FERC recently accepted NERC’s twelve month report on NERC’s Find, Fix, and Track (FFT) implementation and NERC’s proposal to expand the FFT program to be used to track some moderate risk possible violations.
The FFT program was originally proposed by NERC to gain efficiency and effectiveness by streamlining the compliance and enforcement process. By allowing a registered entity to self-manage possible violations of lesser risk, the registered entity could self-report these possible violations and track remediation progress and completion through a process while minimizing the amount of effort put forth by both sides to manage a compliance deficiency. The report discussing the FFT program’s success is important for two big reasons. First, FFT has allowed NERC and the Regional Entities to push the management of minimal risk matters back to the Registered Entities. This shift has allowed NERC and the Regional Entities to focus resources on more serious and substantial risks to the Bulk Electric System (BES).
Second, since items managed through the FFT process are only “possible violations”, there will be no penalties for the items managed through FFT. This means that if Registered Entities have low or moderate risk “possible violations” and can manage them through FFT, the Registered Entity can avoid receiving a monetary penalty for those items.
If you are a Responsible Entity, read the FFT report filed by NERC today and find out how you can leverage this process moving forward and apply it to NERC CIP version 3 and NERC CIP version 5.