Compliance Trending. Page 1 of 14

Similar documents
Key Compliance Trends

Key Compliance Trends Item 2.A

Compliance Trending May 2010

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

Violation Process States and Underlying Process Sub states Snapshot comparison between February 1, 2009 and February 28, 2009

Analysis of NERC Compliance Registry & Registration Appeals

APPENDIX 4D TO THE RULES OF PROCEDURE

Total ERO Enterprise 2019 Budgets and Assessments Analysis

Compliance Monitoring and Enforcement Program Report

2017 Budget Presentation to MRO Board of Directors

APPENDIX 4D TO THE RULES OF PROCEDURE

Analysis of 2018 Total ERO Enterprise Budget

NERC Unaudited Summary of Results March 31, Finance and Audit Committee Meeting May 4, 2016

Review of Registered Charites Compliance Rates with Annual Reporting Requirements 2016

December 31, Ms. Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C.

2009 Reassessment As Impacted by Senate Bill 711

BEFORE THE ONTARIO ENERGY BOARD OF THE PROVINCE OF ONTARIO

WESTWOOD LUTHERAN CHURCH Summary Financial Statement YEAR TO DATE - February 28, Over(Under) Budget WECC Fund Actual Budget

NERC TPL Standard Overview

March 16, 2009 TO: INDUSTRY STAKEHOLDERS. Ladies and Gentlemen:

XML Publisher Balance Sheet Vision Operations (USA) Feb-02

HUD NSP-1 Reporting Apr 2010 Grantee Report - New Mexico State Program

133 FERC 61,062 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION. North American Electric Reliability Corporation

Algo Trading System RTM

Spheria Australian Smaller Companies Fund

1.2 The purpose of the Finance Committee is to assist the Board in fulfilling its oversight responsibilities related to:

FRCC 2016 Business Plan & Budget (As Submitted to NERC and Posted for Comments on 5/1/2015) (Not Approved by the FRCC Board of Directors)

TERMS OF REFERENCE FOR THE INVESTMENT COMMITTEE

August 31, Ms. Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C

June 27, Ms. Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C

Compliance Review 2017

Department of Public Welfare (DPW)

PRESS RELEASE. Securities issued by Hungarian residents and breakdown by holding sectors. January 2019

BEFORE THE CROWN INVESTMENT CORPORATION OF THE PROVINCE OF SASKATCHEWAN

Agenda Conference Call Finance and Audit Committee

Compliance Monitoring and Enforcement Program Quarterly Report

PHOENIX ENERGY MARKETING CONSULTANTS INC. HISTORICAL NATURAL GAS & CRUDE OIL PRICES UPDATED TO July, 2018

PRESS RELEASE. Securities issued by Hungarian residents and breakdown by holding sectors. October 2018

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION. North American Electric Reliability ) Docket No. RC Corporation )

Financial & Business Highlights For the Year Ended June 30, 2017

Long-Term Reliability Assessment

PRESS RELEASE. Securities issued by Hungarian residents and breakdown by holding sectors. October 2017

November 4, 2013 VIA ELECTRONIC FILING

Big Walnut Local School District

Business & Financial Services December 2017

Compliance Review 2016

CURRENT CLOSURE STATUS OF ELIGIBLE DISCHARGES. Eligible Discharges Rehabilitated per Fiscal Year as of September 29, 2017

Approve Assure Note. Board of Directors Meeting Report 31 July Agenda item 254/13. Title. Sponsoring Director. Authors.

1 Long Term Debt $ 9,298,554 $ (250,000) $ 9,048, Preferred Stock 30,450 30, % 5 Common Equity 250, %

FERC EL Settlement Agreement

Key IRS Interest Rates After PPA

2016 Business Plan and Budget. Southwest Power Pool Regional Entity. Preliminary Budget

FOR RELEASE: MONDAY, MARCH 21 AT 4 PM

1Q of FY ending December 31, (0.2) (1.9) 11.3 (0.2) (0.2) (0.2) (0.2) (1.2) (89.2) 0.1

