Reliability Assurance Initiative (RAI) Progress Report

Transcription

1 Reliability Assurance Initiative (RAI) Progress Report Jerry Hedrick, Associate Director of Compliance Operations and Regional Entity Oversight Sonia Mendonca, Assistant General Counsel and Director of Enforcement Compliance Committee Meeting February 5, 2014

2 2013 Year End Progress Report Auditor Handbook The first version of auditor handbook was completed. Training and rollout efforts to occur in Prototypes and Pilot Programs The results to date of pilot programs are being compiled. Evaluation criteria has been finalized The assessment timeline and 2014 deliverables are set. Improvements to Self Reporting User guide to support improved self reporting process completed in December Request for broader industry review in January FFT Enhancements Triage process implemented across ERO by January 1, 2014 to expedite disposition of minimal risk issues. Enforcement pilots to test aggregation and exercise of enforcement discretion under way. 2

3 Auditor Handbook Key Deliverables Jan Feb March April May June July Aug Sep Oct Nov Dec March 3 rd Approved handbook provided to Compliance Auditors April 1 st Published handbook on the NERC website August 8 th Complete training for all Compliance Auditors September 1 st All audit engagement use and follow the handbook Industry Perspective Common language to communicate with industry Standardized audit approach across the ERO Enterprise Transparent audit activities 3

4 2014 Timeline for Pilot Program Development Jan Feb March April May June July Aug Sep Oct Nov Dec January Pilot evaluation criteria finalized April ERO executive management presented with recommend audit design October Finalized compliance audit design approved for training and deployment in 2015 Communication will occur through each phase of evaluation, design, and approval. Industry Perspective Defined risk approach that supports two way discussion Evaluation criteria results in appropriately scoped audits based on an entities size and risk Control evaluation is clearly defined and understood 4

5 RAI Regional Pilots Region MRO RF SERC WECC NPCC Pilot Focus End-to-end audit approach for assessing risk, setting audit scope, and the evaluation and testing of controls. Established risk criteria (via maturity model) and entity survey input for control assessment. End-to-end audit approach for assessing risk, setting audit scope, and the evaluation and testing of controls for CIP audits. Established risk criteria and audit scoping methodology. End-to-end audit approach for assessing risk, setting audit scope, and the evaluation and testing of controls. Texas RE, FRCC, and SPP are supporting evaluation and design activities *Second round of pilots 5

6 Status of Enforcement Activities Activity Self Report User Guide Status Discussed with industry focus group in December 2013; Posted for broader stakeholder comment in January 2014 Multi Region Registered Entity Process Current practices reviewed; Recommendations being discussed Triage Process In place at all Regional Entities as of January 1, 2014 Aggregation Pilots In progress until April 2014 Discretion Pilots In progress until April

7 Next Steps for Enforcement Activities Finalize User Guide; MRRE Guidelines (Q1 2014) Analyze Results of Enforcement Pilots (April 2014) FERC filing, if necessary (Q3/4 2014) 7

8 End-State RAI Processes Maturity Continuum Mature controls / Risk assessment Controls not provided Eligible for adjustment in scope, monitoring and related testing May require increased scope, monitoring or testing May be eligible for aggregation/logging Not eligible for aggregation/logging Presumption of discretion No presumption of discretion 8

9 Please send any questions or comments to: 9