DRAFT Meeting Minutes Compliance and Certification Committee September 17, :00 p.m. - 5:00 p.m. ET September 18, :00 a.m.

Transcription

1 DRAFT Meeting Minutes Compliance and Certification Committee September 17, :00 p.m. - 5:00 p.m. ET September 18, :00 a.m. - Noon ET Hyatt Regency Vancouver Vancouver, BC, Canada Introductions and Chair s Remarks Remarks NERC Board and Executive Management Fred Gorbet (BOT), Dave Goulding (BOT), and Charlie Berardesco (NERC) NERC Antitrust Compliance Guidelines and Public Announcement Agenda Items 1. Administrative Secretary and Patti Metro a. Compliance and Certification Committee (CCC) Roster Update* and Hearing Procedures Training b. Anti-trust Compliance Guidelines 2. Committee Business a. Consent Agenda i. Meeting Agenda (Approve) ii. CCC June 2014 Meeting Minutes* (Approve) Patti Metro [LINK] iii. Interim membership (Approve) Patti Metro b. NERC Board and MRC Update from August meetings (Information only) *- Patti Metro c Stakeholders Perception Survey combine with NERC Annual Survey Steve Crutchfield and Ted Hobson The NERC Annual Survey will be issued in November and it includes all the CCC survey questions used in prior survey years, as well as additional NERC questions. Regional-specific questions will be implemented in 2015 to reduce duplicative surveys. Mr. Hobson is working with a NERC advisory group on the NERC Annual Survey, and that group has developed a composite survey that uses the CCC s Stakeholder Perception Survey. NERC and the CCC will use TalentQuest as the survey mechanism. d. CCC 2015 Work Plan Patti Metro and Charlie Berardesco

2 CPPS subcommittee will provide some proposed language changes to the CCC s 2015 Annual Work Plan before CCC s final vote. The CPPS questions whether the Reliability Assurance Initiative Advisory Group (RAIAG) should be included as part of the CCC activities, or at least reference support and participation in other subgroups that may be formed next year. Charlie Berardesco noted that the RAIAG is intended to be short-term to help drive the finalization of the guidance documents and other RAI activities. Long-term, the CCC will hold the role in providing feedback and communication of the how the implementation of RAI processes are going. i. NERC Board Assignment to transition CCC from monitoring role to advisory role Patti Metro described the transition of CCC to become a supporting role to NERC and its now existing internal audit group. Patti Metro and the CCC will coordinate with NERC to define new role and identify revision needs to the NERC Rules of Procedure (ROP) and other governing documents to carry out the new advisory role. Patti Metro will send out work plan to the CCC for an vote to get the work plan on the November 2014 Board agenda for approval. The goal for November Board meeting will be a proposed timeline to the EWRC for transition plan. The CCC will report on the transition at the February 2015 Board meeting and making any necessary FERC filings following the meeting. e. Self-certification report for ORCP and CMEP - Charlie Berardesco and Ted Hobson CCC sent the forms and request letters for NERC self-certifications. The EROMS group reviewed and spoke at a high level on the self-certifications. NERC and the Regional Entities have shown an increased effort in coordinating self-certification of Regional Entity information. Charlie Berardesco summarized the activities for the self-certifications and NERC s compliance under the Rules of Procedure (ROP) related to NERC Compliance Monitoring Enforcement Program (CMEP) and Organization Registration and Certification Program (ORCP). Deviations noted in the self-certifications were minor and there were no adverse activities on either program. NERC and the Regional Entities revised corrective action plans to help ensure deviations are corrected. EROMS recommends that the CCC fulfills its obligation with the solicitation and review of the selfcertification. Further, their recommendation includes no further report to the Board on the summary results as has occurred in the past. The NERC Board has visibility to the results through the EWRC as well as the NERC Internal Audit function so there is no need for the CCC to report the results again directly to the Board. i. Independent Audits* Kristi Knight Standards Process Manual (SPM) and Standards Applicable to NERC (SAN) Compliance and Certification Committee Agenda September 17-18,

