FERC Accepts NERC’s Reliability Assurance Initiative Compliance Filing

On November 4, 2015, in Docket No. RR15-2, FERC conditionally accepted the compliance filing submitted by NERC on May 20, 2015 regarding its Reliability Assurance Initiative (RAI).  The RAI initiative represents NERC’s transition towards a risk-based approach to compliance monitoring and enforcement of reliability standards.  The order accepted NERC’s compliance filing, but also directed NERC to provide additional, more detailed information regarding RAI oversight, self-logging data, success metrics, and other issues. FERC also directed NERC to make conforming changes to the NERC Rules of Procedures within 120 days.  Commissioner LaFleur concurred with a separate statement which cautioned going forward against overly prescriptive requirements or calls for justification that undermine the RAI’s original intent, and instead focusing on important issues such as cybersecurity, geomagnetic disturbances, and the changing generation resource mix.