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