NERC Member Representatives Committee c/o Electricity Consumers Resource Council

I would like to invite the Member Representatives Committee (MRC) to provide policy input on four issues of particular interest to the Board of Trustees (Board) as it prepares for the meetings on August 13-14, 2014, in Vancouver, BC. Enclosed with this request is additional background information to help MRC members solicit inputs from their respective sectors. The four issues are: Item 1: Reliability Assurance Initiative (RAI) The goal of RAI is to fully implement a risk-based compliance monitoring and enforcement program. Partnering with industry, the ERO Enterprise executed a series of pilots to test and implement activities and approaches to support risk-based methods and evaluated the results of the pilots. Since the completion of the pilots, activities continue to document the processes and procedures as well as expand the use of select tools and techniques to additional Registered Entities. The ERO Enterprise is currently finalizing the documentation to complete a single design for the four modules outlined in the Compliance Oversight Framework (Framework): risk elements, inherent risk assessment (IRA), internal controls evaluation, and compliance monitoring and enforcement tools. Following the Board meeting in May, the ERO Enterprise worked on developing the IRA Guide (see Attachment A). The IRA Guide describes the process used to assess inherent risk of Registered Entities by the Regions and serves as a guide for implementing and performing an IRA. The MRC is encouraged to provide feedback on the draft IRA Guide. Specifically, the Board requests input on the following questions: 1. Do you agree with the process design of the draft IRA Guide to appropriately scope oversight? Are there areas for enhancement in the draft IRA Guide that would address specific concerns (please provide examples)