Topic:"Stakeholder Engagement" in M03324

ARTICLE II Membership Section 1 — Members — Membership in the Corporation is voluntary and is open to any person or entity that has an interest in the reliable operation of the North American bulk power system and that registers with the C...

AI summary This section outlines the membership requirements for the Corporation, including voluntary registration, eligibility criteria, and procedures for maintaining and renewing membership. It also describes the responsibilities of the secretary in managing the member roster and handling removals for non-renewal.

ving a regulatory and/or policy interest in wholesale electricity. Entities with regulatory oversight over the Corporation or any regional entity, including U.S., Canadian, and Mexican federal agencies and any provincial entity in Canada h...

AI summary Section 4 outlines eligibility criteria for membership sectors, including nonvoting roles for regulatory agencies and rules for corporate affiliate registration. Section 5 establishes that membership persists as long as qualifications and obligations are met. The text emphasizes structural governance and stakeholder participation frameworks.

the areas of technical electric operations and reliability, legal, market, financial, and regulatory matters, and familiarity with regional system operation issues; and reflects geographic diversity.

AI summary The text outlines criteria for Board composition, emphasizing expertise in technical electric operations, reliability, legal, market, financial, and regulatory matters, along with regional system operation knowledge and geographic diversity.

the results shall be posted on the Corporation's Web site, within ten (10) days of the action vote, and all written responses of the members shall be filed with the minutes of proceedings of members. Section 5 ¾ Meetings of the Members to...

AI summary The Corporation must post meeting results online within 10 days of a vote and file member responses with meeting minutes. Meetings must be publicly accessible, with non-confidential materials posted within 24 hours, though closed sessions may occur for sensitive topics like personnel, litigation, or commercial data.

Section 4 ¾ Adequate Representation of Canadian Interests on the Member Representatives Committee ¾ In addition to the requirements for composition of the Member Representatives Committee specified in Section 1 of this Article VIII, the Me...

AI summary The section mandates that the Member Representatives Committee (MRC) must include Canadian voting representatives proportional to Canada's share of net energy for load (NEL) relative to the U.S. and Canada. If initial elections don't meet this quota, the highest-voted candidate from the Canadian sector is added.

east 135 days before the start of the fiscal year in order to allow for timely submittal of the approved annual budget, business plan, and funding mechanism to the applicable governmental authorities. Section 3 ¾ Criteria for Funding Mecha...

AI summary The document outlines procedures for preparing and adopting annual budgets, business plans, and funding mechanisms, including criteria for funding recovery, consultation requirements with the Member Representatives Committee, and a 30-day review period for draft documents. The funding mechanism must account for projected revenues, program fees, and revenue-expenditure variances.

resentatives of the sectors that elected them as representatives to the Member Representatives Committee and shall thereafter be responsible for acting in the best interests of the members as a whole. Section 6 ¾ Vacancies on the Member Re...

AI summary Section 4 mandates Member Representatives Committee (MRC) members to act in the best interests of all members, while Section 6 outlines procedures for filling vacancies, including sector elections and adherence to specified timelines and procedures.

III. BACKGROUND In 2006, NERC developed an initial version of the plan for Reliability Standards development entitled the Reliability Standards Development Plan: 2007–2009 . NERC has since updated the plan annually, and the 2010–2012 versi...

AI summary NERC's 2010–2012 Reliability Standards Development Plan updates its annual management tool for coordinating reliability standards, engaging stakeholders, and aligning with U.S. and Canadian authorities. The plan is submitted for informational purposes without requesting specific action, building on prior versions and detailing projects in three volumes.

Projects anticipated commencing in 2012: 2012-02 Physical Protection In preparing the 2010 Development Plan , NERC staff reached out to stakeholders and asked for input regarding the 2009 version of the plan. Several stakeholders voiced a...

AI summary NERC's 2010 Development Plan faced stakeholder concerns about overloading concurrent projects, urging focus on high-impact reliability initiatives. The plan addressed feedback by prioritizing reliability improvements, reducing redundant standards, and creating 'Project 2010-06' to align standards with reliability outcomes. Increased interpretation requests also influenced the plan's scope.

er engagement in those issues. Flexibility is therefore required to develop a specific project timeline to account for the projected time necessary to complete stakeholder consideration of the issues. NERC has also determined that in prior...

AI summary NERC acknowledges past delays in standard development due to inadequate regulatory documentation and underestimated stakeholder engagement. To address this, NERC now integrates regulatory coordination into project timelines, accounts for extended comment periods, and allocates time for detailed internal reviews. These adjustments aim to improve timeline accuracy for future projects.

B. NERC Stakeholders Input To support the preparation of the 2010 Development Plan, NERC sought stakeholder comment during two public comment periods, which took place from May 20 through July 6, 2009 and August 28 through September 28, 20...