Development of Economy and Financial Markets of Kazakhstan

Isle Of Wight half year business confidence report

Cost Estimation of a Manufacturing Company

PRESS RELEASE. Securities issued by Hungarian residents and breakdown by holding sectors. April 2016

Compliance Review February 9, 2012

September 8, 2017 VIA ELECTRONIC FILING

Foundations of Investing

Factor Leave Accruals. Accruing Vacation and Sick Leave

Common stock prices 1. New York Stock Exchange indexes (Dec. 31,1965=50)2. Transportation. Utility 3. Finance

2018 ERO Enterprise Metrics

Executive Summary. July 17, 2015

Mandatory Reliability Standards and FERC Enforcement Procedures: A Roadmap for Registered Entities

OTHER DEPOSITS FINANCIAL INSTITUTIONS DEPOSIT BARKAT SAVING ACCOUNT

Voya Indexed Universal Life-Protector

Performance Report October 2018

Looking at a Variety of Municipal Valuation Metrics

Affordable Care Act Implementation Alert

Fiscal Year 2018 Project 1 Annual Budget

TERMS OF REFERENCE FOR THE FINANCE AND AUDIT COMMITTEE

HIPIOWA - IOWA COMPREHENSIVE HEALTH ASSOCIATION Unaudited Balance Sheet As of July 31

HIPIOWA - IOWA COMPREHENSIVE HEALTH ASSOCIATION Unaudited Balance Sheet As of January 31

Asset Manager Performance Comparison

Count Balance $0.00 $0.00 $0.00 Current Delinquent Other 0 0 0

May 30, Ms. Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, DC 20426

129 FERC 61,040 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION

Asset Manager Performance Comparison

NERC Abbreviated Notice of Penalty regarding Sierra Pacific Power Company, FERC Docket No. NP

QUESTION 2. QUESTION 3 Which one of the following is most indicative of a flexible short-term financial policy?

Ohlone Community College District

Exam 1 Problem Solving Questions Review

Ch. 13 Practice Questions Solution

Comparative Annuity Reports Your guide to comparing data about Single Premium Immediate Annuity programs

The Financial Reporting Checklists Every Firm should be Doing

123 FERC 61,282 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION. North American Electric Reliability Corporation

Distribution Group Study Process. August 26, 2014

CITI Bank Bangkok branch. Set B Capital Item1 Capital Structure Table 2 Capital of Foreign Banks Branchs Unit : THB. Item June 30, 2009

(Internet version) Financial & Statistical Report November 2018

Historical Pricing PJM COMED, Around the Clock. Cal '15 Cal '16 Cal '17 Cal '18 Cal '19 Cal '20 Cal '21 Cal '22

SmallBizU WORKSHEET 1: REQUIRED START-UP FUNDS. Online elearning Classroom. Item Required Amount ($) Fixed Assets. 1 -Buildings $ 2 -Land $

ACA Reporting E-File Errors, Penalties & Exchange Notices

City of El Segundo Office of the City Treasurer

Big Walnut Local School District

Performance Report: August 2018

April 6, 2018 VIA OVERNIGHT MAIL. Sheri Young, Secretary of the Board National Energy Board th Avenue SW Calgary, Alberta T2R 0A8

August 2018: Monthly Data Update

Regional overview Gisborne

Transcription:

Compliance Trending Page 1 of 14

Overall Trends The number of new CIP violations received each month continues to rise dramatically over the number of new non-cip violations In September 21, 182 CIP were received compared to 91 Non-CIP. In August 21 13 CIP were received compared to 139 Non-CIP 6 month violation receipt average (April 1, 21 through September, 21) = 183 violations/month 273 violations received in September 21 compared to 242 violations received in August 21 October 5, 21 Page 2 of 14

Compliance Processing Statistics Active violations continue to rise 35 3 25 Number of Violations 2 15 1 5 S-9 O-9 N-9 D-9 J-1 F-1 M-1 A-1 M-1 J-1 J-1 A-1 S-1 Month and Year Active NERC Work UnMitigated Mitigated October 5, 21 Page 3 of 14

