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  • MRO's Vision is to:
    • "maintain and improve the quality of life through a highly reliable regional Bulk Power System."
  • Our purpose is to strive to assure each bulk power system owner and operator within our region is a Highly Effective Reliability Organization, or HERO.
About MROReliability4/1/2017Jessica R. Mitchell
  • MRO's responsibilities include:
    • Assessing compliance with mandatory electric Reliability Standards for those that own, operate or use the interconnected, international bulk power system in our region
    • Conducting assessments of the reliability of the international power grid's ability to meet power demand
    • Performing technical analysis of regional system distrubances and share lessons learned
    • Assisting industry with the identification of risks
About MROReliability4/1/2017Jessica R. Mitchell
  • Many entities play a role in ensuring the reliability of the international bulk power system.
    • System planners, generation and transmission operators, reliability coordinators and/or balancing authorities, and regional reliability organizations, like MRO, monitor for compliance with standards.
    • Some other organizations that play a reliability role continuously monitor the transmission and generation network over wide geographic areas to ensure reliable and efficient operations.
    • On a local level, power generation and transmission companies operate their plants and lines and monitor their equipment to ensure that it is operating safely and reliably.
About MROReliability4/1/2017Jessica R. Mitchell
  • MRO is a Delaware non-stock, nonprofit corporation and is organized under the general corporation law of the State of Delaware.
  • Funding is provided by those bulk power system operators and owners who provide electricity to load. 
  • The details of the funding mechanism for MRO are described in Section 9 (Funding) of the Regional Delegation Agreement signed between MRO and NERC.
About MROGovernance4/1/2017Jessica R. Mitchell
  • Nominated by the board and elected by all members, Independent Directors have relevant senior management expertise and experience in the reliable operation of the bulk power system in North America.
  • An Independent Director is NOT:
    • An officer or employee of MRO
    • A member, director, officer or employee of a member of MRO
    • A director, officer, or employee of any registered entity on the NERC registry
    • Reasonably perceived as having a direct financial interest in the outcome of a decision by the board of directors
  • An Independent Director:
    • Does not have any other relationship that would interfere with the exercise of independent judgment in carrying out the responsibilities of a director
    • Meets any additional requirements of independence established by the board of directors​
About MROLeadership4/1/2017Jessica R. Mitchell
  • All directors serve three-year, staggered terms.
    • Any director elected by an industry sector may be removed at any time by the affirmative vote of two-thirds (2/3) of the members of particular industry sector.
    • An Independent Director may be removed by the affirmative vote of two-thirds of the remaining directors.
    • Any director may be removed by the board of directors for non-attendance of three consecutive board meetings.
About MROLeadership4/1/2017Jessica R. Mitchell
  • The officers of MRO currently include a President and CEO, a corporate secretary, an assistant corporate secretary, and a treasurer. 
  • The same individual may hold any number of offices, except that of President and CEO.
About MROLeadership4/1/2017Jessica R. Mitchell
  • The bulk power system is the electricity power generation facilities combined with the high-voltage transmission system, which together create and transport electricity around North America.
    • Put another way, the bulk power system is the continent’s electricity system except for the local electricity facilities you see in your town or city.
  • Neither NERC nor MRO deliver or regulate power to homes and businesses. That service generally is provided by a local distribution utility.
    • Local distribution delivery may be under the jurisdiction of state, provincial or local utility regulatory agencies.
About MROReliability4/1/2017Jessica R. Mitchell
  • Certain Reliability Standards include requirements related to retention of associated data, including what specific data must be retained and the retention period.
  • If such data retention requirements have been defined, they are generally documented under the "Compliance" section of the Reliability Standard.
Compliance MonitoringData Retention3/1/2019Desiree A. Sawyer
  • Entities are expected to perform a compliance self-assessment to determine if they have violated any Standard Requirements as a result of, or during, an event.
    • Entities are also encouraged to share those assessments with MRO.
  • The Risk Assessment and Mitigation department reviews all events from a compliance perspective, and is always open to discussing an event, compliance assessments, and compliance evaluations of events.
  • In certain cases, MRO will contact an entity and request a copy of the entity's compliance self-assessment, or issue a self certification related to the event in order to evaluate the entity's compliance during the event.
Compliance MonitoringEvents3/1/2019Dana Klem
  • You can call your RAM representative at MRO for clarification.
  • You can self-report.
  • If you are a self-log participant you can self-log.
Risk Assessment and MitigationOther3/1/2019Dana Klem
  • Any time an entity makes a change that would modify any of the Required Information, outlined in Section 4.0 of the Rules of Procedure Appendix 4d, then a Material Change Report must be submitted.
Compliance MonitoringTFEs3/1/2019Desiree A. Sawyer
  • Registered entities are no longer required to submit quarterly and/or annual reports.
  • All changes to TFEs are now communicated through a Material Change Report.
Compliance MonitoringTFEs1/3/2019Desiree A. Sawyer
  • Each user will need to be set up in the system with a username, password, and digital certificate. The first user for each entity is set up by the Region as a registered entity Administrator/Security Officer ("Administrator") user. This user may create additional users.
  • Each registered entity will receive two certificates which will be paid for by MRO; however, the registered entity may use other certificates they own and may purchase additional certificates.
Compliance MonitoringwebCDMS4/1/2018Cynthia Kneisl
  • All webCDMS communications will be sent to the Primary Compliance Contact, Secondary Compliance Contact, and the Compliance Officer-Primary. If you would like to receive these communications directly from webCDMS, you must be set up as one of the contacts listed above. You can then set up an auto forward in your email system as appropriate.
