are complex and subject to court interpretation that can vary over time and from one court to another The purpose of these guidelines is to alert NERC participants and employees to potential antitrust problems and to set forth policies to be followed with respect to activities that may involve antitrust considerations In some instances the NERC policy contained in these guidelines is stricter than the applicable antitrust laws Any NERC participant or employee who is uncertain about the legal ramifications of a particular course of conduct or who has doubts or concerns about whether NERCrsquos antitrust compliance policy is implicated in any situation should consult NERCrsquos General Counsel immediately II Prohibited Activities Participants in NERC activities (including those of its committees and subgroups) should refrain from the following when acting in their capacity as participants in NERC activities (eg at NERC meetings conference calls and in informal discussions)

bull Discussions involving pricing information especially margin (profit) and internal cost information and participantsrsquo expectations as to their future prices or internal costs

bull Discussions of a participantrsquos marketing strategies

bull Discussions regarding how customers and geographical areas are to be divided among competitors

bull Discussions concerning the exclusion of competitors from markets

bull Discussions concerning boycotting or group refusals to deal with competitors vendors or suppliers

NERC Antitrust Compliance Guidelines 2

bull Any other matters that do not clearly fall within these guidelines should be reviewed with NERCrsquos General Counsel before being discussed

III Activities That Are Permitted From time to time decisions or actions of NERC (including those of its committees and subgroups) may have a negative impact on particular entities and thus in that sense adversely impact competition Decisions and actions by NERC (including its committees and subgroups) should only be undertaken for the purpose of promoting and maintaining the reliability and adequacy of the bulk power system If you do not have a legitimate purpose consistent with this objective for discussing a matter please refrain from discussing the matter during NERC meetings and in other NERC-related communications You should also ensure that NERC procedures including those set forth in NERCrsquos Certificate of Incorporation Bylaws and Rules of Procedure are followed in conducting NERC business In addition all discussions in NERC meetings and other NERC-related communications should be within the scope of the mandate for or assignment to the particular NERC committee or subgroup as well as within the scope of the published agenda for the meeting No decisions should be made nor any actions taken in NERC activities for the purpose of giving an industry participant or group of participants a competitive advantage over other participants In particular decisions with respect to setting revising or assessing compliance with NERC reliability standards should not be influenced by anti-competitive motivations Subject to the foregoing restrictions participants in NERC activities may discuss

bull Reliability matters relating to the bulk power system including operation and planning matters such as establishing or revising reliability standards special operating procedures operating transfer capabilities and plans for new facilities

bull Matters relating to the impact of reliability standards for the bulk power system on electricity markets and the impact of electricity market operations on the reliability of the bulk power system

bull Proposed filings or other communications with state or federal regulatory authorities or other governmental entities

Matters relating to the internal governance management and operation of NERC such as nominations for vacant committee positions budgeting and assessments and employment matters and procedural matters such as planning and scheduling meetings

Public Announcements Face-to-face meeting version Participants are reminded that this meeting is public Notice of the meeting was posted on the NERC website and widely distributed Participants should keep in mind that the audience may include members of the press and representatives of various governmental authorities in addition to the expected participation by industry stakeholders

August 10 2010

Agenda Item 3bCCC Meeting

June 18-19 2019

Compliance and Certification Committee (CCC) Effectiveness and Efficiency Projects

Action Inform

Summary The Compliance and Certification Committee (CCC) after conducting a process to evaluate its effectiveness and efficiency identified several recommendations to implement to strengthen and mature the Committeersquos operations further building on the past successes The projects have been reviewed by the CCC Executive Committee and are presented to the full Committee for action

Engagement and Effectiveness

1 Welcome and Onboarding Package

2 Extranet site and File organization

3 Ease of Website use and content accessibility

4 CCC Reporting Dashboard ndash transparency and information sharing tool

Succession Planning

5 Nominating Subcommittee and CCC Member Criteria

6 Consolidation of EROMS and CPPS

Outreach

7 Outreach Plan and Membership Correlation to Industry Forums (Partnerships securing the long-term value of the CCC with industry the regions NERC and the Board of Trustees)

8 CCC Complaint Procedures and NERC IT Redesign for Complaint submission

Communications Plan

Jennifer Flandermeyer ndash CCC Chair EvergyRyan Stewart ndash Senior Manager Registration and Certification NERCCompliance and Certification Committee (CCC) MeetingJune 18-19 2019

RELIABILITY | ACCOUNTABILITY2Public

bull Key Objectives Outreach in Collaboration with NERC Partnership with Industry to garner feedback Industry participation on CCC goals and work products Succession Planning for CCC membership Others

CCC Communications with Industry


Membership

bull Investor-Owned Utilitybull StateMunicipal Utilitybull Cooperative Utilitybull Federal or Provincial Utility

Federal Power Marketing Administrationbull Transmission Dependentbull Merchant Electricity Generatorbull Electricity Marketerbull Large End-use Electricity Customerbull Small End-use Electricity Customerbull Independent System Operator

Regional Transmission Organizationbull Regional Entitybull Government


bull Current State What tools are currently used

bull Effective use of CCC members participation bull CCC Page redesign (NERC Website)bull New Tools to consider WebEx Brochures or flyers Newsletters Ad-hoc groups

bull Others

Communications Tools


NERC | Scope Document | March 2014 1

Scope Document Compliance and Certification Committee ERO Monitoring Subcommittee

Draft May June 2019

3353 Peachtree Road NE Suite 600 North Tower

Atlanta GA 30326 404-446-2560 | wwwnerccom

Agenda Item 5ciCCC MeetingJune 18-19 2019

NERC | DRAFT EROMS Scope Document | February June 2019

Table of Contents

Preface 1

Section 1 Mission 2

Section 2 ERO Monitoring Subcommittee Tasks and Functions 3

Section 3 Membership 4

31 Goals 4

32 General 4

33 Subgroup Membership and Representation 4

34 Membership Not Restricted to CCC Members 4

35 Resignations 4

36 Proxies 4

37 Exclusions 6

38 Changes in Member Affiliation 6

39 Acknowledgement of a Membership Conflict 6

Section 4 Meetings 7

41 Antitrust Guidelines 7

42 Open Meetings 7

43 Confidential Sessions 7

44 Types of Meetings 7

45 Majority and Minority Views 7

46 Actions without a Meeting 7

47 Quorum 7

Section 5 Officers and Staff 8

51 General 8

52 Chair 8

53 Vice Chair 8

54 Staff Coordinator 8

6 Subordinate Groups 10

61 Committee Organization Hierarchy 10

62 Establishing Subgroups 10

Appendix A ndash CCCPP Responsibilities 11

NERC | DRAFT Scope Document | May June 2019

1

Preface

Summary The North American Electric Reliability Corporation (NERC) is a not-for-profit international regulatory authority whose mission is to ensure the reliability of the Bulk Power System (BPS) in North America NERC develops and enforces Reliability Standards annually assesses seasonal and long-term reliability monitors the BPS through system awareness and educates trains and certifies industry personnel NERCrsquos area of responsibility spans the continental United States Canada and the northern portion of Baja California Mexico NERC is the electric reliability organization (ERO) for North America subject to oversight by the Federal Energy Regulatory Commission (FERC) and governmental authorities in Canada NERCrsquos jurisdiction includes users owners and operators of the BPS which serves more than 334 million people

The Compliance and Certification Committee (CCC) is a NERC board-appointed stakeholder committee serving and reporting directly to the NERC Board of Trustees (Board) and is responsible for engaging with supporting and advising the NERC Board and NERC regarding all facets of the NERC Compliance Monitoring and Enforcement Program (CMEP) Organization Registration Program (Registration program) and Organization Certification Program (Certification program) The CCC is responsible for establishing and implementing a program as specified in Section 405 of the NERC Rules of Procedure (ROP) to monitor NERCrsquos adherence to ROP for Compliance Enforcement including but not limited to the uniform Compliance Monitoring and Enforcement Program (Appendix 4C) and the Sanction Guidelines (Appendix 4B) The Compliance and Certification Committee (CCC) has established the ERO Monitoring Subcommittee to perform the tasks set out in Sections 1 and 2 on behalf and under the supervision of the CCC

Revision History

Date Version Number Comments

February 19 2019 Draft Drafted and circulated for comment

MayJune XX 2019 10 Approved by the Compliance and Certification Committee in order to consolidate EROMS and CPPS

Approved by the Board of Trustees


2

Section 1 Mission

The NERC Compliance and Certification Committee (CCC) is a NERC Board-appointed stakeholder committee serving and reporting directly to the NERC Board Operation and governance of the CCC is as articulated in the CCC Charter

The ERO Monitoring Subcommittee (EROMS) was formed by the CCC to assist the committee in fulfilling its mission and functions1 in a thorough and efficient manner Further details of what the subcommittee will undertake on behalf and under the supervision of the CCC are provided in Section 2

1 See Sections 1 and 2 of the CCC Charter respectively


3

Section 2 ERO Monitoring Subcommittee Tasks and Functions

To fulfill its mission the CCC has established the EROMS to perform the following tasks on behalf and under the supervision of the CCC

i Establish and implement programs to monitor NERCrsquos adherence to the Rules of Procedure regarding the

a Compliance Monitoring and Enforcement Program as specified in Section 405 of NERCrsquos Rules of Procedure and the

b Reliability Standards development process as specified in Section 300 of NERCrsquos Rules of Procedures with the exception of appeals of substantive or procedural action or inaction associated with a Reliability Standard or the Reliability Standards process as defined in the appeals section of the Reliability Standards Development Procedure

appeals of substantive or procedural action or inaction as specified in Section 405 of the NERC Rules of Procedureas defined in the appeals section of the [Reliability Standards Development Procedure or Standards Process Manual] as specified in Section 405 of NERCrsquos Rules of Procedure

ii Establish and implement programs to monitor NERCrsquos compliance with the reliability standards that apply to NERC

iii Develop and maintain CCC operational procedures with respect to the CCC responsibilities under the CCC Charter as specified in Attachment A

iv As assigned by the CCC advise and prepare recommendations to the CCC to address any standards related issues relevant to and within the scope of the NERC Compliance and Certification Committee (eg request from the Standards Committee Standard Drafting Team CCC NERC Compliance Staff etc)

v Perform document review to promote consistency between multiple documents (procedures policies standards rules orders etc) that comprise the overall NERC Compliance Monitoring and Enforcement Program (CMEP) and to assure ensure documents are clear unambiguous consistent and complementary In the event any documents are found to be unclear ambiguous or inconsistent advise the CCC of any such situations and propose changes that it believes will clarify such situations Activities may include but are not limited to

a Reviews of changes to the Rules of Procedure related to the Compliance Monitoring and Enforcement program Registration program and Certification program

b Proposals to change the ROP related to the Compliance Monitoring and Enforcement program Registration program and Certification program

vi Support the development and implementation of enhancements to the CMEP and as specified in ROP 402 develop criteria for NERC to use to assess the effectiveness of each Regional CMEP and make and provide recommendations to the CCC

vii Act as liaison of the CCC to the NERC Standards Committee

viii Implement CCC support in the development of the RSAWs for new Reliability Standards under development or for revisions to existing Reliability Standards

The subcommittee will work within its assigned scope and be accountable for the responsibilities and other related tasks assigned to it by the CCC

Commented [GM1] Need confirmation of how to reference standard program

Commented [GM2] This work is reflected in CCCPP-001 to -003

Commented [ST3] Unless I am completely missing something here I would suggest parroting the language that is included in the CCC Committee functions of the CCC Charter See Bullet 5c ldquo hellipappeals of substantive or procedural action or inaction associated with a Reliability Standard or the Reliability Standards process as defined in the appeals section of the Reliability Standards Development Procedurerdquo The reference point here is to Section 300 of the ROP rather than Section 405 Whatever you decide whatever changes you incorporate will need to be incorporated into the second paragraph of CCCPP-003

Commented [GM4] Changes as recommended during May call to make clear that EROMS work in this area is undertaken at direction of CCC This ensures work efforts are consistent and coordinated across stakeholder committees amp the ERO

Commented [GM5] EROMS Please review this language Ed has observed that the clauses do not fit well into the structure of the rest of the sentence and that the reference to ldquosuch situationsrdquo is undefined and ambiguous

Commented [FPL906R5] Agree we may want to delete or rephrase Proposing some language for consideration

Commented [GM7] This work is reflected in CCCPP-010

Commented [GM8] Deleted as recommended during May call

Commented [GM9] EROMS has opportunity to provide feedback to NERC on RSAWs before they are finalized


4

Section 3 Membership

31 Goals The membership of this subcommittee will be established to address the need for expertise and balance of interests to carry out the subcommitteersquos assigned Tasks and Functions as outlined in Section 2

32 General General membership requirements for members of a subgroup of the CCC are as articulated in Section 7Chapter 5 of the CCC Charter Additional membership requirements for this subcommittee are as defined within this scope document

33 Subgroup Membership and Representation As outlined in the CCC Charter each member of this subcommittee and its officers will be appointed by the chair of the CCC

34 Membership Not Restricted to CCC Members Members of this subcommittee are not required to be members of the CCC but must be eligible to be members of the committee Any member of the subcommittee who is also a member of the Standards Committee or its subcommittees are required to recuse themselves when voting on any matters resulting from monitoring of NERCrsquos adherence to Section 306 of the Rules of Procedure

35 Resignations

a By the Member In the event a member can no longer serve on the subcommittee that member will submit a written resignation to the subcommittee chair or the CCC secretary

b Requested by the Chair The chair may request any subcommittee member who ceases to participate in the subcommittee as indicated by not attending or sending a proxy for two consecutive meetings to submit a resignation or to request continuation of membership with an explanation of extenuating circumstances If a written response is not received within 30 days of the chairrsquos request the lack of response will be considered a resignation

c Referral to the CCC Chair The subcommittee chair will refer the vacancy resulting from a resignation to the chair of the CCC who may recommend a replacement pursuant to the CCC Charter

d By the Board CCC Committee members and by extension members of CCC subcommittees serve at the pleasure of the NERC Board which may request resignation of remove or replace a member as it deems appropriate

36 Proxies A substitute representative or proxy may attend on behalf of a member during all or a portion of a subcommittee meeting provided the absent member notifies the subcommittee chair vice chair or CCC secretary of the proxy

a Notification Such notification will be in writing (electronic medium is acceptable) The proxy representatives and their affiliation will be named in the correspondence

b May Not Serve as a Proxy for Another Member

A voting member of a subcommittee may not serve as a proxy for another voting member on the

Commented [GM10] Need to double check that CCC Chair appointment is required for EROMS membership I think CCC Chair appointment may only be required for Subcomm Chair amp Vice-Chair


5

same subcommittee (ie a member may not cast more than his or her own vote)


6

37 Exclusions Exclusions shall be as articulated in Section 3Chapter 1 of the CCC Charter

38 Changes in Member Affiliation A subcommittee member whose affiliation has changed may remain a member of the subcommittee by remaining subject to membership requirements and by notifying the chair of the CCC and the subcommittee chair of the change and receiving the approval of the chair of the CCC to remain on the subcommittee

39 Acknowledgement of a Membership Conflict No subcommittee member may have a conflict of interest that would impair his or her ability to fulfill obligations under this scope document Any subcommittee member who knows of any form of membership conflict such as working for an entity affiliated with that of another subcommittee member will notify the subcommittee chair and the chair of the CCC within ten business days of obtaining that knowledge


7

Section 4 Meetings

In the absence of specific provisions in this document or the CCC Charter all subcommittee meetings will follow Robertrsquos Rules of Order Newly Revised

Actions requiring a vote by the members of the subcommittee will be approved upon receipt of the affirmative vote of the majority of the voting members of the subcommittee present and voting in person or by proxy at any meeting at which five (5) or more members are present

41 Antitrust Guidelines All persons attending or otherwise participating in a NERC committee or subgroup meeting will act in accordance with NERCrsquos Antitrust Compliance Guidelines at all times during the meeting

42 Open Meetings NERC committee meetings will be open to the public except as noted below under Confidential Sessions

43 Confidential Sessions Meetings where information related to the subcommitteersquos review of non-public information or results in monitoring of NERCrsquos adherence to Section 306 of NERCrsquos Rules of Procedure and the compliance programrsquos adherence to NERCrsquos Rules of Procedure as specified in Section 405 of NERCrsquos Rules of Procedure will be confidential sessions Additionally with approval of the NERC Director of Regulatory Programs or the head of NERCrsquos internal audit function a meeting or portion of a meeting of the subcommittee may have attendance limited based on confidentiality of the information to be disclosed at the meeting Such limitations should be applied sparingly and on a non-discriminatory basis as needed to protect information that is sensitive information or confidential information to one or more parties Confidential information will only be disclosed as provided by Section 1500 of the NERC Rules of Procedure Confidentiality agreements may also be applied as necessary to protect sensitive information or confidential information

44 Types of Meetings Meetings may be conducted in person by conference call or other means The procedures contained in this scope document will apply to all meetings regardless of how they are conducted

45 Majority and Minority Views All members of the subcommittee will be afforded the opportunity to provide alternative views on an issue The results of the subcommittee actions including recorded minutes will reflect the majority as well as any minority views of the subcommittee members The chair will communicate both the majority and any minority views in presenting results to the CCC

46 Actions without a Meeting Actions without a meeting are permitted in accordance with the provisions of the CCC Charter

47 Quorum A quorum for conducting business is 50 percent of the members listed on the current subcommittee roster If a quorum is not present then the subcommittee may not take any actions requiring a vote of the subcommittee However the chair may with the consent of the members present allow discussion of agenda items


8

Section 5 Officers and Staff

51 General a Number of Positions

The subcommittee will have two officers and a secretary

b Officers The subcommittee officers will be one chair and one vice chair

c Secretary The NERC staff coordinator will serve as the subcommitteersquos secretary

d Officers May Vote The subcommittee chair and vice chair are voting members of the subcommittee

e Officers are Named by the CCC Chair for a Two-year Term Officers may be reappointed for a second two-year term

52 Chair The chair will direct and provide general supervision of subcommittee activities including

i Coordinate the schedule of all subcommittee meetings

ii Develop subcommittee agendas and rule on any deviation addition or deletion from a published agenda

iii Preside at and manage subcommittee meetings including the nature and length of discussion recognition of speakers and proxies motions and voting

iv Will act as the spokesperson for the subcommittee to the CCC

The subcommittee chair will serve as a member of the Executive of the CCC as described in the CCC Charter The subcommittee chair must be a member of the CCC

53 Vice Chair The vice chair will assume the responsibilities of the chair under the following conditions

i At the discretion of the chair (for brief periods of time)

ii When the chair is absent or temporarily unable to perform the chairrsquos duties or

iii When the chair is permanently unavailable or unable to perform the chairrsquos duties In the case of a permanent change the vice chair will continue to serve until a new chair is appointed by the chair of the CCC

The vice chair of the subcommittee must be a member of the CCC and may assume the responsibilities of the chair on the CCC Executive Committee in the absence of the chair

54 Staff Coordinator A member of the NERC staff will be selected by NERCrsquos Director of Regulatory Programs to serve as the staff coordinator and secretary of the subcommittee The staff coordinator is not a subcommittee member and does not have a vote Under the direction of the subcommittee officers the chair of the CCC and applicable NERC Bylaws guidelines and Rules of Procedure the staff coordinator will


9

i Manage the day-to-day operation and business of the subcommittee

ii Prepare and distribute the notices of the subcommittee meetings prepare the meeting agenda and prepare and distribute minutes of the subcommittee meetings

iii Act as the subcommitteersquos parliamentarian


10

Section 6 Subordinate Groups

61 Committee Organization Hierarchy As allowed in the NERC Bylaws the CCC organizational structure supports a superior-subordinate hierarchy that is ordered as follows

bull Committee

bull Subcommittee

bull Working Group

bull Task Force 62 Establishing Subgroups The CCC has established this subcommittee and is responsible for it to the NERC Board This subcommittee may establish subordinate groups as discussed in the CCC Charter

NERC | Draft Scope Document | May June 2019

Attachment A ndash CCCPP Responsibilities

It is envisioned that the two CCC Subcommittees will be primarily responsible for maintaining the CCCPPs that they administer as well as the CCC Charter itself The following table shows the delegation of responsibilities by CCC subcommittee

CCCPP for CCC Monitoring Program Responsible Subcommittee

bull CCCPPndash001-2 | Monitoring Program for NERCrsquos Adherence to NERCrsquos Rules of Procedure for Compliance Enforcement

EROMS

bull CCCPPndash002ndash2| Compliance Monitoring Program for Reliability Standards Applicable to NERC

EROMS

bull CCCPPndash003ndash2 | Monitoring Program for NERCrsquos Reliability Standards Development Procedure

EROMS

bull CCCPPndash004ndash2 | NERC Compliance and Certification Committee Hearing Procedures

EROMS

bull CCCPPndash005ndash1 | NERC Compliance and Certification Committee Hearing Procedures for use in Appeals of Certification Matters

ORCS

bull CCCPPndash006ndash2 | NERC Compliance and Certification Committee Mediation Procedures

EROMS

bull CCCPPndash007-3 | Monitoring Program for NERCrsquos Adherence to NERCrsquos Rules of Procedure for Registration and Certification

ORCS

bull CCCPPndash008ndash1 | Program for Monitoring Stakeholders Perceptions

EROMS

bull CCCPPndash009ndash2 | Confidentiality Protocol - Compliance and Certification Committee

EROMS

bull CCCPP-010-5| NERC Compliance and Certification Committee Criteria for Annual Regional Entity Program Evaluation

EROMS

bull CCCPP-011-1 | Procedure to Become a Prequalified Organization Eligible to Submit Implementation Guidance to the ERO

EROMS

bull CCCPP-012 | CCC Participation in NERCrsquos Audits of Regional Entity CMEP Programs in Accordance with Appendix 4A of the NERC Rules of Procedure

EROMS

bull Compliance and Certification Committee Charter EROMS


2 httpwwwnerccomcommCCCPagesRelated20Filesaspx



Draft June 2019



Agenda Item 5ciCCC Meeting June 18-19 2019

NERC | DRAFT EROMS Scope Document | June 2019

Table of Contents

Preface 1

Section 1 Mission 2



31 Goals 4

32 General 4



35 Resignations 4

36 Proxies 4

37 Exclusions 5





42 Open Meetings 6





47 Quorum 6


51 General 7

52 Chair 7

53 Vice Chair 7






NERC | DRAFT Scope Document | June 2019

1

Preface



Revision History



June XX 2019 10 Approved by the Compliance and Certification Committee in order to consolidate EROMS and CPPS