3 Kristi Knight provided background on the SPM and SAN. Audit work wrapped up in early September NERC management is working on formal responses to the audit report, implementation plan, and remediation that will take place. Two findings of noncompliance and two performance improvements (See Handout). In December 2014, the final audit report will be shared and the recommendations and implementation of recommendations will be shared with the CCC. Bob Hoopes noted NERC s performance during the audit and that the process has improved and the audit was done in a timely and efficient manner. Closeout on status of non-conformance findings from audit of NERC Compliance Monitoring Enforcement Program (CMEP) and Organization Registration and Certification Program (ORCP) Kristi Knight provided an overview of the two non-conformance and performance improvements from the audit. NERC s internal audit group tracks the open items and these items are scheduled for full implementation at the end of 2014 (See Handout). f. Reliability Issues Steering Committee (RISC) Update* Terry Bilke i. Presentation - Approaches to use compliance data to reduce reliability risk o Metrics Project Terry Bilke provided information on the work performed on the metric project where the NERC RISC asked for input on managing risk and reliability in the compliance area. Terry went through the work performed and the suggested metrics approach to better align compliance and reliability as well as next steps of the project (See Handout). At this point, no action is needed by the CCC. Patti Metro will coordinate with NERC on next steps and determine further work on the project with defined deliverables. Adina Mineo and Patti Metro will speak with NERC staff on intent and process for use of RISC information from this project may inform Risk Elements and the annual ERO CMEP Implementation Plan. 3. Subcommittee Updates a. Nominating Subcommittee * Patti Metro i. CCC Sector openings To date, all voting positions are filled. Three non-voting positions remain for the two Canadian representatives and one government position. ii. CCC Member Upcoming Term Expirations Compliance and Certification Committee Agenda September 17-18,

4 Six terms are expiring in February Based on individual interest in continuation of service on the committee, nominations will be made and presented for approval. Also, the representatives for the ReliablityFirst and WECC positions will need to be filled. b. ERO Monitoring Subcommittee (EROMS) Ted Hobson i Work Plan Status on deliverables EROMS has completed all its 2014 deliverables on the work plan. EROMS continues to work on the survey with NERC. c. Compliance Processes and Procedures Subcommittee (CPPS) Matt Goldberg i Work Plan review CPPS went through the draft 2015 work plan and how CPPS can contribute to NERC s work plans for internal assessment, EWRC, other RAI activities. Matt Goldberg will provide revisions to the work plan to Adina and Patti by September 23 in order to finalize the work plan and provide it to the Board in November ii. CCCPP-010 Revisions CPPS went through the draft procedure and criteria during the meeting. CPPS is continuing to revise the draft procedures and will continue to coordinate with NERC staff in order to provide at the CCC December meeting, with a goal for Board approval in February d. Organization and Certification Subcommittee (ORCS) Keith Comeaux i Work Plan Status on deliverables i. Risk-Based Registration (RBR) Advisory Group Update ORCS has continued working with the RBR advisory group (RBRAG) and providing comments on the full RBR documents and proposed Rules of Procedures. ORCS will circulate information in October to the CCC on RBRAG activities. ii. Resolution of Multi-registered Regional Entity (MRRE) action item Project is closed for CCC involvement. Stan Kopman summarized the MRRE activities. Stan provided the proposed process for identifying possible MRREs and how the Regional Entities would work with the registered entities to design an optional process for participation in the MRRE process. In October, the ERO Executive Management Committee will review and approve the listing of possible MRRE participants and lead Regions to move forward with participation in the process. The goal is to rollout the process in CCC Ongoing Projects a. Team 4- Data Retention (Identify Reasonable Record Retention and Sampling)* Terry Bilke Compliance and Certification Committee Agenda September 17-18,

5 Terry Bilke provided an overview of Data Retention project results and recommendations (See Handout). Terry Bilke stated that he spoke with the CPPS about the recommendations in the report. CPPS will coordinate with NERC on how NERC is considering the recommendations. Project results identified 5 recommendations. Resolution of three bulleted items (3, 4, and 5) have been passed onto NERC and the Manual Task Force to incorporate the recommendations into development of the Compliance Audit Manual. Remaining bullets (1 and 2) will be distributed to NERC personnel for further consideration. The task force is now retired after passing the information onto the CPPS and the Data Retention Project is closed. Further Action Items include: CPPS will communicate with the Standards Committee to provide information on the results and recommendations. CPPS will report on the status at the Adina Mineo will communicate all recommendations to appropriate NERC staff, including the Manual Task Force and Standards staff. Adina Mineo will confirm that all Data Retention documents are posted on the RAI website at NERC.com 5. NERC Staff Reports Including Status of CCC Work Plan Deliverables a. Reliability Assurance Initiative (RAI) Update i. Compliance Activities and Enforcement Programs -Charlie Berardesco Charlie Berardesco opened RAI discussion and discussed the goal of compliance enforcement. The goal is to take a risk based approach to compliance assurance. But ultimately, even with RAI, compliance is the responsibility of the registered entities. Goal of RAI and risk-based approach: Are we providing reasonable assurance that the registered entities are compliant with the Reliability Standards to prevent risks to reliability? ii. Risk-based Compliance Oversight Framework - Dan Skaar, Regional Entity Manager, Midwest Reliability Organization Dan Skaar made opening remarks to his presentation and the fact that RAI is a recalibration on regulatory practices and how the ERO performs CMEP oversight. Dan Skaar discussed the transformation of existing compliance monitoring and enforcement activities to be risk-informed and provided some details on current activities. Dan then provided the overview of the Risk-based Compliance Oversight Framework (Framework). iii ERO CMEP Implementation Plan Adina Mineo Adina Mineo provided details on the 2015 CMEP Implementation Plan, which includes information on the ERO s Risk-based Compliance Monitoring Framework ( Framework ) (see Handout). Compliance and Certification Committee Agenda September 17-18,