Compliance MonitoringwebCDMS2/1/2017Cynthia Kneisl
  • Yes, you can. MRO will purchase two digital certificates per registered entity, but each registered entity may purchase additional certificates, if needed. 
  • Additional digital certificates must be ordered and purchased directly from OATI at the registered entity's own expense.
Compliance MonitoringwebCDMS2/1/2017Cynthia Kneisl
  • If a webCDMS user currently utilizes a digital certificate for another OATI application, that existing certificate may be used and a second certificate for webCDMS is not needed.
Compliance MonitoringwebCDMS2/1/2017Cynthia Kneisl
  • Yes, but this is a feature each user has to set up individually.
  • Please see Entity User Account Consolidation Quick Start Guide.
Compliance MonitoringwebCDMS2/1/2017Cynthia Kneisl
  • No. A digital certificate may be used in multiple regions.
  • However, a certificate can only be used for a single user within each region.
Compliance MonitoringwebCDMS2/1/2017Cynthia Kneisl
  • Contact OATI directly at 763-201-2000.
Compliance MonitoringwebCDMS2/1/2017Cynthia Kneisl
  • Yes. Digital certificates are transferable. If a user is no longer using the certificate, his or her certificate can be reissued to a new user.
  • Additionally, if a user needs to use different hardware, either permanently or temporarily, the certificate may be reinstalled on the new computer or "loaner" computer as necessary.
Compliance MonitoringwebCDMS2/1/2017Cynthia Kneisl
  • Digital certificates expire after two years.
  • Digital certificates can also be revoked at any time by the Entity's Security Officer and may be reissued to another user.
Compliance MonitoringwebCDMS2/1/2017Cynthia Kneisl
  • webCDMS works with Internet Explorer 7 and higher.
Compliance MonitoringwebCDMS2/1/2017Jennifer L. Matz
  • No, webCDMS does not require Java to be installed in order to access the system.
Compliance MonitoringwebCDMS2/1/2017Jennifer L. Matz
  • "Reliability" simply means our ability to count on power to be supplied where it is needed when it is needed.
  • MRO's regional standard glossary of terms can be found on the MRO standards approved page.
DefinitionsReliability4/1/2017Jessica R. Mitchell
  • "Adequacy" refers to the ability of the electric system to supply customers with power at all times, including periods of high demand.
  • This determination takes into account:
    • Scheduled and reasonably expected unscheduled outages of equipment in the system
    • Availability of fuel resources
    • Sufficient generation equipment and power lines
DefinitionsAdequacy4/1/2017Jessica R. Mitchell
  • MRO encourages entities to save, but not submit their mitigation plans until the MRO Risk Assessment and Mitigation department has had the chance to review the plan.
  • If a mitigation plan is submitted, it cannot be altered, and even a minor change will necessitate MRO "Rejecting" the mitigation plan.
  • By collaborating on the mitigation plan with MRO prior to submitting, the entity can be assured that their submitted mitigation plan will be "Accepted".
MitigationMitigation Plans3/1/2019Dana Klem
  • MRO encourages entities to begin mitigating activities immediately, and to notify MRO of the mitigating activities as soon as possible (the self-report record in CDMS allows entities to enter these, for example).
  • Contact the MRO Risk Assessment and Mitigation department at any time to discuss mitigating activities and/or the status of a mitigation plan at
MitigationMitigation Plans3/1/2019Dana Klem
  • Entities should only list activities that they plan to complete as milestones of a mitigation plan.
  • In order to allow time for MRO to review evidence of the mitigation completion, it's advisable to enter a mitigation plan completion date that is 30 days after the last milestone date.
MitigationMitigation Plans3/1/2019Dana Klem
  • Entities can submit a request for an extension to a milestone, or a mitigation plan due date.
    • However, MRO expects to understand what extenuating circumstances warrant the extension, prior to granting the request.
  • The request must be made within 5 business days of the due date.
  • If an entity does not complete mitigation by the mitigation plan due date, the result is another (new) violation of the Standard Requirement.
MitigationMitigation Plans3/1/2019Dana Klem
  • Event Analysis is an "after the fact" review of an outage or disturbance on the bulk power system to determine the exact causes and what, if anything, can be done to prevent similar disturbances in the future.
Reliability PerformanceEvent Analysis3/1/2019Lisa D. Stellmaker
  • The event analysis is prepared by the entities involved and reviewed by MRO and NERC.
Reliability PerformanceEvent Analysis3/1/2019Lisa D. Stellmaker
  • The goal is to prevent a large cascading power outage by identifying causes and applying lessons learned from the smaller events.
Reliability PerformanceEvent Analysis3/1/2019Lisa D. Stellmaker
  • The results of the analysis are turned into lessons learned and shared with other entities responsible for the reliability of the bulk power system via posting on the NERC website.
Reliability PerformanceEvent Analysis3/1/2019Lisa D. Stellmaker
  • Every event is different and requires thoughtful review and analysis to gather facts and determine the sequence of what happened and why. It may take several weeks or several months, depending on the complexity of the event.
Reliability PerformanceEvent Analysis3/1/2019Lisa D. Stellmaker
  • Causes and causal factors are identified and trended to identify potential reliability risks, to support changes to Standards, provide feedback to equipment manufacturers, or identify possible training or maintenance issues.
Reliability PerformanceEvent Analysis3/1/2019Lisa D. Stellmaker
  • The facts and circumstances of each issue are taken into consideration by the MRO Risk Assessment and Mitigation department in determining risk. Facility size, location, voltage, function, and duration of the issue are all considered.
  • The MRO Risk Assessment and Mitigation department is always open to additional facts and circumstances that the entity would like MRO to consider when determining the risk.
Risk Assessment and MitigationRisk Determinations3/1/2019Dana Klem
  • The board of directors consists of 19 board members.
    • 17 board members are elected by the industry sectors as follows:
      • 3 directors from the Transmission System Operators Sector
      • 2 directors from the Generators and Power Marketers Sector
      • 5 directors from the Investor Owned Utilities Sector 
        • 2 directors must be from utilities with less than 3,000 megawatts of end-use load 
        • 3 directors must be from utilities with 3,000 megawatts or greater of end-use load