2

Section 1 Mission





3






ii Establish and implement programs to monitor NERCrsquos compliance with the reliability standards that apply to

NERC



v Perform document review to promote consistency between multiple documents (procedures policies standards rules orders etc) that comprise the overall NERC Compliance Monitoring and Enforcement Program (CMEP) and to ensure documents are clear unambiguous consistent and complementary In the event any documents are found to be unclear ambiguous or inconsistent advise the CCC and propose changes Activities may include but are not limited to








4



32 General General membership requirements for members of a subgroup of the CCC are as articulated in Chapter 5 of the CCC Charter Additional membership requirements for this subcommittee are as defined within this scope document

33 Subgroup Membership and Representation As outlined in the CCC Charter subcommittee officers will be appointed by the chair of the CCC


35 Resignations








A voting member of a subcommittee may not serve as a proxy for another voting member on the same subcommittee (ie a member may not cast more than his or her own vote)


5

37 Exclusions Exclusions shall be as articulated in Chapter 1 of the CCC Charter




6

Section 4 Meetings











7





















8





9



bull Committee

bull Subcommittee

bull Working Group


NERC | Draft Scope Document | June 2019





EROMS


EROMS


EROMS


EROMS


ORCS


EROMS


ORCS


EROMS


EROMS


EROMS


EROMS


EROMS




Monitoring Program for NERCrsquos Adherence to NERCrsquos Rules of Procedure for Compliance Monitoring and Enforcement CCC Monitoring Program ndash CCCPP-001

May April 7 20152019

NERC | Report Title | Report Date I

Agenda Item 5ciiCCC MeetingJune 18-19 2019

NERC | Monitoring Program for NERCrsquos Adherence to NERCrsquos Rules of Procedure for Compliance Monitoring and Enforcement | May 7 2015

ii

Table of Contents

Preface iii

Revision History iv

1 Introduction 1

2 Monitoring Processes 3

3 Annual Work Plan 5

4 Mitigation Plan 6

41 Contents of a Mitigation Plan 6

42 Timetable for Completion of a Mitigation Plan 6

5 Data Retention and Confidentiality 7

51 Records Management 7

52 Retention Management 7

53 Confidentiality Management 7

6 Reporting and Disclosure 8

61 1 Audit 8

62 Complaint 8

63 Mitigation Plan 8

64 Other Monitoring Activity 8

Preface


3

The North American Electric Reliability Corporation (NERC) is a not-for-profit international regulatory authority whose mission is to assure the reliability of the bulk power system (BPS) in North America NERC develops and enforces Reliability Standards annually assesses seasonal and long-term reliability monitors the BPS through system awareness and educates trains and certifies industry personnel NERCrsquos area of responsibility spans the continental United States Canada and the northern portion of Baja California Mexico NERC is the electric reliability organization (ERO) for North America subject to oversight by the Federal Energy Regulatory Commission (FERC) and governmental authorities in Canada NERCrsquos jurisdiction includes users owners and operators of the BPS which serves more than 334 million people

The North American BPS is divided into several assessment areas within the eight Regional Entity (RE) boundaries as shown in the map and corresponding table below

The Regional boundaries in this map are approximate The highlighted area between SPP and SERC denotes overlap as some load-serving entities participate in one Region while associated transmission ownersoperators participate in another

FRCC Florida Reliability Coordinating Council

MRO Midwest Reliability Organization

NPCC Northeast Power Coordinating Council RF ReliabilityFirst

SERC SERC Reliability Corporation

SPP-RE Southwest Power Pool Regional Entity TRE Texas Reliability Entity

WECC Western Electricity Coordinating Council


4

Revision History

CCCPP-001


June 11 2008 10 Approved by the Compliance and Certification Committee

August 26 2008 10 Approved by the Board of Trustees

April 13 2015

20

Revised by the ERO Monitoring Subcommittee (EROMS) and approved by the Compliance and Certification Committee

May 7 2015 20 Approved by the Board of Trustees June xx 2019 August xx 2019

30 30

Approved by the Compliance and Certification Committee Approved by the Board of Trustees

NERC Compliance and Certification Committee Title Monitoring Program for NERCrsquos Adherence to NERCrsquos Rules of Procedure for Compliance Monitoring and Enforcement Version 20 Revision Date 04132015 Effective Dat e 05072015

Formatted Table

1 Introduction


1

In the capacity of a NERC board-appointed stakeholder committee serving and reporting directly to the Board under a NERC board-approved charter1 as approved by FERC2 and as set forth in the Rules of Procedures (ROP) the CCC will engage with support and advise the Board and NERC Board of Trustees Compliance Committee (BOTCC) regarding all facets of the NERC Compliance Monitoring and Enforcement Program (CMEP) Registration program and Certification program

The CCC is responsible for establishing and implementing a program as specified in Section 405 of the ROP to monitor NERCrsquos adherence to the ROP for Compliance Monitoring and Enforcement including but not limited to the uniform CMEP (Appendix 4C) and the Sanction Guidelines (Appendix 4B) This document describes the program and associated processes to be utilized by the CCC in carrying out this responsibility

As noted in the NERC board-approved CCC Charter monitoring by the CCC is ongoing and does not preclude interfere with or replace in whole or in part the Boardrsquos responsibility to conduct and provide such reviews of these programs as required by FERC regulations 18 CFR sect 393(c) ldquoThe Electric Reliability Organization shall submit an assessment of its performance three years from the date of certification by the Commission and every five years thereafterrdquo

11 Terms The terms defined below are applicable to this program only and are not intended to be applicable to or conflict with the same or similar terms used by NERC for other purposes

111 Adverse Finding A finding of a non-adherence to the ROP as a result of an Audit a Self-Certification a Self-Report or a Spot Check

112 Audit A systematic objective review and examination of records and activities to determine whether NERC has adhered to the ROP for Compliance Monitoring and Enforcement

113 Complaint An allegation that NERC has not adhered to the ROP for Compliance Monitoring and Enforcement

114 Mitigation Plan An action plan developed by NERC to (1) correct an Adverse Finding andor (2) prevent any recurrence of an Adverse Finding

115 Self-Certification Periodic reporting by NERC of adherence or non-adherence to the ROP for Compliance Monitoring and Enforcement

116 Self-Report A report by NERC of a non-adherence to the ROP for Compliance Monitoring and Enforcement based on NERCrsquos own assessment and of any actions taken or that are being taken to resolve the non-adherence

1httpwwwnerccomcommCCCDocumentsCCC20Charter20Approved20RR15-11-000pdf 2 httpwwwnerccomfilesOrder_on_Comp_Filing_06072007_CCC_VSL_Orderpdf


2

1 Introduction

117 Spot Check A process in which NERC is requested to provide information to assess whether NERC adheres to the ROP for Compliance Monitoring and Enforcement

NERC | Monitoring Program for NERCrsquos Adherence to NERCrsquos Rules of Procedure for Compliance Monitoring and Enforcement | May 7November XXX 2018

2015

2 Monitoring Processes

The CCC will monitor and assess NERCrsquos adherence to its ROP for Compliance Monitoring and Enforcement using the processes described below to collect information and make assessments

21 Audits The CCC will work with the Enterprise-wide Risk Committee (EWRC) and the Head of NERCrsquos Senior Director of Internal Audit DepartmentAudits to schedule periodic external Audits of NERCrsquos implementation of the CMEP The CCC will participate as observers in these Audits as described in Section 211 Audits will be conducted at NERCrsquos facility(ies) in a manner consistent with Section 40311 of the ROP All Audits will be conducted in accordance with Audit guides consistent with accepted auditing guidelines as approved by NERC

211 Audit Steps

bull The CCC will collaborate with the Head of NERCrsquos Internal Audit Department NERC S e n i o r Director of Internal Audits and the EWRC to schedule externally led Audits of the NERC CMEP

bull The CCC will participate along with the Head of NERCrsquos Internal Audit DepartmentNERC S e n i o r Director of Internal Audits in the selection of the external auditing contractor to be approved by the Board pursuant to Section 406 of the ROP

bull Each Audit team will include NERC Internal Audit staff assigned CCC observers and the external auditing contractor

bull The assigned CCC observers must identify any applicable conflicts of interest (COI) and will be subject to NERC COI procedures in place at the time of the Audit which includes the ability of NERC to request replacement of an observer who has a COI

bull The assigned CCC observers must have completed NERC Auditor Training

bull The assigned CCC observers must execute Confidentiality Agreements

bull The assigned CCC observers must abide by the NERC-provided observer guidelines

bull The assigned CCC observers will be included in Audit team pre- and post-Audit activities and actual auditing activities including meeting with NERC personnel from the departments that are the subjects of the Audit

bull The assigned CCC observers may provide questions comments and advice to the external auditors during the course of the Audit

bull The assigned CCC observers will have access to non-confidential Audit documents (as determined by NERC) on the secure NERC site

bull The assigned CCC observers will review all daily weekly and final Audit reports

212 Frequency of Audits Audits of NERC will be conducted at least every three (3) years Additionally an unscheduled Audit of NERC may be initiated by the CCC in consultation with the EWRC and the Head of NERCrsquos Internal Audit DepartmentNERC Senior Director of Internal Audits if reasonably determined to be necessary to determine NERCrsquos adherence to the ROP for Compliance Monitoring and Enforcement

213 Scope of Audits An Audit will include elements of the CMEP selected by NERC and elements of the CMEP selected by the CCC


4


214 Audit Reports The Audit team will develop a draft Audit report that will include a description of the objective scope and methodology of the Audit identify any Adverse Findings identify any mitigation activities which have been completed or are pending and identify the nature of any confidential information redacted The draft Audit report may contain other recommendations of the Audit team related to the findings

The draft Audit report will be provided to NERC which will in turn provide the Audit team with comments and descriptions of Mitigation Plans for addressing any Adverse Findings for inclusion in the final Audit report If NERC disputes any Adverse Findings NERC will also provide language to the Audit team addressing such concerns for inclusion in the report

The Audit team will consider comments provided by NERC and develop a final Audit report that includes any Mitigation Plan descriptions provided by NERC as well as any language regarding disputed Adverse Findings The Audit team will then provide the final Audit report to the Board through the EWRC

22 Self-Certifications NERC will certify its adherence to the ROP for Compliance Monitoring and Enforcement with respect to a subset of performance items selected by the CCC on a periodic basis Such Self-Certifications will be achieved through reports to the CCC by a NERC officer or equivalent responsible for ensuring adherence to the ROP for Compliance Monitoring and Enforcement Results of Self-Certifications will be communicated to the Board through the EWRC

23 Spot Checks The CCC in consultation with the EWRC and the Head of NERCrsquos Internal Audit DepartmentNERC Senior Director of Internal Audits may from time to time request NERC to provide information to assess whether NERC adheres to the ROP for Compliance Monitoring and Enforcement A review of this information will be conducted in a manner similar tolike an Audit A Spot Check may also be initiated in response to events or a Complaint Results of a Spot Check will be documented in a Spot Check report and provided to the Board in a manner consistent with reporting for an Audit

24 Self-Reports NERC is encouraged to self-report to the CCC at the time NERC becomes aware of (1) any NERC non-adherence to the ROP for Compliance Monitoring and Enforcement or (2) a change in a previously identified Adverse Finding Results of a Self-Report will be communicated to the Board through the EWRC

25 Complaints The CCC may receive Complaints alleging NERC non-adherence to the ROP for Compliance Monitoring and Enforcement The CCC Chair and the Head of NERCrsquos Senior Director of Internal Audit Department both receive all submitted complaints via email The CCC Chair ins responsible for contacting consultation with the head of NERCrsquos Internal Audit DepartmentNERCrsquos Senior Director of Internal Audit to collaboratively will review complaints and receive advisory input and to assistance the CCC Chair in receive these complaints and review to determininge a course of action The CCC Chair shall contact the CCC Executive Committee (CCCEC) will be to consulted as needed and informed on course of action or dispensationosition conduct a review of each Complaint it receives to determine if the Complaint may be closed as a result of an initial review and assessment or iIf the Complaint provides sufficient basis to warrant further action for the CCC Chair and Head of NERCrsquos Internal Audit Department will contactinform NERCrsquos General Counsel of the complaint and agreed upon course of action in order to receive guidance and advisory feedback The CCC Chair is responsible for documenting the course of action All anonymous Complaints will be reviewed and resolved in a manner that will prevent disclosure of the


5

complainantrsquos identity If the complaint is about NERC Internal Audit NERCrsquos Board of Trustees or its Members the CCC Chair is responsible for informing NERCs CEO andor General Counsel The CCC Chair may notify tThe CCCEC will to consult with the CCC Executive Committee (CCCEC) and EWRC may also be consulted and the NERC Director of Internal Audits to determine if further action is neededto conductregarding a complaint and related the course of action on complaintsnecessary actions and to report on conclusionsmitigation A summary of aAll Complaints and their dispositions will be reported to the CCCEC and EWRC no less than annually to inform inand facilitate their oversight responsibilities All anonymous Complaints will be reviewed and resolved in a manner that will prevent disclosure of the complainantrsquos identity If the complaint is about NERC Internal Audit or the NERCrsquos Board of Trustees or its or Members the CCC will inform NERCs CEO andor General Counsel


6

3 Annual Work Plan

The CCC will maintain and update an Annual Work Plan to be carried out by the CCC in the performance of its responsibilities and duties in implementing this program The plan will be provided to NERC each year and will specify reporting by NERC to the CCC that will be required to provide verification of adherence through any of the monitoring methods described in Section 2 of this document The Work Plan will be posted on the NERC website


7

4 Mitigation Plan

If an Adverse Finding is identified as a result of an Audit a Self-Certification a Self-Report or a Spot Check NERC will develop a corresponding Mitigation Plan

41 Contents of a Mitigation Plan A Mitigation Plan should include the following information

bull The non-adherence to the ROP for Compliance Monitoring and Enforcement that the Mitigation Plan will correct

bull The cause of the non-adherence

bull NERCrsquos action plan to correct the non-adherence

bull NERCrsquos action plan to prevent recurrence of the non-adherence

bull A timetable for completion of the Mitigation Plan

bull Any other information deemed necessary or appropriate

42 Timetable for Completion of a Mitigation Plan A Mitigation Plan should be completed in time to have a reasonable potential to correct the non-adherence prior to the next applicable reportingassessment period after occurrence of the non-adherence for which the Mitigation Plan is provided In all cases the Mitigation Plan should be completed without delay NERC will keep the CCC informed of the status of Mitigation Plan activities and will notify the CCC when a Mitigation Plan has been completed


8

5 Data Retention and Confidentiality

51 Records Management All records associated with this program will be maintained by NERC The associated records management policy will provide for a routine and orderly process for the retention and disposal of electronic and paper records related to this program and ensure verification of compliance with appropriate business regulatory and legal requirements The policy will allow for the maintenance of records as required to implement the CCCrsquos monitoring of NERCrsquos adherence to the ROP for Compliance Monitoring and Enforcement

52 Retention Management NERCrsquos records management policy will require that information and data generated or received pursuant to activities associated with this program be retained for a minimum of five (5) years If the information or data is material to the resolution of a controversy the retention period for such data will not commence until after the controversy is resolved

53 Confidentiality Management NERC and the CCC will maintain confidentiality of all Confidential Information in accordance with Section 1500 of the ROP Information deemed to be critical energy infrastructure information will be redacted and will not be released publicly


9

6 Reporting and Disclosure

61 Audit The CCC will coordinate with NERC to post final Audit reports on its public website after the reports have been reviewed by the NERC Board Such posting will be subject to the confidentiality provisions of the ROP

62 Complaint When the CCC determines that further action is needed regarding Complaints it will report such Complaints to the NERC Board through the EWRC

63 Mitigation Plan NERC will keep the CCC informed of the status of Mitigation Plan activities and will notify the CCC when a Mitigation Plan has been completed

64 Other Monitoring Activity The CCC will report to the NERC Board through the EWRC upon completion of a CCC monitoring activity described in this procedure





ii

Table of Contents

Preface iii

Revision History iv

1 Introduction 1



4 Mitigation Plan 6








61 1 Audit 8

62 Complaint 8



Preface


3











4

Revision History

CCCPP-001




April 13 2015

20



30 30



1 Introduction


1













2

1 Introduction


NERC | Monitoring Program for NERCrsquos Adherence to NERCrsquos Rules of Procedure for Compliance Monitoring and Enforcement | November XXX 2018



21 Audits The CCC will work with the Enterprise-wide Risk Committee (EWRC) and the Head of NERCrsquos Internal Audit Department to schedule periodic external Audits of NERCrsquos implementation of the CMEP The CCC will participate as observers in these Audits as described in Section 211 Audits will be conducted at NERCrsquos facility(ies) in a manner consistent with Section 40311 of the ROP All Audits will be conducted in accordance with Audit guides consistent with accepted auditing guidelines as approved by NERC

211 Audit Steps

bull The CCC will collaborate with the Head of NERCrsquos Internal Audit Department and the EWRC to schedule externally led Audits of the NERC CMEP

bull The CCC will participate along with the Head of NERCrsquos Internal Audit Department in the selection of the external auditing contractor to be approved by the Board pursuant to Section 406 of the ROP







bull The assigned CCC observers may provide questions comments and advice to the external auditors during the Audit


bull The assigned CCC observers will review all Audit reports

212 Frequency of Audits Audits of NERC will be conducted at least every three (3) years Additionally an unscheduled Audit of NERC may be initiated by the CCC in consultation with the EWRC and the Head of NERCrsquos Internal Audit Department if reasonably determined to be necessary to determine NERCrsquos adherence to the ROP for Compliance Monitoring and Enforcement



4






23 Spot Checks The CCC in consultation with the EWRC and the Head of NERCrsquos Internal Audit Department may from time to time request NERC to provide information to assess whether NERC adheres to the ROP for Compliance Monitoring and Enforcement A review of this information will be conducted in a manner like an Audit A Spot Check may also be initiated in response to events or a Complaint Results of a Spot Check will be documented in a Spot Check report and provided to the Board in a manner consistent with reporting for an Audit


25 Complaints The CCC may receive Complaints alleging NERC non-adherence to the ROP for Compliance Monitoring and Enforcement The CCC Chair and the Head of NERCrsquos Internal Audit Department both receive all submitted complaints The CCC Chair is responsible for contacting the head of NERCrsquos Internal Audit Department to collaboratively review complaints and receive advisory input and assistance in determining a course of action If the Complaint provides sufficient basis to warrant further action the CCC Chair and Head of NERCrsquos Internal Audit Department will inform NERCrsquos General Counsel of the complaint and agreed upon course of action The CCC Chair is responsible for documenting the course of action All anonymous Complaints will be reviewed and resolved in a manner that will prevent disclosure of the complainantrsquos identity If the complaint is about NERC Internal Audit NERCrsquos Board of Trustees or its Members the CCC Chair is responsible for informing NERCs CEO andor General Counsel The CCC Chair may notify the CCC Executive Committee (CCCEC) and EWRC regarding a complaint and related course of action A summary of all Complaints and their dispositions will be reported to the CCCEC and EWRC no less than annually to inform and facilitate their oversight responsibilities


5

3 Annual Work Plan



6

4 Mitigation Plan











7






8






Procedure to Become a Prequalified Organization Eligible to Submit Implementation Guidance to the ERO CCC Monitoring Program ndash CCCPP-011-

21 March 2016June 2019

Agenda Item 5ciiiCCC MeetingJune 18-19 2019

Table of Contents

Preface 3

Summary 3

Revision History 3

1 Introduction 1

2 Scope 3

3 Meetings 4

Antitrust Guidelines 4

Open Meetings 4

Types of Meetings 4

Majority and Minority Views 4

Actions without a Meeting 4

Quorum 4

4 Criteria for Approval 5

5 Application and Review Process 6

Submit Application 6

Review Application 6

Notifying Applicant and ERO Enterprise 6

6 Administrative 7

Review Period 7

Retention Management 7

Confidentiality Management 7

Appendix A Application to Become a Prequalified Organization Eligible to Submit Implementation Guidance for Potential Endorsement by NERC 8

Contact Person Details 8

Description of Organization 8

Member Details 8

Application 9

NERC | Procedure to Become a Prequalified Organization | March 2016 ii

Preface

CCCPP-011-1

Summary The North American Electric Reliability Corporation (NERC) is a not-for-profit international regulatory authority whose mission is to ensure the reliability of the bulk power system (BPS) in North America NERC develops and enforces Reliability Standards annually assesses seasonal and long-term reliability monitors the BPS through system awareness and educates trains and certifies industry personnel NERCrsquos area of responsibility spans the continental United States Canada and the northern portion of Baja California Mexico NERC is the electric reliability organization (ERO) for North America subject to oversight by the Federal Energy Regulatory Commission (FERC) and governmental authorities in Canada NERCrsquos jurisdiction includes users owners and operators of the BPS which serves more than 334 million people

The Compliance and Certification Committee (CCC) is a NERC Board-appointed stakeholder committee serving and reporting directly to the NERC Board of Trustees (Board) and is responsible for engaging with supporting and advising the NERC Board and NERC regarding all facets of the NERC Compliance Monitoring and Enforcement Program (CMEP) Organization Registration Program (Registration program) and Organization Certification Program (Certification program)

In accordance with action taken by the NERC Board on November 5 2015 the CCC was asked to play a lead role in developing tools andor procedures that will promote a common understanding among the industry and ERO Enterprise Staff regarding how compliance can be achieved and demonstrated Key to this effort is the development of Implementation Guidance a stakeholder-driven means to develop examples of approaches to illustrate how registered entities could comply with a Standard that are vetted by prequalified organizations and endorsed by the ERO Enterprise

NERC will only consider requests for Implementation Guidance that have been vetted through one of several organizations that are ldquoprequalifiedrdquo to submit guidance for ERO Enterprise endorsement Therefore an organization that has not been prequalified can send a request to the CCC to be added to the prequalified list This document outlines the process by which the CCC will receive and evaluate such requests

Revision History


January 11 2016 10 Working draft circulated to CCC Compliance Guidance Task Force for initial review and discussion

January 25 2016 11 Working draft circulated to CCC Compliance Guidance Task Force for second review and discussion

February 12 2016 12 Working draft circulated to CCC Compliance Guidance Task Force for third review and discussion

