Violation Process States and Underlying Process Sub states Snapshot comparison between December 1, 2009 and December 31, 2009

Transcription

1 Violation Process States and Underlying Process Sub states Snapshot comparison between December 1, 29 and December 31, New Preliminary Alleged Violation Information Submitted Substate A Submitted Information) remanded Submitted Information State 1 (Assessment and Validation) Preliminary Alleged Violation Information Accepted By ; Initial Notice of Alleged Violation Prepared And Sent To FERC Alleged violation in State Substate B ( Preparing Received By and Concurrently sent to Registered Entity 8 76 remanded 2 64 Substate C and Awaiting Registered Entity Response) Dismissal NOAV Contested State 2 (Confirmation) NOAV Accepted or Not Contested 38 Substate E (Pending Hearing ) Substate D ( Preparing NOCV) No hearing requested Substate G Appeal Process) Hearing Hearing decision requested appealed to -1 Alleged violation in State 2 NOCV Hearing decision Not appealed Substate F (RE Hearing Process) remanded hearing decision 47 affirms hearing decision NOCV Received by State 3 (Regulatory Filings) 64 Substate H NOCV and Preparing NOP) NOP Returned to 2 BOT CC approves NOP 282 Substate L Settlement and Preparing NOP) 136 Substate I Issues NOP) Payment of Penalties Fulfillment of Sanctions Completion of Mitigation Plan(s) Exhaustion of Administrative and Judicial Remedies Fulfillment of Settlement Terms State 4 (Closing) Substate J (Violations Closed) BOT CC approves NOP NOP -9 approved settlement 7 Returned to Legend: PNOAV Preliminary Notice of Alleged Violation Notice of Alleged Violation NOCV Notice of Confirmed Violation NOP Notice of Penalty 636 Substate K (Settlement Negotiations in Progress) Initiation of Settlement Negotiations (Anytime after preliminary alleged violation information received) Settlement Negotiation State +42

2 Violation Process State Summary Table Active FERC Enforceable Alleged Violations Below is a breakdown, as of December 31, 29, of the Compliance Monitoring and Enforcement Program (CMEP) Violation state summary for the 195 active violations. State 1 State 2 State 3 State 4 (Assessment and Validation) (Confirmation) Settlement (Regulatory Filings) (Closing) (New) Substate A ) Substate B ( Preparing NAVAP) Substate C NAVAP and awaiting RE Response) Substate D ( Preparing NOCV) Substate E (Pending Hearing) Substate F (RE Hearing Process) Substate G Appeal Process) Substate K (Settlement Negotiations) Substate H NOCV) Substate L Settlement Agreement) FRCC (19) Substate I Issues NOP) Substate J (Violation Closes) MRO (3) NPCC () RFC (9) SERC (23) SPP (11) TRE (1) WECC (39) TOTAL (15) Percentage of.77% 32.5% 3.28% 3.49% 1.95%.%.% 32.62% 3.28% 14.46% 6.97% 1.13% State s Definitions Substate A = Preliminary Notice of Alleged violation information has been received from the but no Initial Notice has been issued to FERC. Substate B = is awaiting receipt of Notice of Alleged Violation Proposed Penalty or Sanction from the. Substate C = has received Notice of Alleged Violation Proposed Penalty or Sanction and is awaiting acceptance, auto acceptance or contest. Substate D = received acceptance letter from Registered Entity, or 3 day clock expired and violation is Auto Accepted and is now Confirmed. Substate E = has received letter contesting violation from Registered Entity. Substate F = has received request for Hearing from Registered Entity. Substate G = has received request for Appeal from Registered Entity. Substate H = has received a Notice of Confirmed Violation from the. Substate I = Violation is Confirmed/Settled and a Notice of Penalty has been issued by to Registered Entity and submitted to FERC. Substate J = Payment of Penalties, Fulfillment of Sanctions, Completion of Mitigation Plan, Exhaustion of Administrative and Judicial Remedies, and Fulfillment of Settlement terms have all been met and violation is closed. Substate K = Settlement negotiations are in progress. Substate L = has received a Settlement Agreement from the. * Includes new violations received through 12/31/29.