      • 2 directors from the Cooperative Sector
      • 2 directors from the Municipal Utilities Sector
      • 1 director from the Federal Power Marketing Agencies
      • 2 directors from the Canadian Utilities Sector provided that both directors are not residents of the same Canadian province
    • 2 board members are Independent Directors nominated by the board and elected by the members.
      • Independent Directors have relevant senior management expertise and experience in the relible operation of the bulk power system in North America
About MROLeadership4/1/2017Jessica R. Mitchell
  • Those with contact roles may or may not have access to webCDMS. MRO requests these contact roles for communication purposes. The Primary Compliance Contact ("PCC") will generally be designated as the Registered Entity Administrator, a user access role. 
    • Compliance Contact - (Primary) - Primary point of contact, who receives notifications/e-mails upon actions in webCDMS.
    • Compliance Contact - (Secondary) - Second point of contact (optional role).
    • Authorizing Officer - Authorized individual for sign-off to Self-Certifications and Mitigation Plan Completion.
      • This role may or may not also be designated as a webCDMS user.
    • Authorizing Officer - (Alternate) - Alternate for primary Authorized Officer (optional role).
    • Registration Contact - Point of contact for MRO regarding registration issues, and other official correspondence from MRO regarding registration.
    • CEO (or equivalent) - Final point of contact for MRO in cases of high priority notices, such as the final step of Attachment 1, "Process for Non-Submittal of Requested Data" of the Compliance Monitoring Enforcement Program.
  • User access roles allow access to webCDMS. Depending on the rights granted by the Registered Entity Administrator, a user may be able to perform different functions.
  • The users of webCDMS may or may not be associated with a specific contact role.
  • The Registered Entity may choose which permissions they wish to allocate to each user.
    • Registered Entity Administrator - This user has all possible Registered Entity webCDMS permissions.
      • This user can view, save, and submit compliance data and is also responsible for adding and maintaining user accounts and entity information under the Administration menu.
    • Registered Entity User - This user can view, save, and submit data, but cannot enter or update user or entity-specific information.
    • Registered Entity Read Only - This user has a login to the system and can view data, but cannot enter or edit data.
Compliance MonitoringwebCDMS2/1/2019Dana Klem
  • MRO takes a risk-based approach to maintaining the reliability and security of the regional bulk power system within the Eastern Interconnection. We do this in consultation with industry and through governmental engagement across the region with the support of NERC.
  • MRO’s approach to regulation is to assure risks are being managed by the industry and to ensure industry compliance with mandatory standards. Articulating our philosophy provides clarity, improved efficiency and effectiveness, and the reasonable assurance that the bulk power system in our region will be operated reliably.
About MROReliability4/1/2017Jessica R. Mitchell
  • MRO is governed by a board of directors consisting of both independent and stakeholder directors (commonly known as a hybrid board of directors) that oversee all of MRO's activities; such as:
    • Establish and oversee all organizational groups
    • Oversee the accomplishment of all work directed by NERC or any governmental entity
    • Enforce member data and information requirements and related confidentiality requirements
    • Establish and approve an annual budget
    • Represent MRO in legal and regulatory proceedings
    • Hire the president and CEO.
  • For more on board governance and leadership, visit the About MRO page on our website.
About MROLeadership4/1/2017Jessica R. Mitchell
  • All directors have the right to reimbursement by MRO for reasonable travel expenses to board meetings or when specifically selected to represent MRO at a business meeting.
  • The board of directors sets reasonable compensation for the service provided by Independent Directors; directors elected by an industry sector do not receive compensation.
About MROGovernance4/1/2017Jessica R. Mitchell
  • Section 5.6 of the Compliance Monitoring and Enforcement Program (CMEP) governs the settlement process and provides that settlement negotiations may occur at any time including prior to the issuance of a Notice of Alleged Violation and Penalty or Sanction until a Notice of Penalty is filed with FERC or other Applicable Government Authority.
  • To request settlement, please select the settlement request option under the Enforcement tab within the webCDMS application, or contact Sara Patrick at 651-855-1708.
EnforcementViolations3/1/2017Janice V. Anderson
About MROGovernance4/1/2017Jessica R. Mitchell
  • MRO strives to make fair, accurate and reasonable enforcement decisions which reflect the risk posed by an individual violation – the greater the risk, the greater the penalty and scrutiny of review and approval
  • Sanctioning of confirmed violations is determined pursuant to the NERC Sanction Guidelines.
  • While MRO considers the Violation Risk Factors and Violation Severity Levels as the initial resource in determining the proposed penalty range, there are numerous mitigating factors described in the NERC Sanction Guidelines.
    • Examples of mitigating factors include an effective and well-funded compliance and ethics program, self-reported violations, and if the level of cooperation is above what is normally expected of a registered entity.
  • Additionally, MRO considers acceptance of responsibility to be a key indicator of a strong commitment to reliability and worthy of consideration in our enforcement determinations.
EnforcementPenalties11/30/2017Janice V. Anderson
  • Pursuant to §5.0 of the Compliance Monitoring and Enforcement Program (CMEP), MRO is authorized to utilize alternatives to the enforcement process where it is deemed more appropriate, efficient, and desirable to do so.
  • MRO, the other Regional Entities, and NERC have implemented a program to expand the exercise of discretion by identifying minimal risk noncompliance which would be recorded and mitigated without triggering an enforcement action.
  • Noncompliance that is resolved without an enforcement action is a Compliance Exception.
Risk Assessment and MitigationRisk Determinations3/1/2019Dana Klem
MembershipExisting Members4/1/2017Jessica R. Mitchell
MembershipExisting Members4/1/2017Jessica R. Mitchell
  • To change information on your company's membership, please fill out the Membership Change Form.
