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WECC Compliance Report

WECC Compliance Report. 1 Title Page Audit and Spot Check Reports Explanation of Slide 2 Violation Validation-Data Explanation of Slide 4 Violation Validation-Line Chart Explanation of Slide 6 Mitigation Plan Review-Data Explanation of Slide 8 Mitigation Plan Review-Line Chart

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WECC Compliance Report

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  1. WECC Compliance Report 1 Title Page • Audit and Spot Check Reports • Explanation of Slide 2 • Violation Validation-Data • Explanation of Slide 4 • Violation Validation-Line Chart • Explanation of Slide 6 • Mitigation Plan Review-Data • Explanation of Slide 8 • Mitigation Plan Review-Line Chart • Explanation of Slide 10 • Violations Received (Reporting Method) • Explanation of Slide 12 • Violation Reporting Methods (shown by percent) 15 Explanation of Slide 14

  2. Non-public Audit & Spot Check Reports Measure: Average days to produce audit report and file with NERC (“non-public” = violations are not yet processed to finality) Spot Check data includes only those since 1/1/2011 when reports were required to be sent to NERC. “Days Outstanding” measures average days that the incomplete reports are pending Goal: Per CMEP, “normally” 60 days for audit reports; 90 days for spot check reports if there are no violations) * Year-to-date

  3. Explanation of Measures Slide 2 Explanation: Audit and Spot Check Reports Measure: This data chart measures the average number of days it takes for the WECC audit team to produce an audit report following an audit and file it with NERC. It also measures the number of completed reports, the number of incomplete reports and the total number of days incomplete reports are outstanding. Measurement Period: One year. (3 years’ worth of audit reports and 2 years’ worth of spot check reports are shown) Purpose: WECC measures this to gauge our compliance with the CMEP time suggested; to gauge the audit and audit support staff efficiency and efficiency of both staff and tools. Terms: “Non public” :refers to final audit reports send to NERC. Audit reports are not posted publically until all due process relating to disposing of any violations are complete, i.e. a Notice of Penalty is approved by FERC. “Days outstanding” measures the average number of days that the incomplete reports have been pending. Goal: 60 days for audit report; 90 days for spot check report. Per the Compliance Monitoring and Enforcement Program) CMEP, “normally” audit reports would be filed with NERC 60 days following conclusion of the audit. The CMEP indicates that for spot check reports, these should be filed within 90 days if there are no violations. Notes: Spot Check data includes only those since 1/1/2011 when reports were required to be sent to NERC.

  4. Violation Validation Measure: Average days to complete reviews for validated (enforceable) violations reviewed during the referenced period. Includes technical review. Upon completion of review validated violations are sent to Enforcement staff for further processing and final disposition. This data does not include dismissed violations. Goal: 60 days (Internal goal; no CMEP requirements) # CIP pending review as of 5/31/2012: 40 # O&P pending review as of 5/31/2012: 26 * Quarter-to-date

  5. Explanation of Measures Slide 4 Explanation: Violation Review Report (Data) Measure: This data chart measures, broken out by Critical Infrastructure Protection (CIP) and Operations and Planning (O&P) standards, the average number of days staff (generally SMEs, Subject Matter Experts) takes to complete reviews of all NPVs (New Possible Violations) which are validated and transferred to WECC Enforcement staff for processing and disposition. It also measures the number of violations reviewed and validated and the number of violations pending review > 90 days at the end of the measurement period. Also noted are the total number of CIP and O&P violations currently pending review. Measurement Period: Quarter (six most recent quarters are shown) Purpose: WECC measures this as a gauge of staffing sufficiency given workload, and efficiency of both staff and processes. Terms: “NPV” is New Possible Violation. NPVs are reported and entered into the tracking system within five days after initial indication of a violation (for example, at the end of an audit, or upon receiving a Self Report, or a Self Certification indicating noncompliance). “CMEP” is the FERC-approved Compliance Monitoring and Enforcement Program: Goal: 60 days from entry of the NPV to the date it is either dismissed or referred for further processing by WECC Enforcement staff. This is an internal goal; the CMEP specifies no goals or requirements. Notes: New Possible Violations are reviewed by an appropriate WECC SME, who may review the available record (for example, the Self Report filed by the entity), request further information from the entity, or issue data requests, for example. At that point, the NPV is either: (1) Dismissed (meaning that upon review the SME determined that no violation in fact exists) or (2) “Validated” and becomes an “Alleged Violation” which is forwarded to the WECC Enforcement staff for appropriate disposition (for example, through FFT, Find, Fix and Track, or an Expedited Settlement Agreement, Notice of Penalty, or Spreadsheet NOP). This measure currently does not include violations that are dismissed. The dismissal data in WECC’s new webCDMS system includes a number of out-of-process outliers, which can skew the average days calculation. WECC is working with the webCDMS vendor to add the ability to flag these outliers for exclusion.