February 25 2016 13 Working draft circulated to CCC Compliance Guidance Task Force for fourth review and discussion

March 2 2016 14 Document approved by CCC

NERC | Procedure to Become a Prequalified Organization | March 2016 iii

NERC Compliance and Certification Committee Title Criteria for Annual Regional Entity Program Evaluation

Version 15 Revision Date 4072016 Effective Date 03022016

Commented [GM1] NERC will need to revise this header

Preface


April 7 2016 15 Modification to process to remove pre-qualified organizations

XXXX YY 2019 2 Complete periodic review of procedure Ministerial changes only

Formatted Table

NERC | Procedure to Become a Prequalified Organization | March 2016

NERC | Procedure to Become a Prequalified Organization | March 2016 1

1 Introduction

In the capacity of a NERC Board-appointed stakeholder committee serving and reporting directly to the Board under a NERC Board-approved charter1 as approved by FERC2 and as set forth in the Rules of Procedure (ROP) the CCC will engage with support and advise the Board and NERC Board of Trustees Compliance Committee (BOTCC) regarding all facets of the NERC CMEP Registration program and Certification program

In accordance with action taken by the NERC Board on November 5 2015 the CCC was asked to play a lead role in developing tools and procedures that will promote a common understanding among the industry and ERO Enterprise Staff regarding how compliance can be achieved and demonstrated Key to this effort is the development of Implementation Guidance a stakeholder-driven means for registered entities to develop examples of approaches to illustrate how registered entities could comply with a Standard that are vetted by prequalified organizations and endorsed by the ERO Enterprise

As of May 2018 NERC requires that Implementation Guidance be vetted through one of the following prequalified organizations prior to being submitted to the ERO Enterprise for endorsement

bull1 American Public Power Association (APPA)

bull2 Canadian Electricity Association (CEA)

bull3 Edison Electric Institute (EEl)

bull4 Electricity Consumers Resource Council (ELCON)

5 Electric Power Supply Association (EPSA)

bull6 EnergySec

bull7 ISORTO Council

bull8 Large Public Power Council (LPPC)

bull9 National Association of Regulatory Utility Commissioners (NARUC)

bull10 National Rural Electric Cooperative Association (NRECA)

bull11 North American Generator Forum (NAGF)

bull12 North American Transmission Forum (NATF)

13 Northwest Public Power Association (NWPPA)

bull14 Nuclear Energy Institute (NEI)

bull15 Transmission Access Policy Study Group (TAPS)

bull16 Western Interconnection Compliance Forum (WICF)

bull17 NERC Planning Committee (PC)

bull18 NERC Operating Committee (OC)

bull19 NERC Critical Infrastructure Protection Committee (CIPC) and

bull20 Regional Entity Stakeholder Committees

NERC will post and maintain the list on the NERC website In order to be added to the list of ldquoprequalifiedrdquo organizations that are eligible to serve as a potential submitter of Implementation Guidance NERC requires an organization to submit a request to the CCC Each of the prequalified organizations are comprised of stakeholders

Formatted Numbered + Level 2 + Numbering Style 12 3 hellip + Start at 1 + Alignment Left + Aligned at 036 + Indent at 061

Formatted Not Expanded by Condensed by



1 httpwwwnerccomcommCCCDocumentsCCC20Charter20Approved20RR15-11-000pdf 2 httpwwwnerccomfilesOrder_on_Comp_Filing_06072007_CCC_VSL_Orderpdf


1 Introduction

that 1) are actively involved in the various technical and policy operations of NERC 2) have methods to assure technical rigor in the development process and 3) possess the ability to vet content through its members


2 Scope

The CCC is responsible for reviewing and considering applications for organizations who desire to become a prequalified organization eligible to submit Implementation Guidance to the ERO Enterprise The CCC Compliance Processes and Procedures The CCC EROMS Subcommittee (CPPS) will review and consider such applications


3 Meetings

In the absence of specific provisions in this document or the CCC Charter all EROMS CPPS sub-committee meetings will follow Robertrsquos Rules of Order Newly Revised Actions requiring a vote by the members of the CPPS EROMS will be approved upon receipt of the affirmative vote of the majority of the voting members of EROMS the CPPS present and voting in person or by proxy at any meeting at which three (3) or more members are present

Antitrust Guidelines All persons attending or otherwise participating in EROMS the CPPS will act in accordance with NERCrsquos Antitrust Compliance Guidelines at all times during the meeting

Open Meetings NERC committee meetings will be open to the public except as noted below under Confidential Sessions

Types of Meetings Meetings may be conducted in person by conference call or other means The procedures contained in this scope document will apply to all meetings regardless of how they are conducted

Majority and Minority Views All members of the working group will be afforded the opportunity to provide alternative views on an issue The results of EROMS the CPPS actions including recorded minutes will reflect the majority as well as any minority views of the working group members The Chair will communicate both the majority and any minority views in presenting results to the CCC

Actions without a Meeting Actions without a meeting are permitted in accordance with the provisions of the CCC Charter

Quorum A quorum for conducting business is 50 of the members listed on the current EROMS CPPS roster If a quorum is not present then the subcommittee may not take any actions requiring a vote of EROMSthe CPPS however the Chair may with the consent of the members present allow discussion of agenda items


4 Criteria for Approval

As noted above any organization that is seeking to be prequalified to submit Implementation Guidance to the ERO Enterprise will be evaluated based on the following criteria

bull Is a known entity on the list of NERC registered entities or in the alternative represents a group of registered entities

bull Is actively involved in the various technical and policy operations of NERC

bull Has methods to assure technical rigor in the development process and

bull Possesses the ability to vet content through its organization providing a high level of confidence to the CCC that the Guidance has been fully vetted

The CCC will also take into consideration any characteristics and additional information of the applicant

The CCC is ultimately responsible for reviewing and considering any applications for organizations to become a prequalified organization The CCC reserves the right to periodically review the list of prequalified entities and recommend to the ERO Enterprise whether to have specific prequalified organizations removed In doing so the CCC will submit to the ERO Enterprise a request to remove an organization explaining the circumstances behind the request Upon concurrence of the recommendation by the ERO Enterprise any such removals must be approved by the NERC Board of Trustees Section 5 outlines the application and review process which will be subject to periodic review and modification as determined by the CCC


5 Application and Review Process

Submit Application An applicant must submit a completed application form (shown in Appendix A) to EROMS the CPPS to begin the review process EROMS The CPPS will acknowledge receipt of the application within five business days of receipt and notify the applicant by electronic mail

Review Application EROMS The CPPS will review applications at its regularly scheduled quarterly meetings EROMS The CPPS will review an application at its next regularly scheduled meeting if the application is submitted to EROMS CPPS more than 20 business days prior to the next regularly scheduled EROMS CPPS meeting EROMS The CPPS will make a formal recommendation to the CCC at that time which will be followed by formal action taken by the CCC EROMS The CPPS will evaluate the applications in accord with the criteria outlined in Section 4

Notifying Applicant and ERO Enterprise The CCC Chair or their designated representative will notify the applicant of the CCC decision whether to add the applicant to the prequalified list If the CCC approves the application then the CCC will inform the ERO Enterprise and request the ERO Enterprise to modify the list of prequalified organizations and post on the ERO Enterprise website


6 Administrative

Review Period The Criteria for Approval in Section 4 will be reviewed by the CCC on an annual basis and modified as needed

Retention Management NERCrsquos records retention management policy will require that information and data generated or received under activities associated with this program be retained for a minimum of five years If the information or data is material to the resolution of a controversy the retention period for such data will not begin until after the controversy is resolved

Confidentiality Management NERC and the CCC will maintain confidentiality of all Confidential Information in accordance with Section 1500 of the ROP Information deemed to be critical energy infrastructure information will be redacted and will not be released publicly


Appendix A Application to Become a Prequalified Organization Eligible to Submit Implementation Guidance for Potential Endorsement by NERC

The NERC Compliance and Certification Committee determines whether an organization will be prequalified to submit Implementation Guidance to NERC for endorsement

Contact Person Details

TitleEmployer

First name Last Name

Address

City State or Province

Zip Code or Postal Code

Phone (daytime) Mobile Email Name of Organization to be Applicant

Description of Organization

Member Details

Use this space to provide profile information to describe general structure of the organization

Use this space to provide information about the organizationrsquos members and why the members are impactful to NERC



Application

Please send this form to the following location Email ComplianceGuidancenercnet

Use this space to explain the reasons why NERC should consider this organization as a prequalified organization to submit Implementation Guidance to the ERO Enterprise

Explain how this organization includes stakeholders that possess the following characteristics

bull Must be a known entity on the list of NERC registered entities or in the alternative represent a group of registered entities



bull Possesses the ability to vet content through its members providing a high level of confidence to the CCC that an issue has been fully vetted

Explain the reasons the entity is unable to have one of the prequalified organizations vet its proposed Implementation Guidance

Procedure to Become a Prequalified Organization Eligible to Submit Implementation Guidance to the ERO CCC Monitoring Program ndash CCCPP-011-1

March 2016



ii

Table of Contents

Preface 3

Summary 3

Revision History 3

1 Introduction 1

2 Scope 3

3 Meetings 4


Open Meetings 4

Types of Meetings 4



Quorum 4






6 Administrative 7

Review Period 7






Member Details 8

Application 9


Preface

NERC Compliance and Certification Committee CCCPP-011-1 Title Criteria for Annual Regional Entity Program Evaluation

Version 15 Revision Date 4072016 Effective Date 03022016 Summary The North American Electric Reliability Corporation (NERC) is a not-for-profit international regulatory authority whose mission is to ensure the reliability of the bulk power system (BPS) in North America NERC develops and enforces Reliability Standards annually assesses seasonal and long-term reliability monitors the BPS through system awareness and educates trains and certifies industry personnel NERCrsquos area of responsibility spans the continental United States Canada and the northern portion of Baja California Mexico NERC is the electric reliability organization (ERO) for North America subject to oversight by the Federal Energy Regulatory Commission (FERC) and governmental authorities in Canada NERCrsquos jurisdiction includes users owners and operators of the BPS which serves more than 334 million people The Compliance and Certification Committee (CCC) is a NERC Board-appointed stakeholder committee serving and reporting directly to the NERC Board of Trustees (Board) and is responsible for engaging with supporting and advising the NERC Board and NERC regarding all facets of the NERC Compliance Monitoring and Enforcement Program (CMEP) Organization Registration Program (Registration program) and Organization Certification Program (Certification program) In accordance with action taken by the NERC Board on November 5 2015 the CCC was asked to play a lead role in developing tools andor procedures that will promote a common understanding among the industry and ERO Enterprise Staff regarding how compliance can be achieved and demonstrated Key to this effort is the development of Implementation Guidance a stakeholder-driven means to develop examples of approaches to illustrate how registered entities could comply with a Standard that are vetted by prequalified organizations and endorsed by the ERO Enterprise NERC will only consider requests for Implementation Guidance that have been vetted through one of several organizations that are ldquoprequalifiedrdquo to submit guidance for ERO Enterprise endorsement Therefore an organization that has not been prequalified can send a request to the CCC to be added to the prequalified list This document outlines the process by which the CCC will receive and evaluate such requests Revision History







Preface





1 Introduction In the capacity of a NERC Board-appointed stakeholder committee serving and reporting directly to the Board under a NERC Board-approved charter1 as approved by FERC2 and as set forth in the Rules of Procedure (ROP) the CCC will engage with support and advise the Board and NERC Board of Trustees Compliance Committee (BOTCC) regarding all facets of the NERC CMEP Registration program and Certification program In accordance with action taken by the NERC Board on November 5 2015 the CCC was asked to play a lead role in developing tools and procedures that will promote a common understanding among the industry and ERO Enterprise Staff regarding how compliance can be achieved and demonstrated Key to this effort is the development of Implementation Guidance a stakeholder-driven means for registered entities to develop examples of approaches to illustrate how registered entities could comply with a Standard that are vetted by prequalified organizations and endorsed by the ERO Enterprise NERC requires that Implementation Guidance be vetted through one of the following prequalified organizations prior to being submitted to the ERO Enterprise for endorsement

bull American Public Power Association (APPA)

bull Canadian Electricity Association (CEA)

bull Edison Electric Institute (EEl)

bull Electricity Consumers Resource Council (ELCON)

bull Electric Power Supply Association (EPSA)

bull ISORTO Council

bull Large Public Power Council (LPPC)

bull National Association of Regulatory Utility Commissioners (NARUC)

bull National Rural Electric Cooperative Association (NRECA)

bull North American Generator Forum (NAGF)

bull North American Transmission Forum (NATF)

bull Northwest Public Power Association (NWPPA)

bull Transmission Access Policy Study Group (TAPS)

bull Western Interconnection Compliance Forum (WICF)

bull NERC Planning Committee (PC)

bull NERC Operating Committee (OC)

bull NERC Critical Infrastructure Protection Committee (CIPC) and

bull Regional Entity Stakeholder Committees NERC will post and maintain the list on the NERC website In order to be added to the list of ldquoprequalifiedrdquo organizations that are eligible to serve as a potential submitter of Implementation Guidance NERC requires an organization to submit a request to the CCC Each of the prequalified organizations are comprised of stakeholders


1 Introduction




2 Scope The CCC is responsible for reviewing and considering applications for organizations who desire to become a prequalified organization eligible to submit Implementation Guidance to the ERO Enterprise The CCC Compliance Processes and Procedures Subcommittee (CPPS) will review and consider such applications


3 Meetings In the absence of specific provisions in this document or the CCC Charter all CPPS sub-committee meetings will follow Robertrsquos Rules of Order Newly Revised Actions requiring a vote by the members of the CPPS will be approved upon receipt of the affirmative vote of the majority of the voting members of the CPPS present and voting in person or by proxy at any meeting at which three (3) or more members are present Antitrust Guidelines All persons attending or otherwise participating in the CPPS will act in accordance with NERCrsquos Antitrust Compliance Guidelines at all times during the meeting Open Meetings NERC committee meetings will be open to the public except as noted below under Confidential Sessions Types of Meetings Meetings may be conducted in person by conference call or other means The procedures contained in this scope document will apply to all meetings regardless of how they are conducted Majority and Minority Views All members of the working group will be afforded the opportunity to provide alternative views on an issue The results of the CPPS actions including recorded minutes will reflect the majority as well as any minority views of the working group members The Chair will communicate both the majority and any minority views in presenting results to the CCC Actions without a Meeting Actions without a meeting are permitted in accordance with the provisions of the CCC Charter Quorum A quorum for conducting business is 50 of the members listed on the current CPPS roster If a quorum is not present then the subcommittee may not take any actions requiring a vote of the CPPS however the Chair may with the consent of the members present allow discussion of agenda items


4 Criteria for Approval As noted above any organization that is seeking to be prequalified to submit Implementation Guidance to the ERO Enterprise will be evaluated based on the following criteria





The CCC will also take into consideration any characteristics and additional information of the applicant The CCC is ultimately responsible for reviewing and considering any applications for organizations to become a prequalified organization The CCC reserves the right to periodically review the list of prequalified entities and recommend to the ERO Enterprise whether to have specific prequalified organizations removed In doing so the CCC will submit to the ERO Enterprise a request to remove an organization explaining the circumstances behind the request Upon concurrence of the recommendation by the ERO Enterprise any such removals must be approved by the NERC Board of Trustees Section 5 outlines the application and review process which will be subject to periodic review and modification as determined by the CCC


5 Application and Review Process Submit Application An applicant must submit a completed application form (shown in Appendix A) to the CPPS to begin the review process The CPPS will acknowledge receipt of the application within five business days of receipt and notify the applicant by electronic mail Review Application The CPPS will review applications at its regularly scheduled quarterly meetings The CPPS will review an application at its next regularly scheduled meeting if the application is submitted to CPPS more than 20 business days prior to the next regularly scheduled CPPS meeting The CPPS will make a formal recommendation to the CCC at that time which will be followed by formal action taken by the CCC The CPPS will evaluate the applications in accord with the criteria outlined in Section 4 Notifying Applicant and ERO Enterprise The CCC Chair or their designated representative will notify the applicant of the CCC decision whether to add the applicant to the prequalified list If the CCC approves the application then the CCC will inform the ERO Enterprise and request the ERO Enterprise to modify the list of prequalified organizations and post on the ERO Enterprise website


6 Administrative Review Period The Criteria for Approval in Section 4 will be reviewed by the CCC on an annual basis and modified as needed Retention Management NERCrsquos records retention management policy will require that information and data generated or received under activities associated with this program be retained for a minimum of five years If the information or data is material to the resolution of a controversy the retention period for such data will not begin until after the controversy is resolved Confidentiality Management NERC and the CCC will maintain confidentiality of all Confidential Information in accordance with Section 1500 of the ROP Information deemed to be critical energy infrastructure information will be redacted and will not be released publicly


Appendix A Application to Become a Prequalified Organization Eligible to Submit Implementation Guidance for Potential Endorsement by NERC The NERC Compliance and Certification Committee determines whether an organization will be prequalified to submit Implementation Guidance to NERC for endorsement Contact Person Details

TitleEmployer


Address

City State or Province Zip Code or Postal Code



Member Details





Application


Use this space to explain the reasons why NERC should consider this organization as a prequalified organization to submit Implementation Guidance to the ERO Enterprise Explain how this organization includes stakeholders that possess the following characteristics






Agenda Item 7 CCC Meeting June 18- 19 2019

Internal Audit Report

Action Update

Background At every Compliance and Certification Committee (CCC) meeting NERCrsquos Internal Audit and Corporate Risk Management Department (IA) provides an update regarding the status of CCC audits and other monitoring activities of NERC and the Regional Entities

Summary IA will update the CCC on the status of the audit of Regional Entity evaluations of registered entity internal controls and the CCC audit plan for 2019

Matt Gibbons Director of Internal Audit and Corporate Risk ManagementCompliance and Certification Committee (CCC) Meeting June 18 - 19 2019

NERC Internal Audit (IA) Risk Process

Agenda Item 7CCC Meeting June 18-19 2019

RELIABILITY | ACCOUNTABILITY2

Appendix 4A Audits

bull Audit of Regional Entity internal control evaluations is in reporting phase

bull Items previously reported complete Auditor Training Kickoff Meeting All Onsite Visits Audit Fieldwork

bull Items completed since last report Audit report drafted Audit report reviewed with CCC Observers NERC and REs

bull Items remaining Finalize audit report and present to EWRC in August


2019 CCC CMEPORCP Audits

bull Audit of NERC CMEPORCP is underwaybull Items previously reported complete RFP sent to independent audit firms

bull Items completed since last report Independent auditor selected CCC observer team assembled and trained Audit risk assessment and scoping with CCC observer team Audit kickoff planning and fieldwork interviews with NERC staff

bull Items remaining Finish audit fieldwork Review observations with CCC Observers Audit reporting review and presentation to EWRC


NERC CMEP Update

Ed Kichline Senior Counsel and Director of Enforcement OversightSteve Noess Director of Regulatory ProgramsCompliance and Certification Committee (CCC) Meeting June 18-19 2019



Coordinated Oversight Program for MRREs

Distribution of MRREs under Coordinated Oversight by Lead RE


bull ERO Enterprise Trainingbull Ongoing CMEP Activities Compliance Oversight Plans (COPs) Implementation Plan | Risk Elements and Areas of Focus Align Transition of FRCC to SERC Review Compliance Guidance program Violation Themes Webinars Further streamlining of minimal risk noncompliance Alignment and documentation of common methodology for risk

assessment of noncompliance

Ongoing and Upcoming Oversight and CMEP Activities


Centralized Organization Registration ERO System (CORES) UpdateRyan Stewart ndash Senior Manager of Registration and Certification NERC Compliance and Certification Committee (CCC) Meeting June 17-18 2019

Agenda Item 9CCC MeetingJune 18-19 2019


bull Overviewbull Registered entity Pilot Sessionsbull Upcoming Activities and Events

Agenda


bull The objective of the Centralized Organization Registration ERO System (CORES) project is to create a centralized registration system for the ERO This project will address Processing of registration requests Granting of a NERC Compliance Registry (NCR) identification number The information collected in CORES will be based upon the existing

Common Registration Form that each Regional Entity currently uses for processing registration requests

Link to CORES project page ndash FAQs timeline opportunities for engagement (httpswwwnerccompacompPagesCORESTechnologyProjectaspx)

Overview


bull The CORES application is hosted on the ERO Portal Each entity user that will register or modify registration with NERC will

need an ERO Portal account httpseroportalnercnet

bull Registered entities will not need to register againbull The process for collecting data is different ndash the data is virtually

the same

Key Points About CORES Transition


bull Benefits CORES will expand current functionality align regional registration

processes and provide an improved system-based approach to processing registration requests

Central repository for collecting registered entity data and related documentation

New functionality for entities in multiple regionso Coordinated Oversight information updated to My Entity page

ndash Process is the same

Easily update information in a central location ndash Functional registration ndash Parent company amp affiliatesndash Functional mapping

Benefits


bull CORES is not currently planned to be used for Compliance Monitoring and Enforcement Functions ndash see the Align projecto httpswwwnerccomResourceCenterPagesCMEPTechnologyProjectaspx

Certification or Certification Reviewso No system in place for Certification or Certification reviews at this time

BES Exceptionso BES Exceptions will continue to utilize the BESnet application for processing



bull The information collected in CORES will be based upon the Common Registration Form Entity names Contact information Functional registration

request information Parent company and

affiliate information

Common Registration Form Data Collection Points


bull The information collected in CORES will include Joint Registration

Organization (JRO) information

Multi-Regional Registered Entity (MRRE) information

Functional model relationships

Role information for specific contacts



bull Focus Groupbull AWGbull ORCSbull CCCbull Bulletinsbull Regional Workshopsbull Registered Entity Pilots ndash Testingbull Training

Outreach and Engagements


Website


bull Registered Entity Pilot Sessions May 14 | RF Hosted Reg Entity Pilot Roadshow May 16 | Texas RE Hosted Reg Entity Pilot Roadshow May 21 | NPCC Hosted Reg Entity Pilot Roadshow May 23 | NERCSlalom Hosted Reg Entity Pilot Roadshow

Registered Entity Pilot Sessions


bull Planned Training Dates (subject to change) June 6-7 2019 | Post Training Materials June 11 2019 | NERC hosted ERO WebEx (pre-release) June 17-22 2019 | System release this week June 27 2019 | NERC hosted ATL ERO In-person amp WebEx open QampA

