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ERO Mitigation Plan Guide Revised April 2014 3353 Peachtree Road NE Suite 600, North Tower Atlanta, GA 30326 404-446-2560 | www.nerc.com ERO Mitigation Plan Guide | Revised April 2014 1 of 23 Table of Contents Table of Contents .......................................................................................................................................................2 Disclaimer ...................................................................................................................................................................3 Document Revisions ...................................................................................................................................................4 Introduction and Purpose...........................................................................................................................................7 Mitigation Plan Contents ............................................................................................................................................8 What is a Mitigation Plan? ..................................................................................................................................8 What should be included in a Mitigation Plan? ..................................................................................................8 Appendix – Reference Documents .......................................................................................................................... 21 ERO Mitigation Plan Guide | Revised April 2014 2 of 23 Disclaimer The guidance contained in this document represents suggestions on particular topics to be applied by Registered Entities according to the individual facts and circumstances surrounding specific instances of noncompliance. This guidance does not create binding norms, establish mandatory reliability standards, or create parameters to monitor or enforce compliance with Reliability Standards. This guidance provides information and advice for Registered Entities to use when reporting instances of noncompliance to a Compliance Enforcement Authority (CEA). ERO Mitigation Plan Guide | Revised April 2014 3 of 23 Acknowledgments Acknowledgments Executive Sponsors Charles A. Berardesco, North American Electric Reliability Corporation Lane Lanford, Texas Reliability Entity, Inc. Daniel P. Skaar, Midwest Reliability Organization Development Team Lead Drafters Rick Dodd, Florida Reliability Coordinating Council Keshav Sarin, Western Electricity Coordinating Council Tasha Ward, Southwest Power Pool Regional Entity Drafting Team Commenters Jenny Anderson, Southwest Power Pool RE Ingrid Bjorklund, Midwest Reliability Organization Rashida Caraway, Texas Reliability Entity, Inc. Walter Cintron, Northeast Power Coordinating Council, Inc. Theresa M. Cunniff, ReliabilityFirst Derrick Davis, Texas Reliability Entity, Inc. Michelle Johnson, Florida Reliability Coordinating Council Ed Kichline, North American Electric Reliability Corporation Andrea Koch, SERC Reliability Corporation Chris Luras, Western Electricity Coordinating Council Sonia Mendonça, North American Electric Reliability Corporation Matthew Moore, Western Electricity Coordinating Council Sara Patrick, Midwest Reliability Organization Jacob Phillips, Midwest Reliability Organization Niki Schaefer, ReliabilityFirst Patrick VanGuilder, Florida Reliability Coordinating Council Industry Focus Group Michael Ayotte, ITC Holdings Tom Bowe, PJM Interconnection, LLC Randy Crissman, New York Power Authority Annette Johnston, MidAmerican Energy Helen Nalley, Southern Company Industry Commenters ACES American Electric Power American Transmission Company Bonneville Power Administration Brazos Electric Power Cooperative Buckeye Power Duke Energy Exelon FirstEnergy ERO Mitigation Plan Guide | Revised April 2014 4 of 23 Acknowledgments Hydro One ISO/RTO Council Massachusetts Municipal Wholesale Electric Company MRO Performance Risk Oversight Subcommittee National Grid New York Power Authority Pepco Holdings, Inc. Reliability Compliance Legal Group Santee Cooper Public Service Authority Tampa Electric Company The Southern Company and Affiliates The United Illuminating Company Wisconsin Electric ERO Mitigation Plan Guide | Revised April 2014 5 of 23 Document Revisions Document Revisions Date Version Number Document Changes January 17, 2014 1.0 April 17, 2014 2.0 Multiple revisions based on Comments received during public comment period, January 22, 2014 through February 21, 2014. ERO Mitigation Plan Guide | Revised April 2014 6 of 23 Introduction and Purpose The ability of a CEA to arrive at a final determination with respect to all noncompliance in an efficient manner is in part dependent on the quality of