  • A member may change its industry sector designation once each calendar year, by providing notice to the president and CEO.
MembershipExisting Members4/1/2017Jessica R. Mitchell
  • Membership with MRO is separate and not related to NERC registration in any way. Membership is voluntary, free of charge, and provides several benefits.
  • NERC registration, however, is mandatory. All Bulk Electric System owners, operators and users are required to register with NERC.
MembershipOther4/1/2017Jessica R. Mitchell
  • Members' primary obligations are:
    • To elect the board of directors
    • Participate in the advancement of regional reliability by providing expertise to effectively complete regional initiatives
    • Ensure that the organization's functions have adequate resources
MembershipOther4/1/2017Jessica R. Mitchell
  • Members hold an annual meeting each calendar year in December, or when specified by the board of directors, in order to review the proposed budget and operations.
    • Adjunct members may attend this meeting.
  • The failure to hold an annual meeting will not affect the validity of a corporate action.
MembershipMeetings4/1/2017Jessica R. Mitchell
  • A quorum for a meeting of members is a majority of the industry sector votes entitled to vote at the meeting.
  • A quorum for a meeting of an industry sector is a majority of the members of that industry sector present or voting electronically on matters before the meeting.
  • A quorum is necessary for the transaction of business at a meeting of members.
    • If a quorum is not present, a meeting may be adjourned from time to time for that reason by the industry sectors or members then represented or present.
MembershipMeetings4/1/2017Jessica R. Mitchell
  • Members vote by industry sector, with each industry sector entitled to the same number of votes as it has directors on the board.
    • Within an industry sector, each member has one vote. If a quorum is present, the affirmative vote of the majority of the members within the industry sector present and entitled to vote, is the vote of that industry sector.
    • Abstentions are not counted and do not impact the voting tabulation.
    • Adjunct Members do not vote.
MembershipMeetings4/1/2017Jessica R. Mitchell
  • “Member” means any entity eligible to belong to an industry sector.
  • “Adjunct Member” means an entity that:
    • Is not eligible to belong to an Industry Sector
    • Has a material interest in reliability issues in the MRO Region
    • Becomes an Adjunct Member of the Corporation.
MembershipOther4/1/2017Jessica R. Mitchell
  • Each Affiliate of a Member or Adjunct Member may separately be a Member or Adjunct Member, respectively.
  • “Affiliate” means with respect to any entity, any other entity that, directly or indirectly, through one or more intermediaries, controls, or is controlled by, or is under common control with, such entity, as determined in the sole discretion of MRO Board of Directors.
MembershipOther4/1/2017Jessica R. Mitchell
  • Any agency with regulatory responsibility over rates, terms, or conditions of electric service, or the planning, siting, construction, or operation of electric facilities in the region is encouraged to participate in MRO as an adjunct member.
MembershipOther4/1/2017Jessica R. Mitchell
  • There are no annual dues for any members of MRO.
MembershipDues4/1/2017Jessica R. Mitchell
  • You can withdraw from membership by providing written notice to the President and CEO of MRO. Specify a date, not before 30 days of the effective date.
MembershipWithdrawal4/1/2017Jessica R. Mitchell
  • In general, an entity should try to incorporate some type of evidence for each milestone that shows the milestone was completed, and completed by the milestone date.
  • Contact the the MRO Risk Assessment and Mitigation department if you want to discuss what type or amount of evidence is adequate at
MitigationMitigation Plans3/1/2019Dana Klem
  • Yes, Entities registered as a Distribution Provider (DP), Generator Owner (GO), or Transmission Owner (TO), must submit a response via webCDMS every quarter no later than 60 days after the end of the previous quarter.
  • The process to indicate that the Entity does not own a Transmission Protection System is conducted through the Attestation Form and checklist.
Reliability PerformanceProtection System Misoperations Reporting3/1/2019Lisa D. Stellmaker
  • Yes, the Misoperations Reporting Instruction Document is located in webCDMS.
  • To access the file:
    • Log into webCDMS
    • Select the Compliance tab
    • Select Document Download
    • Open the file titled "webCDMS Misoperation Reporting Instructions"
Reliability PerformanceProtection System Misoperations Reporting3/1/2019Lisa D. Stellmaker
  • RAPA stands for the Reliability Assessment Performance Analysis.
    • The acronym is used to reference a Program Area/Department at NERC and is also the name of an Electric Reliability Organization (ERO) working group that works with NERC in this program area.
  • Please refer to the NERC website for additional information:
Reliability PerformanceProtection System Misoperations Reporting3/1/2019Lisa D. Stellmaker
  • Yes, Entities will need to complete a mis-operation form for each mis-operation that occurs; however, Entities will only need to complete one Attestation Form and one Checklist for each quarter.
Reliability PerformanceProtection System Misoperations Reporting3/1/2019Lisa D. Stellmaker
  • Entities are responsible for all requirements that match their registered function.
  • NERC has provided the Violation Risk Factor/Applicability Matrix (VRF Matrix) which lists all regulatory-approved requirements and associated functions.
Registration and CertificationVRF Matrix4/1/2018Cynthia Kneisl
  • MRO applies the NERC Rules of Procedure, Appendix 5B, NERC Statement of Compliance Registry Criteria to determine which entities are placed on the NERC Compliance Registry (NCR).
  • Registration is based upon ownership of BES assets and/or functions provided by an entity towards the operation and planning of the BPS.
Registration and CertificationMRO Registered Entities4/1/2018Cynthia Kneisl
  • "Bulk Electric System" means, as defined by the Regional Entity, the electrical generation resources, transmission lines, interconnections with Neighboring systems, and associated equipment, generally operated at voltages of 100kV or higher. Radial transmission facilities serving only load with one transmission source are generally not included in this definition.
  • "bulk power system" means, depending on the context: Facilities and control systems necessary for operating an interconnected electric energy supply and transmission network (or any portion thereof), and electric energy from generating facilities needed to maintain transmission system reliability. The tern does not include facilities used in the local distribution of electric energy.