(post-release) July 17 2019 | NERC hosted ERO WebEx (in-person) open QampA (post-

release) optional

Training




release) optional

Whatrsquos Next


1

Agenda Item 12 CCC Meeting June 18-19 2019

Report of May 2019 Member Representative Committee (MRC) and Board of Trustees (Board)

Action Informational

Background These notes are provided by Compliance and Certification Committee (CCC) attendees at the meetings and not intended to represent all agenda topics in full The North American Electric Reliability Corporation (NERC) MRC and Board of Trustees convened their quarterly meetings in St Louis Missouri on May 8-9 2019

MRC Meeting Summary

The following describes some of the significant highlights from the meetings The Agenda package and the associated presentations are available from the following links

httpswwwnerccomgovbotMRCAgenda20Highlights20nad20Minutes202013MRC_Meeting_Agenda_Package-May-8-2019pdf

httpswwwnerccomgovbotMRCAgenda20Highlights20nad20Minutes202013MRC20Presentation20Package20-20May208202019pdf

Supply Chain Report

A significant amount of the MRC meeting was spent discussing a draft Supply Chain Report prepared by NERC staff Howard Gugel opened the discussion with an overview of the supply chain issue and potential vulnerabilities related to electronic access control physical access control and low impact BES systems

Mr Gugel summarized the range of policy input provided pursuant to NERC Board Chair Roy Thillyrsquos Policy Input Letter to the MRC which included the following observations

bull There was broad support for the adoption of the report

bull Most agreed that low impact BES cyber assets should remain out

bull Stakeholders are supportive of a third-party verification program

bull Cost should be considered along with risk

bull There were concerns about the use of ldquopre-audit surveys something that Mr Gugelcould be addressed by modifying the text in the final version of the report

2

Board Chair Thilly suggested that the Board could accept the report with the understanding that the things Mr Gugel suggested in his comments would be addressed In that case the Board could approve the report without another formal meeting

Electromagnetic Pulse (EMP) Concerns NERC announced the established of an EMP task force which will review a recently published EPRI report on EMP vulnerabilities identify reliability concerns assess vulnerabilities and recommend mitigation actions for NERC to consider The group will meet monthly Task force participation will be solicited in April with an initial meeting in May It is expected that draft recommendations will be published by the Task Force be available in the third quarter of 2019

Effectiveness and Efficiency Update NERCrsquos Mark Lauby provided the MRC with the latest developments surrounding NERCrsquos efforts to improve the long-term effectiveness and efficiency of the ERO Enterprise As noted in the last quarterly update NERC is considering restructuring the technical stakeholder committees (Operating Committee Planning Committee and the Critical Infrastructure Protection Committee) and is looking to bring a proposal to the NERC Board later this year A Stakeholder Engagement Team including three CCC members (Jennifer Flandermeyer Patti Metro and Scott Tomashefsky) are working with NERC staff and NERC Board members Gorbet and DeFontes to develop the proposal

Mr Lauby reported that the team is considering two potential options 1) retain the existing technical committee structure and create an oversight committee which coordinates and directs the work of the technical committees or 2) consolidate the three committees into one Reliability Council which reports to the NERC Board and oversees the work of the various technical Subcommittees Working Groups and Task Forces The proposal will be refined based on feedback the MRC provides to the group After two additional group meetings NERC will host a Policy Input webinar in mid-July and bring back the proposal for additional discussion in August Final approval of a package is scheduled to come in front of the NERC Board in November 2019

CCC Overview Presentation to the MRC A presentation providing an overview of CCC activities to the MRC was postponed until the August 2019 meeting

Board Meeting Summary

The following notes represent some of the significant highlights from the meetings The Agenda package and the associated presentation are available from the following links

httpswwwnerccomgovbotAgenda20highlights20and20Mintues202013Board_Open_Meeting_May_9_2019_Agenda_Packagepdf

httpswwwnerccomgovbotAgenda20highlights20and20Mintues202013Board_Open_Meeting_May_9_2019_Presentationspdf

3

Key Areas of Specific Interest to the CCC

bull Nicole Mosher ndash Nova Scotia Power was newly appointed for a three-year term to theCCC representing the Regional Entity Northeast Power Coordinating Council position

bull Greg Campoli ndash New York ISO was reappointed for a three-year term to the CCCrepresenting the ISORTO sector

bull Jim Stanton ndash SOS International was reappointed for a three-year term to the CCCrepresenting the Small End-Use Electricity Generator sector

bull Ted Hobson ndash JEA was also approved to serve on the CCC representing the RegionalEntity Florida Reliability Coordinating Council (FRCC) until the FRCC dissolution becomeseffective

bull CCC Chair Jennifer Flandermeyer provided a quarterly update to the Board summarizingthe results of CCC meetings held in Washington DC on March 12-13 2019

bull The Board adopted a proposal to retire 84 requirements included in various reliabilitystandards stemming from Phase 1 work associated with the Standards EfficiencyReview initiative NERC will subsequently develop a formal request to FERC to formallyeliminate the requirements The CCCrsquos John Allen led this effort and will continue to leadadditional work being done under Phase 2 Based on the review of the Phase 2 SERsurveys that were sent out to industry it is possible that the CCC will be assigned someof this work

bull During the discussion of the 2018 ERO Effectiveness Survey NERC Chair Roy Thillymentioned the need to rethink the range of questions asked in future surveys includingthose included in the CCC portion of the ERO Effectiveness Survey

Senior Management Changes bull NERC CEOPresident Jim Robb announced that Mechelle Thomas and Howard Gugel

were promoted to vice president positions at NERC Ms Thomas takes over as VP andChief Compliance Officer and will be the CCCrsquos senior executive sponsor Mr Gugelassumes the role of VP and Director of Engineering and Standards

Other Items of Interest

bull NERC CEOPresident Jim Robb reflected on his first year as head of NERC and progressbeing made regarding the four major initiatives he has been focusing on since his arrivallast spring

bull FERC Commissioner Bernard McNamee provided remarks for the first time since beingappointed to the agency He indicated to the NERC Board that his main area of interestas it relates to the ERO will be cyber and physical security

bull The NERC Board accepted the Supply Chain Report subject to changes outlined byHoward Gugel during the MRC meeting (see above) The redline will go back to theBoard but no further action will be taken Mr Gugel will check back with the varioustrade associations to make sure that the text is incorporated as discussed

bull The NERC Board approved the ERO Five-Year Assessment after NERC General CounselBerardesco presented a summary The presentation highlighted NERCrsquos responses to

4

directives outlined in a 2014 FERC Order including increased focus on information sharing the development of standards to address cyberphysical security and numerous activities related to the Compliance Monitoring and Enforcement Program

bull Reports were presented to the Board as a normal course of business by the variousBoard Committees NERC Committees and Forum Groups

Board Committee Summaries

The remainder of this document ordinarily highlights items discussed at various Board Committee meetings that are most relevant to CCC members The Board of Trustees Compliance Committee did not meet during the course of the May 2019 Board meetings so much of the comments related to the CCC were made at the MRC and Board meetings

CCC Standards Efficiency

Review Update

John AllenJune 19 2019

SER Project ScopeEvaluate NERC Reliability Standards using a risk-based approach to identify potential efficiencies through retirement or modification of Reliability Standard Requirements Considering that many Reliability

Standards have been mandatory and enforceable for 10+ years in North America this project seeks to identify potential candidate

requirements that are not essential for reliability could be simplified or consolidated and could thereby reduce regulatory obligations

andor compliance burden

Phase 1 Team Scopebull Three teams based on horizonsbull Evaluate O amp P Standardsbull Three options available

ndash No actionndash Full retirement ndash Alternatives to retirement

bull Parking lot alternatives for Phase 2

Phase 1 Resultsbull SAR proposing to retire 107 requirements bull Redundant requirementsbull Non-essential market-based requirementsbull Project 2018-03 approved retirement of 84bull Petition to the FERC on June 7

Modifications Sub-teambull Team members (Phase 1 and Phase 2)bull Evaluate transfers from Phase 1 bull Evaluate feedback from initial surveybull Language modificationsbull Consolidation of requirementsbull Upcoming SAR

Phase 2 ScopeEvaluate NERC Reliability Standards (OampP and CIP) as informed by implementation experiences and compliance practices to develop and recommend standards-based solutions intended to reduce inefficiencies and unnecessary regulatory burdens for the purpose of supporting continued safe secure and reliable operations

Perceived Issuesbull Costs exceed benefitsbull Zero defect environmentbull Difficult to demonstratebull Unclear performance expectationsbull Unscaled applicabilitybull Unnecessary CMEP activity

Efficiency Conceptsbull Six efficiency conceptsbull Presented to industry February 22bull Survey to industry ending March 22bull Analysis of Feedback

Efficiency Conceptsbull Concept 1 Evidence Retention (812)bull Concept 5 Consolidate InfoData Exchange (811)bull Concept 3 Move to Guidance (785)bull Concept 2 Prototype Standard (778)bull Concept 6 Move to CertControls Review (685)bull Concept 4 ConsolidateSimplify Training (619)

Efficiency Conceptsbull Prioritization and Next Steps - June 11

bull Evidence Retention bull Consolidate InfoData Exchange bull Move to Guidance bull Prototype Standard

SER CIP Projectbull Determining scopebull Retirements and modificationsbull Industry surveybull Solicit team members

Questions

Evidence Retentionbull Michael Puscas ndash ISO New Englandbull Tino Zaragoza ndash Imperial Irrigation Distbull Terry Bilke ndash MISObull White Paper ndash September 2014

ndash Risk-based record retentionndash Sampling

Analysis of Standardsbull Collected data from OampP and CIPbull 50 different retention schemes bull Inconsistentbull Arbitrarybull Draft report with recommendations

Recommendationsbull Consistent retention schemesbull Minimize time frame based on riskbull Update NERC auditor resourcesbull Update ROPSPMbull Engage appropriate stakeholdersbull Establish implementation plantimeline

Questions

Page | 0 Created 6132019 Last Saved 6132019

NERC Standard Efficiency Review (SER) Phase 2 Evidence Retention Teamrsquos Recommended Evidence Retention

Schemes for NERC Standards

Evidence and Data Retention

Report Analysis and

Recommendations

Puscas Michael ISO-NE Tino Zaragoza IID Terry Bilke MISO

June 13 2019


Table of Contents Contents Executive Summary 1

Overall SER Project Scope 3

SER Phase 2 Evidence Retention Project Scope 3

SER Phase 2 Efficiency Concepts 3

Analysis of 2014 Evidence Retention White Paper 4

Tasks Performed by the 2014 Evidence Retention Team 4

Purpose of the 2014 White Paper 4

Identified Evidence Retention Problems Issues and Concerns 4

Recommendations from the 2014 Evidence Retention Study Team 5

Introduction to SER Phase 2 Evidence Retention Project 6

SER Phase 2 Evidence Retention Project Team 6

Evidence Retention Project Objectives 6

Evidence Retention Project Scope 7

Evidence Retention Out of Scope 7

Evidence Retention Project Assumptions 7

Evidence Retention Questions 7

Benefits of Revised Data Retention Rules 8

Challenges 8

Project Timeline 8

Introduction 9

Observations of Existing Evidence Retention Schemes 9

Evidence Retention Language 10

Evidence Categories 11

Results Error Bookmark not defined Different Headings in NERC Standards 11

General Observations 11

Recommendations 12

List of Existing Evidence Retention Schemes in NERC Standards 14


Executive Summary This document analyzes the evidence or data retention sections of NERC CIP and OampP Standards as part of the NERC Standards Efficiency Review (SER) Phase 2 Project 1

Executive Summary The Rules of Procedure (ROP) of the North American Electric Reliability Corporation (NERC) dated July 19 2018 indicates

ldquoAll Bulk Power System owners operators and users shall provide to NERC and the applicable Regional Entity such information as is necessary to monitor compliance with the Reliability Standards NERC and the applicable Regional Entity will define the data retention and reporting requirements in the Reliability Standards and compliance reporting proceduresrdquo2

The ROP indicates how long evidence should be retained by Compliance Enforcement Authorities (CEA) but the amount of time evidence must be retained by registered entities gets more complicated There are over 50 evidence retention schemes in the existing set of NERC Operation and Planning (OampP) and CIP Standards (see Appendix A) Many evidence retention schemes apply to only one requirement in one Standard Other evidence retention schemes are overly burdensome especially when the risk to reliability is very low This is not a new or unknown problem NERC and an associated study team produced a ldquoData Retention White Paperrdquo dated September 12 20143 This document described a research and analysis project that started in 2013 when the Electric Reliability Organization (ERO) Enterprise assembled an advisory group to provide input and advice for modification of existing NERC Reliability Standard data retention requirements The data retention team was comprised of representatives from NERC and the NERC Compliance and Certification Committee (CCC) The 2014 data retention study team began reviewing and analyzing current data retention requirements and soliciting industry feedback on current data retention requirements Their subsequent white paper presented their findings and made recommendations for changes to current guidance documents future NERC Reliability Standard development and auditing processes The white paperrsquos analysis explored possible options for establishing uniform tools and applications and standardizing evidence retention requirements across the ERO Enterprise to promote consistency in demonstrating compliance These options were intended to provide improvements that support reliability and ensure that resources allocated by the ERO Enterprise and registered entities are commensurate with the potential risks of noncompliance to reliability The 2014 white paper recommended that NERC modify data retention requirements so that the burden of producing records necessary to demonstrate compliance is commensurate with the risk to the reliability of the BPS It further recommended including a consistent data retention period of either a rolling 6-months for high-volume data4 or a 4-year retention period for all other data with two specific exceptions

1 Standards requiring a current program or procedure which would be limited to the currently effective version with a revision history specifying changes and dates of review and

1 Author Dr Michael Puscas EdD Compliance Manager ISO-NE Reviewer Tino Zaragoza Reliability Compliance Officer Imperial Irrigation District 2 NERC Rules of Procedure Link see pg 22 3 pg 27 3 and Section 90 pg 29 3 Data Retention White Paper - 2014 4 ldquoHigh-volume datardquo as used herein refers to electronic data sets and files paper documents or audio recordings with sizes making it cost- or space-prohibitive to gather maintain track and provide the data to auditors within a reasonable period Examples of high-volume data could be access logs video surveillance tapes or voice and telephone recordings

Evidence and Data Retention ndash NERC Standards NERC SER Phase 2 Project

Page | 2 Data and Evidence Retention Analysis NERC SER Phase 2 Project

2 Standards requiring testing at intervals which would require the retention of the last full testing record and evidence of recurrence

The white paper recommended simplifying data requests by including as a part of the ERO Compliance Auditor Manual and Handbook a recommendation that regardless of the data retention requirements of the Standard and time between Compliance Audits auditors focus sampling to the most recent two years This recommended method of sampling would be more efficient and less burdensome for registered entities and the ERO Enterprise By instituting the recommended method of sampling the ERO Enterprise and registered entities could reallocate resources to areas of greater risk to the reliability of the BPS The recommendations contained in the 2014 white paper were presented to NERC but never carried out Data and evidence retention schemes remain overly complicated and burdensome The Standards Efficiency Review (SER) Phase 2 team recognized that data and evidence retention issues remain and require attention The SER Phase 2 team continued the work of the 2014 team The evidence retention team once again analyzed the current evidence retention schemes in the current set of OampP and CIP mandatory standards They discovered over 50 different evidence retention schemes They prepared a draft set of eight new and simplified evidence retention schemes and proposed a new evidence retention scheme for each NERC Standard requirement The remainder of this report is divided into the following sections

Section Page

A general description of the SER Phase 2 effort

A summary of the 2014 Data Retention Study effort

A description of the SER Phase 2 Evidence Retention teamrsquos work

Attachment A The current evidence retention schemes in OampP and CIP Standards

Attachment B Recommended new evidence retention schemes for each Standard and requirement based on risk level


Overview - SER Phase 2 Overview This portion of the evidence retention report summarizes the SER Phase 2 Project

Overall SER Project Scope Evaluate NERC Reliability Standards using a risk-based approach to identify potential efficiencies through retirement or modification of Reliability Standard Requirements Considering that many Reliability Standards have been mandatory and enforceable for 10+ years in North America this project seeks to identify potential candidate requirements that are not essential for reliability could be simplified or consolidated and could thereby reduce regulatory obligations andor compliance burden5

SER Phase 2 Evidence Retention Project Scope Evaluate NERC Reliability Standards (OampP and CIP) as informed by implementation experiences and compliance practices to develop and recommend standards-based solutions intended to reduce inefficiencies and unnecessary regulatory burdens for the purpose of supporting continued safe secure and reliable operations The Phase Two Team will focus on the following activities

bull Identify areas of inefficiency in the current framework of Reliability Standards bull Collaborate and communicate with industry to ensure all areas of inefficiency and potential

solutions are considered bull Potential solutions may include but are not limited to the following

o SARs to remove inefficiencies in the Reliability Standards o Policy recommendations to appropriate ERO staff or committee6

SER Phase 2 Efficiency Concepts The SER Phase 2 team identified six efficiency concepts including

1 Evidence Retention Overhaul 2 Prototype Standard 3 Move Requirements to Guidance 4 Consolidate and Simplify Training Requirements 5 Consolidate InformationData Exchange Requirements 6 Relocate Competency-based Requirements to Certification ProgramCMEP Controls Review

The SER Phase 2 team surveyed the industry through a questionnaire that concluded on March 22 2019 The highest rated efficiency concept was Evidence Retention Therefore this became the first priority for the SER Phase 2 team

5 httpswwwnerccompaStandPagesStandards-Efficiency-Reviewaspx 6 Ibid


Summary of the 2014 Evidence Retention Project Analysis of 2014 Evidence Retention White Paper The SER Phase 2 Evidence Retention team began by reviewing and analyzing the work of the 2014 project team (see Objectives pg 5) to avoid unnecessary duplication of effort and to validate the recommendations by that project team

Tasks Performed by the 2014 Evidence Retention Team The data retention team began reviewing and analyzing the data retention requirements in the then currently-enforceable and NERC Board of Trustee approved NERC Reliability Standards the NERC Rules of Procedure and guidelines for auditing included in the Generally Accepted Government Auditing Standards (GAGAS) Finally the data retention team reviewed the ERO Enterprise Compliance Auditor Manual and Handbook (Auditor Manual) They completed the following tasks

bull Identified and evaluated data retention requirements in the then current NERC Standards bull Recommended improvements to reduce the data-maintenance burdens on registered entities bull Provided guidance regarding the levels of data necessary to support proof of compliance bull Recommended revised data retention requirements to be commensurate with risk to the BPS and bull Recommended methods of sampling that are more efficient and less burdensome for registered

entities

Purpose of the 2014 White Paper The 2014 Evidence Retention study team created a ldquoWhite Paperrdquo to present their findings The twofold purpose of the evidence retention white paper was to provide rationale for proposed revisions to

1 The data retention requirements in NERC Reliability Standards and 2 The methodology of Compliance Audit and Spot Check data sampling requests

The goal was to minimize the Compliance Enforcement Authority (CEA) and registered entity resources used for gathering storing and producing data while maintaining reasonable assurance of compliance with the effective NERC Reliability Standards and reliability of the BPS

Identified Evidence Retention Problems Issues and Concerns The 2014 Evidence Retention team examined the data retention requirements of each active NERC Standard7 The 2014 team identified a series of data retention problems for example

bull There is no current consistent data retention period prescribed by FERC (the Commission) or NERC applicable to all Reliability Standards For example

o BAL-001-01a requires a one-year retention period for real-time operating data o VAR-002-2b requires two years of real-time operating data o COM-001-11 requires a 90-day retention of operator logs o IRO-006-5 if the records are audio recordings they have a 90-day retention but if

documented transcripts then it should be 12 months o MOD-028-2 requires retaining data for 12 months for seven of its requirements but

either 14 30 or 60 days for two other requirements 7 NOTE Many NERC Standards that were active in 2014 are now either inactive or replaced by newer versions



bull There are different requirements for the length of time registered entities must keep identical types of data for certain Reliability Standards

bull The ERO Enterprise has considerable flexibility to determine and identify how long a registered entity must retain evidence to show compliance

bull Current evidence retention policies arenrsquot related to high reliability risk areas and therefore places undue administrative burden on registered entities

bull The NERC Rules of Procedure (ROP)8 do not include specific evidence retention guidance for registered entities The Rules of Procedure leave the assignment of data retention and reporting requirements to NERC or the Regional Entity

bull Industry responses voiced a frustration and opinion that the focus of auditor data requests and NERC Reliability Standards data retention requirements are on proving compliance and not enhancing reliability They voiced a desire to focus on current practices and policies instead of historical documents which may not have been relevant for several years

Recommendations from the 2014 Evidence Retention Study Team The 2014 Evidence Retention team documented a series of recommendations

bull NERC should modify data retention requirements in Standards so that the burden of producing records necessary to demonstrate compliance is commensurate with the impact to the reliability of the BPS

bull All new Standards receive a default four-year data retention period This four-year period will exclude the following

o Voice and audio recordings which will continue to be a 90-day rolling retention period o High-volume data which would be restricted to a six-month rolling retention period o Standards requiring a current program or procedure which would restrict to the currently

effective version with a revision history specifying changes and dates of review o Standards requiring testing intervals (eg PRC-005) which would restrict to the most

recent full testing records with evidence of previous testing intervals bull If current Reliability Standards are silent as to a data retention period then the four-year or six-

month data retention period should be used bull Data sampling by CEAs should be focused on the most recent two years unless the data sample

would be statistically too small or irregularities are identified in the initial samples

8 httpswwwnerccomFilingsOrdersusRuleOfProcedureDLNERC_ROP_Effective_20180719pdf


2019 SER Phase 2 Evidence Retention Project Overview Introduction to SER Phase 2 Evidence Retention Project This project evaluates and continues the work completed by the 2014 Evidence Retention team NERC conducted a survey to gather industry comments related to six efficiency concepts Analysis of industry comments indicated that the Evidence Retention concept was the highest rated SER Phase 2 concept NERC and the SER Advisory Group selected the Evidence Retention concept as the first SER Phase 2 initiative This will be verified through meetings with the CCC on June 18th 2019 and with the NERC Standards Committee (SC) on June 26th 2019

