3353 Peachtree Road NE Suite 600, North Tower Atlanta, GA 30326 404-446-2560 | www.nerc.com April 9, 2013 Ms. Carol Chinn, Chair NERC Member Representatives Committee Re: Policy Input to NERC Board of Trustees Dear Carol: I want to thank you and Vice Chair John Anderson for your coordination and collaboration to improve the overall communication, effectiveness and efficiency among the Board, its committees and the MRC. To further support these efforts, and consistent with our letter of March 15 to MRC members and Trustees, I would like to invite the MRC to provide policy input on three issues of particular interest to the Board as we prepare for our meetings on May 8-9, 2013 in Boston, MA. The full agenda packages for the Board, Board committees and MRC meetings will not be available until April 24, but I have enclosed additional background information with this request that will provide the MRC with some detail to formulate input from their respective sectors on each of the following topics: Reliability Assurance Initiative (RAI) – In February 2013, the MRC and Board heard about activities underway to mature the RAI program from its conceptual design phase to its implementation phase. Over the past several weeks, staff from both NERC and the Regional Entities initiated the project planning phase for the RAI program. In addition, NERC recently held a workshop with participants from the Regions, MRC, trade associations and the Compliance and Certification Committee to discuss three key components of the enhancements being considered under the RAI program: internal controls, risk assessment, and enforcement strategy. The Board would appreciate feedback on three key areas related to the RAI program. • First, the current plan calls for continued work on the FFT enhancements and a review of the current self-reporting process as high priority items over the next six to nine months to reduce the compliance burden on registered entities. Does industry agree with these priorities? • Second, defining a process to assess a registered entity’s internal controls was a topic of great discussion during the recent workshop. Similarly, whether and how the ERO would perform a risk assessment of a registered entity and how this would be used in audit scoping was also discussed at length. Would industry support the use of small pilot programs to help develop and field test proposed approaches in these key areas? Fred W. Gorbet, Chair Board of Trustees