When should BPS or BES be used?

  • Both BES and BPS are acceptable to use in light of NERC's scope of authirity in the Energy Policy Act. BPS is the term to use when generally speaking about the interconnected network or power grid. BES is a FERC-approved term in the NERC Glossary of Terms Used in NERC Reliability Standards. In Order 693, FERC found that BES was acceptable and should be used in the context of applicability of Reliability Standards or NERC's monitoring and enforcement of compliance with the standards. BES is the portion of the BPS to which standards apply.
  • The term bulk power system comes from the Energy Policy Act of 2005 and is set forth in Section 215 of the Federal Power Act. It states that: (1) the term bulk power system means:
    • facilities and control systems necessary for operating an interconnected electric energy transmission network (or any portion thereof), and
    • electric energy from generation facilities needed to maintain transmission system reliability.
DefinitionsBulk Electric System4/1/2017Jessica R. Mitchell
  • Registered Entities are expected to be compliant at the time of registration. If not, the entity must comply with a Remedial Action Directive or have a mitigation plan in place.
Registration and CertificationOther3/1/2018Cynthia Kneisl
  • The facts and circumstances of each issue are taken into consideration by the MRO Risk Assessment and Mitigation department in determining risk. Facility size, location, voltage, function, and duration of the issue are all considered.
  • The MRO Risk Assessment and Mitigation department is always open to additional facts and circumstances that the entity would like MRO to consider when determining the risk, but it is important that the MRO Risk Assessment and Mitigation department understands these facts and circumstances in order to quantify the risk of a particular issue.
Risk Assessment and MitigationRisk Determinations3/1/2019Dana Klem
  • Section 215 of the Federal Power Act requires NERC to develop mandatory and enforceable reliability standards for all owners, operators, and users of the North American Bulk Power System (BPS). NERC uses an American National Standards Institute (“ANSI”) accredited process to ensure the standards development process is open to all who are directly and materially affected by the reliability of the BPS. NERC Reliability Standards define the reliability requirements for planning and operating the BPS. The requirements also state the specific obligations of the owners, operators, and users of the BPS.
  • For more information, please visit the NERC Standards Process Manual on the NERC Standards web page.