AI summary NERC gathered stakeholder input for its 2010 Development Plan through two public comment periods and technical committee consultations. Over 30 organizations provided feedback, with a major theme being the need for a triage of reliability standards. NERC responded by adding Project 2010-06 to address results-based reliability standards.

A. Process for Development of Revised Pro Forma Delegation Agreement NERC and the Regional Entities have negotiated a revised pro forma Delegation Agreement, and individual Delegation Agreements based on the new pro forma agreement, in res...

AI summary NERC and Regional Entities updated the Delegation Agreement due to operational issues identified in the 2008-2009 ERO Assessment Report. Stakeholder input was sought, and FERC approved a one-year extension for the agreement's expiration. The revised agreement was finalized in 2010 after stakeholder feedback and board approvals.

A. Process for Development of Proposed Amendments NERC and the Regional Entities developed a set of proposed amendments to the NERC ROP in conjunction with their development of the revised pro forma Delegation Agreement. The origin of the...

AI summary NERC and Regional Entities developed proposed amendments to the NERC ROP, driven by issues in the Three-Year ERO Assessment Report. Revisions target compliance enforcement, certification, and monitoring processes. Stakeholder feedback was solicited, leading to revisions approved by the NERC Board of Trustees on May 12, 2010.

II. NOTICES AND COMMUNICATIONS Notices and communications with respect to this filing may be addressed to: Gerald W. Cauley President and Chief Executive Officer David N. Cook Vice President and General Counsel North American Electric Reli...

AI summary The section provides contact information for Gerald W. Cauley, David N. Cook, and Rebecca J. Michael of the North American Electric Reliability Corporation (NERC), including addresses, phone numbers, and email contacts for communication regarding the filing.

the proposed Standard Processes Manual. Improvements in the reliability standards development process that will result from the use of the processes described in the Standard Processes Manual include: - Improved control on timing for initi...

AI summary The proposed Standard Processes Manual aims to enhance the reliability standards development process through improved project prioritization, informal stakeholder feedback, quality reviews, and expedited timelines. Key changes include formal quality reviews, concurrent commenting, and clearer procedures for definitions and data analysis.

Collecting Informal Feedback on Preliminary Drafts 9 The Reliability Standard Development Plan is a three-year plan used by NERC to identify and prioritize the reliability standard development projects in the immediate three-year horizon....

AI summary NERC's Reliability Standard Development Plan allows drafting teams to collect informal feedback via conferences, webinars, or comment periods. Stakeholders requested this flexibility, authorized by the Standards Committee. ANSI mandates formal comment periods for final drafts but permits informal ones for preliminary stages, requiring summary responses to stakeholder input.

IV. SUMMARY OF DEVELOPMENT — STANDARD PROCESSES MANUAL The proposed Standard Processes Manual was initially posted for a 45-day industry review period that concluded on March 12, 2010. Stakeholders submitted 37 sets of comments, representi...

AI summary The Standard Processes Manual underwent a 45-day review period, receiving 37 sets of comments from 75 organizations. Modifications followed, leading to an 80.48% weighted segment approval in the initial ballot. A recirculation ballot was required due to negative ballots with comments. Stakeholders emphasized the need for formal comment periods, detailed processes, and typographical corrections, prompting revisions that included a 30-day formal comment period.

2. Development of NERC's 2010 Business Plan and Budget NERC prepared its 2010 Business Plan and Budget (and worked with the Regional Entities in the development of their business plans and budgets) through a rigorous process that provided...

AI summary NERC developed its 2010 Business Plan and Budget through a rigorous process involving stakeholder input and coordination with Regional Entities. The Finance and Audit Committee of the NERC Board approved the timeline in February 2009, with budget assumptions discussed in March 2009 meetings.

ll identify actions that NERC and the Regional Entities plan to take to improve NERC's and the Regional Entities' operations and to continue to enhance the reliable operation of the bulk power system. This performance assessment includes a...

AI summary The text outlines NERC's performance assessment and collaboration with eight Regional Entities to improve bulk power system reliability. It details the review of NERC's programs across North America, the preparation of draft statements by Regional Entities, and stakeholder engagement processes. The Commission's 2007 approval of delegation agreements is cited as a legal reference.

ndards do not undermine the more important goal of establishing a culture of compliance that encourages the open sharing of information learned from the Compliance Monitoring and Enforcement Programs. Regional Entities and NERC have not pr...

AI summary Stakeholders highlight delays in processing compliance violations, inconsistencies in enforcement, and inadequate NERC leadership. Issues include slow handling of alleged violations, inconsistent registration and audit processes, and calls for greater NERC oversight to standardize Regional Entity operations.

ess. NERC and the Regional Entities have developed substantial compliance program staffs, and a significant portion of their staffing and resources is devoted to compliance monitoring and enforcement. B. NERC Has Established Rules that Ass...