SER Phase 2 Evidence Retention Project Team 1 Michael Puscas Evidence Retention Team Lead 2 Tino Zaragoza Evidence Retention Team Co-Lead 3 Chris Larson NERC SER Phase 2 Project Lead 4 Amy Casuscelli SC Vice-Chair 5 Ed Kichline 6 John Allen SER Phase 2 Project Chair 7 Ryan Mauldin 8 Kiel Lyons 9 Steve Noess 10 Jennifer Flandermeyer (NERC CCC Chair) 11 Richard Burt (CMG Rep) 12 Terry Bilke (MISO)

Evidence Retention Project Objectives The SER Phase 2 Evidence Retention team will

Objective Status

1 Review and analyze the 2014 Evidence Retention efforts retaining recommendations that are still appropriate and valid

1st Draft Complete

2 Inventory and analyze the Evidence Retention schemes in currently enforceable Standards to determine impact on reliability and high risks

1st Draft Complete

3 Build on the work of the 2014 Evidence Retention team and document a new and much simplified set of data retention guidelines

1st Draft Complete

4 Recommend and justify proposed dataevidence retention solutions for each NERC Standard

1st Draft Complete

5 Determine in concert with the SER Advisory Committee NERC CCC and NERC Management how to implement the recommendations of the Evidence Retention Team and the appropriate committee to oversee the successful implementation of the recommendations

In progress



Evidence Retention Project Scope The Evidence Retention efficiency project includes

bull Analysis of current mandatory OampP and CIP Standards bull Analysis of the risk levels of each Standard requirement bull Analysis of Data and Evidence Retention sections of the NERC Standards

Evidence Retention Out of Scope The Evidence Retention efficiency project does not include

bull OampP and CIP Standards subject to future enforcement bull Auditor compliance evidence sampling methodologies bull Specific evidence retention implementation plans and strategies bull Changes to any portion of a given NERC Standard

Evidence Retention Project Assumptions The Evidence Retention efficiency project assumes

bull The recommendations of the SER Phase 2 teamrsquos recommendations will be assigned to an owner who will assure that the evidence retention recommendations are fully implemented

bull The committee or owner will establish an implementation strategy and timeline for the new evidence retention schemes

Evidence Retention Questions The Evidence Retention team considered the following questions

Questions Answers What is the purpose and value of evidence retention

Data and evidence is important because it provides information to support decision-making by auditors and is mandatory to meet regulatory requirements

How are measures related to evidence retention Should they be considered as part of this effort Is it beneficial to have measures in the Standard

Standard requirement measures often indicate what the specific evidence should look like The data or evidence retention portion of the Standard explains how long to keep that evidence The two are somewhat related Measures describe the tangible artifacts while the dataevidence retention rules are time-based

Are there potential benefits if the measures especially for high Violation Risk Factor requirements were written differently

Measures in NERC Standards are already sufficiently detailed to indicate what information needs to be collected Rewriting them by adding retention information would only create more confusion

Can we find opportunities to revise the measure language to reduce the burden of collecting storing and producing records

Going forward as new Standards are developed or existing Standards are revised it is important to assure that the measures are clearly and specifically written without reference to how long to keep records

Is it even practical to collect the type of evidence mentioned in the requirements andor measures if the reliability risk is low



Benefits of Revised Data Retention Rules The advantages of a simplified set of data retention rules include

bull Simplified evidence retention schemes reduce the compliance costs associated with low risk activity registered entities donrsquot need to spend resources on low risk activities especially if evidence retention is not required

bull Evidence retention takes up space on servers which could be used for other purposes Excessive data retention increases costs to manage backup compile and review data for compliance monitoring and enforcement activities

bull Simplified evidence retention schemes offer innovative approaches that mitigate high risks Ultimately evidence retention is tied logically to risk mitigation which replaces arbitrary evidence retention schedules

bull Simplified evidence retention schemes will enable entities to align their internal retention policies with the NERC requirements

bull Examination of current dataevidence retention schemes incentivizes creative thinking and best practices The envisioned future state is a simplified and flexible set of data retention rules that are in line with risk and reliability The rules will address changing technology and emerging threats

bull Simplified rules provide long-term stability to the Reliability Standards and it provides clear guidance to SDTrsquos which reduces the overall Standard development time

Challenges Potential challenges include

bull Proposed evidence retention rules may require changes to the NERC Rules of Procedure depending on how the Evidence Retention teamrsquos recommendations are addressed

bull The ERO Compliance Auditor Manual and Handbook may also need to be updated After update all CEA auditors must be trained in the new evidence retention and data sampling rules This assures that all regions are auditing and sampling in a consistent fashion

bull The proposed evidence retention schemes the implementation process and timeline will require further study and verification by NERC and the committee or task force assigned to implement the recommendations of the SER Phase 2 evidence retention team

Project Timeline Date Event Status 5819 Draft Evidence Retention Report Due Complete 51319 Working Meeting Complete 52019 Meet with Chris Larson and John Allen Complete 61119 SER Advisory Committee Meeting in Atlanta GA Complete 61519 Second draft of the Evidence Retention Report Due Complete 61819 John Allen meets with NERC CCC for status update Scheduled 62619 Meet with SC Scheduled 63019 Third draft of the Evidence Retention Report Due Scheduled TBD Industry Feedback Next Steps (Webinar White Paper SC Committee) TBD TBD Final Draft of the Evidence Retention Report Due TBD


Analysis of Existing Evidence Retention Schemes Introduction Many Standards studied in 2014 are either inactive or were replaced with newer versions of the Standard Therefore the SER Phase 2 evidence retention team analyzed all mandatory and enforceable Operations and Planning (OampP) and Critical Infrastructure Protection (CIP) Standards focusing attention on the data retention requirements of each Standard and each requirement They discovered over 50 different evidence retention schemes strewn throughout various Standards and requirements Specific information on each scheme and applicable Standards and requirements is included in Appendix A

Observations of Existing Evidence Retention Schemes

Applicability of Evidence Retention Schemes Many current evidence retention schemes apply to only one requirement in one Standard (See Appendix A) for example PRC-026-1 R3 The largest evidence retention schemes include

o ldquoLast 3 Calendar Yearsrdquo with over 40 applicable requirements o ldquoSince Last Compliance Auditrdquo with 34 applicable requirements o ldquoCurrent Plus 3 Previous Calendar Yearsrdquo with 28 applicable requirements

Similarity of Schemes There was very little difference between certain evidence retention schemes for example the following retention schemes are basically the same

o 12 Calendar Months vs 12 Calendar Months Following Completion of each CAP o 12 Calendar Months vs One Calendar Year o 12 Calendar Months vs Current Year o 12 Calendar Months vs Last 12 Calendar Months o Two Calendar Years vs Current Calendar Year Plus One Previous Calendar Year

Plans Assessments Models Tests and Document Schemes There were many similarities when specifying the current and previous version of plans assessments models tests and documents for example

o Current and Previous Model Used to Determine Flowgates and TFC o Current and Prior Transfer Capability Methodology Since Last Compliance Audit o Current and Prior Versions o Current Blackstart Testing Results and Previous Testing Results o Current GMD Vulnerability Assessment and Preceding Assessment o Current In-Force ATCID Provided by TSP and Prior Versions of ATCID o Current In-Force Documents and Previous Documents

Poor Descriptions or Non-Existent Schemes Some evidence retention schemes were poorly described for example ldquoCurrent and Previous Calendar Yearsrdquo but the exact number of previous calendar years was not specified Six requirements had no evidence retention schemes specified at all One evidence retention scheme was extremely general and



potentially no longer applicable for example ldquoRetain Evidence of Any Path and Rating Prior to 1194rdquo as shown in MOD-029-2a R2

Variations on a Theme There were a lot of variations on the theme of ldquoCurrentrdquo for example

bull Current In-Force Data Specification for Analysis and Real-Time Monitoring bull Current In-Force Documents bull Current In-Force Documents and Previous Documents bull Current In-Force Facility Ratings Methodology bull Current In-Force Outage Coordination Process bull Current Model Used to Calculate TTC bull Current Planning Analysis Results bull Current Plus 1 Previous Calendar Year bull Current Plus 2 Previous Calendar Years bull Current Plus 3 Previous Calendar Years bull Current Version and Prior Version of The TTC Study Reports bull Current Year

Evidence Retention Language NERC Reliability Standards contain language in the data retention or evidence retention sections that are exactly the same from Standard to Standard as noted below Sometimes however language differs slightly

bull Evidence retention periods identify the period of time an entity is required to retain specific evidence to demonstrate compliance For instances where the evidence retention period specified below is shorter than the time since the last audit the Compliance Enforcement Authority may ask an entity to provide other evidence to show that it was compliant for the full-time period since the last audit

bull In addition entities found non-compliant shall keep information related to the non-compliance until found compliant

bull If a Transmission Service Provider or Transmission Operator is found noncompliant it shall keep information related to the non-compliance until found compliant

bull If a Planning Coordinator is found non-compliant it shall keep information related to the non-compliance until found compliant or for the time periods specified above whichever is longer

bull If a Reliability Coordinator Transmission Operator Balancing Authority Generator Operator or Distribution Provider is found non‐compliant it shall keep information related to the non‐compliance until mitigation is complete and approved or for the time specified above whichever is longer

bull If an entity is found non-compliant the entity shall keep information related to the noncompliance until found compliant or for two years plus the current year whichever is longer

bull Evidence used as part of a triggered investigation shall be retained by the entity being investigated for one year from the date that the investigation is closed as determined by the Compliance Monitor

bull The Compliance Monitor shall keep the last periodic audit report and all requested and submitted subsequent compliance records

bull Not all NERC Standards have a ldquoData Retentionrdquo section bull Some Standards have a single data retention directive bull Some Standards have data retention specifications for each requirement in the Standard bull Some Standards have data retention specifications related to the Standardrsquos measurements



bull Many Standards use the term ldquoData Retentionrdquo Newer Standards use the term ldquoEvidence Retentionrdquo

Evidence Categories The existing NERC Standards describe Data and Evidence retention periods that attempt to address evidence that falls into one or more of the following evidence categories

1 Voice Data 2 Logs 3 Documents Processes and Plans 4 Models and Methodologies 5 Assessments Lists Records and Studies 6 Agreements

Different Headings in NERC Standards The team discovered that two headings were used interchangeably in the NERC Standards

1 Data Retention 2 Evidence Retention

General Observations The Evidence Retention team observed

bull The dataevidence retention schemes were somewhat arbitrary Some were excessively long some very short but there was no consistent rationale for retention length

bull Similar evidence categories described in different Standards have different evidence retention schemes Evidence retention schemes vary within specific Standards by requirement

bull Some evidence retention schemes are one-of-a-kind that is they appear only once This is usually because they are so specific they apply only to one Standard and one requirement These overly specific data retention schemes are not necessary for example PRC-026-1 R3


Evidence Retention Recommendations This section of the report presents SER Phase 2 recommendations for evidence retention

Recommended Evidence Retention Schemes Simplify the existing evidence retention schemes to a manageable set of eight evidence retention schemes or rules to cover all NERC OampP and CIP Standards and requirements as shown in the following table

Recommended DataEvidence Retention Schemes

Rationale for the DataEvidence Retention Scheme

1 Rolling three-year data retention period

Many existing evidence retention schemes call for a three year retention schedule which is less than the default 4-year schedule but it should be a rolling three-year period

2 Rolling 90-day data retention period for voice and audio recordings

Voice and audio recordings take up a lot of space on computer systems Therefore only 90-days of history are necessary

3 Default four-year data retention period

Unless specifically called out this is the default dataevidence retention scheme

4 Rolling 6 Months data retention period for high volume data

This may not be needed if 30 days of rolling data is enough to satisfy compliance-related issues

5 Current plan model agreement methodology study program or procedure with a revision history specifying changes and dates of review

This satisfies the need for auditors to see the most recent documentation in a variety of areas

6 Most recent full testing records with evidence of previous testing intervals

This satisfies the requirements to complete and document various tests

7 Rolling 12 Calendar months data retention period

This satisfies the requirement to have at least 12 months of data Given the type of data itrsquos not necessary to have 3 or more years of data

8 Rolling 30-day data retention period

This is high volume data and thus requires only 30 days of data to demonstrate compliance

Additional Recommendations The SER Phase 2 team DataEvidence Retention Project team recommends the following

1 All NERC Standards should bear the same heading ldquoData and Evidence Retentionrdquo 2 Compliance Data and Evidence should be retained for the shortest possible time-frame to clearly

demonstrate compliance 3 There are three evidence retention categories



31 Paper 32 Electronic Data 33 Storage Intense Data (Voice etc)

4 Update the NERC Auditorrsquos Manual and associated training with the new dataevidence retention schemes Retrain all auditors and SDTs on the new evidence retention schemes

5 Update the NERC Rules of Procedure with guidance for the Standard SDTs 6 Itrsquos important to have TOsGOs engaged on the socialization The primary proponents of this

issue were originally TOsGOs and they pointed to standard families like PRC as forming the need for this type of relief Their audit cycle experience ndash which also is pertinent to this issue ndash tends to be different than RCBATOPs as well It will be easier to socialize the issue if those entities most impacted by the proposed recommendation help communicate the importance of it

7 It is important to have the SCCCC Chairs and key NERC Personnel talk about what questionsissues each needs to resolve to determine what their role is in accepting the evidence retention recommendations The process will move this concept more effectively if the Committees first understand what they are being asked to consider and what steps NERC is willing to take on this as the ERO

8 Define upfront an expected close out date for acceptingrejecting recommendations with the Committee Chairs and NERC personnel The SER team suggests we map out who needs to review what what decisions they need to make and when those decisions can reasonably happen That way if we start to approach a date and completion doesnrsquot look imminent we can discuss how to respond Without a proposed completion date discussion could get drawn out

9 Create an implementation timeline for next steps to avoid what happened with the work completed in 2014 NERC needs to assure that specific actions are taken and there is agreement on who ldquoownsrdquo the implementation of the evidence retention project and recommendations

10 Determine how the new evidence retention schemes will be implemented possibly through the Enhanced Periodic Review (EPR) to avoid confusion and a massive overhaul of existing Standards

11 Assure that evidence retention is concentrated on the highest risk requirements and not necessarily on all requirements


Appendix ndash Results of Analyzing Current Evidence Retention Schemes List of Existing Evidence Retention Schemes in NERC Standards The following table summarizes the results of analyzing the dataevidence retention schemes listed in all active NERC OampP and CIP Standards NOTE The list did not exclude Standards and requirements slated for retirement as part of SER Phase 1 efforts since at the time of this report retirements were not yet effective

Current Evidence Retention Scheme Total Standards and Requirements List

1 12 Calendar Months Following Completion of each CAP

1 PRC-026-1 R3

2 90 Calendar Days 3 CIP-007-6 R4 IRO-018-1(i) R3 PRC-001-11(ii) R2

3 90 Calendar Days Voice 12 Months for Logs 2 FAC-003-4 R1 TOP-002-4 R1

4 Approved Plan and Previous Plan Since Last Compliance Audit

2 EOP-005-3 R1 EOP-006-3 R1

5 Current and Previous Calendar Years (time not specified)

1 EOP-008-2 R7

6 Current and Previous Model Used to Determine Flowgates and TFC

1 MOD-030-3 R2

7 Current and Previous Planning Assessment 1 TPL-001-4 R1

8 Current and Prior Transfer Capability Methodology Since Last Compliance Audit

1 FAC-013-2 R1

9 Current and Prior Versions 1 EOP-005-3 R6

10 Current Blackstart Testing Results and Previous Testing Results

1 EOP-005-3 R7

11 Current Calendar Year Plus One Previous Calendar Year except operator logs and voice recordings - retain for 90 calendar days

7 COM-002-4 R1 R2 IRO-018-1(i) R1 TOP-001-4 R1 R15 R22 TOP-010-1(i) R1

12 Current GMD Vulnerability Assessment and Preceding Assessment

1 TPL-007-1 R4

13 Current In-Force Agreement 1 NUC-001-3 R2

14 Current In-Force ATCID Provided by TSP and Prior Versions of ATCID Since Last Compliance Audit

3 MOD-001-1a R3 MOD-029-2a R1 MOD-030-3 R1




15 Current In-Force Data Specification for Analysis and Real-Time Monitoring

1 TOP-003-3 R2

16 Current In-Force Documents 1 PRC-001-11(II) R1

17 Current In-Force Documents and Previous Documents Since Last Compliance Audit

3 EOP-008-2 R8 IRO-002-5 R1 IRO-014-3 R1

18 Current In-Force Facility Ratings Methodology Since Last Compliance Audit

2 FAC-008-3 R2 R3

19 Current In-Force Outage Coordination Process Since Last Compliance Audit

1 IRO-017-1 R1

20 Current Model Used to Calculate TTC 2 MOD-028-2 R2 MOD-029-2a R1

21 Current OPA Real-time Monitoring and Real-time Assessments Since Last Audit

2 IRO-010-2 R1 TOP-003-3 R1

22 Current Operating Plan and Previous Plans Since Last Compliance Audit

5 EOP-004-4 R1 EOP-008-2 R1 R6 EOP-011-1 R1 R2

23 Current Planning Analysis Results 1 NUC-001-3 R3

24 Current Plus 1 Previous Calendar Year 7 IRO-002-5 R5 MOD-001-1a R2 R6 MOD-030-3 R5 TOP-001-4 R20 R23 VAR-002-41 R1

25 Current Plus 2 Previous Calendar Years 4 NUC-001-3 R4 R5 PER-004-2 R1 PRC-001-11(ii) R3

26 Current Plus 3 Previous Calendar Years 28 BAL-001-2 R1 BAL-002-3 R2 BAL-003-11 R1 BAL-005-1 R1 EOP-005-3 R2 R3 R4 R5 EOP-006-3 R2 R3 R4 R5 R6 FAC-008-3 R1 IRO-014-3 R6 MOD-001-1a R5 MOD-004-1 R1 R2 R3 R4 R6 R10 R11 MOD-008-1 R2 R4 MOD-029-2a R3 R7 MOD-030-3 R22

27 Current Version and Prior Version of The TTC Study Reports

1 MOD-029-2a R2

28 Current Year 1 EOP-008-2 R2

29 Five Calendar Years 4 PRC-002-2 R1 R5



Current Evidence Retention Scheme Total Standards and Requirements List TPL-007-1 R1 R7

30 Last 12 Calendar Months 13 FAC-014-2 R1 IRO-014-3 R5 MOD-028-2 R3 R4 R10 MOD-030-3 R21 R4 PRC-004-5(i) R1 R5 R6 PRC-006-3 R6 PRC-026-1 R2 VAR-001-5 R1

31 Last 12 Calendar Months Plus Current Month 3 IRO-006-5 R1 IRO-006-East-2 R1 R2

32 Last 14 Days Past 30 Days Daily Values And Past 60 Days for Monthly Values

3 MOD-028-2 R8 MOD-029-2a R5 MOD-030-3 R6

33 Last 3 Calendar Years Over 40

CIP-002-51a All CIP-003-6 All CIP-004-6 All CIP-005-5 All CIP-006-6 All CIP-007-6 All CIP-008-5 All CIP-009-6 All CIP-010-2 All CIP-011-2 All CIP-014-2 All EOP-010-1 R1 FAC-001-3 R1 FAC-002-2 R1 FAC-003-4 R1 R2 R3 R5 R6 R7 FAC-008-3 R4 R7 R8 IRO-010-2 R2 IRO-017-1 R2 R3 R4 MOD-026-1 R1 R3 MOD-027-1 R1 R3 PRC-006-NPCC-1 R1 PRC-018-1 R1 PRC-023-4 R1 PRC-024-2 R1 PRC-025-2 R1 TOP-003-3 R3 R4

34 Last Load Control or Active PowerFrequency Control System Model Verification

1 MOD-027-1 R2

35 Latest Excitation Control System or Plant voltvar Control Function Model

1 MOD-026-1 R2

36 Latest Transmittals and Receipts 1 NUC-001-3 R1




37 Most Recent 12 Calendar Months Except Operator Logs and Voice Recordings - Retain for 90 Calendar Days

3 IRO-002-5 R3 TOP-001-4 R21 R24

38 Most Recent 12 Calendar Months Except Voice Recordings Most Recent 90 Calendar Days

7 COM-001-3 R1 R12 R13 R3 R5 R7 R8

39 Most Recent 3 Calendar Months Plus Current Month 6 INT-004-31 R1 R3 INT-006-4 R1 R2 INT-009-21 R1 INT-010-21 R1

40 Most Recent 90 Calendar Days 2 IRO-010-2 R3 TOP-003-3 R5

41 Most Recent 90-Calendar Days Voice Most Recent 12 Calendar Months Documentation

2 IRO-001-4 R1 R2

42 Most Recent List of Circuits 1 PRC-023-4 R6

43 None Specified 6 MOD-020-0 R1 PRC-008-0 R1 PRC-011-0 R1 PRC-015-1 R1 PRC-016-1 R1 PRC-017-1 R1

44 One Calendar Year 1 PRC-026-1 R1

45 One Year from SOL Methodology Change 2 FAC-010-3 R1 FAC-011-3 R1

46 Retain Evidence of Any Path and Rating Prior to 1194 1 MOD-029-2a R2

47 Rolling 12-Month Period 1 IRO-009-2 R1

48 Rolling 30-Days 4 IRO-008-2 R4 IRO-018-1(ii) R2 TOP-001-4 R13 TOP-010-1(i) R3

49 Rolling 90-Calendar Days for Voice 12 Months for Operating Logs

3 IRO-008-2 R1 IRO-014-3 R3 TOP-002-4 R1

50 Since Last Compliance Audit 34 BAL-002-3 R1 EOP-004-4 R2 EOP-008-2 R3 R4 R5 EOP-011 R3 R5 R6 FAC-008-3 R1 FAC-013-2 R2 MOD-001-1a R1 MOD-008-1 R1 MOD-025-2 R1 R3 MOD-028-2 R1 MOD-031-2 R1



Current Evidence Retention Scheme Total Standards and Requirements List MOD-032-1 R1 MOD-033-1 R1 PER-005-3 R1 R2 PRC-005-6 R1 R2 R5 PRC-006-3 R1 R10 R7 R8 R9 TPL-001-4 R2 R3 R4 R5 R6 R7