Graph Definitions Active All Violations that have not been Closed or Dismissed Closed Violations have all the following characteristics: Violation NOP approved by FERC, Verified Completion of Mitigation Plan, and Payment of any associated Penalties. NERC Work Active Violations minus Violation Sub State I (NERC Issues NOP) Unmitigated Violations where Mitigation Plans have not been received or not yet been closed minus completed Mitigation Plans that NERC is reviewing Closed Mitigation Plan: Regional Entity has Verified Completion of all Mitigated Elements specified by Plan Mitigated Active Violations minus Unmitigated Deem Date Date of the violation which the Regional Entity is using for purposes of calculating penalties and / or sanctions October 5, 21 Page 4 of 14

Violation In/Out Trend BOTCC Approves Omnibus Filing 7 Omnibus Filing made at FERC 6 Number of Violations 5 4 3 2 1 S-9 O-9 N-9 D-9 J-1 F-1 M-1 A-1 M-1 J-1 J-1 A-1 S-1 Month and Year Violations Received BOTCC Approved + Dismissed Dismissed + Violations Closed October 5, 21 Page 5 of 14

Violations at NERC for Processing 2 18 595 16 14 Number of Violations 12 1 8 6 66 68 86 98 8 122 92 57 62 74 4 43 2 9 S-9 O-9 N-9 D-9 J-1 F-1 M-1 A-1 M-1 J-1 J-1 A-1 S-1 Month and Year of BOTCC Approval Page 6 of 14

Improving Efficiencies Current Violations Processing Status Total Violations 2659 NERC Legal Processing 295 295 September 3, 21 Approved by BOTCC need final cleanup and filing NERC E&M Processing 257 Regional Entity Processing 217 2 (2) Oct 54 (29)* Nov 61 (21) 142 (39) SA Negotiation: 893 NOCV Prep: 16 Scheduled for BOTCC Consideration In the Queue Returned to Region for rework Various states (have not seen) INAV; possibly to NAVAPS: 1196 * Number in parenthesis = number of actions (SAs & NOCVs) ** 91 of the total violations above have been submitted to NERC in unexecuted SAs; 38 have been approved by the BOTCC, 52 are with E&M for processing and 1 has been returned to the region. For purposes of this chart, these violations have been moved from SA Negotiations to NERC Legal Processing, NERC E&M Processing and Returned to Region for rework, respectively. Page 7 of 14

Settlement Negotiation Trend 7 6 5 Number of Violations 4 3 2 1 S-9 O-9 N-9 D-9 J-1 F-1 M-1 A-1 M-1 J-1 J-1 A-1 S-1 Month and Year October 5, 21 Violations Into Settlement Negotiation Violations Out of Negotiations (Agreement Received or Dismissed) Page 8 of 14

Violations Active at NERC and Regional Entities 35 3 25 Number of Violations 2 15 1 5 S-9 O-9 N-9 D-9 J-1 F-1 M-1 A-1 M-1 J-1 J-1 A-1 S-1 Month and Year Active Violations Violations at Region Violations at NERC (Sub State H) NERC issues NOP (Sub State I) October 5, 21 Page 9 of 14

Deem Dates from September 21 Violations (273 Violations) 12 1 All 14 violations were CIP-2 thru CIP-9 Number of Violations 8 6 4 35 of 4 violations were CIP-2 thru CIP-9 2 J-7 J-7 A-7 S-7 O-7 N-7 D-7 J-8 F-8 M-8 A-8 M-8 J-8 J-8 A-8 S-8 O-8 N-8 D-8 J-9 F-9 M-9 A-9 M-9 J-9 J-9 A-9 S-9 O-9 N-9 D-9 J-1 F-1 M-1 A-1 M-1 J-1 J-1 A-1 S-1 Month and Year of Deem Date October 5, 21 Page 1 of 14

Deem Date Trend for Active and Closed Violations 5 45 43 of the 439 violations were CIP-2 thru CIP-9 4 35 Number of Violations 3 25 2 194 of the 217 violations were CIP-2 thru CIP-9 21 of the 215 violations were CIP-2 thru CIP-9 15 1 5 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep 28 29 21 Deem Date of Violation October 5, 21 Page 11 of 14