Standards and RulesNERC Standards3/1/2018Cynthia Kneisl
  • All persons who are directly and materially affected by the reliability of the North American bulk power systems are permitted to request a formal interpretation of a standard.
  • If a question regarding the interpretation of a standard was sent to MRO, it would be forwarded to NERC for formal interpretation.
    • Interpretation requests should explain the specific circumstances surrounding the request and what clarifications are required as applied to those circumstances.
  • The detailed process steps can be found on the NERC website.
Standards and RulesInterpretations3/1/2018Cynthia Kneisl
  • MRO follows the definitions posted in the NERC glossary of terms used in reliability standards. NERC's definition of terms may be found here.
Standards and RulesTerms4/1/2018Cynthia Kneisl
  • While MRO does not currently have any Regional Reliability Standards, MRO maintains a Standards Process should the need for a Regional Reliability Standard ever arise.
Standards and RulesRegional Standards3/1/2018Cynthia Kneisl
  • Here are some of the benefits of membership with MRO:
    • Contribute to the development of regional reliability policies
    • Participate on MRO organizational groups and subgroups
    • Vote on corporate matters, like board leadership
    • Participate in North American and Interconnection-wide technical assessments and policy development
    • Develop a network of industry peers
    • Associate with a regional organization dedicated to improving reliability for the benefit of all end users
  • Membership with MRO is not in any way associated with or connected to NERC Registration.
MembershipOther4/1/2017Jessica R. Mitchell
  • The enforcement process includes multiple processing methods scaled to the risk posed by an individual violation.  Below is a summary of the enforcement processing methods currently utilized by MRO:
    • Find, Fix Track and Record (FFT) includes minimal risk and a "limited pool" of moderate risk issues.  Publicly posted in a spreadsheet format on NERC website each month. 
      • NERC and FERC review a sample within 60 days of posting.
    • Spreadsheet Notice of Penalty (SNOP) includes minimal risk and moderate risk violations.  Minimal risk violations resolved through SNOP process generally indicate systemic issues requiring a more formal enforcement action. 
      • Filed with FERC in a spreadsheet format requiring FERC review and order in 30 days.
    • Full Notice of Penalty (Full NOP) includes significant risk and other complex violations as MRO deems appropriate.  Full NOP requires a more comprehensive record and includes a full Disposition Document detailing the violation, mitigation, and penalty considerations. 
      • Full NOP are reviewed and approved by the NERC Board of Trustees Compliance Committee prior to filing with FERC.  FERC has 30 days to review and issue an order.
    • Dismissal includes those instances where a Notice of Possible Violation has been issued and MRO has subsequently determined that there is an insufficient basis to allege a violation.  While not limited to these instances, dismissal may result where additional evidence is provided demonstrating compliance, a Possible Violation is determined to be a duplicate of another Possible Violation currently being processed, or where a Possible Violation is transferred to another Region for a coordinated mitigation and enforcement process.
EnforcementOther3/1/2017Janice V. Anderson
EnforcementOther3/1/2017Janice V. Anderson
  • MRO has two types of member: Members and Adjunct Members. Adjunct Members have limited rights.
  • To apply for membership, simply complete the Membership Application and submit it to MRO. The president and CEO will review the membership application and may request demonstration by the applicant that it qualifies for membership in a particular industry sector or as an adjunct member.
  • Any dispute with respect to a member's qualifications for a particular sector will be resolved by the board of directors.
MembershipOther4/1/2017Jessica R. Mitchell
  • Assurance that the reporting entity understands the issue and managed it well
  • Reduction or elimination of SME discussions or additional requests for evidence
  • Reduction in processing time
  • Focus on mitigating activities
Risk Assessment and MitigationSelf-Reports3/1/2019Dana Klem
  • Identification of the Standard and Requirement (including version) of the noncompliance
  • Description of the noncompliance, containing sufficient information for MRO to understand what happened without the need to request an SME interview
  • Root cause of the issue
  • Description of mitigating activities
  • The Registered Entity's assessment of risk arising from the noncompliance
Risk Assessment and MitigationSelf-Reports3/19/2020Dana Klem

