Self-Report and Mitigation

Registered entities are encouraged to self-report and mitigate Possible Violations as soon as they are identified. Self-reporting is a characteristic of an effective Internal Compliance Program and demonstrates a level of internal control. Prompt mitigation decreases any increased risk to reliability caused by the violation.  Both self-reporting and prompt mitigation are considered when SERC staff determines the appropriate disposition method and any sanction or penalty for a violation. 

Self-Reports

A Self-Report is a report by a registered entity stating that the registered entity believes it has, or may have, violated a NERC Reliability Standard. The ERO Self-Report User Guide provides guidance to assist registered entities with the submission of self‐reports. This User Guide explains the information necessary for NERC and the Regional Entities to provide efficient and timely resolution of instances of potential noncompliance.

Once a registered entity has identified an instance of potential noncompliance, the registered entity’s actions can be as important as the facts that led to the potential noncompliance. Prompt detection is the first step. After detection, the registered entity must complete these critical steps to resolve any instance of noncompliance: prompt cessation, correction, and reporting. Most importantly, a registered entity must mitigate any potential or actual risk to the reliability of the Bulk Power System as quickly as possible.

Self-Report forms can be submitted using the Self-Report form in the Compliance Portal. To submit a Self-Report, log into the 
Compliance Portal, select Self-Reports and Add Self-Report from the left navigation menu. 

The ERO Self-Report User Guide can be found on NERC's website in the Design Resources section of the Reliability Assurance Initiative page.

Mitigation

A Mitigation Plan is an action plan developed by the registered entity to (1) correct a violation of a NERC Reliability Standard and (2) prevent reoccurrence of the violation.  Mitigating activities are actions taken by a registered entity to correct and prevent recurrence of noncompliance, whether or not the actions are embodied in a Mitigation Plan.

A registered entity found to be in violation of a NERC Reliability Standard shall file with the Compliance Enforcement Authority (CEA) (a) a proposed Mitigation Plan to correct the violation, or (b) a description of how the violation has been mitigated.

If the CEA asks a registered entity to submit a Mitigation Plan, the ERO Mitigation Plan Guide provides guidelines and steps  to develop a Mitigation Plan according to Appendix 4C,. This Guide will help the registered entity develop a plan to identify and correct the original possible noncompliance and include steps to prevent future occurrence of similar issues. For a discussion of mitigation activities that could be provided as part of a Self-Report, please refer to the ERO Self-Report User Guide.

Mitigation Plans can be submitted using the Mitigation Plan form in the Compliance Portal. To submit a Mitigation Plan, log into the Compliance Portal, select Mitigation Plans and Add Mitigation Plan from the left navigation menu. Mitigating Activities can be provided in the Self-Report form. 

The
ERO Mitigation Plan Guide can be found on NERC's website in the Design Resources section of the Reliability Assurance Initiative page.

Request Settlement

At any time, a registered entity may request settlement negotiations for Possible Violations of the NERC Reliability Standards or the SERC Regional Reliability Standards.  Registered entities should submit requests for settlement negotiations on company letterhead using the settlement request template.

Quick Links