CIP versus Non-CIP Violation Trend 2 18 16 14 Number of Violations 12 1 8 6 4 2 F-9 M-9 A-9 M-9 J-9 J-9 A-9 S-9 O-9 N-9 D-9 J-1 F-1 M-1 A-1 M-1 J-1 J-1 A-1 S-1 Month and Year of Violation Submission Non-CIP Violations CIP Violations October 5, 21 Page 12 of 14

Mitigation Status 1 9 8 Number of Violations 7 6 5 4 3 2 1 S-9 O-9 N-9 D-9 J-1 F-1 M-1 A-1 M-1 J-1 J-1 A-9 S-9 Month and Year Region Awaiting MP (A) Entity Implementation (E) MP Validated Complete (G) October 5, 21 Page 13 of 14

Top Ten Standards for Violations Submitted without Mitigation Plans Top 1 Standards with Missing Mitigation Plans 14 12 123 Number of Violations 1 8 6 11 97 58 46 4 2 37 35 34 26 23 Total Of NERC_Violation_ID October 5, 21 Page 14 of 14

TOP TWENTY MOST VIOLATED STANDARDS

25 Top 2 FERC Enforceable Standards Rolling 12 Months Submit dates: 1/1/29 thru 9/3/21 222 215 21 2 Number of Violations 15 1 98 96 95 5 68 64 61 61 52 5 44 44 38 37 34 31 29 2 Standards Analysis Complete: PRC 5, CIP 4, FAC 8, FAC 9, CIP 1, VAR 2, PER 2 Numbers in Parenthesis () Indicate Previous Months Ranking Page 1 of 2

7 Top 2 All Time Violated Standards Active + Closed Violations thru 9/3/21 6 596 5 Number of Violations 4 3 385 321 242 2 162 1 132 128 125 118 11 13 12 11 97 93 88 85 81 75 68 Standard Analysis Complete: PRC 5, CIP 4, FAC 8, FAC 9, CIP 1, VAR 2, PER 2 Numbers in Parenthesis () Indicate Previous Months Ranking Page 2 of 2

MONTHLY REPORTING UPDATES

Snapshot comparison between September 1, 21 and September 3, 21 261 New 261 Preliminary Alleged Violation Information Submitted State 1 (Assessment and Validation) +159 116 Substate A (Region Preparing NAVAPS NAVAPS +159 36 NAVAPS Received By NERC and Concurrently sent to Registered Entity 32 Substate C (NERC Reviewing NAVAPS and Awaiting Registered Entity Response) -3 State 2 (Confirmation) NOAV Accepted or Not Contested -3 16 Substate D (Region Preparing NOCV) NOCV -1 NOCV Received by NERC State 3 (Regulatory Filings) -79 8 134 463 Substate H (NERC Reviewing NOCV and Settlement and Preparing NOP) -79 NERC issues NOP State 4 (Filed/Awaiting Closing Actions) +78 233 Substate I (Awaiting Closing Action) 62 State 5 (Closing) +62 1153 Substate J (Violations Closed) +78 +62 3 1 4 Substate E (Pending Hearing ) Hearing decision Not appealed No hearing requested Substate F (RE Hearing Process) NERC affirms hearing decision Substate G (NERC Appeal Process) Region approved settlement Hearing Hearing decision requested appealed to NERC +1 63 Alleged violation Dismissed in State 1 53 Dismissal +15 5 Alleged violation Dismissed in State 2 47 NERC remanded hearing decision 6 Legend: PNOAV Preliminary Notice of Alleged Violation NAVAPS Notice of Alleged Violation NOCV Notice of Confirmed Violation NOP Notice of Penalty Initiation of Settlement Negotiations (Anytime after preliminary alleged violation information received) 984 Substate K (Settlement Negotiations in Progress) 12 +56 Settlement Negotiation State +56 Page 1 of 7