AI summary NERC has substantial compliance program resources and a governance structure ensuring independence and stakeholder representation through elected trustees and balanced committees. The Board of Trustees includes independent members elected by Member Representatives Committee, with committees composed to reflect U.S. and Canadian NEL proportions.

the basis of NEL (i) between the United States, Canadian and Mexican jurisdictions, (ii) among Regional Entities in the United States, and (iii) to LSEs or their designees within each Regional Entity. Each Regional Entity's approved statut...

AI summary NERC and Regional Entities have effectively managed business planning, budgeting, and financial reporting, achieving near 100% collection of statutory assessments. Stakeholders suggested improving transparency in cost increases, incorporating stakeholder input, and adopting multi-year planning for better resource forecasting.

APPENDIX A LIST OF SPECIFIC NERC ACTIONS IN RESPONSE TO STAKEHOLDER AND REGIONAL ENTITY COMMENTS AND RECOMMENDATIONS (Available on the NERC Website at http://www.nerc.com/fileUploads/File/Filings/3-year_Assessment_attachments.pdf )

AI summary Appendix A outlines NERC's specific actions addressing stakeholder and regional entity comments and recommendations, available on the NERC website via a provided link to a 3-year assessment attachment.

e repeated, although experience indicates that even the most complex standards converge within two or three postings. More narrowly defined projects can be completed with a single posting for comment. - Each standard is reviewed to determi...

AI summary The text outlines a structured process for developing reliability standards, emphasizing stakeholder engagement, field testing criteria, ballot procedures, and approval requirements. It details iterative commenting, ballot formation, and the use of weighted voting to ensure balanced stakeholder interests in standard approval.

, emails, memos, computer based training, etc.); - Indirect communications (e.g., posters, intranet, brochures, etc.); - Management support and reinforcement (e.g., presentations, meetings, etc.).

AI summary The text outlines communication methods for requirements dissemination, including direct (emails, memos), indirect (posters, intranet), and management support (presentations, meetings). These channels are emphasized for effective implementation and reinforcement of policies or procedures.

Stakeholder Participation The signatories anticipate that the NSUARB will require notification to stakeholders of the NERC application and the NPCC application and will provide opportunity for review and comment on the applications by stak...

AI summary The signatories anticipate NSUARB will notify stakeholders of NERC and NPCC applications, requiring stakeholder review and comment. They acknowledge responsibilities to respond to information requests and participate in discovery or hearings if ordered. Key topics include reliability standards, regional criteria, and cost considerations in Nova Scotia.

Stakeholder Participation The signatories anticipate that the NSUARB will require notification to stakeholders of the NERC application and the NPCC application and will provide opportunity for review and comment on the applications by stak...

AI summary The NSUARB may require stakeholder notification and review of NERC and NPCC applications, potentially including discovery and hearings. Signatories agree to comply with NSUARB timelines and respond to information requests, with NSPI focusing on Nova Scotia-specific cost considerations.

Alberta: The Alberta Transmission Regulation (Reg 288/2009 as amended) outlines the fratnework for Reliability Standards in Alberta. The North American Electric Reliability Corporation (NERC) Reliability Standards apply in Alberta to the e...

AI summary Alberta's Transmission Regulation incorporates NERC Reliability Standards, with AESO consulting stakeholders and recommending standards to the Alberta Commission. The 2007 Ministerial Order recognized NERC as ERO, and the 2009 Act formalized enforcement by the Alberta Commission and MSA, including penalties for violations.

2. Progress in Implementing Specific NERC Actions Identified in the Assessment Related to Each Area of Discussion Attachment 2 of the Assessment included summaries of stakeholder and Regional Entity comments and recommendations that were r...

AI summary NERC and Regional Entities collaborated to revise agreements and rules following stakeholder feedback, filing revised Delegation Agreements in 2010. Progress on implementing NERC actions across areas like reliability standards, compliance, and event analysis is detailed in Appendix A. NERC filed an informational report with FERC in 2011 and notified Canadian authorities.

A. Response to FERC Discussion of Opportunities for Improvement in Each Program Area In its September 16, 2010 Order, P 12, FERC stated: "The Commission believes that the July 6 Conference provided a useful, high level discussion of topics...

AI summary FERC plans to hold a second Commissioner-led technical conference in 2011 to discuss reliability monitoring, enforcement, compliance, and policy issues related to NERC Reliability Standards. The Commission emphasizes public dialogue to clarify expectations for standard development and will collaborate with NERC and international regulators on agenda development.