A description of the affected BES Cyber System(s), Transmission Facility or equipment, impacted personnel or department, etc.

  • BES Cyber System(s) example:
    • What is the impact rating?
    • What is the type of system (e.g., control center, substation, or generation facility)?
    • Does the affected system(s) have External Routable Connectivity?
    • Is the affected device(s) a BCA, EACMS, PCA, PACS?
  • Relay Maintenance example:
    • What is the operating voltage of the protected equipment?
    • Is the facility or affected equipment part of an IROL, Cranking Path, or Remedial Action Scheme?
    • When was the last successful relay maintenance testing performed?
    • Does the relay have internal diagnosis or alarming capability?
    • Were multiple assets (or persons, relays, transmission lines, generating units, etc.) affected? If so, how many?
    • Are there similar assets which were not affected? If so, how many and why not?
    • Narrative describing what went wrong and how it was discovered. Be sure to take credit if the noncompliance was discovered by an internal control!
    • Dates:
      • When the noncompliance started
      • When it was discovered
      • When the noncompliance stopped
      • When mitigation was complete (may be different from when the noncompliance stopped due to mitigation to prevent reoccurrence)
    • If the entity is registered in multiple regions, what other regions were affected?
Risk Assessment and MitigationSelf-Reports3/19/2020Dana Klem