51 Since Last Compliance Audit Plus one Previous Compliance Audit

2 EOP-005-3 R10 EOP-006-3 R8

52 Six Calendar Years 3 PRC-006-3 R11 PRC-010-2 R1 PRC-019-2 R1

53 Three Calendar Years 6 PRC-002-2 R2 R6 R7 PRC-005-11b R1 TOP-001-4 R12 R14

54 Three Years or Since Last Compliance Audit Whichever is Longer

1 PER-003-1 R1


NERC Reliability Issues Steering Committee

Action Discussion

Background The NERC Reliability Issues Steering Committee (RISC) is developing the 2019 ERO Reliability Risk Priorities Report The report incorporates the data that was derived from the Emerging Risks Survey that was completed by the members of the various NERC Standing Committees

Summary The RISC Committee with NERC hosted the 2019 Reliability Leadership Conference on March 14 2019 in Washington DC The meeting attendees included electric industry leaders and regulators The conference provided an opportunity to discuss identified and emerging risks to the bulk power system (BPS) as well as to provide commentary and strategic direction from system planners and operators regulators policy makers and industry on current emerging risks to the BPS On March 15 2019 the RISC conducted an in-person meeting to review and summarize the information shared at the conference The results were used to develop the Emerging Risks Survey

The RISC analyzed the results of the Emerging Risks Survey and decided to consolidate the risks into five risk profiles

bull Changing Resource Mix BPS Planning and Resource Adequacy and Performance

bull Increased Complexity in Protection and Control Systems and Human Performance and SkilledWorkforce

bull Loss of Situational Awareness

bull Extreme Natural Events

bull Physical Security Vulnerabilities Cybersecurity Risk and Critical InfrastructureInterdependency

The focus of the RISC for the third quarter is to create the 2019 ERO Reliability Risk Priorities Report which will be available for comment in the Board Policy Input request for the August 2019 NERC Board meeting

The report will include

bull More focus on providing clarity for the target audience

bull Improved layout and graphics

bull Succinct messaging

bull Prioritization of risks and mitigating activities

bull Expanded Heat Maps

CCC Agenda June 2019

NERC AntiTrust Compliance Guidelines

NERC Public Announcements

Agenda Item 3b Effectiveness and Efficiency Summary with Action Items

Agenda Item 3c - Communications Plan

Agenda Item 5ci -New EROMS Scope redline

3353 Peachtree Road NE Suite 600 North Tower Atlanta GA 30326

404-446-2560 | wwwnerccom

Section 1 Mission



31 Goals

32 General

33 Subgroup Membership and Representation

34 Membership Not Restricted to CCC Members

35 Resignations

a By the Member

b Requested by the Chair

c Referral to the CCC Chair

d By the Board

36 Proxies

a Notification


37 Exclusions

38 Changes in Member Affiliation

39 Acknowledgement of a Membership Conflict

Section 4 Meetings

41 Antitrust Guidelines

42 Open Meetings

43 Confidential Sessions

44 Types of Meetings

45 Majority and Minority Views

46 Actions without a Meeting

47 Quorum


51 General

a Number of Positions

b Officers

c Secretary

d Officers May Vote

e Officers are Named by the CCC Chair for a Two-year Term

52 Chair

53 Vice Chair

54 Staff Coordinator


61 Committee Organization Hierarchy

62 Establishing Subgroups


Agenda Item 5ci - New EROMS Scope clean



Section 1 Mission



31 Goals

32 General



35 Resignations

a By the Member



d By the Board

36 Proxies

a Notification


37 Exclusions



Section 4 Meetings


42 Open Meetings





47 Quorum


51 General


b Officers

c Secretary

d Officers May Vote


52 Chair

53 Vice Chair






Agenda Item 5cii - CCCPP-001 Monitoring Program for NERCs Adherence to NERCs Rules of Procedure for Compliance Enforcement redline

Agenda Item 5cii - CCCPP-001 Monitoring Program for NERCs Adherence to NERCs Rules of Procedure for Compliance Enforcement clean


Agenda Item 5ciii CCCPP-011 Procedure to Become a Prequalified Organization Eligible to Submit Implementation Guidance to the ERO redline

Preface

CCCPP-011-1

Summary

Revision History

Antitrust Guidelines

Open Meetings

Types of Meetings

Majority and Minority Views

Actions without a Meeting

Quorum

Submit Application

Review Application

Notifying Applicant and ERO Enterprise

Review Period

Retention Management

Confidentiality Management



Member Details

Application

Please send this form to the following location

Agenda Item 5ciii CCCPP-011 Procedure to Become a Prequalified Organization Eligible to Submit Implementation Guidance to the ERO Clean

Preface

Summary

Revision History

1 Introduction

2 Scope

3 Meetings


Open Meetings

Types of Meetings



Quorum



Submit Application

Review Application


6 Administrative

Review Period






Member Details

Application

Agenda Item 7 -NERC Internal Audit (IA) Risk Process


Action

Background

Summary

Agenda Item 7ii - NERC Internal Audit (IA)Risk Process

Slide Number 1

Appendix 4A Audits


Slide Number 4

Agenda Item 8 ERO CMEP

Agenda Item 9 CORES Rollout

Slide Number 1

Agenda

Overview


Benefits





Website


Training

Whatrsquos Next

Slide Number 14

Agenda Item 12 NERC Board of Trustees and MRC Meeting Summary - May 2019 Meetings

Agenda Item 13 - Standards Efficiency Review Update

Agenda Item 13 - Standard Efficiency Review Phase 2- Data Retention

Agenda Item 14 RISC Reliability Risk Report

Agenda Item 13 - Evidence Retention for NERC Standard Requirements-draftpdf

Executive Summary

Overall SER Project Scope

SER Phase 2 Evidence Retention Project Scope

SER Phase 2 Efficiency Concepts

Analysis of 2014 Evidence Retention White Paper

Tasks Performed by the 2014 Evidence Retention Team

Purpose of the 2014 White Paper

Identified Evidence Retention Problems Issues and Concerns

Recommendations from the 2014 Evidence Retention Study Team

Introduction to SER Phase 2 Evidence Retention Project

SER Phase 2 Evidence Retention Project Team

Evidence Retention Project Objectives

Evidence Retention Project Scope

Evidence Retention Out of Scope

Evidence Retention Project Assumptions

Evidence Retention Questions

Benefits of Revised Data Retention Rules

Challenges

Project Timeline

Introduction


Applicability of Evidence Retention Schemes

Similarity of Schemes

Plans Assessments Models Tests and Document Schemes

Poor Descriptions or Non-Existent Schemes

Variations on a Theme

Evidence Retention Language

Evidence Categories

Different Headings in NERC Standards

General Observations

Recommended Evidence Retention Schemes

Additional Recommendations

List of Existing Evidence Retention Schemes in NERC Standards


Action

Background

Summary

Agenda Item 13 - Standards Efficiency Reviewpdf

CCC Standards Efficiency Review Update

SER Project Scope

Phase 1 Team Scope

Phase 1 Results

Modifications Sub-team

Phase 2 Scope

Perceived Issues

Efficiency Concepts

Efficiency Concepts

Efficiency Concepts

SER CIP Project

Slide Number 12

Evidence Retention

Analysis of Standards

Recommendations

Slide Number 16

Agenda Item - Communications Planpdf

Slide Number 1


Membership


Slide Number 5

Action Items

Archive

CCC Archived Action Item List - March 2019

Date Responsible Parties Due Date Status Comments and Next Steps

1 Roster Update - Fill gaps and resolve errors in CCC CCC plus and subcommittee lists Roster to include term completion of auditor training and NDA on file Adina Mineo Brooke Thornton Closed Update the ListServe as needed

2 RAI Support - CCC has a request from the NERC BOTCC to survey regions to identify and summarize Regional initiatives that support (entity controls application guides active committees etc) Earl to provide an RAI presentation at the next Denver F2F p CCC Members Jerry Hedrick and Sonia Mendonca Closed Item closed Open items transitioned to eh CCC 2014 Work Plan for RAI activities

3 NERC to send Nominating Form out to industry semiannually Hope Mabry Jim Hughes Martin Huang Closed Next Nomination Form will be sent by NERC two week after the February and September CCC meetings

4 Sep-12 Access - CCC Members need to secure a login for the CCC ftp site Members and Adina Mineo 93013 Closed

5 FERC Audit Education - John Hairstons task force to build out his information on what Registered Entities can expect if they receive a FERC audit Deliverable to include recommendations on how to harmonize with NERC audits spot checks and controls-eval John Hairston Closed Presentation given Need to locate presentation and post in Related Files (NERC or Shared site)

6 Enforcement Stats - Work with staff to track and improve cycle times on the various (Full NOP Spreadsheet NOP FFT) enforcement actions to demonstrate improvements in all areas Utilize current and readily available statistics where possible Goal is t CPPS Sonia Mendonca and Ed Kichline (Farzena) Closed Ongoing NERC and Regional Entity initiative Need to check on current reporting to BOTCC and other reports to query data and understand the FFT cycle for violation processing

7 Sep-13 Distribute - Jim to distribute the Auditor Handbook (draft) to the CCC Adina Mineo Closed Posted on NERC website on April 30 2014

8 Jan-13 RISC Item RISC asked for guidance on Planning AuthorityPlanning Coordinator issue ORCS Closed Jennifer Flandermeyer to report to RISC by explaining the new registration program This will address concerns about which entities are registered as PC and determine if there are gaps in PC registration

9 Mar-13 2014 CCC Work Plan Review plan to revamprefresh to address new NERC Strategic Plan Each subcommittee chair to provide Terry a bulleted list of accomplishments to date where they are at now and what is planned for 2014 CCC Closed Approved at May 2014 Board meeting

10 Mar-13 Feedback Gerry Cauley requested that the CCC review and provide feedback on the NERC Pro forma Internal Controls Document CCC Closed Adina will check with Jerry Hedrick about the feedback on the Internal Controls evaluation portion of the entity risk assessment under RAI

11 Independent Audit in 2012 of NERC - CCC to complete remaining items from ORC and CMEP processes and present report to the NERC BOT NERC to provide plan for public posting of results of 2012 Independent Audit Sept 2013 Update Present - NERC staff to co Clay Smith Mechelle Ferguson Closed CCC provided final report with action items NERC needs to publically post the report on the NERC website

12 Sep-13 Present - Jim Stanton to finalize RSAW comments to CCC for final review and comment from all members to provide NERC staff the CCCs recommendations for RSAW considerations in the RAI project Jim Stanton 93013 Closed Brooke needs to repost final document (originally posted on SIS site) to CPPS site

13 Mar-13 Evaluation of combining subcommitteesworking group - SIS PROCS and RBRCWG to review charters SISPROCSRBRCWGMatt Goldberg Closed Complete review for discussion at June 2013 CCC meeting and final presentation at the September F2F

14 Mar-13 2012 Stakeholder Perception Survey Results Rollout and Improvement Plan NERC Staff on detailed recommendations to support BOTCC request on improving stakeholder perception survey results Present the results of the 2012 Self-Certifications Perception EROMS Closed Report and recommendations have been finalized and sent to the Board Report posted on NERC website

15 Jun-13 PER-005 - RSAW issues related to additional requirements imbedded in RSAW that are not included in standard CCC also asked to identify other RSAWs with similar issues Matt Goldberg and Earl Shockley Closed June 2013 Matt provided specific issues to Earl Awaiting response from Earl

16 Jun-13 Review -NERC to provide Multi-Regional Registered Entity (MRRE) pilot documents to ORCS for review Sonia Mendonca and ORCS Closed

17 Sep-13 Post - Bob Hoopes to provide Jim the RAI documents for posting Jim Hughes 92513 Closed NERC will not be posting as a result on the ongoing RAI Adina will update the current FAQ with a disclaimer that NERC and the CCC will coordinate a future update once the risk assessment process and internal controls reviews are finalized

18 Jun-13 Distribute - NERC staff to distribute the Impacts and benefits document after NERC review Jim Hughes 92513 Closed V1 was posted on 12714

19 Jun-13 Present - NERC staff the KRSSC recommendations after vetting through CCC members Jennifer F 103113 Closed

20 Jun-13 Present - CCC members to present various examples of internal controls at the next F2F meeting in Denver CCC Members Closed

21 Jun-13 Present - CCC members to provide Jim Stanton various examples of RSAWS for efficiencies CCC Members Closed

22 Jun-13 Present - CCC members to provide NERC various examples of compliance monitoring inconsistencies at the next F2F (NERC needs details to act on feedback) CCC Members Closed Need to ask CPPS whether this remains open

24 Sep-13 Present - Terry to reach out to NERC staff and BOT for charter changes due to 2014 work plan approval Terry 123113 Closed

25 Sep-13 Present - Terry to reach out to BOT regarding COM-003 and the IR resolution Terry 123113 Closed

26 Sep-13 Present - Clay to present the RISC updates as a standing agenda item Clay Smith 11113 Closed Added as a standing item

27 Sep-13 Present - NERC staff to present action plan status with due dates and milestones at each meeting (Survey) so the CCC can fulfil its obligation under the BOT letter Adina Mineo 11113 Closed

28 Sep-13 Present - NERC staff to consider putting what the ERO has done with the stakeholder survey at RE workshops Adina Mineo and Jerry Hedrick 11113 Closed Board wants consideration on what value the survey adds and how can the report lead to further improvements in training and communication

29 Sep-13 Present - NERC staff to provide feedback to the CCC RAI groups from the RAIcommentsnercnet Adina Mineo 11113 Closed

30 13-Dec Need action items from members Closed

31 Mar-14 Compliance and Certification Committee (CCC) Roster Update (Primary and Plus) - tasked participants to review for accuracy and completeness Thornton and Huang 6414 Closed Roster updated to reflect May Board Also CCC roster posted on NERC CCC website

32 Mar-14 2014 Work Plan - develop executive summary with specific deliverables to better communicate the projects to the BOT Metro and Mineo 5714 Closed Presented at May Board

33 Mar-14 Caroline Dupuis approved as an interim member until NERC BOT approval - get on the BOT agenda for approval (NERC) Mineo 5714 Closed Presented at May Board

34 Mar-14 CCC Policies and Procedures Review - CCCPPs review of responsibilities Action Item ndash CCC SharePoint site discussion with CCC executive committee Metro and Mineo 6414 Closed SharePoint site is up and running Need CCC members to sign up Need Subcommittee chairs to review procedures and ensure current versions are posted and being used

35 Mar-14 Nominating Subcommittee - Openings were shared - solicit nominations for openings Huang 5714 Closed Presented at May Board

36 Mar-14 Update and closure of RISC request on Planning Authority Planning Coordinator issue ndash Action Item ndash Letter to RISC to close this out Flandermeyer 6414 Closed

37 Mar-14 ORCS will coordinate the review and comments on the Risked Based Registration Whitepaper ORCS 6414 Closed

38 Mar-14 Development of a white paper or expansion of current product to address voluntary versus non-voluntary related to internal controls Hoopes Team and Hedrick 6414 Closed Hoopes provided draft paper to NERC NERC is circulating and will report at June 2014 meeting

39 Mar-14 CPPS scope document provided to the BOT in May 2014 Goldberg 5714 Closed Presented at May Board

40 Mar-14 Determine whether there is anything NERC wants the CPPS to assist on the RSAW recommendation Hedrick 6404 Closed

41 Jun-14 Members will receive an electronic roster and should update all fields related to their position Metro 6404 Closed

42 Jun-14 CCC will provide interim member approvals in the August Board agenda for John Hairston BPA representing Federal Utility and Kevin Conway Intelliblind representing Small-end Use Customer Huang 6404 Closed

43 Jun-14 CCC will send revised CCC protocols (CCCPP-001 through 003 and 007) to NERC legal for review and comment HobsonAbrams 6404 Closed Team continues work but revised document was circulated following the June meeting

44 Jun-14 CCC needs NERC to check on 2015 budget availability for conducting the 2014 Stakeholdersrsquo Perception Survey Mineo 6404 Closed

45 Jun-14 CCC and NERC staff will hold a July 2014 WebEx on the CCC secure site following member site registration Discussion will include site ownership and management activities MineoMetro 6404 Closed

46 Jun-14 NERC should revise RSAWs that still include or do not indicate retirement of Paragraph 81 Requirements Mineo 6404 Closed Adina Mineo reported on item during September 2014 meeting

47 Jun-14 NERC should coordinate with Regions on how certain data is being requested via audits versus 1600 data requests specifically for PRC-004 Mineo Hect Closed

48 Jun-14 CPPS will draft CCCPP-010 revisions to include effectiveness assessment criteria with a completion goal for the September 2014 meeting CPPS 3315 Closed CCCPP10 was approved by the CCC at the March 2015 meeting

49 Jun-14 CPPS and NERC will coordinate a WebEx for NERC to provide an overview of the Compliance amp Enforcement trends matrix presented to the BOTCC quarterly KichlineGoldberg 6404 Closed

50 Jun-14 NERC staff will send auditor training notification to CCC members for registration Knight 6404 Closed

51 Jun-14 NERC staff will add NERC calendar items for the September and December 2014 meetings Thornton 6404 Closed

52 Sep-14 RISC Metrics Project Adina Mineo and Patti Metro will speak with NERC staff on whether and how RISC information from this project may inform Risk Elements and the annual ERO CMEP Implementation Plan MetroMineo Closed Participation from CCC occurring - formal request for support is closed

53 Sep-14 Matt Goldberg will provide CPPS revisions to the work plan to Adina and Patti by September 23 in order to finalize the work plan and provide it to the Board in November 2014 Goldberg Nov-14 Closed

54 Dec-14 NERC noted that it is taking an action item to develop and provide CCC members talking points and information to share with their sectors to further understanding of the transition to risk-based compliance and enforcement as well as developing a more for Mineo Hect Closed

55 Dec-14 The CCC asked Ms Iwanechko to work with the advisory group to identify communication needs with industry to reflect the convergence of surveys and the new process for the survey for 2014 (Iwanechko NERC) Iwanechko Hobson Jan-15 Closed

56 Dec-14 CCC members should provide feedback and input to Terry Bilke on the RISC project by December 19 2014 CCC Bilke Dec-14 Closed

57 Dec-14 CCC members should provide thoughts to the CCC Chair on any input into the ERO corporate risk assessments with Mechelle Thomas CCC Metro Dec-14 Closed

58 Mar-15 Kristin Iwanechko Brooke Thornton to send email request to CCC plus list to ask for feedback on the ERO survey process Iwanechko Thornton Closed

59 Mar-15 NERC staff to verify language in EROMS procedures with FERC order Kichline Stasko Mar-15 Closed Procedures accurately represent intent of Commission

60 Mar-15 CCC members provide feedback on full RISC report by March 27 2015 to Terry Bilke CCC members Closed

61 Mar-15 CCC Chair to send EROMS procedures and Charter to full CCC for review Metro Mar-15 Closed

62 Mar-15 Report out to the CCC on some frequency on the Regional Consistency Tool Edge Closed Carter will report again at September meeting and then will report to CCC twice per year thereafter

63 Jun-15 Post the updated CCC roster on the Committee Web page after the Board meeting Metro 15-Sep-15 Closed

64 Jun-15 CCC will review the requirements and history related to the CCC procedural documents and proposal to move those to the scope of the EWRC Clay Smith 15-Jul-15 Closed

65 Jun-15 CCC members will email Patti on willingness to participate in the NERC audits of CMEP and ORCP CCC members 1-Jul-15 Closed Members responded and the spots have been filled

66 Jun-15 Check on availability of NRECA offices for December 2016 meeting Patti Metro 15-Sep-15 Closed

67 Jun-15 Items for CIP v5 guidance documents to Ben Engelby by June 26 2015 for July 1 meeting CCC members 26-Jun-15 Closed

68 Jun-15 CCC will review the requirements and history related to the CCC procedural documents and proposal to move those to the scope of the EWRC Clay Smith Jul-15 Closed

69 Sep-15 CCC Nominating Committee will formally post the open positions requesting nominations Nalley Dec-15 Closed

70 Jun-15 Follow up on NERC funding to LSE reference in RoP section 1106 and will report back at September meeting Brinker Dec-15 Closed

71 Jun-15 Follow up with NERC and the Regions to see if the action to resolve the potential registration issue related to Transmission development Brinker Dec-15 Closed Note to reference TRE process Lumped into ORC Emerging Issues

72 Jun-15 Follow up on Ballot Pool Clean up Process with Standards Development Group Stewart Bunch Mar-16 Closed

73 Sep-15 EROMS will follow up with Kristin Iwanechko on distribution list on ERO Stakeholder Survey for Canadian Entities Hobson Iwanechko Mar-16 Closed Canadian Entities do not have a PCC so they do not receive the survey

74 Sep-15 Create and maintain a workplan responsibility and status update report as part of the agenda package Flandermeyer Hect Mar-16 Closed Ensure status updates are captured and common understanding of responsibility

75 Mar-15 Scheduling a hearing training for the new members Metro Stasko Jun-16 Closed Follow up with Patti Jennifer and Legal

76 Jun-15 Follow up on participation of CCC on Quality Reviews with Standards Development Group Stewart CPPS Jun-16 Closed CPPS action item

77 Mar-16 Review opportunity for communications plan and materials to support NERC in promotion of Risk-Based CMEP processes (self-logging ICE etc) CCCEC Sep-16 Closed Marisa and Jennifer will schedule a follow up call with NERC and the CCEC There will be a summary closing discussion and next steps for Septembers meeting

78 Jun-16 Letter for transmittal of the Self Certification to the EWRC Hobson Metro Sep-16 Closed

79 Jun-16 Posting of open CCC positions from Nominating Committee Nalley Hect Jul-16 Closed

80 Jun-16 Rewrite header in intro for the discussion document on CMEP Metro Hect Jul-16 Closed

81 Jun-16 Follow up email to FMAG for clarification of use of Functional Model and comments or review from ORCS Metro ORCS Jul-16 Closed

82 Sep-16 Review of output from focused feedback sessions with NERC management and full CCC on some frequency basis Metro Flandermeyer Ongoing Closed

83 Sep-16 Helen and Marisa will send list to the CCC of the members that have completed hearing training and executed confidentiality agreements Nalley Hect Sep-16 Closed Helen sent the list of CCC members and hearing training status to Marisa Marisa will send to CCC prior to meeting in November

84 Nov-16 Mechelle Thomas to send an email to CCC requesting observers for the NERC SPM Audit Thomas Flandermeyer Feb-17 Closed

