On April 15, 2010, NERC issued Compliance Public Bulletin No. 2010-003 concerning the reporting of ongoing or repeat violations of reliability standards during the period of time when a registered entity is implementing an approved mitigation plan. Specifically, the bulletin explains that, because the underlying condition(s) that caused or contributed to the violations might not be fully mitigated until completion of a mitigation plan, the registered entity implementing such mitigation plan might have continuing and/or repeat violations when the specified reported periods are reached. In these cases, the specific facts and circumstances will dictate whether the violations should be treated as a continuation of the original violations or new violations. Accordingly, the bulletin addresses: (i) how to determine whether new, additional violations have occurred; (ii) how to report such new, additional violations; and, (iii) how such new, additional violations will be treated under the CMEP.
To read the full text of NERC Compliance Public Bulletin No. 2010-003, click here