Quarterly Report on Performance Metrics

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1 Quarterly Report on Performance Metrics Sonia Mendonca, Assistant General Counsel and Director of Enforcement Compliance Committee Meeting February 6, RELIABILITY ACCOUNTABILITY

2 Overview The ERO reduced its caseload in 2012 The Compliance Enforcement Initiative (CEI) has positively affected processing Eighty percent reduction in violations older than two years Older and higher-risk violations remain in focus 2 RELIABILITY ACCOUNTABILITY

3 Progress in Violation Processing Number of Violations Violation Processing Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Dec For the Year 2012 End of year 2011 New Dismissed Filed Total Dismissed and Filed Violation Processing RELIABILITY ACCOUNTABILITY

4 Processing Before and After CEI Impact of CEI Streamlined Processing Tracks Pre-CEI Monthly Average: 91 Number of Issues Full NOP Full NOP FFT and SNOP Post- CEI Monthly Average: ACP 16 months before CEI 16 months after CEI 4 RELIABILITY ACCOUNTABILITY

5 Use of Streamlined Processing Tracks Since September 2011 NOP 23% FFT 41% SNOP 36% FFT SNOP NOP 5 RELIABILITY ACCOUNTABILITY

6 80% Reduction in Pre-2011 Case Load Active Pre-2011 Caseload Available for Processing Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Dec-12 Active 6 RELIABILITY ACCOUNTABILITY

7 What Remains ERO Inventory CIP and Non-CIP Violations Based on Discovery Dates from June 2007 to December 31, 2012 Focus for NON CIP CIP * Reflects Violations for Federal Entities Being Processed Excludes Canadian Violations 7 RELIABILITY ACCOUNTABILITY

8 Where the Violations are by Region 600 ERO Inventory Regional Breakdown CIP and Non-CIP Violations Based on Discovery Dates from June 2007 to December 31, SERC FRCC MRO NCEA NPCC RFC SPP TRE WECC * Reflects Violations for Federal Entities Being Processed Excludes Canadian Violations NON CIP CIP 8 RELIABILITY ACCOUNTABILITY

9 Next Steps Continue to reduce caseload Improve metrics to highlight positive effects of enforcement on reliability 9 RELIABILITY ACCOUNTABILITY

10 10 RELIABILITY ACCOUNTABILITY

11 Compliance Enforcement Initiative Sonia Mendonca, Assistant General Counsel and Director of Enforcement Compliance Committee Meeting February 6, RELIABILITY ACCOUNTABILITY

12 Overview Compliance Enforcement Initiative (CEI) benefits: Processing improvements Reliability Allocation of ERO and stakeholder time and resources One-year report to FERC on CEI 2 RELIABILITY ACCOUNTABILITY

13 Processing Before and After CEI Impact of CEI Streamlined Processing Tracks Pre-CEI Monthly Average: 91 Number of Issues Full NOP Full NOP FFT and SNOP Post- CEI Monthly Average: ACP 16 months before CEI 16 months after CEI 3 RELIABILITY ACCOUNTABILITY

14 Use of Streamlined Processing Tracks Since September 2011 NOP 23% FFT 41% SNOP 36% FFT SNOP NOP 4 RELIABILITY ACCOUNTABILITY

15 Reliability Benefits of CEI A more risk-based approach to enforcement CEI s more streamlined approach allows for enhanced focus on higher-risk issues by the ERO and registered entities There is general consensus within industry on the benefits of CEI, with a recent survey showing: Greater willingness to self-monitor and self-report Improved compliance culture 5 RELIABILITY ACCOUNTABILITY

16 Maximizing CEI Evaluating experience thus far Monitoring consistency of implementation across the ERO o Pre-filing review of FFTs o FFT sampling Identifying improvements going forward Incorporating enhancements to bring additional benefits o Simpler tracking and reporting requirements o Earlier identification of FFTs o Streamlined documentation of mitigation 6 RELIABILITY ACCOUNTABILITY

17 One-Year Report to FERC on CEI Benefits of CEI Effect on caseload Focus on higher-risk reliability matters Evaluation of risk Proposed improvements Monitoring of implementation and overall consistency Impact on self-reporting Due on March 15, 2013, one year after CEI Order 7 RELIABILITY ACCOUNTABILITY

18 8 RELIABILITY ACCOUNTABILITY

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