the information it has about the noncompliance and related mitigation. With that in mind, the Electric Reliability Organization (ERO) enterprise has developed this ERO Mitigation Plan Guide and a companion Self-Report User Guide to describe the type and quality of information that must be submitted in order to allow for a prompt evaluation. While the benefits of more thorough and timely mitigation plans being submitted to Regional Entities include faster determination of how an issue of non-compliance should be processed and faster processing times, it is important for the Registered Entity to perform the actions necessary to correct the instant issue to protect reliability of bulk power system (BPS). This guide supplements information provided in the NERC Compliance Monitoring and Enforcement Program, Rules of Procedure, Appendix 4C, Section 6.0, by providing further guidance on what should be included in a Mitigation Plan. While NERC and almost every Regional Entity have posted guidance on these issues in the past, this user guide is intended to be an ERO enterprise document that may be used by Registered Entities regardless of location. ERO Mitigation Plan Guide | Revised April 2014 7 of 23 Mitigation Plan Contents Mitigation Plan Contents These guidelines inform a Registered Entity on proper steps to take, and items to consider, when creating Mitigation Plans according to Appendix 4C, if the CEA requests that a Mitigation Plan be submitted. These sections will help guide the Registered Entity to develop a plan that will not only identify and correct the original possible noncompliance but will also include steps to prevent future occurrence of similar issues. For a discussion of mitigation activities that could be provided as part of a Self-Report, please refer to the ERO Self-Report User Guide. What is a Mitigation Plan? A Mitigation Plan is an action plan developed by a Registered Entity to (1) correct noncompliance with a Reliability Standard and (2) prevent recurrence of the noncompliance. As noted above, the guidelines in this document are intended to supplement the requirements and information provided in the CMEP. In addition, a Registered Entity may cover multiple violations of the same standard and requirement in one Mitigation Plan per the CMEP. This guide was not intended to directly address the references to mitigation plans and action plans made in the Reliability Standards. This guide, however, can be used when performing the activities required by those Standards and Requirements as the activities required cover the same areas of topic to be resolved. What should be included in a Mitigation Plan? A Mitigation Plan should address the actual and potential risk posed by the possible noncompliance, identify controls and corrective actions to reduce the likelihood of a future occurrence, and outline the steps a Registered Entity will perform to mitigate the possible noncompliance. It should be noted that the intent of these Guidelines is to outline the activities that should be considered by Registered Entities while submitting a Mitigation Plan. However, the activities are not outlined in the order they should necessarily be implemented. Registered Entities are strongly encouraged to take prompt steps to remediate possible noncompliance as soon as it is discovered. In this guide, there are examples of statements that are included in a Mitigation Plan. For each Mitigation Plan heading, there is a Lacking, Better, and Best example. By providing the three levels, a Registered Entity can gauge where its current Mitigation Plan language stands and set the goal to produce the “Best” level statements and information going forward. Overview Mitigation Plans should address the following. 1. Scope of Possible Noncompliance 2. Root Cause of Possible Noncompliance 3. Corrective, Preventive, and Detective Actions 4. Milestones 5. Proposed Completion Date 6. Interim Risk Reduction 7. Prevention of Future Risk to Reliability Included in Appendix A is a Mitigation Plan Checklist for a Registered Entity to use to ensure that it is completing the steps of the Mitigation Plan process. ERO Mitigation Plan Guide | Revised April 2014 8 of 23 Mitigation Plan Contents Scope of Possible Noncompliance In this section of the Mitigation Plan, the Registered Entity should identify the originally reported scope of the possible noncompliance and note any changes in scope that were found. When identifying the scope of the possible noncompliance, the Registered Entity should consider all procedures, assets, facilities, or personnel that are directly impacted or that could be impacted by the possible noncompliance. The Mitigation Plan should include a brief narrative describing the comprehensive review that was done by the Registered Entity to verify the full