ReliabilityFirst’s Enforcement Philosophy
ReliabilityFirst is focused on reliability and seeks to ensure that Registered Entities in our footprint share this focus. Registered Entities can demonstrate a reliability focus through commitments to continuous improvement, effective management practices, and strong internal compliance programs.
ReliabilityFirst strives to make informed decisions based on these demonstrated commitments and to drive behavior through our actions, using the appropriate incentives (to reward demonstrated commitment) and deterrents (where there is a lack of demonstrated commitment).
Below is how the Enforcement Department ensures its actions align with ReliabilityFirst’s message.
ReliabilityFirst’s Enforcement Commitment
1. Informed decision making (disposition method, resource allocation, etc.) focused on risk to
2. Use all available tools (penalties, non-monetary sanctions, above and beyond actions) to
drive desired conduct and deter undesired conduct
3. Collaborate with Registered Entities, Regional partners, and NERC throughout enforcement action
4. Transparency, objectiveness, predictability and consistency
Examples of Enforcement Philosophy Implementation
1. Award significant credit for reliability-focused solutions that go beyond compliance with Reliability
2. Work with Registered Entities to craft holistic solutions to reliability and security issues instead of
addressing compliance on a piecemeal basis
3. Process minimal risk issues through available streamlined mechanisms so that time and effort
remain focused on greater reliability risks
4. Share internal processes and basis for decisions with Registered Entities, Regional partners, and
NERC to enable uniform, consistent, and transparent results
5. Reward Registered Entities that have demonstrated the ability to effectively identify, assess and
correct potential noncompliances with the Reliability Standards