3 47 Violation Process States Snapshot comparison between December 1, 29 and December 31, State 1 (Assessment and Validation) 64 Change State 2 (Confirmation) 17 Change NOCV and Preparing NOP 64 Change +8 State 3 (Pending Regulatory Filing) Issues NOP 136 Change State 4 (Completed and Closed) closed 751 Settlement and Preparing NOP Change -9 Settlement State 636 Change +42 5

4 Pending Violations Summary by Process Steps FERC Enforceable Alleged Violations Summarized by State ITEM D Below is a breakdown, as of December 31, 29, of the Compliance Monitoring and Enforcement Program (CMEP) Violation Process Steps summarized by State for the 2679 FERC enforceable violations. Pending Regulatory Filing Completed and Closed Assessment and Validation Confirmation Settlement FRCC MRO NPCC RFC SERC SPP TRE WECC TOTAL * Includes new violations received through 12/31/29. Report Date: 1/6/21

5 Summary of all Post June 18, 27 Alleged Violations by ITEM E Below is a breakdown, as of December 31, 29 of the Compliance Monitoring and Enforcement (CMEP) alleged violation summary for all 3742 violations. Previously Closed Newly Closed FERC Enforceable Normalized by Registered Entity % Non- Document Related Canadian Violations FRCC % 39 MRO % NPCC % 5 16 RFC % 233 SERC % 439 SPP % 194 TRE % 82 WECC % % 35 TOTAL % Includes new violations received through 12/31/29. Report Date: 1/6/21

6 Top 1 FERC Enforceable Standards (Submit Dates: 1/1/29 thru 12/31/29) EOP-1 - Emergency Operations Planning - 37 VAR-2 - Generator Operation for Maintaining Network Voltage Schedules - 39 PER-2 - Operating Personnel Training - 4 CIP-7 - Systems Security Management - 48 Standards TOP-2 - Normal Operations Planning - 48 FAC-8 - Facility Ratings Methodology - 5 EOP-5 - System Restoration Plans - 62 CIP-1 - Sabotage Reporting - 71 CIP-4 - Personnel & Training PRC-5 - Transmission and Generation Protection System Maintenance and Testing Excludes dismissed violations. Number of Violations Report Date: 1/6/21

7 Snapshot comparison between December 1, 29 and December 31, 29 State 1 (al Assessment) State 2 Assessment) State 3 (Mitigation Plan Implementation) State 4 (al Verification of Completion) State 5 (Closing) 15 New Mitigation Plan requested by al Entity 443 Substate A ( awaiting mitigation plan) Awaiting -15 Proposed mitigation plan received by al Entity 84 Substate B ( reviewing mitigation plan) -16 accepts active MP and sends to and the Registered Entity remands active MP for revision 27 Substate C reviewing active mitigation plan) Active MP +5 Active MP becomes completed/ verified prior to approval approves active MP and sends to FERC 157 Substate E (Registered Entity Implementing Mitigation Plan) Mitigation Implementation -18 Mitigation Plan is Complete 182 Substate F ( Verifying Mitigation Plan Completion) Mitigation Verification +44 informs that Mitigation Plan is Complete and Verified 86 Substate G (Mitigation Plan Validated Complete) Mitigation Completed Violation Mitigated Violation Mitigation Plans Verified Complete accepts and verifies completed MP and sends to and the Registered Entity remands completed MP for revision Completed MP Substate D reviewing completed mitigation plan) approves completed MP Dismissal

8 Mitigation Plans Process State Table Active FERC Enforceable Alleged Violations Item H Below is a breakdown, as of December 31, 29, of the Compliance Monitoring and Enforcement Program (CMEP) Mitigation Plan state summary for the 11 active violations. Report Date: 1/21/21 State 1 State 2 State 3 State 4 State 5 (al Assessment) Assessment) (Mitigation Plan Implementation) (al Verification of Completion) (Closing) Substate A Substate B Substate C Substate D Substate E Substate F Substate G Awaiting Accepted MP Not Received from Active MP Completed MP Registered Entity Implementation al Verification of MP Completion Mitigation Plan Validated Complete FRCC MRO NPCC RFC SERC SPP TRE WECC TOTAL State s Definitions Substate A = is still awaiting receipt of mitigation plan from Registered Entity. Substate B = has received mitigation plan and is reviewing. Substate C = has received mitigation plan and is reviewing. Also includes any mitigation plans not yet received by. Substate D = Mitigation plan has been verified completed by the but is still awaiting approval by. Substate E = Mitigation plan has been approved by, and sent to FERC, but has not been completed. Substate F = Mitigation Plan has been completed per Registered Entity but is being verified by the. Substate G = Mitigation plan has been verified completed by, has been approved by, and sent to FERC. Includes Mitigation Plans received through 12/31/29. Mitigation information reported at the violation level.