  6. Violation Validation Shows information from the preceding slide (slide 4) Goal: 60 days (Internal; no CMEP requirements) # pending review as of 5/31/2012: 66 # pending review > 90 days as of 5/31/2012: 42 * Quarter-to-date

  7. Explanation of Measures Slide 6 Explanation: Violation Review Report (Line Chart) Measure: This line chart measures, broken out by Critical Infrastructure Protection (CIP) and Operations and Planning (O&P), the average number of days staff (generally SMEs, Subject Matter Experts) takes to complete reviews of all NPVs (New Possible Violations) which are validated and transferred to WECC Enforcement staff for processing and disposition. Also noted are the total number of violations currently pending review and the total number of violations pending review > 90 days. This chart is a depiction of data contained in Slide 4 Measurement Period: Quarter (six most recent quarters are shown) Purpose: See Slide 4 explanation Terms: See Slide 4 explanation Goal: See Slide 4 explanation Notes: See Slide 4 explanation

  8. Mitigation Plan Review Measure: Average days to complete reviews for accepted Mitigation Plans reviewed during the referenced period Does not include rejected MPs or MPs with dismissed violations Goal: 60 days (Internal goal. CMEP: Region has 30 days to accept, reject, or extend review. If the MP is not reviewed within 30 days, WECC always extends the review within 30 days.) # CIP pending review as of 5/31/2012: 32 # O&P pending review as of 5/31/2012: 11 * Quarter-to-date

  9. Explanation of Measures Slide 8 Explanation: Mitigation Plan Review (Data) Measure: This data chart measures, broken out by Critical Infrastructure Protection (CIP) and Operations and Planning (O&P), the average number of days staff (generally SMEs, Subject Matter Experts) takes to complete reviews of Mitigation Plans (MPs) which were accepted during the referenced period. It also measures the number of MPs reviewed and accepted and the number of MPs pending review > 90 days at the end of the measurement period. Also noted are the total number of CIP and O&P MPs currently pending review. These measures do not include MPs that were rejected after review or that pertain to violations that ultimately were dismissed. [Going forward, we now can capture data on MPs that relate to violations that later were dismissed.] Measurement Period: Quarter (six most recent quarters are shown) Purpose: WECC measures this as a gauge of staffing sufficiency given workload, and efficiency of both staff and processes. Terms: “MP” is Mitigation Plan. Entities are required to file these on a requirements (rather than Standard) level. Thus, for example, violations of two different requirements relating of a single standard would result in two MPs rather than one. “CMEP” is the FERC-approved Compliance Monitoring and Enforcement Program: Goal: 60 days from submittal of MP to the date it is either accepted or rejected. This is an internal goal; the CMEP specifies the region has 30 days to accept, reject, or extend the review period. WECC always extends the review period within 30 days, if necessary. Notes: WECC and some other regions believe and continue to advocate to NERC that 30 days for review is not a realistic goal, primarily because of the interface of MPs with other, related CMEP processes. Under the CMEP, entities are not required to file MPs until 30 days after issuance of the NOAV (Notice of Alleged Violation), if not contested. On the other hand, entities (rightly) are encouraged to file MPs as quickly as possible once they believe they are in violation. WECC entities have a good record in this respect; it’s an indicator of a good compliance culture. Consequently, it is not unusual for an entity to file a Self Report, or certify non-compliance, simultaneously (or nearly so) with a corresponding MP. The dilemma is that WECC cannot assess the sufficiency of the MP until it understands the violation by performing its review (initial validation of the New Possible Violation, then Enforcement staff assessing of the scope and risk of the Alleged Violation). The CMEP contains no measures for these violation review activities, but it’s only after doing some work can staff assess whether it can accept the MP. Doing both the violation review and MP review within 30 days is a major challenge.

  10. Mitigation Plan Review Measure: Shows information from the preceding slide (slide 8) Goal: 60 days (Internal. CMEP: Region has 30 days to accept, reject, or extend review. WECC always extends the review within 30 days, if necessary.) # pending review as of 5/31/2012: 43 # pending review > 90 days as of 5/31/2012: 4 * Quarter-to-date

  11. Explanation of Measures Slide 10 Explanation: Average Days to Complete Mitigation Plan Review (Line Chart) Measure: This line chart measures, broken out by Critical Infrastructure Protection (CIP) and Operations and Planning (O&P), the average number of days staff (generally SMEs, Subject Matter Experts) takes to complete reviews of Mitigation Plans (MPs) which were accepted during the referenced period. Also noted are the total number of MPs currently pending review and the total number of MPs pending review > 90 days. These measures do not include MPs that were rejected after review or that pertain to violations that ultimately were dismissed. Measurement Period: Quarter (six most recent quarters are shown) Purpose: See Slide 8 explanation Terms: See Slide 8 explanation Goal: See Slide 8 explanation Notes: See Slide 8 explanation

  12. Violations Reporting Method Measure: Enforceable violations (Reviewed violations that are not dismissed) shown by source (CMEP monitoring method) * "Other" includes Spot Check, Exception Report, Periodic Data Submittal, Compliance Investigation and Complaint ** Year-to-date

  13. Explanation of Measures Slide 12 Explanation: Enforceable Violations Measure: This bar chart measures the number of enforceable violations by reporting method: Self-Report; Self-Certification; Audit and Other. Measurement Period: One year (3 most recent years are shown) Purpose: This does not measure performance or efficiency. It is used to track the number of discovered violations relative to the various reporting methods, primarily to assess trends. This information occasionally is requested by stakeholders. Terms: "Other" includes Spot Check, Exception Report, Periodic Data Submittal, Compliance Investigation and Complaint. “Enforceable violations” are violations that are reviewed and validated. Goal: N/A Notes: Dismissed violations are not enforceable.

  14. Violation Reporting Method Measure: Enforceable violations (Reviewed violations that are not dismissed), with source expressed as a percentage of enforceable violations. * "Other" includes Spot Check, Exception Report, Periodic Data Submittal, Compliance Investigation and Complaint ** Year-to-date

  15. Explanation of Measures Slide 14 Explanation: Percentage of Enforceable Violations Measure: This bar chart measures the percentage of enforceable violations by reporting method: Self-Report; Self-Certification; Audit and Other. This is based on the information from Slide 12. Measurement Period: Year (3 most recent quarters are shown) Purpose: See Slide 12 explanation Terms: See Slide 12 explanation Goal: See Slide 12 explanation Notes: See Slide 12 explanation

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