85 Sep-14 Data Retention Project o CPPS will communicate with the Standards Committee to provide information on the results and recommendations CPPS will report on the status at the December meetingo Adina Mineo will communicate all recommendations to appropriate parties CCC SC Mar-17 Closed Send the Data Retention Item to full CCC for review to affirm document is still reflective of the requested action from the SC Once that is completed someone from the CCC will participate in the SC call or meeting to present the issue for closure The Compliance Assurance aspect of this action item is closed

86 Jun-15 Follow up on process with NERC staff on how to file a complaint related to NERCs adherence to the RoP (CMEP ORCP) with the CCC beyond the procedural documents Metro Kichline Sep-17 Closed Ed Teri Clay and Patti are working on this process and will provide a suggested complaint process for the CCC to consider

85 Dec-15 Review the existing hearing procedures and evaluate if changes are required based on NERCs revised hearing procedures for the ERO CPPS Sep-17 Closed Action required Review CCCPP-004 and 006 procedures to determine if any impacts or required changes

86 Mar-17 Follow up with Regional Entities on RE Stakeholder Groups (Group 18) to clarify who is represented in that group in the Compliance Guidance Policy NERC May-17 Closed

87 Mar-17 Small group to suggest path and language to capture of principles related to Internal Controls related to the ERO Practice Guide on Internal Controls Bilke amp group May-17 Closed

88 May-17 Share Compliant Process Form with CCC before buildout for comments Metro Nov-17 Closed

89 May-17 Propose a meeting with the ERO CMG on Internal Controls and ICE to promote ERO success Metro McIntyre Mar-18 Closed

90 Nov-17 CCC Members should express interest in the CCC Chair or Vice Chair position to Helen Nalley by January 16 2018 CCC Members Jan-18 Closed

91 Nov-17 ListServ reviews and clean up NERC and CCCEC Dec-17 Closed Closed

92 Nov-17 Transmittal of SPM and SAN audit results CCC Chair Jan-18 Closed Closed

93 Nov-17 Transmittal of 2017 CMEP and ORCP Self Certification Results CCC Chair Jan-18 Closed Closed

94 Nov-17 Transmittal of CCC Charter CCCPP documents and 2018 CCC Workplan to EWRC for endorsement or approval CCC Chair Jan-18 Closed Closed

95 Nov-17 CCC to provide feedback to CCC VC on CANs proposed for retirement by January 5 COB CCC Members Jan-18 Closed Closed

96 Nov-17 CCC VC to submit aggregated CAN feedback to NERC staff by January 26 CCC VC Jan-18 Closed Closed

97 Nov-17 Address Confidentiality references and material distribution based on November report out on the NERC SPM Audit results Whaley Mar-18 Closed Confidentiality reminder added to the CCC production schedule and confidential materials will be distributed to CCC only

98 Nov-17 ORCG and NERC Management will generate a plan rollout schedule and communciation plan for the CFR Tool expansion of tool for UAT or proof of concept for CMEP Technology development Stewart Mar-18 Open In progress

99 Mar-18 Dr Bilke will send the CCC Resilience Framework comments to the CCC for input CCC members respond to Dr Bilke and Ms Metro Bilke Mar-18 Closed

100 Mar-18 CCC Chair submit CCC comments on Resilience Framework to NERC RISC by March 28 Metro Mar-18 Closed

101 Mar-18 Clarify language and expectations for Industry related to MRRE and Coordinated Oversight for entities NERC Jun-18 Open In progress

102 Mar-18 Update NERC website CCC Page with 2018 Workplan Whaley Mar-18 Closed

103 Mar-18 Work with CCC members on expertise to assign everyone to Subcommittees CCC VC Jun-18 Open In progress

104 Mar-18 CCC Members email Adina by 328 to participate on a small subteam on the CCC Industry Outreach Work Plan Goal CCC Members Mar-18 Closed

105 Mar-18 CCC members email Patti and Jennifer with topics for the June agenda by April 4th CCC Members Apr-18 Closed

106 Jun-18 Consider and provide response to the NERC OC on review of reliability plans relationship to Certficiation and Standards Metro Edge Jul-18 Closed No additional progress on this issue since the June 2018 CCC meetings Dropped off the CCC action item list

107 Jun-18 Participation in the audit of the regions Request for response by end of June Gibbons Jun-18 Closed All volunteers have been secured and meetings are scheduled

108 Jun-18 AWG facilitating collection of CCC input for the ERO on the CMEP Technology Project AWG Jul-18 Closed CCC input incoporated into AWG response to Andy Rodriguez

109 Jun-18 CMEP Technology Project feedback from CCC to Jennifer and Scott by 620 CCC Jun-18 Closed

110 Jun-18 Focused discussion feedback summary to CCC for review due back on 625 Tomashefsky Jun-18 Closed

111 Jun-18 Discussion summary provided to NERC by June 30 and follow up call scheduled with Andy Rodriguez with AWG Flandermeyer Jun-18 Closed

112 Jun-18 Follow up on sharing the RFP for the CMEP Technology Project McIntyre Jun-18 Closed RFP provided to AWG members

113 Jun-18 Work to spot problems with NERC Listservs and resolve communications issues McIntyre Flandermeyer Sep-18 Closed

114 Sep-18 EROMS to review CCCPP-001 and determine what changes that are needed to Section 25 EROMS Dec-18 Closed

115 Sep-18 2019 Work plan Tomashefsky Dec-18 Closed

CCC Action Item List - As of June 2019

Date Workplan Project Name Workplan Project Workplan Deliverable Activity Responsible Parties Due Date Status Comments and Next Steps

Activities Completed During 2019

1 Sep-18 Enhancing CCC Program Efficiencies Strategic Planning - 3 NA Clarify extent to which CCC observers and CCC proxy holders can participate in CCC and CCC Subcommittee meetings Stasko Dec-18 Closed Discussed at Dec 2018 meetings Need to determine if written documentation needed

2 Mar-19 ERO Effectiveness Survey Ongoing Responsibilities - 10 2 Finalize CCC Report on the 2018 CCC Effectiveness Survey EROMS Q1 2019 Closed Document finalized 31119 Provided to EWRC and discussed at 5219 EWRC meeting

3 Mar-19 NERC Self-Certifications Ongoing Responsibilities - 4 3 2018 CMEP ORCP and SPM results memo to CCC EROMS Q1 2019 Closed 2018 CMEP ORCP and SPM results finalized and included in EWRC meeting packet for 12518

4 Mar-19 Review and Update of CMEP and CCC Programs and Procedures Ongoing Responsibilities - 1 4c Revise documents for CCCPP-001 to CCCPP-009 to reflect changes to the CMEP and other NERC initiatives that involve CCC programs and procedures CCC Subcommittee Complete by end of 2019 Closed CCCPP-004 and CCCPP-006 have been updated

Activities Scheduled for Completion in Q2 2019

5 Sep-18 Enhancing CCC Program Efficiencies Strategic Planning - 3 NA Assess effectiveness and efficiency of CCC as part of broader ERO effort FlandermeyerTomashefsky Q2 2019 Open Themes developed in December 2018

6 Mar-19 Review and Update of CMEP and CCC Programs and Procedures Ongoing Responsibilities - 1 4a Consider updates to CCC Charter reflecting 1) any changes to the ERO Enterprise andor adjustment to the CCC scope of work 2) updated vision statement Executive Committee Complete by Q2 2019 BOT approval by Q4 2019 Open

7 Mar-19 Review and Update of CMEP and CCC Programs and Procedures Ongoing Responsibilities - 1 4b Revise EROMS Scope to address consolidation of EROMS and CPPS EROMS Q2 2019 Open Updated draft scope document reviewed by EROMS at 313 and 513 meetings To be considered for approval at June 2019 CCC meeting

8 Mar-19 NERC Self-Certifications Ongoing Responsibilities - 4 3 2019 Self-Certification Form to NERC via direct communication from CCC Chair EROMS Q2 2019 Open Draft form circulated to EROMS for review on 51319

9 Mar-19 Review and Update of CMEP and CCC Programs and Procedures Ongoing Responsibilities - 1 4d Revise CCCPP-012 document (Procedures for becoming a Pre-Qualified Organization for Compliance Guidance) EROMS Q2 2019 Open

10 Mar-19 Review and Update of CMEP and CCC Programs and Procedures Ongoing Responsibilities - 1 4c Update CCCPP-001 EROMS Q2 2019 Open CCCPP-001 expected to be sent to EROMS for further comment To be considered for approval at June 2019 CCC meeting

11 Mar-19 ERO Regional Entity Compliance Program Audits Ongoing Responsibilities - 5 7 Provide results of Regional Entity audit report to EWRC EROMS Q2 2019 Open

12 Mar-19 Enhancing CCC Program Efficiencies Strategic Planning - 3 NA Develop CCC Extranet Webpages for CCC members GoldbergBoyd-Witherspoon Q2 2019 Open Extranet site being developed

Activities Scheduled for Completion

13 Mar-19 CCC Onboarding Materials Strategic Planning - 1 5 Develop full package of briefing materials for new CCC members Executive Committee Q3 2019 Open

14 Jun-19 Stakeholder Collaboration Ongoing Responsibilities - 11 NA Presentation with Industry Standards and Compliance Workshop - July 23-24 (Minneapolis) Flandermeyer Q3 2019 Open

15 Mar-19 CCC Meeting Logistics - 2020 NA NA Secure 2020 CCC meeting dates and locations Tomashefsky Q3 2019 Open Meeting dates finalized for all of 2020 Locations secured for June and September meetings March and meeting locations still pending

16 Mar-19 NERC CMEP and ORCP Independent Audit Ongoing Responsibilities - 5 8 Provide results of NERC independent audit of CMEP and ORCP programs to EWRC EROMSORCS Q4 2019 Open Planning session held in May 2019 Audit to be completed June 10-14 Five CCC members serving as observers for the audit

17 Mar-19 Review and Update of CMEP and CCC Programs and Procedures Ongoing Responsibilities - 1 4c Update CCCPP-010 EROMS Complete by end of 2019 Subcommittees will develop review schedule Open CCCPP-010 will be addressed during 2019 CCC meeting

Activities Without Specific Timeline for Completion

18 Mar-19 ERO Enterprise Program Alignment Ongoing Responsibilities - 9 1 Provide periodic reports regarding the effectiveness of the ERO Program Alignment Initiative and Reporting Tool (with NERC management) AWG Ongoing Open

19 Mar-19 Industry Collaboration Strategic Planning - 2 6 Standards Efficiency Review Initiative Take projects from Phase II SER team into CCC channels to work to completion or resolution ORCSAllen Schedule based on timing of feedback from Phase II SER Team Open CCC well-represented in Phase 2 SER drafting effort led by John Allen Jennifer Flandermayer also involved in SER Phase II team

20 Sep-18 Succession Planning Strategic Planning - 1 NA NERC staff will provide presentation to CCC regarding what the ERO does to align issues across the regions TBD TBD Open Need to schedule


ii CCCPP-001 (Monitoring Program for NERCrsquos Adherence to NERCrsquos Rules of Procedure forCompliance Enforcement) ndash (Approve)

iii CCCPP-011 (Procedure to Become a Prequalified Organization Eligible to SubmitImplementation Guidance to the ERO) ndash (Approve)

iv NERC 2019 CCC Self Certification SPM

v CCCPP-010 (Criteria for Annual Regional Entity Program Evaluation)

vi Compliance Monitoring and Enforcement Program Organization Registration andCertification Program Audit

d Alignment Working Group ndash (Inform) ndash Martha Henson

e Standing Committee Coordination Group (SCCG) ndash (Update) ndash Scott Tomashefsky

6 Focused Discussion ndash (Discuss) ndash Jennifer Flandermeyer

a Application of Risk Principles

i Inherent Risk

ii Residual Risk

iii Risk-based CMEP

b Risk Identification and Valuation

c Risk Tolerance

d Committee Risk Activities

7 NERC Internal Audit (IA) Risk Process ndash (Update) ndash Matt Gibbons

8 ERO CMEP ndash (Update) ndash Steve Noess Ed Kichline

9 CORES Rollout ndash (Update) - Ryan Stewart

10 ALIGN Project ndash (Discuss) ndash Andy Rodriquez

11 NERC Board of Trustees Enterprise-wide Risk Committee ndash (Update) ndash Jennifer Flandermeyer

12 NERC Board of Trustees and Members Representative Committee (MRC) May 2019 Meetings -(Update) ndash Scott Tomashefsky

13 Standard Efficiency Review Phase II (Evidence Retention) ndash (Update) ndash John Allen

14 RISC Reliability Risk Report ndash (Discuss) ndash Patti Metro

15 Review of Action Items ndash (Review) ndash Scott Tomashefsky

16 Future Meeting Dates ndash (Inform)

a Confirmed 2019 Dates

i September 17-18 2019 Kansas City MO (KCPampL Offices)























