FERC, NERC Praise Low-Risk Violation Handling

Holden Mann | Source: RTO Insider | Posted 09/29/2025

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NERC and its regional entities proposed the FFT program in 2011 as an alternative to Notices of Penalty (NOPs) and spreadsheet Notices of Penalty (SNOPs) for processing minimal- and moderate-risk reliability standard violations. 


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The Federal Energy Regulatory Commission (FERC) and the North American Electric Reliability Corporation (NERC) have expressed satisfaction with the effectiveness of the Find, Fix, Track and Report (FFT) and Compliance Exception (CE) programs in managing low-risk violations. In a report submitted to FERC, NERC highlighted that these programs are successfully streamlining the handling of lower-risk noncompliance cases, with a significant number of moderate and minimal-risk violations processed through these methods since their introduction. The FFT program, proposed in 2011, and the CE program, approved in 2015, allow for more efficient processing of violations without penalties, encouraging entities to self-assess their compliance without fear of repercussions for minor issues.

NERC's report indicated that both programs have become the preferred methods for addressing violations, with a substantial majority of cases being handled through FFTs and CEs in recent years. The report also noted a joint review by FERC and ERO staff, which confirmed that regional entities are effectively implementing these programs, with no material misrepresentations found in the assessed cases. This alignment across the ERO Enterprise suggests a growing consistency in understanding and managing the risks associated with noncompliance, ultimately fostering a more proactive compliance culture among registered entities.



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