C-RATS Report Date: 1/7/21 C-RATS Violation Process State Summary Table Active FERC Enforceable Alleged Violations Below is a breakdown, as of September 3, 21 of the Compliance Monitoring and Enforcement Program (CMEP) Violation state summary for the 445 active violations. State 1 State 2 State 3 State 4 State 5 Assessment and Validation Confirmation Settlement Substate A (NERC Reviewing) Substate C (NERC Reviewing NAVAP and awaiting RE Response) Substate D (Region Preparing NOCV) Substate E (Pending Hearing) Substate F (RE Hearing Process) Substate G (NERC Appeal Process) Substate K (Settlement Negotiations) Regulatory Filings Substate H (NERC Reviewing NOCV / Settlement) Filed/Awaiting Closing Actions Substate I (NERC Issues NOP) Completed and Closed Substate J (Violation Closed) Region (New) Total FRCC (3) 45 24 1 18 6 337 MRO (15) 6 17 21 9 52 159 NPCC (9) 53 3 1 4 18 16 39 17 RFC (97) 317 97 64 27 98 63 SERC (27) 265 71 22 15 189 562 SPP (6) 146 4 18 25 22 19 396 TRE 17 2 1 24 9 9 25 87 WECC (84) 188 26 12 3 351 294 1 671 1645 NERC (2) 69 17 86 TOTAL (261) 116 32 16 4 984 463 233 1153 445 Percentage of Total 28.68%.79%.4%.1%.%.% 24.33% 11.45% 5.76% 28.5% State Totals 116 52 984 463 233 1153 Definitions Substate A = Preliminary Notice of Alleged violation information has been received from the Region and NERC is awaiting receipt of Notice of Alleged Violation Proposed Penalty or Sanction from the Region. Substate C = NERC has received Notice of Alleged Violation Proposed Penalty or Sanction and is awaiting acceptance, auto acceptance or contest. Substate D = Region received acceptance letter from Registered Entity, or 3 day clock expired and violation is Auto Accepted and is now Confirmed. Substate E = Region has received letter contesting violation from Registered Entity. Substate F = Region has received request for Hearing from Registered Entity. Substate G = NERC has received request for Appeal from Registered Entity. Substate H = NERC has received a Notice of Confirmed Violation or a Settlement Agreement from the Region. Substate I = Violation is Confirmed/Settled and a Notice of Penalty has been issued by NERC 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. * Includes new violations received through 9/3/21. Page 2 of 7

Snapshot comparison between September 1, 21 and September 3, 21 261 Dismissed 3 State 1 (Assessment and Validation) 116 Change +159 Dismissed State 2 (Confirmation) 52 Change -3 Dismissed State 3 (Regulatory Filings) 36 8 62 NERC Reviewing NOCV and Settlement and Preparing NOP 463 Change -79 134 State 4 (Filed/Awaiting Closing Action) NERC Issues NOP 233 Change +78 State 5 (Completed and Closed) Total closed 1153 58 63 6 47 Settlement State 984 Change +56 12 Dismissed Page 3 of 7

C-RATS Pending Violations Summary by Process Steps FERC Enforceable Alleged Violations Summarized by State Below is a breakdown, as of September 3, 21, of the Compliance Monitoring and Enforcement Program (CMEP) Violation Process Steps summarized by State for the 445 FERC enforceable violations. Region Assessment and Validation Confirmation Settlement NERC Enforcement Actions Awaiting Closing Actions Completed and Closed FRCC 45 24 1 18 6 337 MRO 6 17 21 9 52 159 NPCC 53 4 4 18 16 39 17 RFC 317 97 64 27 98 63 SERC 265 71 22 15 189 562 SPP 146 4 18 25 22 19 396 TRE 17 3 24 9 9 25 87 WECC 188 41 351 294 1 671 1645 NERC 69 17 86 TOTAL 116 52 984 463 233 1153 445 Total * Includes new violations received through 9/3/21. C-RATS Report Date: 1/5/21 Page 4 of 7