NERC Response to FERC's Other Actions – PP 12 and 13 NERC participated in the November 2010 and February 2011 high-level technical conferences along with a number of other stakeholders. NERC believes those conferences were extremely benefi...

AI summary NERC participated in technical conferences with FERC and stakeholders, advocating for annual high-level dialogues on bulk power system reliability and Canadian stakeholder inclusion. FERC's Order P 57 (2010) affirmed satisfaction with NERC's Rules of Procedure, noting their fairness and encouraging continued international recognition efforts.

eminate information regarding regional reliability standards. As such, the RSG will consider the practices identified by FERC in P 76 for use in the Regional Entities' standards development processes. NERC agrees with FERC's suggestion to...

AI summary NERC agrees with FERC's proposal to post proposed regional reliability standards for stakeholder comment while allowing final determinations through regional entities. NERC will follow its procedures for concurrent posting during development and a second posting after regional entity processes are complete, alongside submitting technical comments. A dedicated staff member was added in 2011 to support this activity.

Appendix 3A — Reliability Standards Development Procedure may be necessary or desirable.] As the result of amendments submitted and approved since the 3-Year ERO Performance Assessment Report was filed with the Commission, the current NERC...

AI summary The NERC Standard Processes Manual outlines procedures for gathering stakeholder feedback during reliability standards development, including mandatory 30-day informal comment periods and public summary responses. This follows amendments approved by the Commission in 2010, emphasizing transparency in the drafting process.

andard drafting team chair, allow NERC staff coordinator to provide a straw man draft reliability standard in advance of the first standard drafting team meeting to optimize effective team discussion. NERC staff has reached an understandin...

AI summary NERC aims to enhance reliability standard development by providing pre-meeting draft standards, engaging trade groups like APPA and NRECA to involve smaller entities, and improving stakeholder communication through subcommittees and forums. Efforts are ongoing since the 3-Year Assessment Report.

7. Enhance Stakeholder Communications. a. Continue to conduct open Webcasts to present and obtain feedback on proposed concepts; for example, to stakeholders as reliability standards are being developed. The conduct of webcasts, webinars,...

AI summary NERC aims to enhance stakeholder communication through webcasts, forums, and blogs, though progress is delayed due to website redesign. They also seek to expedite fill-in-the-blank reliability standards as part of their 2011–2013 development plan.

valuate and implement ways to make registered entities more aware of means currently available to them to obtain guidance on how to comply with reliability standards and how to demonstrate compliance. Compliance Application Notices, Compli...

AI summary The text outlines NERC's initiatives to enhance compliance awareness among registered entities through webinars, workshops, and quarterly updates with industry groups. It emphasizes collaboration with trade associations and expanding training programs to improve compliance with reliability standards.

K. Stakeholder Communications and Public Relations - 1. NERC Website functionality and ease of use. - a. NERC will continue to conduct regular surveys of the users of the NERC Website and develop tools to track and measure usability of its...

AI summary NERC is enhancing its website's usability through surveys and implementing improvements, including adding an 'Approvals' box with board and FERC approval dates, and improving access to information on mandatory standards' effective dates. The website coordinator role is being filled to drive these changes.

of the Alberta Commission and the Market Surveillance Administrator (MSA). Specified penalties for violations of Reliability Standards were adopted by the Alberta Commission, effective November 2010. The AESO established the AESO Reliabili...

AI summary Alberta's regulatory framework for reliability standards involves the Alberta Commission, Market Surveillance Administrator (MSA), and Alberta Electric System Operator (AESO). The AESO Reliability Committee (ARC) advises on reliability standards, with 69 NERC standards reviewed and amended for Alberta's system. A compliance monitoring program and revised work plan prioritize risk-based implementation.

On receipt of a report the BCUC must make it available to the public in a reasonable manner and for a reasonable period of time and consider any comments it receives in response. After this period of public notice the BCUC must adopt the R...

AI summary The BCUC must adopt Reliability Standards after public consultation, unless a hearing determines it's not in the public interest. BC Hydro reviews standards post-NERC approval to avoid rescission risks. NERC and WECC standards were approved in 2009 with compliance deadlines, though some dates have been adjusted based on stakeholder input.

Question Please clarify what is meant by the term, "appropriate parties." Moreover, who within the Interconnection hierarchy deems parties to be appropriate?

AI summary The question seeks clarification on the definition of 'appropriate parties' in regulatory proceedings and identifies which entity within the Interconnection hierarchy determines this designation. It focuses on procedural governance and stakeholder inclusion criteria.

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AI summary The text appears to be a partially corrupted or encoded table, likely from a regulatory proceeding, discussing information related to a matrix of violation risk factors. It contains fragmented text and may relate to topics such as information disclosure, regulatory compliance, and stakeholder engagement.