The description of the root cause should not simply be a restatement of the noncompliance:

  1. The cause is often a process deficiency or a failure to implement a process. A not-so-good example might be "…failed to remove access within the time mandated by CIP-xxx-xx, Ry.z."
  2. A better example might be "The employee's manager failed to submit a Personnel Change Form because the manager was new to the job and had not yet completed scheduled training related to personnel changes;" or "The manager was called away to deal with an urgent family matter."
  3. Supplemental information, in addition to the brief identification of the root cause, can be helpful.
Risk Assessment and MitigationSelf-Reports3/19/2020Dana Klem

​The root cause must be addressed by at least one of the mitigation steps.

Include planned or actual completion dates for each mitigation step that stopped the noncompliance.

Was an "extent of condition" investigation performed (may not be necessary, especially if the noncompliance was caught by an internal control)?

If additional instances were found, were they mitigated? Include dates.

Were additional mitigation steps taken to prevent reoccurrence?

  • If so, describe them.
  • Include planned or actual completion dates for each step.

Formal mitigation plans are not required for minimal risk noncompliances.

  • If a formal mitigation plan is created in webCDMS, the process must be completed in webCDMS.
Risk Assessment and MitigationSelf-Reports3/19/2020Dana Klem

​The entity provides a statement of its assessment of the risk resulting from the noncompliance. MRO may contact the Registered Entity for clarification.

Identify any actual impact that occurred as a result of the noncompliance (e.g., "Two persons entered the control center without proper authorization" or "The facility was operated above its maximum seasonal rating").

Internal controls can be risk reducers; take credit for any internal controls that limited the duration or the effects of the noncompliance.

If there are characteristics or circumstances that reduce risk of the issue, describe them (e.g., "No Interactive Remote Access is possible to the affected BES Cyber System." or "The System Operator had completed all of the required training hours, but had not formally renewed her NERC Certification").

Risk Assessment and MitigationSelf-Reports3/19/2020Dana Klem