The Expectation for Consistency across Regional Entities: What to do if Inconsistency is Experienced

The North American Electric Reliability Corporation (NERC) and the Regional Entities are committed to ensuring and promoting consistency across the ERO Enterprise. The ERO Enterprise defines consistency to mean that “the approach, methods, and practices are the same across the ERO Enterprise and that the outcomes…are fair, reasonable, and without bias.” However, consistency does not mean “that each Regional Entity produce identical outcomes given a particular set of circumstances.” In order to help achieve the expected consistency, methods of feedback have been provided by NERC. One of the primary methods is a "Consistency Reporting Tool" using a third-party application hosted by EthicsPoint. The Reporting Tool is not associated with and does not replace the NERC Compliance Hotline or any Regional Entity Compliance Hotline. Each Regional Entity maintains a Compliance Hotline that can be found on their websites.
NERC partnered with the third-party provider EthicsPoint to develop this reporting tool. Reports are entered and submitted directly on the EthicsPoint secure server. EthicsPoint provides these reports to NERC system administrators who have permission to receive the reports. The stakeholder submitting a report in the tool has the option to request to remain anonymous. This Reporting Tool creates an open channel of communication to report perceived inconsistencies and will augment efforts to ensure and promote consistency across the ERO Enterprise.
This NERC Consistency Reporting Tool allows Registered Entities or other relevant industry stakeholders to report any perceived inconsistency in the approach, methods, or practices implemented and executed by the Regional Entities. Report categories include the following:

• Compliance
• Enforcement
• Organization Certification
• Organization Registration
• Reliability Assessment and Performance Analysis
• Reliability Risk Management
• Reliability Standards
• Situation Awareness and Events Analysis
• Training and Education
• Other

The Reporting Tool does not function as an appeal of a Regional Entity action or decision. Filing a report will not affect ongoing activities, including but not limited to entity registrations, compliance audits, and enforcement actions.

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