August 10 2010


June 18-19 2019


Action Inform







Succession Planning



Outreach



Communications Plan






Membership







bull Others





Draft May June 2019





Table of Contents

Preface 1

Section 1 Mission 2



31 Goals 4

32 General 4



35 Resignations 4

36 Proxies 4

37 Exclusions 6





42 Open Meetings 7





47 Quorum 7


51 General 8

52 Chair 8

53 Vice Chair 8







1

Preface



Revision History






2

Section 1 Mission





3



























4






35 Resignations











5



6





7

Section 4 Meetings











8





















9





10



bull Committee

bull Subcommittee

bull Working Group







EROMS


EROMS


EROMS


EROMS


ORCS


EROMS


ORCS


EROMS


EROMS


EROMS


EROMS


EROMS






Draft June 2019





Table of Contents

Preface 1

Section 1 Mission 2



31 Goals 4

32 General 4



35 Resignations 4

36 Proxies 4

37 Exclusions 5





42 Open Meetings 6





47 Quorum 6


51 General 7

52 Chair 7

53 Vice Chair 7







1

Preface



Revision History






2

Section 1 Mission





3







NERC











4






35 Resignations










5





6

Section 4 Meetings











7





















8





9



bull Committee

bull Subcommittee

bull Working Group







EROMS


EROMS


EROMS


EROMS


ORCS


EROMS


ORCS


EROMS


EROMS


EROMS


EROMS


EROMS









ii

Table of Contents

Preface iii

Revision History iv

1 Introduction 1



4 Mitigation Plan 6








61 1 Audit 8

62 Complaint 8



Preface


3











4

Revision History

CCCPP-001




April 13 2015

20



30 30



Formatted Table

1 Introduction


1













2

1 Introduction



2015




211 Audit Steps















4










5



6

3 Annual Work Plan



7

4 Mitigation Plan











8






9










ii

Table of Contents

Preface iii

Revision History iv

1 Introduction 1



4 Mitigation Plan 6








61 1 Audit 8

62 Complaint 8



Preface


3











4

Revision History

CCCPP-001




April 13 2015

20



30 30



1 Introduction


1













2

1 Introduction






211 Audit Steps















4










5

3 Annual Work Plan



6

4 Mitigation Plan











7






8









Table of Contents

Preface 3

Summary 3

Revision History 3

1 Introduction 1

2 Scope 3

3 Meetings 4


Open Meetings 4

Types of Meetings 4



Quorum 4






6 Administrative 7

Review Period 7






Member Details 8

Application 9


Preface

CCCPP-011-1





Revision History











Preface




Formatted Table



1 Introduction









bull6 EnergySec






















1 Introduction



2 Scope



3 Meetings























6 Administrative








TitleEmployer


Address





Member Details





Application










March 2016



ii

Table of Contents

Preface 3

Summary 3

Revision History 3

1 Introduction 1

2 Scope 3

3 Meetings 4


Open Meetings 4

Types of Meetings 4



Quorum 4






6 Administrative 7

Review Period 7






Member Details 8

Application 9


Preface









Preface











bull ISORTO Council














1 Introduction




















TitleEmployer


Address




Member Details





Application










Action Update







Appendix 4A Audits











NERC CMEP Update















Agenda





Overview





the same









Benefits






















Website







release) optional

Training




release) optional

Whatrsquos Next


1





MRC Meeting Summary




Supply Chain Report








2










3
















4






Review Update


















Questions





Questions





Report Analysis and

Recommendations


June 13 2019



















Challenges 8

Project Timeline 8

Introduction 9






Recommendations 12













Section Page





















entities





























Objective Status


1st Draft Complete


1st Draft Complete


1st Draft Complete


1st Draft Complete


In progress













































































































1 PRC-026-1 R3




2 EOP-005-3 R1 EOP-006-3 R1


1 EOP-008-2 R7


1 MOD-030-3 R2



1 FAC-013-2 R1



1 EOP-005-3 R7




1 TPL-007-1 R4



3 MOD-001-1a R3 MOD-029-2a R1 MOD-030-3 R1





1 TOP-003-3 R2



3 EOP-008-2 R8 IRO-002-5 R1 IRO-014-3 R1


2 FAC-008-3 R2 R3


1 IRO-017-1 R1



2 IRO-010-2 R1 TOP-003-3 R1


5 EOP-004-4 R1 EOP-008-2 R1 R6 EOP-011-1 R1 R2






1 MOD-029-2a R2









3 MOD-028-2 R8 MOD-029-2a R5 MOD-030-3 R6




1 MOD-027-1 R2


1 MOD-026-1 R2






3 IRO-002-5 R3 TOP-001-4 R21 R24


7 COM-001-3 R1 R12 R13 R3 R5 R7 R8




2 IRO-001-4 R1 R2









3 IRO-008-2 R1 IRO-014-3 R3 TOP-002-4 R1






2 EOP-005-3 R10 EOP-006-3 R8




1 PER-003-1 R1



Action Discussion
























Section 1 Mission



31 Goals

32 General



35 Resignations

a By the Member



d By the Board

36 Proxies

a Notification


37 Exclusions



Section 4 Meetings


42 Open Meetings





47 Quorum


51 General


b Officers

c Secretary

d Officers May Vote


52 Chair

53 Vice Chair









Section 1 Mission



31 Goals

32 General



35 Resignations

a By the Member



d By the Board

36 Proxies

a Notification


37 Exclusions



Section 4 Meetings


42 Open Meetings





47 Quorum


51 General


b Officers

c Secretary

d Officers May Vote


52 Chair

53 Vice Chair










Preface

CCCPP-011-1

Summary

Revision History


Open Meetings

Types of Meetings



Quorum

Submit Application

Review Application


Review Period





Member Details

Application



Preface

Summary

Revision History

1 Introduction

2 Scope

3 Meetings


Open Meetings

Types of Meetings



Quorum



Submit Application

Review Application


6 Administrative

Review Period






Member Details

Application



Action

Background

Summary


Slide Number 1

Appendix 4A Audits


Slide Number 4



Slide Number 1

Agenda

Overview


Benefits





Website


Training

Whatrsquos Next

Slide Number 14






Executive Summary

















Challenges

Project Timeline

Introduction








Evidence Categories







Action

Background

Summary



SER Project Scope

Phase 1 Team Scope

Phase 1 Results


Phase 2 Scope

Perceived Issues

Efficiency Concepts

Efficiency Concepts

Efficiency Concepts

SER CIP Project

Slide Number 12

Evidence Retention


Recommendations

Slide Number 16


Slide Number 1


Membership


Slide Number 5

Action Items

Archive







































































































































































August 10 2010


June 18-19 2019


Action Inform







Succession Planning



Outreach



Communications Plan






Membership







bull Others





Draft May June 2019





Table of Contents

Preface 1

Section 1 Mission 2



31 Goals 4

32 General 4



35 Resignations 4

36 Proxies 4

37 Exclusions 6





42 Open Meetings 7





47 Quorum 7


51 General 8

52 Chair 8

53 Vice Chair 8







1

Preface



Revision History






2

Section 1 Mission





3



























4






35 Resignations











5



6





7

Section 4 Meetings











8





















9





10



bull Committee

bull Subcommittee

bull Working Group







EROMS


EROMS


EROMS


EROMS


ORCS


EROMS


ORCS


EROMS


EROMS


EROMS


EROMS


EROMS






Draft June 2019





Table of Contents

Preface 1

Section 1 Mission 2



31 Goals 4

32 General 4



35 Resignations 4

36 Proxies 4

37 Exclusions 5





42 Open Meetings 6





47 Quorum 6


51 General 7

52 Chair 7

53 Vice Chair 7







1

Preface



Revision History






2

Section 1 Mission





3







NERC











4






35 Resignations










5





6

Section 4 Meetings











7





















8





9



bull Committee

bull Subcommittee

bull Working Group







EROMS


EROMS


EROMS


EROMS


ORCS


EROMS


ORCS


EROMS


EROMS


EROMS


EROMS


EROMS









ii

Table of Contents

Preface iii

Revision History iv

1 Introduction 1



4 Mitigation Plan 6








61 1 Audit 8

62 Complaint 8



Preface


3











4

Revision History

CCCPP-001




April 13 2015

20



30 30



Formatted Table

1 Introduction


1













2

1 Introduction



2015




211 Audit Steps















4










5



6

3 Annual Work Plan



7

4 Mitigation Plan











8






9










ii

Table of Contents

Preface iii

Revision History iv

1 Introduction 1



4 Mitigation Plan 6








61 1 Audit 8

62 Complaint 8



Preface


3











4

Revision History

CCCPP-001




April 13 2015

20



30 30



1 Introduction


1













2

1 Introduction






211 Audit Steps















4










5

3 Annual Work Plan



6

4 Mitigation Plan











7






8









Table of Contents

Preface 3

Summary 3

Revision History 3

1 Introduction 1

2 Scope 3

3 Meetings 4


Open Meetings 4

Types of Meetings 4



Quorum 4






6 Administrative 7

Review Period 7






Member Details 8

Application 9


Preface

CCCPP-011-1





Revision History











Preface




Formatted Table



1 Introduction









bull6 EnergySec






















1 Introduction



2 Scope



3 Meetings























6 Administrative








TitleEmployer


Address





Member Details





Application










March 2016



ii

Table of Contents

Preface 3

Summary 3

Revision History 3

1 Introduction 1

2 Scope 3

3 Meetings 4


Open Meetings 4

Types of Meetings 4



Quorum 4






6 Administrative 7

Review Period 7






Member Details 8

Application 9


Preface









Preface











bull ISORTO Council














1 Introduction




















TitleEmployer


Address




Member Details





Application










Action Update







Appendix 4A Audits











NERC CMEP Update















Agenda





Overview





the same









Benefits






















Website







release) optional

Training




release) optional

Whatrsquos Next


1





MRC Meeting Summary




Supply Chain Report








2










3
















4






Review Update


















Questions





Questions





Report Analysis and

Recommendations


June 13 2019



















Challenges 8

Project Timeline 8

Introduction 9






Recommendations 12













Section Page





















entities





























Objective Status


1st Draft Complete


1st Draft Complete


1st Draft Complete


1st Draft Complete


In progress













































































































1 PRC-026-1 R3




2 EOP-005-3 R1 EOP-006-3 R1


1 EOP-008-2 R7


1 MOD-030-3 R2



1 FAC-013-2 R1



1 EOP-005-3 R7




1 TPL-007-1 R4



3 MOD-001-1a R3 MOD-029-2a R1 MOD-030-3 R1





1 TOP-003-3 R2



3 EOP-008-2 R8 IRO-002-5 R1 IRO-014-3 R1


2 FAC-008-3 R2 R3


1 IRO-017-1 R1



2 IRO-010-2 R1 TOP-003-3 R1


5 EOP-004-4 R1 EOP-008-2 R1 R6 EOP-011-1 R1 R2






1 MOD-029-2a R2









3 MOD-028-2 R8 MOD-029-2a R5 MOD-030-3 R6




1 MOD-027-1 R2


1 MOD-026-1 R2






3 IRO-002-5 R3 TOP-001-4 R21 R24


7 COM-001-3 R1 R12 R13 R3 R5 R7 R8




2 IRO-001-4 R1 R2









3 IRO-008-2 R1 IRO-014-3 R3 TOP-002-4 R1






2 EOP-005-3 R10 EOP-006-3 R8




1 PER-003-1 R1



Action Discussion
























Section 1 Mission



31 Goals

32 General



35 Resignations

a By the Member



d By the Board

36 Proxies

a Notification


37 Exclusions



Section 4 Meetings


42 Open Meetings





47 Quorum


51 General


b Officers

c Secretary

d Officers May Vote


52 Chair

53 Vice Chair









Section 1 Mission



31 Goals

32 General



35 Resignations

a By the Member



d By the Board

36 Proxies

a Notification


37 Exclusions



Section 4 Meetings


42 Open Meetings





47 Quorum


51 General


b Officers

c Secretary

d Officers May Vote


52 Chair

53 Vice Chair










Preface

CCCPP-011-1

Summary

Revision History


Open Meetings

Types of Meetings



Quorum

Submit Application

Review Application


Review Period





Member Details

Application



Preface

Summary

Revision History

1 Introduction

2 Scope

3 Meetings


Open Meetings

Types of Meetings



Quorum



Submit Application

Review Application


6 Administrative

Review Period






Member Details

Application



Action

Background

Summary


Slide Number 1

Appendix 4A Audits


Slide Number 4



Slide Number 1

Agenda

Overview


Benefits





Website


Training

Whatrsquos Next

Slide Number 14






Executive Summary

















Challenges

Project Timeline

Introduction








Evidence Categories







Action

Background

Summary



SER Project Scope

Phase 1 Team Scope

Phase 1 Results


Phase 2 Scope

Perceived Issues

Efficiency Concepts

Efficiency Concepts

Efficiency Concepts

SER CIP Project

Slide Number 12

Evidence Retention


Recommendations

Slide Number 16


Slide Number 1


Membership


Slide Number 5

Action Items

Archive


















































































































































June 18-19 2019


Action Inform







Succession Planning



Outreach



Communications Plan






Membership







bull Others





Draft May June 2019





Table of Contents

Preface 1

Section 1 Mission 2



31 Goals 4

32 General 4



35 Resignations 4

36 Proxies 4

37 Exclusions 6





42 Open Meetings 7





47 Quorum 7


51 General 8

52 Chair 8

53 Vice Chair 8







1

Preface



Revision History






2

Section 1 Mission





3



























4






35 Resignations











5



6





7

Section 4 Meetings











8





















9





10



bull Committee

bull Subcommittee

bull Working Group







EROMS


EROMS


EROMS


EROMS


ORCS


EROMS


ORCS


EROMS


EROMS


EROMS


EROMS


EROMS






Draft June 2019





Table of Contents

Preface 1

Section 1 Mission 2



31 Goals 4

32 General 4



35 Resignations 4

36 Proxies 4

37 Exclusions 5





42 Open Meetings 6





47 Quorum 6


51 General 7

52 Chair 7

53 Vice Chair 7







1

Preface



Revision History






2

Section 1 Mission





3







NERC











4






35 Resignations










5





6

Section 4 Meetings











7





















8





9



bull Committee

bull Subcommittee

bull Working Group







EROMS


EROMS


EROMS


EROMS


ORCS


EROMS


ORCS


EROMS


EROMS


EROMS


EROMS


EROMS









ii

Table of Contents

Preface iii

Revision History iv

1 Introduction 1



4 Mitigation Plan 6








61 1 Audit 8

62 Complaint 8



Preface


3











4

Revision History

CCCPP-001




April 13 2015

20



30 30



Formatted Table

1 Introduction


1













2

1 Introduction



2015




211 Audit Steps















4










5



6

3 Annual Work Plan



7

4 Mitigation Plan











8






9










ii

Table of Contents

Preface iii

Revision History iv

1 Introduction 1



4 Mitigation Plan 6








61 1 Audit 8

62 Complaint 8



Preface


3











4

Revision History

CCCPP-001




April 13 2015

20



30 30



1 Introduction


1













2

1 Introduction






211 Audit Steps















4










5

3 Annual Work Plan



6

4 Mitigation Plan











7






8









Table of Contents

Preface 3

Summary 3

Revision History 3

1 Introduction 1

2 Scope 3

3 Meetings 4


Open Meetings 4

Types of Meetings 4



Quorum 4






6 Administrative 7

Review Period 7






Member Details 8

Application 9


Preface

CCCPP-011-1





Revision History











Preface




Formatted Table



1 Introduction









bull6 EnergySec






















1 Introduction



2 Scope



3 Meetings























6 Administrative








TitleEmployer


Address





Member Details





Application










March 2016



ii

Table of Contents

Preface 3

Summary 3

Revision History 3

1 Introduction 1

2 Scope 3

3 Meetings 4


Open Meetings 4

Types of Meetings 4



Quorum 4






6 Administrative 7

Review Period 7






Member Details 8

Application 9


Preface









Preface











bull ISORTO Council














1 Introduction




















TitleEmployer


Address




Member Details





Application










Action Update







Appendix 4A Audits











NERC CMEP Update















Agenda





Overview





the same









Benefits






















Website







release) optional

Training




release) optional

Whatrsquos Next


1





MRC Meeting Summary




Supply Chain Report








2










3
















4






Review Update


















Questions





Questions





Report Analysis and

Recommendations


June 13 2019



















Challenges 8

Project Timeline 8

Introduction 9






Recommendations 12













Section Page





















entities





























Objective Status


1st Draft Complete


1st Draft Complete


1st Draft Complete


1st Draft Complete


In progress













































































































1 PRC-026-1 R3




2 EOP-005-3 R1 EOP-006-3 R1


1 EOP-008-2 R7


1 MOD-030-3 R2



1 FAC-013-2 R1



1 EOP-005-3 R7




1 TPL-007-1 R4



3 MOD-001-1a R3 MOD-029-2a R1 MOD-030-3 R1





1 TOP-003-3 R2



3 EOP-008-2 R8 IRO-002-5 R1 IRO-014-3 R1


2 FAC-008-3 R2 R3


1 IRO-017-1 R1



2 IRO-010-2 R1 TOP-003-3 R1


5 EOP-004-4 R1 EOP-008-2 R1 R6 EOP-011-1 R1 R2






1 MOD-029-2a R2









3 MOD-028-2 R8 MOD-029-2a R5 MOD-030-3 R6




1 MOD-027-1 R2


1 MOD-026-1 R2






3 IRO-002-5 R3 TOP-001-4 R21 R24


7 COM-001-3 R1 R12 R13 R3 R5 R7 R8




2 IRO-001-4 R1 R2









3 IRO-008-2 R1 IRO-014-3 R3 TOP-002-4 R1






2 EOP-005-3 R10 EOP-006-3 R8




1 PER-003-1 R1



Action Discussion
























Section 1 Mission



31 Goals

32 General



35 Resignations

a By the Member



d By the Board

36 Proxies

a Notification


37 Exclusions



Section 4 Meetings


42 Open Meetings





47 Quorum


51 General


b Officers

c Secretary

d Officers May Vote


52 Chair

53 Vice Chair









Section 1 Mission



31 Goals

32 General



35 Resignations

a By the Member



d By the Board

36 Proxies

a Notification


37 Exclusions



Section 4 Meetings


42 Open Meetings





47 Quorum


51 General


b Officers

c Secretary

d Officers May Vote


52 Chair

53 Vice Chair










Preface

CCCPP-011-1

Summary

Revision History


Open Meetings

Types of Meetings



Quorum

Submit Application

Review Application


Review Period





Member Details

Application



Preface

Summary

Revision History

1 Introduction

2 Scope

3 Meetings


Open Meetings

Types of Meetings



Quorum



Submit Application

Review Application


6 Administrative

Review Period






Member Details

Application



Action

Background

Summary


Slide Number 1

Appendix 4A Audits


Slide Number 4



Slide Number 1

Agenda

Overview


Benefits





Website


Training

Whatrsquos Next

Slide Number 14






Executive Summary

















Challenges

Project Timeline

Introduction








Evidence Categories







Action

Background

Summary



SER Project Scope

Phase 1 Team Scope

Phase 1 Results


Phase 2 Scope

Perceived Issues

Efficiency Concepts

Efficiency Concepts

Efficiency Concepts

SER CIP Project

Slide Number 12

Evidence Retention


Recommendations

Slide Number 16


Slide Number 1


Membership


Slide Number 5

Action Items

Archive

















































































































































Communications Plan






Membership







bull Others





Draft May June 2019





Table of Contents

Preface 1

Section 1 Mission 2



31 Goals 4

32 General 4



35 Resignations 4

36 Proxies 4

37 Exclusions 6





42 Open Meetings 7





47 Quorum 7


51 General 8

52 Chair 8

53 Vice Chair 8







1

Preface



Revision History






2

Section 1 Mission





3



























4






35 Resignations











5



6





7

Section 4 Meetings











8





















9





10



bull Committee

bull Subcommittee

bull Working Group







EROMS


EROMS


EROMS


EROMS


ORCS


EROMS


ORCS


EROMS


EROMS


EROMS


EROMS


EROMS






Draft June 2019





Table of Contents

Preface 1

Section 1 Mission 2



31 Goals 4

32 General 4



35 Resignations 4

36 Proxies 4

37 Exclusions 5





42 Open Meetings 6





47 Quorum 6


51 General 7

52 Chair 7

53 Vice Chair 7







1

Preface



Revision History






2

Section 1 Mission





3







NERC











4






35 Resignations










5





6

Section 4 Meetings











7





















8





9



bull Committee

bull Subcommittee

bull Working Group







EROMS


EROMS


EROMS


EROMS


ORCS


EROMS


ORCS


EROMS


EROMS


EROMS


EROMS


EROMS









ii

Table of Contents

Preface iii

Revision History iv

1 Introduction 1



4 Mitigation Plan 6








61 1 Audit 8

62 Complaint 8



Preface


3











4

Revision History

CCCPP-001




April 13 2015

20



30 30



Formatted Table

1 Introduction


1













2

1 Introduction



2015




211 Audit Steps















4










5



6

3 Annual Work Plan



7

4 Mitigation Plan











8






9










ii

Table of Contents

Preface iii

Revision History iv

1 Introduction 1



4 Mitigation Plan 6








61 1 Audit 8

62 Complaint 8



Preface


3











4

Revision History

CCCPP-001




April 13 2015

20



30 30



1 Introduction


1













2

1 Introduction






211 Audit Steps















4










5

3 Annual Work Plan



6

4 Mitigation Plan











7






8









Table of Contents

Preface 3

Summary 3

Revision History 3

1 Introduction 1

2 Scope 3

3 Meetings 4


Open Meetings 4

Types of Meetings 4



Quorum 4






6 Administrative 7

Review Period 7






Member Details 8

Application 9


Preface

CCCPP-011-1





Revision History











Preface




Formatted Table



1 Introduction









bull6 EnergySec






















1 Introduction



2 Scope



3 Meetings























6 Administrative








TitleEmployer


Address





Member Details





Application










March 2016



ii

Table of Contents

Preface 3

Summary 3

Revision History 3

1 Introduction 1

2 Scope 3

3 Meetings 4


Open Meetings 4

Types of Meetings 4



Quorum 4






6 Administrative 7

Review Period 7






Member Details 8

Application 9


Preface









Preface











bull ISORTO Council














1 Introduction




















TitleEmployer


Address




Member Details





Application










Action Update







Appendix 4A Audits











NERC CMEP Update















Agenda





Overview





the same









Benefits






















Website







release) optional

Training




release) optional

Whatrsquos Next


1





MRC Meeting Summary




Supply Chain Report








2










3
















4






Review Update


















Questions





Questions





Report Analysis and

Recommendations


June 13 2019



















Challenges 8

Project Timeline 8

Introduction 9






Recommendations 12













Section Page





















entities





























Objective Status


1st Draft Complete


1st Draft Complete


1st Draft Complete


1st Draft Complete


In progress













































































































1 PRC-026-1 R3




2 EOP-005-3 R1 EOP-006-3 R1


1 EOP-008-2 R7


1 MOD-030-3 R2



1 FAC-013-2 R1



1 EOP-005-3 R7




1 TPL-007-1 R4



3 MOD-001-1a R3 MOD-029-2a R1 MOD-030-3 R1





1 TOP-003-3 R2



3 EOP-008-2 R8 IRO-002-5 R1 IRO-014-3 R1


2 FAC-008-3 R2 R3


1 IRO-017-1 R1



2 IRO-010-2 R1 TOP-003-3 R1


5 EOP-004-4 R1 EOP-008-2 R1 R6 EOP-011-1 R1 R2






1 MOD-029-2a R2









3 MOD-028-2 R8 MOD-029-2a R5 MOD-030-3 R6




1 MOD-027-1 R2


1 MOD-026-1 R2






3 IRO-002-5 R3 TOP-001-4 R21 R24


7 COM-001-3 R1 R12 R13 R3 R5 R7 R8




2 IRO-001-4 R1 R2









3 IRO-008-2 R1 IRO-014-3 R3 TOP-002-4 R1






2 EOP-005-3 R10 EOP-006-3 R8




1 PER-003-1 R1



Action Discussion
























Section 1 Mission



31 Goals

32 General



35 Resignations

a By the Member



d By the Board

36 Proxies

a Notification


37 Exclusions



Section 4 Meetings


42 Open Meetings





47 Quorum


51 General


b Officers

c Secretary

d Officers May Vote


52 Chair

53 Vice Chair









Section 1 Mission



31 Goals

32 General



35 Resignations

a By the Member



d By the Board

36 Proxies

a Notification


37 Exclusions



Section 4 Meetings


42 Open Meetings





47 Quorum


51 General


b Officers

c Secretary

d Officers May Vote


52 Chair

53 Vice Chair










Preface

CCCPP-011-1

Summary

Revision History


Open Meetings

Types of Meetings



Quorum

Submit Application

Review Application


Review Period





Member Details

Application



Preface

Summary

Revision History

1 Introduction

2 Scope

3 Meetings


Open Meetings

Types of Meetings



Quorum



Submit Application

Review Application


6 Administrative

Review Period






Member Details

Application



Action

Background

Summary


Slide Number 1

Appendix 4A Audits


Slide Number 4



Slide Number 1

Agenda

Overview


Benefits





Website


Training

Whatrsquos Next

Slide Number 14






Executive Summary

















Challenges

Project Timeline

Introduction








Evidence Categories







Action

Background

Summary



SER Project Scope

Phase 1 Team Scope

Phase 1 Results


Phase 2 Scope

Perceived Issues

Efficiency Concepts

Efficiency Concepts

Efficiency Concepts

SER CIP Project

Slide Number 12

Evidence Retention


Recommendations

Slide Number 16


Slide Number 1


Membership


Slide Number 5

Action Items

Archive





















































































































































Membership







bull Others





Draft May June 2019





Table of Contents

Preface 1

Section 1 Mission 2



31 Goals 4

32 General 4



35 Resignations 4

36 Proxies 4

37 Exclusions 6





42 Open Meetings 7





47 Quorum 7


51 General 8

52 Chair 8

53 Vice Chair 8







1

Preface



Revision History






2

Section 1 Mission





3



























4






35 Resignations











5



6





7

Section 4 Meetings











8





















9





10



bull Committee

bull Subcommittee

bull Working Group







EROMS


EROMS


EROMS


EROMS


ORCS


EROMS


ORCS


EROMS


EROMS


EROMS


EROMS


EROMS






Draft June 2019





Table of Contents

Preface 1

Section 1 Mission 2



31 Goals 4

32 General 4



35 Resignations 4

36 Proxies 4

37 Exclusions 5





42 Open Meetings 6





47 Quorum 6


51 General 7

52 Chair 7

53 Vice Chair 7







1

Preface



Revision History






2

Section 1 Mission





3







NERC











4






35 Resignations










5





6

Section 4 Meetings











7





















8





9



bull Committee

bull Subcommittee

bull Working Group







EROMS


EROMS


EROMS


EROMS


ORCS


EROMS


ORCS


EROMS


EROMS


EROMS


EROMS


EROMS









ii

Table of Contents

Preface iii

Revision History iv

1 Introduction 1



4 Mitigation Plan 6








61 1 Audit 8

62 Complaint 8



Preface


3











4

Revision History

CCCPP-001




April 13 2015

20



30 30



Formatted Table

1 Introduction


1













2

1 Introduction



2015




211 Audit Steps















4










5



6

3 Annual Work Plan



7

4 Mitigation Plan











8






9










ii

Table of Contents

Preface iii

Revision History iv

1 Introduction 1



4 Mitigation Plan 6








61 1 Audit 8

62 Complaint 8



Preface


3











4

Revision History

CCCPP-001




April 13 2015

20



30 30



1 Introduction


1













2

1 Introduction






211 Audit Steps















4










5

3 Annual Work Plan



6

4 Mitigation Plan











7






8









Table of Contents

Preface 3

Summary 3

Revision History 3

1 Introduction 1

2 Scope 3

3 Meetings 4


Open Meetings 4

Types of Meetings 4



Quorum 4






6 Administrative 7

Review Period 7






Member Details 8

Application 9


Preface

CCCPP-011-1





Revision History











Preface




Formatted Table



1 Introduction









bull6 EnergySec






















1 Introduction



2 Scope



3 Meetings























6 Administrative








TitleEmployer


Address





Member Details





Application










March 2016



ii

Table of Contents

Preface 3

Summary 3

Revision History 3

1 Introduction 1

2 Scope 3

3 Meetings 4


Open Meetings 4

Types of Meetings 4



Quorum 4






6 Administrative 7

Review Period 7






Member Details 8

Application 9


Preface









Preface











bull ISORTO Council














1 Introduction




















TitleEmployer


Address




Member Details





Application










Action Update







Appendix 4A Audits











NERC CMEP Update















Agenda





Overview





the same









Benefits






















Website







release) optional

Training




release) optional

Whatrsquos Next


1





MRC Meeting Summary




Supply Chain Report








2










3
















4






Review Update


















Questions





Questions





Report Analysis and

Recommendations


June 13 2019



















Challenges 8

Project Timeline 8

Introduction 9






Recommendations 12













Section Page





















entities





























Objective Status


1st Draft Complete


1st Draft Complete


1st Draft Complete


1st Draft Complete


In progress













































































































1 PRC-026-1 R3




2 EOP-005-3 R1 EOP-006-3 R1


1 EOP-008-2 R7


1 MOD-030-3 R2



1 FAC-013-2 R1



1 EOP-005-3 R7




1 TPL-007-1 R4



3 MOD-001-1a R3 MOD-029-2a R1 MOD-030-3 R1





1 TOP-003-3 R2



3 EOP-008-2 R8 IRO-002-5 R1 IRO-014-3 R1


2 FAC-008-3 R2 R3


1 IRO-017-1 R1



2 IRO-010-2 R1 TOP-003-3 R1


5 EOP-004-4 R1 EOP-008-2 R1 R6 EOP-011-1 R1 R2






1 MOD-029-2a R2









3 MOD-028-2 R8 MOD-029-2a R5 MOD-030-3 R6




1 MOD-027-1 R2


1 MOD-026-1 R2






3 IRO-002-5 R3 TOP-001-4 R21 R24


7 COM-001-3 R1 R12 R13 R3 R5 R7 R8




2 IRO-001-4 R1 R2









3 IRO-008-2 R1 IRO-014-3 R3 TOP-002-4 R1






2 EOP-005-3 R10 EOP-006-3 R8




1 PER-003-1 R1



Action Discussion
























Section 1 Mission



31 Goals

32 General



35 Resignations

a By the Member



d By the Board

36 Proxies

a Notification


37 Exclusions



Section 4 Meetings


42 Open Meetings





47 Quorum


51 General


b Officers

c Secretary

d Officers May Vote


52 Chair

53 Vice Chair









Section 1 Mission



31 Goals

32 General



35 Resignations

a By the Member



d By the Board

36 Proxies

a Notification


37 Exclusions



Section 4 Meetings


42 Open Meetings





47 Quorum


51 General


b Officers

c Secretary

d Officers May Vote


52 Chair

53 Vice Chair










Preface

CCCPP-011-1

Summary

Revision History


Open Meetings

Types of Meetings



Quorum

Submit Application

Review Application


Review Period





Member Details

Application



Preface

Summary

Revision History

1 Introduction

2 Scope

3 Meetings


Open Meetings

Types of Meetings



Quorum



Submit Application

Review Application


6 Administrative

Review Period






Member Details

Application



Action

Background

Summary


Slide Number 1

Appendix 4A Audits


Slide Number 4



Slide Number 1

Agenda

Overview


Benefits





Website


Training

Whatrsquos Next

Slide Number 14






Executive Summary

















Challenges

Project Timeline

Introduction








Evidence Categories







Action

Background

Summary



SER Project Scope

Phase 1 Team Scope

Phase 1 Results


Phase 2 Scope

Perceived Issues

Efficiency Concepts

Efficiency Concepts

Efficiency Concepts

SER CIP Project

Slide Number 12

Evidence Retention


Recommendations

Slide Number 16


Slide Number 1


Membership


Slide Number 5

Action Items

Archive















































































































