C-RATS Summary of all Post June 18, 27 Alleged Violations by Region Below is a breakdown, as of September 3, 21 of the Compliance Monitoring and Enforcement (CMEP) alleged violation summary for all 5286 violations. Dismissed Previously Closed Newly Closed Total FERC Enforceable Normalized by Registered Entity % Non- Document Related Total Canadian Violations Total FRCC 66 6 277 2.64 62% 43 MRO 44 52 17 1.57 56% 1 213 NPCC 22 37 2 131.37 63% 2 212 RFC 31 93 5 55 1.7 74% 634 SERC 75 166 23 373 1.27 58% 637 SPP 21 19 377 5.71 58% 417 TRE 2 25 62.22 56% 17 WECC 921 639 32 974 1.51 51% 2566 NERC 11 86 21.5 83% 97 TOTAL 1211 191 62 2892 1.26 6% 3 5286 Includes new violations received through 9/3/21. C-RATS Report Date: 1/5/21 Page 5 of 7

Snapshot comparison between September 1, 21 and September 3, 21 State 1 (Regional Assessment) State 2 (NERC Assessment) State 3 (Mitigation Plan Implementation) State 4 (Regional Verification of Completion) State 5 (Closing) 261 New Mitigation Plan requested by Regional Entity 92 Substate A (Region awaiting mitigation plan) Region Awaiting +8 Proposed mitigation plan received by Regional Entity 19 Substate B (Region reviewing mitigation plan) Region Reviewing Region accepts active MP and sends to NERC and the Registered Entity NERC remands active MP for revision 159 Substate C (NERC reviewing active mitigation plan) NERC Reviewing Active MP +9 Active MP becomes completed/ verified prior to NERC approval NERC approves active MP and sends to FERC 141 Substate E (Registered Entity Implementing Mitigation Plan) Mitigation Implementation -95 Mitigation Plan is Complete 89 Substate F (Region Verifying Mitigation Plan Completion) Mitigation Verification -4 Region informs NERC that Mitigation Plan is Complete and Verified 131 Substate G (Mitigation Plan Validated Complete) Mitigation Completed Violation Mitigated Total Violation Mitigation Plans Verified Complete Region accepts and verifies completed MP and sends to NERC and the Registered Entity NERC Reviewing Completed MP +44 NERC approves completed MP 2479 NERC remands completed MP for revision 79 Substate D (NERC reviewing completed mitigation plan) 15 Dismissal Page 6 of 7

Mitigation Plans Process State Table Active FERC Enforceable Alleged Violations Below is a breakdown, as of September 3, 21, of the Compliance Monitoring and Enforcement Program (CMEP) Mitigation Plan state summary for the 1691 active violations. Region State 1 State 2 State 3 State 4 State 5 (Regional Assessment) (NERC Assessment) (Mitigation Plan Implementation) (Regional Verification of Completion) (Closing) Substate A Substate B Substate C Substate D Substate E Substate F Substate G Mitigation Accepted MP NERC Regional Plan Region Region Not Received Reviewing NERC Reviewing Registered Entity Verification of Validated Awaiting Reviewing from Region Active MP Completed MP Implementation MP Completion Complete FRCC 15 2 2 2 11 26 13 4 93 MRO 5 1 2 7 5 2 2 3 72 NPCC 4 7 3 34 1 85 RFC 3 23 36 2 21 11 53 446 SERC 178 11 1 4 7 8 15 314 SPP 148 6 2 2 21 24 7 1 238 TRE 8 2 7 2 2 2 2 1 35 WECC 17 49 3 45 38 25 45 27 339 NERC 56 4 9 69 TOTAL 92 19 43 116 79 141 89 131 1691 State Totals 192 238 141 89 131 Definitions Substate A = Region is still awaiting receipt of mitigation plan from Registered Entity. Substate B = Region has received mitigation plan and is reviewing. Substate C = NERC has received mitigation plan and is reviewing. Also includes any mitigation plans not yet received by NERC. Substate D = Mitigation plan has been verified completed by the Region but is still awaiting approval by NERC. Substate E = Mitigation plan has been approved by NERC, 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 Region. Substate G = Mitigation plan has been verified completed by Region, has been approved by NERC, and sent to FERC. Includes Mitigation Plans received through 9/3/21. Mitigation information reported at the violation level. Total C-RATS Report Date: 1/7/21 Page 7 of 7