6 iv. CCC Member Participation in Reviews of RAI document Helen Nalley, Matt Goldberg, and Rick Terrill walked through their presentations on each areas of the Framework (See Handouts). o Risk Elements Helen Nalley o Internal Controls Evaluation (ICE) Matt Goldberg o Inherent Risk Assessment (IRA) Rick Terrill b. RSAW Update on CCC Input Adina Mineo Adina Mineo reported that NERC staff has updated all RSAWs related to Paragraph 81 requirement references. In June 2014, NERC updated the RSAWs to add language for the retired Requirement from Paragraph 81, as well as removed data fields and boxes to help eliminate confusion of which Requirements remain in effect. c. BES Definition and Implementation of BESNet Bob Cummings Bob Cummings provided an overview of the BES definition and implementation of BESNet (See Handout). Bob covered both the inclusions and exclusions from the BES definition and how the definition is applied. Bob also covered the process for any exception requests, as well as the use of BESNET and the use of the centralized system. d. Risk Based Registration Update Rebecca Michael (call-in) Rebecca Michael and Earl Shockley provided an update on the RBR Initiative. Proposed amendments to the NERC Rules of Procedure to implement RBR are posted for a 45 day comment period that ends on October 10. A technical report in support of the proposed amendments also is posted. As a result of ongoing studies, the technical report will be updated to reflect additional information that is being developed and reviewed. The package for NERC Board approval will be posted on October 28 in advance of the November 2014 Board meeting. If approved by the NERC Board, NERC will submit a filing to FERC and other applicable governmental entities shortly after the Board meeting. 6. Member Round Table Patti Metro 7. Review of Action Items and CCC Work Plan Deliverables i. Outreach plan for CCC marketing at Regional Entity level Jennifer Flandermeyer and Patti Metro Item tabled until next meeting ii. Secure document CCC site Bob Hoopes and Adina Mineo o Registration [LINK] o Secure site (once approved) [LINK] Compliance and Certification Committee Agenda September 17-18,

7 Item tabled until next meeting. iii. Action Items from September 2014 Meeting Data Retention Project: o CPPS will communicate with the Standards Committee to provide information on the results and recommendations. CPPS will report on the status at the December meeting. o Adina Mineo will communicate all recommendations to appropriate NERC staff, including the Manual Task Force and Standards staff. o Adina Mineo will confirm that all Data Retention documents are posted on the RAI website at NERC.com. RISC Metrics Project: Adina Mineo and Patti Metro will speak with NERC staff on whether and how RISC information from this project may inform Risk Elements and the annual ERO CMEP Implementation Plan. Matt Goldberg will provide CPPS revisions to the work plan to Adina and Patti by September 23 in order to finalize the work plan and provide it to the Board in November Formal recognition of CCC Member Patti Metro formally thanked Bob Hoopes on his participation and contributions in the CCC. The September 2014 meeting will be Bob s last meeting as a member. 9. Future Meeting Dates a. December 3-4, 2014: Phoenix, AZ (APS host location) b. March 3 4, 2015: Atlanta, GA (NERC) c. June 10-11, 2015: Arlington, VA (NRECA host location) d. December 2-3: Atlanta, GA (NERC) e. Discuss proposed dates and locations for September Adjourn i. Toronto, ONT (TBD), co-located with other committees ii. September or Member hosted week of September 21 Meeting adjourned on September 18, 2014 at 11:00 AM. *Background materials provided Compliance and Certification Committee Agenda September 17-18,