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Project 2007-23
Violation Severity Levels
Related Files
Status
In August 2010, the
VSL drafting team posted for a 45-day comment
period its “Filing 2 VSLs,” the second of two sets of Violation Severity
Levels (VSLs) requiring revision based on directives in a June 19, 2008
FERC Order and a November 20, 2008 FERC Order. The VSL drafting team
reviewed these comments, made corresponding changes to the VSLs, and
posted a consideration of comments report in September 2010.
In September 2010, the VSL drafting
team conducted a 30-day review and 10-day nonbinding poll of the Filing
2 VSLs that ended on November 6, 2010. Of those who registered to
participate, 79% provided an opinion, and support ranged from 60% on the
BAL and INT VSLs to 83% on PRC and TPL standards. Based on the comments
received during the nonbinding poll, the drafting team and NERC staff
made final changes to the VSLs to address outstanding issues (especially
for the BAL and INT standards). These changes were approved by the NERC
Board of Trustees on November 19, 2010 and filed with FERC on December
1, 2010. A consideration of comments form, a set of clean Filing 2 VSLs,
and a set of Filing 2 VSLs redlined against the latest FERC-approved
versions are included below.
In February 2011, the VSL drafting team
also posted supplemental revisions to 14 sets of VSLs from the original
VSL filing (filed with FERC on March 5, 2010) for a 30-day comment
period. A non-binding poll was held during the final ten days of the
comment period. Of those who registered to participate, 78% provided an
opinion; 72% of those who provided an opinion indicated support for the
VSLs that were proposed. The drafting team has revised certain VSLs
based on comments, and the revised VSLs have been posted on the project
page. The changes were approved by the NERC Board of Trustees on March
10, 2011 and filed with FERC on March 21, 2011.
Purpose/Industry Need
The
FERC, in the Order on Compliance Filing dated June 7, 2007 (Docket
#RR06-1-007), directed NERC to replace the "Levels of Non-compliance"
(in the 83 standards it approved) with "Violation Severity Levels”
(VSLs). In compliance with the directives in paragraphs 13, 41, 42, and
56 of FERC’s June 19, 2008 Order (Docket #RR08-4-000), and paragraph 30
in the November 20, 2008 Order (Docket #RR08-4-001 and #RR08-4-002),
NERC was directed to make further changes to the VSLs to ensure
consistency with
FERC’s and NERC’s
VSL assignment guidelines.
NERC, as the ERO, is required to comply
with FERC directives. By
replacing the existing ‘Levels of Non-compliance’ with ‘Violation
Severity Levels’ the ERO’s Sanctions Guidelines can be used as designed.
The Sanctions Guidelines use ‘Violation Severity Levels’ as an element
in determining the size of a sanction.
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