Quarterly Report on Performance Metrics

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Transcription:

Quarterly Report on Performance Metrics Sonia Mendonca, Assistant General Counsel and Director of Enforcement Compliance Committee Meeting February 6, 2013 1 RELIABILITY ACCOUNTABILITY

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

Progress in Violation Processing Number of Violations 600 550 500 450 400 350 300 250 200 150 100 50 0-50 -100-150 -200-250 540-58 -178-191 Violation Processing 165 27 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Dec-12-60 -1-78 -139-5 -145 For the Year 2012 End of year 2011 New 2569 2944 Dismissed 924 962 Filed 1768 1695 Total Dismissed and Filed 2692 2657 Violation Processing -123 287 3 RELIABILITY ACCOUNTABILITY

Processing Before and After CEI 3000 2500 Impact of CEI Streamlined Processing Tracks Pre-CEI Monthly Average: 91 Number of Issues 2000 1500 1000 Full NOP Full NOP FFT and SNOP Post- CEI Monthly Average: 151 500 0 ACP 16 months before CEI 16 months after CEI 4 RELIABILITY ACCOUNTABILITY

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

80% Reduction in Pre-2011 Case Load Active Pre-2011 Caseload Available for Processing 1200 1000 1026 947 848 800 600 680 660 617 537 498 462 400 363 330 200 207 0 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

What Remains 1600 1400 1200 ERO Inventory CIP and Non-CIP Violations Based on Discovery Dates from June 2007 to December 31, 2012 Focus for 2013 1000 800 600 400 200 0 2008 2009 2010 2011 2012 NON CIP CIP * Reflects Violations for Federal Entities Being Processed Excludes Canadian Violations 7 RELIABILITY ACCOUNTABILITY

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, 2012 500 400 300 200 100 0 2007-2010 2011-2012 2011-2012 2007-2010 2011-2012 2011-2012 2011-2012 2007-2010 2011-2012 2007-2010 2011-2012 2007-2010 2011-2012 2007-2010 2011-2012 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

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

10 RELIABILITY ACCOUNTABILITY

Compliance Enforcement Initiative Sonia Mendonca, Assistant General Counsel and Director of Enforcement Compliance Committee Meeting February 6, 2013 1 RELIABILITY ACCOUNTABILITY

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

Processing Before and After CEI 3000 2500 Impact of CEI Streamlined Processing Tracks Pre-CEI Monthly Average: 91 Number of Issues 2000 1500 1000 Full NOP Full NOP FFT and SNOP Post- CEI Monthly Average: 151 500 0 ACP 16 months before CEI 16 months after CEI 3 RELIABILITY ACCOUNTABILITY

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

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

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

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

8 RELIABILITY ACCOUNTABILITY