The North American Electric Reliability Corporation (“NERC”) submitted this filing providing notice of revisions to the NERC Rules of Procedure (“ROP”) related to the Compliance Monitoring and Enforcement Program (“CMEP”), the Personnel Certification and Credential Maintenance Program, and the Training and Education Program. NERC proposed revisions to Sections 400 and 1500 and Appendices 2 and 4C related to the CMEP to enhance the ERO Enterprise’s risk-based approach to compliance monitoring and enforcement and to update and clarify the ROP.
Among the most significant proposed revisions to the CMEP, the ERO Enterprise proposes to refine several rules related to compliance monitoring, especially Compliance Audits. These changes are intended to move away from a more arbitrary, time-based approach to monitoring that at times prevents the ERO Enterprise from prioritizing activities based on risk. The changes provide a better way to balance the ERO Enterprise’s flexibility to monitor risk on a more real-time basis while still providing registered entities with enough time to prepare for monitoring activities. The changes include:
The ERO Enterprise also proposes to increase the efficiency of resolving minimal risk noncompliance. The increased efficiency is crucial to allow both the ERO Enterprise and industry to allocate resources to significant risks while maintaining visibility into emerging risks and trends. The proposed revisions build upon many years of successful implementation of prior streamlining efforts. Specifically, the ERO Enterprise proposes to: