Complete Violation Severity Level Matrix

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					         Complete Violation Severity Levels Matrix
Encompassing All Commission-Approved Reliability Standards




                        October 4, 2010

                                                             Page 1
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard    Requirement
                                     Text of Requirement                       Lower VSL            Moderate VSL                High VSL                Severe VSL
   Number        Number
BAL-001-0.1a   R1.           Each Balancing Authority shall              The Balancing           The Balancing            The Balancing            The Balancing
                             operate such that, on a rolling 12-         Authority Area’s        Authority Area’s value   Authority Area’s value   Authority Area’s value
                             month basis, the average of the clock-      value of CPS1 is less   of CPS1 is less than     of CPS1 is less than     of CPS1 is less than
                             minute averages of the Balancing            than 100% but           95% but greater than     90% but greater than     85%.
                             Authority’s Area Control Error (ACE)        greater than or equal   or equal to 90%.         or equal to 85%.
                             divided by 10B (B is the clock-minute       to 95%.
                             average of the Balancing Authority
                             Area’s Frequency Bias) times the
                             corresponding clock-minute averages
                             of the Interconnection’s Frequency
                             Error is less than a specific limit. This
                             limit is a constant derived from a
                             targeted frequency bound (separately
                             calculated for each Interconnection)
                             that is reviewed and set as necessary
                             by the NERC Operating Committee.
                             See Standard for Formula.
BAL-001-0.1a   R2.           Each Balancing Authority shall              The Balancing           The Balancing            The Balancing            The Balancing
                             operate such that its average ACE for       Authority Area’s        Authority Area’s value   Authority Area’s value   Authority Area’s value
                             at least 90% of clock-ten-minute            value of CPS2 is less   of CPS2 is less than     of CPS2 is less than     of CPS2 is less than
                             periods (6 non-overlapping periods          than 90% but greater    85% but greater than     80% but greater than     75%.
                             per hour) during a calendar month is        than or equal to        or equal to 80%.         or equal to 75%.
                             within a specific limit, referred to as     85%.
                             L10. See Standard for Formula.
BAL-001-0.1a   R3.           Each Balancing Authority providing          N/A                     N/A                      N/A                      The Balancing
                             Overlap Regulation Service shall                                                                                      Authority providing
                             evaluate Requirement R1 (i.e., Control                                                                                Overlap Regulation
                             Performance Standard 1 or CPS1) and                                                                                   Service failed to use a
                             Requirement R2 (i.e., Control                                                                                         combined ACE and
                             Performance Standard 2 or CPS2)                                                                                       frequency bias.
                             using the characteristics of the
                             combined ACE and combined
                             Frequency Bias Settings.
BAL-001-0.1a   R4.           Any Balancing Authority receiving           N/A                     N/A                      N/A                      The Balancing
                             Overlap Regulation Service shall not                                                                                  Authority receiving

                                                                                                                                                                 Page 2
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard    Requirement
                                     Text of Requirement                     Lower VSL      Moderate VSL         High VSL        Severe VSL
   Number        Number
                             have its control performance evaluated                                                         Overlap Regulation
                             (i.e. from a control performance                                                               Service failed to ensure
                             perspective, the Balancing Authority                                                           that control
                             has shifted all control requirements to                                                        performance was being
                             the Balancing Authority providing                                                              evaluated in a manner
                             Overlap Regulation Service).                                                                   consistent with the
                                                                                                                            calculation
                                                                                                                            methodology as
                                                                                                                            described in BAL-001-
                                                                                                                            01 R3.
BAL-002-0     R1.            Each Balancing Authority shall have       N/A               N/A               N/A              The Balancing
                             access to and/or operate Contingency                                                           Authority does not
                             Reserve to respond to Disturbances.                                                            have access to and/or
                             Contingency Reserve may be supplied                                                            operate Contingency
                             from generation, controllable load                                                             Reserve to respond to
                             resources, or coordinated adjustments                                                          Disturbances.
                             to Interchange Schedules.
BAL-002-0     R1.1.          A Balancing Authority may elect to        N/A               N/A               N/A              The Balancing
                             fulfill its Contingency Reserve                                                                Authority has elected
                             obligations by participating as a                                                              to fulfill its
                             member of a Reserve Sharing Group.                                                             Contingency Reserve
                             In such cases, the Reserve Sharing                                                             obligations by
                             Group shall have the same                                                                      participating as a
                             responsibilities and obligations as                                                            member of a Reserve
                             each Balancing Authority with respect                                                          Sharing Group and the
                             to monitoring and meeting the                                                                  Reserve Sharing Group
                             requirements of Standard BAL-002.                                                              has not provided the
                                                                                                                            same responsibilities
                                                                                                                            and obligations as
                                                                                                                            required of the
                                                                                                                            responsible entity with
                                                                                                                            respect to monitoring
                                                                                                                            and meeting the
                                                                                                                            requirements of
                                                                                                                            Standard BAL-002.
BAL-002-0     R2.            Each Regional Reliability                 The Regional      The Regional      The Regional     The Regional
                             Organization, sub-Regional Reliability    Reliability       Reliability       Reliability      Reliability

                                                                                                                                           Page 3
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard    Requirement
                                     Text of Requirement                 Lower VSL           Moderate VSL                 High VSL                 Severe VSL
   Number        Number
                             Organization or Reserve Sharing       Organization, sub-     Organization, sub-        Organization, sub-        Organization, sub-
                             Group shall specify its Contingency   Regional Reliability   Regional Reliability      Regional Reliability      Regional Reliability
                             Reserve policies, including:          Organization, or       Organization, or          Organization, or          Organization, or
                                                                   Reserve Sharing        Reserve Sharing Group     Reserve Sharing Group     Reserve Sharing Group
                                                                   Group has failed to    has failed to specify 2   has failed to specify 4   has failed to specify all
                                                                   specify 1 of the       or 3 of the following     or 5 of the following     6 of the following sub-
                                                                   following sub-         sub-requirements.         sub-requirements.         requirements.
                                                                   requirements.
BAL-002-0     R2.1.          The minimum reserve requirement for   N/A                    N/A                       N/A                       The Regional
                             the group.                                                                                                       Reliability
                                                                                                                                              Organization, sub-
                                                                                                                                              Regional Reliability
                                                                                                                                              Organization, or
                                                                                                                                              Reserve Sharing Group
                                                                                                                                              has failed to specify
                                                                                                                                              the minimum reserve
                                                                                                                                              requirement for the
                                                                                                                                              group.
BAL-002-0     R2.2.          Its allocation among members.         N/A                    N/A                       N/A                       The Regional
                                                                                                                                              Reliability
                                                                                                                                              Organization, sub-
                                                                                                                                              Regional Reliability
                                                                                                                                              Organization, or
                                                                                                                                              Reserve Sharing Group
                                                                                                                                              has failed to specify
                                                                                                                                              the allocation of
                                                                                                                                              reserves among
                                                                                                                                              members.
BAL-002-0     R2.3.          The permissible mix of Operating      N/A                    N/A                       N/A                       The Regional
                             Reserve – Spinning and Operating                                                                                 Reliability
                             Reserve – Supplemental that may be                                                                               Organization, sub-
                             included in Contingency Reserve.                                                                                 Regional Reliability
                                                                                                                                              Organization, or
                                                                                                                                              Reserve Sharing Group
                                                                                                                                              has failed to specify
                                                                                                                                              the permissible mix of
                                                                                                                                              Operating Reserve –

                                                                                                                                                             Page 4
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard    Requirement
                                     Text of Requirement                   Lower VSL     Moderate VSL         High VSL        Severe VSL
   Number        Number
                                                                                                                         Spinning and
                                                                                                                         Operating Reserve –
                                                                                                                         Supplemental that may
                                                                                                                         be included in
                                                                                                                         Contingency Reserve.
BAL-002-0     R2.4.          The procedure for applying              N/A               N/A              N/A              The Regional
                             Contingency Reserve in practice.                                                            Reliability
                                                                                                                         Organization, sub-
                                                                                                                         Regional Reliability
                                                                                                                         Organization, or
                                                                                                                         Reserve Sharing Group
                                                                                                                         has failed to provide
                                                                                                                         the procedure for
                                                                                                                         applying Contingency
                                                                                                                         Reserve in practice.
BAL-002-0     R2.5.          The limitations, if any, upon the       N/A               N/A              N/A              The Regional
                             amount of interruptible load that may                                                       Reliability
                             be included.                                                                                Organization, sub-
                                                                                                                         Regional Reliability
                                                                                                                         Organization, or
                                                                                                                         Reserve Sharing Group
                                                                                                                         has failed to specify
                                                                                                                         the limitations, if any,
                                                                                                                         upon the amount of
                                                                                                                         interruptible load that
                                                                                                                         may be included.
BAL-002-0     R2.6.          The same portion of resource capacity   N/A               N/A              N/A              The Regional
                             (e.g., reserves from jointly owned                                                          Reliability
                             generation) shall not be counted more                                                       Organization, sub-
                             than once as Contingency Reserve by                                                         Regional Reliability
                             multiple Balancing Authorities.                                                             Organization, or
                                                                                                                         Reserve Sharing Group
                                                                                                                         has allowed the same
                                                                                                                         portion of resource
                                                                                                                         capacity (e.g., reserves
                                                                                                                         from jointly owned
                                                                                                                         generation) to be

                                                                                                                                       Page 5
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard    Requirement
                                     Text of Requirement                   Lower VSL              Moderate VSL               High VSL               Severe VSL
   Number        Number
                                                                                                                                               counted more than
                                                                                                                                               once as Contingency
                                                                                                                                               Reserve by multiple
                                                                                                                                               Balancing Authorities.
BAL-002-0     R3.            Each Balancing Authority or Reserve       The Balancing           The Balancing           The Balancing           The Balancing
                             Sharing Group shall activate sufficient   Authority or Reserve    Authority or Reserve    Authority or Reserve    Authority or Reserve
                             Contingency Reserve to comply with        Sharing Group’s         Sharing Group’s         Sharing Group’s         Sharing Group’s
                             the DCS.                                  Average Percent         Average Percent         Average Percent         Average Percent
                                                                       Recovery per the        Recovery per the        Recovery per the        Recovery per the
                                                                       NERC DCS                NERC DCS quarterly      NERC DCS quarterly      NERC DCS quarterly
                                                                       quarterly report was    report was less than    report was less than    report was less than
                                                                       less than 100% but      95% but greater than    90% but greater than    85%.
                                                                       greater than or equal   or equal to 90%.        or equal to 85%.
                                                                       to 95%.
BAL-002-0     R3.1.          As a minimum, the Balancing               The Balancing           N/A                     N/A                     The Balancing
                             Authority or Reserve Sharing Group        Authority or Reserve                                                    Authority or Reserve
                             shall carry at least enough               Sharing Group failed                                                    Sharing Group failed
                             Contingency Reserve to cover the          to review their                                                         to carry at least enough
                             most severe single contingency. All       probable                                                                Contingency Reserve
                             Balancing Authorities and Reserve         contingencies to                                                        to cover the most
                             Sharing Groups shall review, no less      determine their                                                         severe single
                             frequently than annually, their           prospective most                                                        contingency.
                             probable contingencies to determine       severe single
                             their prospective most severe single      contingencies
                             contingencies.                            annually.
BAL-002-0     R4.            A Balancing Authority or Reserve          The Balancing           The Balancing           The Balancing           The Balancing
                             Sharing Group shall meet the              Authority or Reserve    Authority or Reserve    Authority or Reserve    Authority or Reserve
                             Disturbance Recovery Criterion            Sharing Group met       Sharing Group met the   Sharing Group met the   Sharing Group met the
                             within the Disturbance Recovery           the Disturbance         Disturbance Recovery    Disturbance Recovery    Disturbance Recovery
                             Period for 100% of Reportable             Recovery Criterion      Criterion within the    Criterion within the    Criterion within the
                             Disturbances. The Disturbance             within the              Disturbance Recovery    Disturbance Recovery    Disturbance Recovery
                             Recovery Criterion is:                    Disturbance             Period for more than    Period for more than    Period for more than
                                                                       Recovery Period for     80% and less than or    70% and less than or    0% and less than or
                                                                       more than 90% and       equal to 90% of         equal to 80% of         equal to 70% of
                                                                       less than 100% of       Reportable              Reportable              Reportable
                                                                       Reportable              Disturbances.           Disturbances.           Disturbances.
                                                                       Disturbances.

                                                                                                                                                             Page 6
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard    Requirement
                                     Text of Requirement                       Lower VSL          Moderate VSL                High VSL                 Severe VSL
   Number        Number
BAL-002-0     R4.1.          A Balancing Authority shall return its      N/A                   N/A                      N/A                      The Balancing
                             ACE to zero if its ACE just prior to                                                                                Authority failed to
                             the Reportable Disturbance was                                                                                      return its ACE to zero
                             positive or equal to zero. For negative                                                                             if its ACE just prior to
                             initial ACE values just prior to the                                                                                the Reportable
                             Disturbance, the Balancing Authority                                                                                Disturbance was
                             shall return ACE to its pre-                                                                                        positive or equal to
                             Disturbance value.                                                                                                  zero or for negative
                                                                                                                                                 initial ACE values
                                                                                                                                                 failed to return ACE to
                                                                                                                                                 its pre-Disturbance
                                                                                                                                                 value.
BAL-002-0     R4.2.          The default Disturbance Recovery            N/A                   N/A                      N/A                      N/A
                             Period is 15 minutes after the start of a
                             Reportable Disturbance. This period
                             may be adjusted to better suit the
                             needs of an Interconnection based on
                             analysis approved by the NERC
                             Operating Committee.
BAL-002-0     R5.            Each Reserve Sharing Group shall            The Reserve Sharing   The Reserve Sharing      The Reserve Sharing      The Reserve Sharing
                             comply with the DCS. A Reserve              Group met the DCS     Group met the DCS        Group met the DCS        Group met the DCS
                             Sharing Group shall be considered in a      requirement for       requirements for more    requirements for more    requirements for more
                             Reportable Disturbance condition            more than 90% and     than 80% and less than   than 70% and less than   than 0% and less than
                             whenever a group member has                 less than 100% of     or equal to 90% of       or equal to 80% of       or equal to 70% of
                             experienced a Reportable Disturbance        Reportable            Reportable               Reportable               Reportable
                             and calls for the activation of             Disturbances.         Disturbances.            Disturbances.            Disturbances.
                             Contingency Reserves from one or
                             more other group members. (If a
                             group member has experienced a
                             Reportable Disturbance but does not
                             call for reserve activation from other
                             members of the Reserve Sharing
                             Group, then that member shall report
                             as a single Balancing Authority.)
                             Compliance may be demonstrated by
                             either of the following two methods:
BAL-002-0     R5.1.          The Reserve Sharing Group reviews           N/A                   N/A                      N/A                      N/A
                                                                                                                                                               Page 7
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard    Requirement
                                     Text of Requirement                   Lower VSL           Moderate VSL                High VSL                 Severe VSL
   Number        Number
                             group ACE (or equivalent) and
                             demonstrates compliance to the DCS.
                             To be in compliance, the group ACE
                             (or its equivalent) must meet the
                             Disturbance Recovery Criterion after
                             the schedule change(s) related to
                             reserve sharing have been fully
                             implemented, and within the
                             Disturbance Recovery Period.
BAL-002-0     R5.2.          The Reserve Sharing Group reviews       N/A                    N/A                      N/A                      N/A
                             each member’s ACE in response to
                             the activation of reserves. To be in
                             compliance, a member’s ACE (or its
                             equivalent) must meet the Disturbance
                             Recovery Criterion after the schedule
                             change(s) related to reserve sharing
                             have been fully implemented, and
                             within the Disturbance Recovery
                             Period.
BAL-002-0     R6.            A Balancing Authority or Reserve        The Balancing          The Balancing            The Balancing            The Balancing
                             Sharing Group shall fully restore its   Authority or Reserve   Authority or Reserve     Authority or Reserve     Authority or Reserve
                             Contingency Reserves within the         Sharing Group          Sharing Group restored   Sharing Group restored   Sharing Group restored
                             Contingency Reserve Restoration         restored less than     less than or equal to    less than or equal to    less than 70% of its
                             Period for its Interconnection.         100% but greater       90% but greater than     80% but greater than     Contingency Reserves
                                                                     than 90% of its        80% of its contingency   or equal to 70% of its   during the
                                                                     contingency reserves   reserves during the      Contingency Reserve      Contingency Reserve
                                                                     during the             Contingency Reserve      during the               Restoration Period.
                                                                     Contingency            Restoration Period.      Contingency Reserve
                                                                     Reserve Restoration                             Restoration Period.
                                                                     Period.
BAL-002-0     R6.1.          The Contingency Reserve Restoration     N/A                    N/A                      N/A                      N/A
                             Period begins at the end of the
                             Disturbance Recovery Period.
BAL-002-0     R6.2.          The default Contingency Reserve         N/A                    N/A                      N/A                      N/A
                             Restoration Period is 90 minutes.
                             This period may be adjusted to better
                             suit the reliability targets of the
                                                                                                                                                           Page 8
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard     Requirement
                                      Text of Requirement                     Lower VSL          Moderate VSL                High VSL                  Severe VSL
   Number         Number
                              Interconnection based on analysis
                              approved by the NERC Operating
                              Committee.
BAL-003-0.1b   R1.            Each Balancing Authority shall review     N/A                   N/A                      The Balancing              The Balancing
                              its Frequency Bias Settings by January                                                   Authority reviewed its     Authority failed to
                              1 of each year and recalculate its                                                       Frequency Bias             review its Frequency
                              setting to reflect any change in the                                                     Settings prior January     Bias Settings prior to
                              Frequency Response of the Balancing                                                      1, but failed to           January 1, and failed to
                              Authority Area.                                                                          recalculate its setting    recalculate its setting
                                                                                                                       to reflect any change in   to reflect any change in
                                                                                                                       the Frequency              the Frequency
                                                                                                                       Response of the            Response of the
                                                                                                                       Balancing Authority        Balancing Authority
                                                                                                                       Area.                      Area.
BAL-003-0.1b   R1.1.          The Balancing Authority may change        N/A                   N/A                      N/A                        The Balancing
                              its Frequency Bias Setting, and the                                                                                 Authority changed its
                              method used to determine the setting,                                                                               Frequency Bias Setting
                              whenever any of the factors used to                                                                                 by changing the
                              determine the current bias value                                                                                    method used to
                              change.                                                                                                             determine the setting,
                                                                                                                                                  without any of the
                                                                                                                                                  factors used to
                                                                                                                                                  determine the current
                                                                                                                                                  bias value changing.
BAL-003-0.1b   R1.2.          Each Balancing Authority shall report     The Balancing         The Balancing            The Balancing              The Balancing
                              its Frequency Bias Setting, and           Authority has not     Authority has not        Authority has not          Authority has failed to
                              method for determining that setting, to   reported its method   reported its frequency   reported its method for    report as directed by
                              the NERC Operating Committee.             for calculating       bias setting.            calculating frequency      the requirement.
                                                                        frequency bias                                 bias and has not
                                                                        setting.                                       reported its frequency
                                                                                                                       bias setting.
BAL-003-0.1b   R2.            Each Balancing Authority shall            N/A                   N/A                      N/A                        The Balancing
                              establish and maintain a Frequency                                                                                  Authority established
                              Bias Setting that is as close as                                                                                    and maintained a
                              practical to, or greater than, the                                                                                  Frequency Bias Setting
                              Balancing Authority’s Frequency                                                                                     that was less than, the
                              Response. Frequency Bias may be                                                                                     Balancing Authority’s
                                                                                                                                                                 Page 9
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard     Requirement
                                      Text of Requirement                      Lower VSL     Moderate VSL         High VSL        Severe VSL
   Number         Number
                              calculated several ways:                                                                       Frequency Response.
BAL-003-0.1b   R2.1.          The Balancing Authority may use a          N/A               N/A              N/A              The Balancing
                              fixed Frequency Bias value which is                                                            Authority
                              based on a fixed, straight-line function                                                       determination of the
                              of Tie Line deviation versus                                                                   fixed Frequency Bias
                              Frequency Deviation. The Balancing                                                             value was not based on
                              Authority shall determine the fixed                                                            observations and
                              value by observing and averaging the                                                           averaging the
                              Frequency Response for several                                                                 Frequency Response
                              Disturbances during on-peak hours.                                                             from Disturbances
                                                                                                                             during on-peak hours.
BAL-003-0.1b   R2.2.          The Balancing Authority may use a          N/A               N/A              N/A              The Balancing
                              variable (linear or non-linear) bias                                                           Authorities variable
                              value, which is based on a variable                                                            frequency bias
                              function of Tie Line deviation to                                                              maintained was not
                              Frequency Deviation. The Balancing                                                             based on analyses of
                              Authority shall determine the variable                                                         Frequency Response as
                              frequency bias value by analyzing                                                              it varied with factors
                              Frequency Response as it varies with                                                           such as load,
                              factors such as load, generation,                                                              generation, governor
                              governor characteristics, and                                                                  characteristics, and
                              frequency.                                                                                     frequency.
BAL-003-0.1b   R3.            Each Balancing Authority shall             N/A               N/A              N/A              The Balancing
                              operate its Automatic Generation                                                               Authority did not
                              Control (AGC) on Tie Line Frequency                                                            operate its Automatic
                              Bias, unless such operation is adverse                                                         Generation Control
                              to system or Interconnection                                                                   (AGC) on Tie Line
                              reliability.                                                                                   Frequency Bias, during
                                                                                                                             periods when such
                                                                                                                             operation would not
                                                                                                                             have been adverse to
                                                                                                                             system or
                                                                                                                             Interconnection
                                                                                                                             reliability.
BAL-003-0.1b   R4.            Balancing Authorities that use             N/A               N/A              N/A              The Balancing
                              Dynamic Scheduling or Pseudo-ties                                                              Authority that used
                              for jointly owned units shall reflect                                                          Dynamic Scheduling
                                                                                                                                          Page 10
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard     Requirement
                                      Text of Requirement                     Lower VSL     Moderate VSL         High VSL        Severe VSL
   Number         Number
                              their respective share of the unit                                                            or Pseudo-ties for
                              governor droop response in their                                                              jointly owned units did
                              respective Frequency Bias Setting.                                                            not reflect their
                                                                                                                            respective share of the
                                                                                                                            unit governor droop
                                                                                                                            response in their
                                                                                                                            respective Frequency
                                                                                                                            Bias Setting.
BAL-003-0.1b   R4.1.          Fixed schedules for Jointly Owned         N/A               N/A              N/A              The Balancing
                              Units mandate that Balancing                                                                  Authority (A) that
                              Authority (A) that contains the Jointly                                                       contained the Jointly
                              Owned Unit must incorporate the                                                               Owned Unit with fixed
                              respective share of the unit governor                                                         schedules did not
                              droop response for any Balancing                                                              incorporate the
                              Authorities that have fixed schedules                                                         respective share of the
                              (B and C). See the diagram below.                                                             unit governor droop
                                                                                                                            response for any
                                                                                                                            Balancing Authorities
                                                                                                                            that have fixed
                                                                                                                            schedules (B and C).
BAL-003-0.1b   R4.2.          The Balancing Authorities that have a     N/A               N/A              N/A               The Balancing
                              fixed schedule (B and C) but do not                                                           Authorities that have a
                              contain the Jointly Owned Unit shall                                                          fixed schedule (B and
                              not include their share of the governor                                                       C) but do not contain
                              droop response in their Frequency                                                             the Jointly Owned
                              Bias Setting. See Standard for                                                                Unit, included their
                              Graphic                                                                                       share of the governor
                                                                                                                            droop response in their
                                                                                                                            Frequency Bias
                                                                                                                            Setting.
BAL-003-0.1b   R5.            Balancing Authorities that serve          N/A               N/A              N/A              The Balancing
                              native load shall have a monthly                                                              Authority that served
                              average Frequency Bias Setting that is                                                        native load failed to
                              at least 1% of the Balancing                                                                  have a monthly
                              Authority’s estimated yearly peak                                                             average Frequency
                              demand per 0.1 Hz change.                                                                     Bias Setting that was at
                                                                                                                            least 1% of the entities

                                                                                                                                         Page 11
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard     Requirement
                                      Text of Requirement                     Lower VSL      Moderate VSL               High VSL                 Severe VSL
   Number         Number
                                                                                                                                           estimated yearly peak
                                                                                                                                           demand per 0.1 Hz
                                                                                                                                           change.
BAL-003-0.1b   R5.1.          Balancing Authorities that do not         N/A               N/A                     N/A                      The Balancing
                              serve native load shall have a monthly                                                                       Authority that does not
                              average Frequency Bias Setting that is                                                                       serve native load did
                              at least 1% of its estimated maximum                                                                         not have a monthly
                              generation level in the coming year                                                                          average Frequency
                              per 0.1 Hz change.                                                                                           Bias Setting that was at
                                                                                                                                           least 1% of its
                                                                                                                                           estimated maximum
                                                                                                                                           generation level in the
                                                                                                                                           coming year per 0.1 Hz
                                                                                                                                           change.
BAL-003-0.1b   R6.            A Balancing Authority that is             N/A               The Balancing           The Balancing            N/A
                              performing Overlap Regulation                               Authority that was      Authority that was
                              Service shall increase its Frequency                        performing Overlap      performing Overlap
                              Bias Setting to match the frequency                         Regulation Service      Regulation Service
                              response of the entire area being                           changed its Frequency   failed to increase its
                              controlled. A Balancing Authority                           Bias Setting while      Frequency Bias Setting
                              shall not change its Frequency Bias                         performing              to match the frequency
                              Setting when performing                                     Supplemental            response of the entire
                              Supplemental Regulation Service.                            Regulation Service.     area being controlled.
BAL-004-0      R1.            Only a Reliability Coordinator shall      N/A               N/A                     N/A                      The responsible entity
                              be eligible to act as Interconnection                                                                        has designated more
                              Time Monitor. A single Reliability                                                                           than one
                              Coordinator in each Interconnection                                                                          interconnection time
                              shall be designated by the NERC                                                                              monitor for a single
                              Operating Committee to serve as                                                                              interconnection.
                              Interconnection Time Monitor.
BAL-004-0      R2.            The Interconnection Time Monitor          N/A               N/A                     N/A                      The RC serving as the
                              shall monitor Time Error and shall                                                                           Interconnection Time
                              initiate or terminate corrective action                                                                      Monitor failed to
                              orders in accordance with the NAESB                                                                          initiate or terminate
                              Time Error Correction Procedure.                                                                             corrective action
                                                                                                                                           orders in accordance
                                                                                                                                           with the NAESB Time
                                                                                                                                                          Page 12
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard    Requirement
                                     Text of Requirement                    Lower VSL            Moderate VSL                High VSL                Severe VSL
   Number        Number
                                                                                                                                                Error Correction
                                                                                                                                                Procedure.
BAL-004-0     R3.            Each Balancing Authority, when           The Balancing           The Balancing            The Balancing            The Balancing
                             requested, shall participate in a Time   Authority               Authority participated   Authority participated   Authority participated
                             Error Correction by one of the           participated in more    in more than 50% and     in more than 25% and     in less than or equal to
                             following methods:                       than 75% and less       less than or equal to    less than or equal to    25% of requested Time
                                                                      than 100% of            75% of requested Time    50% of requested Time    Error Corrections for
                                                                      requested Time          Error Corrections for    Error Corrections for    the calendar year.
                                                                      Error Corrections for   the calendar year.       the calendar year.
                                                                      the calendar year.
BAL-004-0     R3.1.          The Balancing Authority shall offset     The Balancing           The Balancing            The Balancing            The Balancing
                             its frequency schedule by 0.02 Hertz,    Authority failed to     Authority failed to      Authority failed to      Authority failed to
                             leaving the Frequency Bias Setting       offset its frequency    offset its frequency     offset its frequency     offset its frequency
                             normal; or                               schedule by 0.02        schedule by 0.02 Hertz   schedule by 0.02 Hertz   schedule by 0.02 Hertz
                                                                      Hertz and leave their   and leave their          and leave their          and leave their
                                                                      Frequency Bias          Frequency Bias Setting   Frequency Bias Setting   Frequency Bias Setting
                                                                      Setting normal for 0    normal for 25 to 50%     normal for 50 to 75%     normal for 75% or
                                                                      to 25% of the time      of the time error        of the time error        more of the time error
                                                                      error corrections for   corrections for the      corrections for the      corrections for the
                                                                      the year.               year.                    year.                    year.
BAL-004-0     R.3.2.         The Balancing Authority shall offset     The Balancing           The Balancing            The Balancing            The Balancing
                             its Net Interchange Schedule (MW) by     Authority failed to     Authority failed to      Authority failed to      Authority failed to
                             an amount equal to the computed bias     offset its net          offset its net           offset its net           offset its net
                             contribution during a 0.02 Hertz         interchange schedule    interchange schedule     interchange schedule     interchange schedule
                             Frequency Deviation (i.e. 20% of the     frequency schedule      frequency schedule by    frequency schedule by    frequency schedule by
                             Frequency Bias Setting).                 by 20% of their         20% of their frequency   20% of their frequency   20% of their frequency
                                                                      frequency bias for 0    bias for 25 to 50% of    bias for 50 to 75% of    bias for 75% or more
                                                                      to 25% of the time      the time error           the time error           of the time error
                                                                      error corrections.      corrections.             corrections.             corrections.
BAL-004-0     R4.            Any Reliability Coordinator in an        N/A                     N/A                      N/A                      The RC serving as the
                             Interconnection shall have the                                                                                     Interconnection Time
                             authority to request the                                                                                           Monitor failed to
                             Interconnection Time Monitor to                                                                                    initiate or terminate
                             terminate a Time Error Correction in                                                                               corrective action
                             progress, or a scheduled Time Error                                                                                orders in accordance
                             Correction that has not begun, for                                                                                 with the NAESB Time
                                                                                                                                                Error Correction
                                                                                                                                                               Page 13
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard     Requirement
                                      Text of Requirement                     Lower VSL     Moderate VSL         High VSL         Severe VSL
   Number         Number
                              reliability considerations.                                                                   Procedure.
BAL-004-0      R4.1.          Balancing Authorities that have           N/A               N/A              N/A              The Balancing
                              reliability concerns with the execution                                                       Authority with
                              of a Time Error Correction shall notify                                                       reliability concerns
                              their Reliability Coordinator and                                                             failed to notify the
                              request the termination of a Time                                                             Reliability Coordinator
                              Error Correction in progress.                                                                 and request the
                                                                                                                            termination of a Time
                                                                                                                            Error Correction in
                                                                                                                            progress.
BAL-005-0.1b   R1.            All generation, transmission, and load    N/A               N/A              N/A              N/A
                              operating within an Interconnection
                              must be included within the metered
                              boundaries of a Balancing Authority
                              Area.
BAL-005-0.1b   R1.1.          Each Generator Operator with              N/A               N/A              N/A              The Generator
                              generation facilities operating in an                                                         Operator with
                              Interconnection shall ensure that those                                                       generation facilities
                              generation facilities are included                                                            operating in an
                              within the metered boundaries of a                                                            Interconnection failed
                              Balancing Authority Area.                                                                     to ensure that those
                                                                                                                            generation facilities
                                                                                                                            were included within
                                                                                                                            metered boundaries of
                                                                                                                            a Balancing Authority
                                                                                                                            Area.
BAL-005-0.1b   R1.2.          Each Transmission Operator with           N/A               N/A              N/A              The Transmission
                              transmission facilities operating in an                                                       Operator with
                              Interconnection shall ensure that those                                                       transmission facilities
                              transmission facilities are included                                                          operating in an
                              within the metered boundaries of a                                                            Interconnection failed
                              Balancing Authority Area.                                                                     to ensure that those
                                                                                                                            transmission facilities
                                                                                                                            were included within
                                                                                                                            metered boundaries of
                                                                                                                            a Balancing Authority

                                                                                                                                         Page 14
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard     Requirement
                                      Text of Requirement                       Lower VSL     Moderate VSL         High VSL           Severe VSL
   Number         Number
                                                                                                                              Area.
BAL-005-0.1b   R1.3.          Each Load-Serving Entity with load          N/A               N/A              N/A              The Load-Serving
                              operating in an Interconnection shall                                                           Entity with load
                              ensure that those loads are included                                                            operating in an
                              within the metered boundaries of a                                                              Interconnection failed
                              Balancing Authority Area.                                                                       to ensure that those
                                                                                                                              loads were included
                                                                                                                              within metered
                                                                                                                              boundaries of a
                                                                                                                              Balancing Authority
                                                                                                                              Area.
BAL-005-0.1b   R2.            Each Balancing Authority shall              N/A               N/A              N/A              The Balancing
                              maintain Regulating Reserve that can                                                            Authority failed to
                              be controlled by AGC to meet the                                                                maintain Regulating
                              Control Performance Standard.                                                                   Reserve that can be
                                                                                                                              controlled by AGC to
                                                                                                                              meet Control
                                                                                                                              Performance Standard.
BAL-005-0.1b   R3.            A Balancing Authority providing             N/A               N/A              N/A              The Balancing
                              Regulation Service shall ensure that                                                            Authority providing
                              adequate metering, communications                                                               Regulation Service
                              and control equipment are employed                                                              failed to ensure
                              to prevent such service from                                                                    adequate metering,
                              becoming a Burden on the                                                                        communications, and
                              Interconnection or other Balancing                                                              control equipment was
                              Authority Areas.                                                                                provided.
BAL-005-0.1b   R4.            A Balancing Authority providing             N/A               N/A              N/A              The Balancing
                              Regulation Service shall notify the                                                             Authority providing
                              Host Balancing Authority for whom it                                                            Regulation Service
                              is controlling if it is unable to provide                                                       failed to notify the
                              the service, as well as any                                                                     Host Balancing
                              Intermediate Balancing Authorities.                                                             Authority for whom it
                                                                                                                              is controlling if it was
                                                                                                                              unable to provide the
                                                                                                                              service, as well as any
                                                                                                                              Intermediate Balancing

                                                                                                                                           Page 15
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard    Requirement
                                     Text of Requirement                    Lower VSL             Moderate VSL             High VSL        Severe VSL
   Number        Number
                                                                                                                                      Authorities.
BAL-005-0.1b   R5.           A Balancing Authority receiving          N/A                      N/A                   N/A              The Balancing
                             Regulation Service shall ensure that                                                                     Authority receiving
                             backup plans are in place to provide                                                                     Regulation Service
                             replacement Regulation Service                                                                           failed to ensure that
                             should the supplying Balancing                                                                           back-up plans were in
                             Authority no longer be able to provide                                                                   place to provide
                             this service.                                                                                            replacement
                                                                                                                                      Regulation Service.
BAL-005-0.1b   R6.           The Balancing Authority’s AGC shall      The Balancing            The Balancing         N/A              The Balancing
                             compare total Net Actual Interchange     Authority failed to      Authority failed to                    Authority failed to
                             to total Net Scheduled Interchange       notify the Reliability   calculate ACE as                       notify the Reliability
                             plus Frequency Bias obligation to        Coordinator within       specified in the                       Coordinator within 30
                             determine the Balancing Authority’s      30 minutes of its        requirement.                           minutes of its inability
                             ACE. Single Balancing Authorities        inability to calculate                                          to calculate ACE and
                             operating asynchronously may employ      ACE.                                                            failed to use the ACE
                             alternative ACE calculations such as                                                                     calculation specified in
                             (but not limited to) flat frequency                                                                      the requirement in its
                             control. If a Balancing Authority is                                                                     attempt to calculate
                             unable to calculate ACE for more than                                                                    ACE.
                             30 minutes it shall notify its
                             Reliability Coordinator.
BAL-005-0.1b   R7.           The Balancing Authority shall operate    N/A                      N/A                   N/A              The Balancing
                             AGC continuously unless such                                                                             Authority failed to
                             operation adversely impacts the                                                                          operate AGC
                             reliability of the Interconnection. If                                                                   continuously when
                             AGC has become inoperative, the                                                                          there were no adverse
                             Balancing Authority shall use manual                                                                     impacts OR if their
                             control to adjust generation to                                                                          AGC was inoperative
                             maintain the Net Scheduled                                                                               the Balancing
                             Interchange.                                                                                             Authority failed to use
                                                                                                                                      manual control to
                                                                                                                                      adjust generation to
                                                                                                                                      maintain the Net
                                                                                                                                      Scheduled Interchange.
BAL-005-0.1b   R8.           The Balancing Authority shall ensure     N/A                      N/A                   N/A              The Balancing
                             that data acquisition for and                                                                            Authority failed to
                                                                                                                                                   Page 16
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard     Requirement
                                      Text of Requirement                     Lower VSL     Moderate VSL         High VSL        Severe VSL
   Number         Number
                              calculation of ACE occur at least                                                             ensure that data
                              every six seconds.                                                                            acquisition for and
                                                                                                                            calculation of ACE
                                                                                                                            occurred at least every
                                                                                                                            six seconds.
BAL-005-0.1b   R8.1.          Each Balancing Authority shall            N/A               N/A                               The Balancing
                              provide redundant and independent                                                             Authority failed to
                              frequency metering equipment that                                                             provide redundant and
                              shall automatically activate upon                                                             independent frequency
                              detection of failure of the primary                                                           metering equipment
                              source. This overall installation shall                                                       that automatically
                              provide a minimum availability of                                                             activated upon
                              99.95%.                                                                                       detection of failure,
                                                                                                                            such that the minimum
                                                                                                                            availability was less
                                                                                                                            than 99.95%.
BAL-005-0.1b   R9.            The Balancing Authority shall include     N/A               N/A              N/A              The Balancing
                              all Interchange Schedules with                                                                Authority failed to
                              Adjacent Balancing Authorities in the                                                         include all
                              calculation of Net Scheduled                                                                  Interchanged
                              Interchange for the ACE equation.                                                             Schedules with
                                                                                                                            Adjacent Balancing
                                                                                                                            Authorities in the
                                                                                                                            calculation of Net
                                                                                                                            Scheduled Interchange
                                                                                                                            for the ACE equation.
BAL-005-0.1b   R9.1.          Balancing Authorities with a high         N/A               N/A              N/A              The Balancing
                              voltage direct current (HVDC) link to                                                         Authority with a high
                              another Balancing Authority                                                                   voltage direct current
                              connected asynchronously to their                                                             (HVDC) link to
                              Interconnection may choose to omit                                                            another Balancing
                              the Interchange Schedule related to                                                           Authority connected
                              the HVDC link from the ACE                                                                    asynchronously to their
                              equation if it is modeled as internal                                                         Interconnection chose
                              generation or load.                                                                           to omit the Interchange
                                                                                                                            Schedule related to the
                                                                                                                            HVDC link from the

                                                                                                                                         Page 17
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard     Requirement
                                      Text of Requirement                    Lower VSL     Moderate VSL         High VSL        Severe VSL
   Number         Number
                                                                                                                           ACE equation. but
                                                                                                                           failed to model it as
                                                                                                                           internal generation or
                                                                                                                           load.
BAL-005-0.1b   R10.           The Balancing Authority shall include    N/A               N/A              N/A              The Balancing
                              all Dynamic Schedules in the                                                                 Authority failed to
                              calculation of Net Scheduled                                                                 include all Dynamic
                              Interchange for the ACE equation.                                                            Schedules in the
                                                                                                                           calculation of Net
                                                                                                                           Scheduled Interchange
                                                                                                                           for the ACE equation.
BAL-005-0.1b   R11.           Balancing Authorities shall include      N/A               N/A              N/A              The Balancing
                              the effect of Ramp rates, which shall                                                        Authority failed to
                              be identical and agreed to between                                                           include the effect of
                              affected Balancing Authorities, in the                                                       Ramp rates in the
                              Scheduled Interchange values to                                                              Scheduled Interchange
                              calculate ACE.                                                                               values to calculate
                                                                                                                           ACE.
BAL-005-0.1b   R12.           Each Balancing Authority shall           N/A               N/A              N/A              The Balancing
                              include all Tie Line flows with                                                              Authority failed to
                              Adjacent Balancing Authority Areas                                                           include all Tie Line
                              in the ACE calculation.                                                                      flows with Adjacent
                                                                                                                           Balancing Authority
                                                                                                                           Areas in the ACE
                                                                                                                           calculation.
BAL-005-0.1b   R12.1.         Balancing Authorities that share a tie   N/A               N/A              N/A              The Balancing
                              shall ensure Tie Line MW metering is                                                         Authority failed to
                              telemetered to both control centers,                                                         ensure Tie Line MW
                              and emanates from a common, agreed-                                                          metering was
                              upon source using common primary                                                             telemetered to both
                              metering equipment. Balancing                                                                control centers, and
                              Authorities shall ensure that                                                                emanates from a
                              megawatt-hour data is telemetered or                                                         common, agreed-upon
                              reported at the end of each hour.                                                            source using common
                                                                                                                           primary metering
                                                                                                                           equipment.

                                                                                                                                        Page 18
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard     Requirement
                                      Text of Requirement                     Lower VSL     Moderate VSL         High VSL        Severe VSL
   Number         Number
                                                                                                                            OR
                                                                                                                            The Balancing
                                                                                                                            Authority failed to
                                                                                                                            ensure that megawatt-
                                                                                                                            hour data is
                                                                                                                            telemetered or reported
                                                                                                                            at the end of each hour.
BAL-005-0.1b   R12.2.         Balancing Authorities shall ensure the    N/A               N/A              N/A              The Balancing
                              power flow and ACE signals that are                                                           Authority failed to
                              utilized for calculating Balancing                                                            ensure the power flow
                              Authority performance or that are                                                             and ACE signals that
                              transmitted for Regulation Service are                                                        are utilized for
                              not filtered prior to transmission,                                                           calculating Balancing
                              except for the Anti-aliasing Filters of                                                       Authority performance
                              Tie Lines.                                                                                    or that are transmitted
                                                                                                                            for Regulation Service
                                                                                                                            were filtered prior to
                                                                                                                            transmission, except
                                                                                                                            for the Anti-aliasing
                                                                                                                            Filters of Tie Lines.
BAL-005-0.1b   R12.3.         Balancing Authorities shall install       N/A               N/A              N/A              The Balancing
                              common metering equipment where                                                               Authority failed to
                              Dynamic Schedules or Pseudo-Ties                                                              install common
                              are implemented between two or more                                                           metering equipment
                              Balancing Authorities to deliver the                                                          where Dynamic
                              output of Jointly Owned Units or to                                                           Schedules or Pseudo-
                              serve remote load.                                                                            Ties were implemented
                                                                                                                            between two or more
                                                                                                                            Balancing Authorities
                                                                                                                            to deliver the output of
                                                                                                                            Jointly Owned Units or
                                                                                                                            to serve remote load.
BAL-005-0.1b   R13.           Each Balancing Authority shall            N/A               N/A              N/A              The Balancing
                              perform hourly error checks using Tie                                                         Authority failed to
                              Line megawatt-hour meters with                                                                perform hourly error
                              common time synchronization to                                                                checks using Tie Line
                              determine the accuracy of its control                                                         megawatt-hour meters
                                                                                                                                         Page 19
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard    Requirement
                                     Text of Requirement                      Lower VSL     Moderate VSL         High VSL               Severe VSL
   Number        Number
                             equipment. The Balancing Authority                                                                    with common time
                             shall adjust the component (e.g., Tie                                                                 synchronization to
                             Line meter) of ACE that is in error (if                                                               determine the accuracy
                             known) or use the interchange meter                                                                   of its control
                             error (IME) term of the ACE equation                                                                  equipment OR the
                             to compensate for any equipment error                                                                 Balancing Authority
                             until repairs can be made.                                                                            failed to adjust the
                                                                                                                                   component (e.g., Tie
                                                                                                                                   Line meter) of ACE
                                                                                                                                   that is in error (if
                                                                                                                                   known) or use the
                                                                                                                                   interchange meter error
                                                                                                                                   (IME) term of the ACE
                                                                                                                                   equation to
                                                                                                                                   compensate for any
                                                                                                                                   equipment error until
                                                                                                                                   repairs can be made.
BAL-005-0.1b   R14.          The Balancing Authority shall provide      N/A               N/A              N/A                     The Balancing
                             its operating personnel with sufficient                                                               Authority failed to
                             instrumentation and data recording                                                                    provide its operating
                             equipment to facilitate monitoring of                                                                 personnel with
                             control performance, generation                                                                       sufficient
                             response, and after-the-fact analysis of                                                              instrumentation and
                             area performance. As a minimum, the                                                                   data recording
                             Balancing Authority shall provide its                                                                 equipment to facilitate
                             operating personnel with real-time                                                                    monitoring of control
                             values for ACE, Interconnection                                                                       performance,
                             frequency and Net Actual Interchange                                                                  generation response,
                             with each Adjacent Balancing                                                                          and after-the-fact
                             Authority Area.                                                                                       analysis of area
                                                                                                                                   performance.
BAL-005-0.1b   R15.          The Balancing Authority shall provide      N/A               N/A              The Balancing           The Balancing
                             adequate and reliable backup power                                            Authority failed to     Authority failed to
                             supplies and shall periodically test                                          periodically test       provide adequate and
                             these supplies at the Balancing                                               backup power supplies   reliable backup power
                             Authority’s control center and other                                          at the Balancing        supplies to ensure
                             critical locations to ensure continuous                                       Authority’s control     continuous operation
                             operation of AGC and vital data                                               center and other        of AGC and vital data
                                                                                                                                                Page 20
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard    Requirement
                                     Text of Requirement                      Lower VSL          Moderate VSL         High VSL                  Severe VSL
   Number        Number
                             recording equipment during loss of the                                             critical locations to      recording equipment
                             normal power supply.                                                               ensure continuous          during loss of the
                                                                                                                operation of AGC and       normal power supply.
                                                                                                                vital data recording
                                                                                                                equipment during loss
                                                                                                                of the normal power
                                                                                                                supply.
BAL-005-0.1b   R16.          The Balancing Authority shall sample       The Balancing          N/A              The Balancing              The Balancing
                             data at least at the same periodicity      Authority failed to                     Authority failed to flag   Authority failed to
                             with which ACE is calculated. The          collect coincident                      missing or bad data for    sample data at least at
                             Balancing Authority shall flag missing     data to the greatest                    operator display and       the same periodicity
                             or bad data for operator display and       practical extent.                       archival purposes.         with which ACE is
                             archival purposes. The Balancing                                                                              calculated.
                             Authority shall collect coincident data
                             to the greatest practical extent, i.e.,
                             ACE, Interconnection frequency, Net
                             Actual Interchange, and other data
                             shall all be sampled at the same time.
BAL-005-0.1b   R17.          Each Balancing Authority shall at          N/A                    N/A              N/A                        The Balancing
                             least annually check and calibrate its                                                                        Authority failed to at
                             time error and frequency devices                                                                              least annually check
                             against a common reference. The                                                                               and calibrate its time
                             Balancing Authority shall adhere to                                                                           error and frequency
                             the minimum values for measuring                                                                              devices against a
                             devices as listed below: See                                                                                  common reference.
                             Standard for Values
BAL-006-1.1    R1.           Each Balancing Authority shall             N/A                    N/A              N/A                        Each Balancing
                             calculate and record hourly                                                                                   Authority failed to
                             Inadvertent Interchange.                                                                                      calculate and record
                                                                                                                                           hourly Inadvertent
                                                                                                                                           Interchange.
BAL-006-1.1    R2.           Each Balancing Authority shall             N/A                    N/A              The Balancing              The Balancing
                             include all AC tie lines that connect to                                           Authority failed to        Authority failed to
                             its Adjacent Balancing Authority                                                   include all AC tie lines   include all AC tie lines
                             Areas in its Inadvertent Interchange                                               that connect to its        that connect to its
                             account. The Balancing Authority                                                   Adjacent Balancing         Adjacent Balancing
                             shall take into account interchange                                                Authority Areas in its     Authority Areas in its
                                                                                                                                                        Page 21
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard    Requirement
                                     Text of Requirement                   Lower VSL          Moderate VSL             High VSL                 Severe VSL
   Number        Number
                             served by jointly owned generators.                                                 Inadvertent              Inadvertent
                                                                                                                 Interchange account.     Interchange account.
                                                                                                                 OR                       AND
                                                                                                                 Failed to take into      Failed to take into
                                                                                                                 account interchange      account interchange
                                                                                                                 served by jointly        served by jointly
                                                                                                                 owned generators.        owned generators.
BAL-006-1.1   R3.            Each Balancing Authority shall ensure   N/A                   N/A                   N/A                      The Balancing
                             all of its Balancing Authority Area                                                                          Authority failed to
                             interconnection points are equipped                                                                          ensure all of its
                             with common megawatt-hour meters,                                                                            Balancing Authority
                             with readings provided hourly to the                                                                         Area interconnection
                             control centers of Adjacent Balancing                                                                        points are equipped
                             Authorities.                                                                                                 with common
                                                                                                                                          megawatt-hour meters,
                                                                                                                                          with readings provided
                                                                                                                                          hourly to the control
                                                                                                                                          centers of Adjacent
                                                                                                                                          Balancing Authorities.
BAL-006-1.1   R4.            Adjacent Balancing Authority Areas      The Balancing         The Balancing         The Balancing            N/A
                             shall operate to a common Net           Authority failed to   Authority failed to   Authority failed to
                             Interchange Schedule and Actual Net     record Actual Net     compute Inadvertent   operate to a common
                             Interchange value and shall record      Interchange values    Interchange.          Net Interchange
                             these hourly quantities, with like      that are equal but                          Schedule that is equal
                             values but opposite sign. Each          opposite in sign to                         but opposite to its
                             Balancing Authority shall compute its   its Adjacent                                Adjacent Balancing
                             Inadvertent Interchange based on the    Balancing                                   Authorities.
                             following:                              Authorities.
BAL-006-1.1   R4.1.          Each Balancing Authority, by the end    N/A                   N/A                   N/A                      The Balancing
                             of the next business day, shall agree                                                                        Authority, by the end
                             with its Adjacent Balancing                                                                                  of the next business
                             Authorities to:                                                                                              day, failed to agree
                                                                                                                                          with its Adjacent
                                                                                                                                          Balancing Authorities
                                                                                                                                          to the hourly values of
                                                                                                                                          Net Interchanged

                                                                                                                                                       Page 22
 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard    Requirement
                                     Text of Requirement                  Lower VSL     Moderate VSL         High VSL        Severe VSL
   Number        Number
                                                                                                                        Schedule.
                                                                                                                        AND
                                                                                                                        The hourly integrated
                                                                                                                        megawatt-hour values
                                                                                                                        of Net Actual
                                                                                                                        Interchange.
BAL-006-1.1   R4.1.1.        The hourly values of Net Interchange   N/A               N/A              N/A              The Balancing
                             Schedule.                                                                                  Authority, by the end
                                                                                                                        of the next business
                                                                                                                        day, failed to agree
                                                                                                                        with its Adjacent
                                                                                                                        Balancing Authorities
                                                                                                                        to the hourly values of
                                                                                                                        Net Interchanged
                                                                                                                        Schedule.
BAL-006-1.1   R4.1.2.        The hourly integrated megawatt-hour    N/A               N/A              N/A              The Balancing
                             values of Net Actual Interchange.                                                          Authority, by the end
                                                                                                                        of the next business
                                                                                                                        day, failed to agree
                                                                                                                        with its Adjacent
                                                                                                                        Balancing Authorities
                                                                                                                        to the hourly integrated
                                                                                                                        megawatt-hour values
                                                                                                                        of Net Actual
                                                                                                                        Interchange.
BAL-006-1.1   R4.2.          Each Balancing Authority shall use     N/A               N/A              N/A              The Balancing
                             the agreed-to daily and monthly                                                            Authority failed to use
                             accounting data to compile its                                                             the agreed-to daily and
                             monthly accumulated Inadvertent                                                            monthly accounting
                             Interchange for the On-Peak and Off-                                                       data to compile its
                             Peak hours of the month.                                                                   monthly accumulated
                                                                                                                        Inadvertent
                                                                                                                        Interchange for the On-
                                                                                                                        Peak and Off-Peak
                                                                                                                        hours of the month.
BAL-006-1.1   R4.3.          A Balancing Authority shall make       N/A               N/A              N/A              The Balancing

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 Complete Violation Severity Level Matrix (BAL)
 Encompassing All Commission-Approved Reliability Standards
   Standard   Requirement
                                    Text of Requirement                    Lower VSL              Moderate VSL                  High VSL         Severe VSL
   Number       Number
                            after-the-fact corrections to the                                                                              Authority failed to
                            agreed-to daily and monthly                                                                                    make after-the-fact
                            accounting data only as needed to                                                                              corrections to the
                            reflect actual operating conditions                                                                            agreed-to daily and
                            (e.g. a meter being used for control                                                                           monthly accounting
                            was sending bad data). Changes or                                                                              data to reflect actual
                            corrections based on non-reliability                                                                           operating conditions or
                            considerations shall not be reflected in                                                                       changes or corrections
                            the Balancing Authority’s Inadvertent                                                                          based on non-
                            Interchange. After-the-fact                                                                                    reliability
                            corrections to scheduled or actual                                                                             considerations were
                            values will not be accepted without                                                                            reflected in the
                            agreement of the Adjacent Balancing                                                                            Balancing Authority’s
                            Authority(ies).                                                                                                Inadvertent
                                                                                                                                           Interchange.
BAL-006-1.1   R5.           Adjacent Balancing Authorities that        Adjacent Balancing      Adjacent Balancing         N/A              N/A
                            cannot mutually agree upon their           Authorities that        Authorities that could
                            respective Net Actual Interchange or       could not mutually      not mutually agree
                            Net Scheduled Interchange quantities       agree upon their        upon their respective
                            by the 15th calendar day of the            respective Net          Net Actual Interchange
                            following month shall, for the             Actual Interchange      or Net Scheduled
                            purposes of dispute resolution, submit     or Net Scheduled        Interchange quantities
                            a report to their respective Regional      Interchange             by the 15th calendar
                            Reliability Organization Survey            quantities, submitted   day of the following
                            Contact. The report shall describe the     a report to their       month, failed to submit
                            nature and the cause of the dispute as     respective Regional     a report to their
                            well as a process for correcting the       Reliability             respective Regional
                            discrepancy.                               Organizations           Reliability
                                                                       Survey Contact          Organizations Survey
                                                                       describing the nature   Contact describing the
                                                                       and the cause of the    nature and the cause of
                                                                       dispute but failed to   the dispute as well as a
                                                                       provide a process for   process for correcting
                                                                       correcting the          the discrepancy.
                                                                       discrepancy.




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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards

 Standard    Requirement
                                      Text of Requirement                        Lower VSL      Moderate VSL                 High VSL                   Severe VSL
 Number        Number
CIP-001-1   R1.            Each Reliability Coordinator, Balancing         N/A               N/A                       The responsible entity      The responsible entity
                           Authority, Transmission Operator,                                                           has procedures for the      failed to have
                           Generator Operator, and Load-Serving                                                        recognition of              procedures for the
                           Entity shall have procedures for the                                                        sabotage events on its      recognition of and for
                           recognition of and for making their                                                         facilities and multi site   making their operating
                           operating personnel aware of sabotage                                                       sabotage affecting          personnel aware of
                           events on its facilities and multi site                                                     larger portions of the      sabotage events on its
                           sabotage affecting larger portions of the                                                   Interconnection but         facilities and multi site
                           Interconnection.                                                                            does not have a             sabotage affecting
                                                                                                                       procedure for making        larger portions of the
                                                                                                                       their operating             Interconnection.
                                                                                                                       personnel aware of
                                                                                                                       said events.
CIP-001-1   R2.            Each Reliability Coordinator, Balancing         N/A               N/A                       The responsible entity      The responsible entity
                           Authority, Transmission Operator,                                                           has demonstrated the        failed to have a
                           Generator Operator, and Load-Serving                                                        existence of a              procedure for
                           Entity shall have procedures for the                                                        procedure to                communicating
                           communication of information concerning                                                     communicate                 information
                           sabotage events to appropriate parties in the                                               information                 concerning sabotage
                           Interconnection.                                                                            concerning sabotage         events.
                                                                                                                       events, but not all of
                                                                                                                       the appropriate parties
                                                                                                                       in the interconnection
                                                                                                                       are identified.
CIP-001-1   R3.            Each Reliability Coordinator, Balancing         N/A               The responsible entity    The responsible entity      The responsible entity
                           Authority, Transmission Operator,                                 has demonstrated the      has demonstrated the        failed to have a
                           Generator Operator, and Load-Serving                              existence of a response   existence of a response     response guideline for
                           Entity shall provide its operating personnel                      guideline for reporting   guideline for reporting     reporting disturbances
                           with sabotage response guidelines,                                disturbances due to       disturbances due to         due to sabotage
                           including personnel to contact, for reporting                     sabotage events, but      sabotage events,            events.
                           disturbances due to sabotage events.                              the guideline did not     including all of the
                                                                                             list all of the           appropriate personnel
                                                                                             appropriate personnel     to contact, but the
                                                                                             to contact.               guideline was not
                                                                                                                       available to its
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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard     Requirement
                                      Text of Requirement                       Lower VSL      Moderate VSL                High VSL                   Severe VSL
 Number         Number
                                                                                                                     operating personnel.
CIP-001-1    R4.            Each Reliability Coordinator, Balancing       N/A               N/A                      The responsible entity     The responsible entity
                            Authority, Transmission Operator,                                                        has established            failed to establish
                            Generator Operator, and Load-Serving                                                     communications             communications
                            Entity shall establish communications                                                    contacts, as applicable,   contacts, as applicable,
                            contacts, as applicable, with local Federal                                              with local Federal         with local Federal
                            Bureau of Investigation (FBI) or Royal                                                   Bureau of                  Bureau of
                            Canadian Mounted Police (RCMP) officials                                                 Investigation (FBI) or     Investigation (FBI) or
                            and develop reporting procedures as                                                      Royal Canadian             Royal Canadian
                            appropriate to their circumstances.                                                      Mounted Police             Mounted Police
                                                                                                                     (RCMP) officials, but      (RCMP) officials, nor
                                                                                                                     has not developed a        developed a reporting
                                                                                                                     reporting procedure.       procedure.
 CIP-002-1   R1.            Critical Asset Identification Method — The    N/A               N/A                      N/A                        The responsible entity
                            Responsible Entity shall identify and                                                                               has not documented a
                            document a risk-based assessment                                                                                    risk-based assessment
                            methodology to use to identify its Critical                                                                         methodology to use to
                            Assets.                                                                                                             identify its Critical
                                                                                                                                                Assets as specified in
                                                                                                                                                R1.
CIP-002-1    R1.1           The Responsible Entity shall maintain         N/A               The Responsible          The Responsible            The Responsible
                            documentation describing its risk-based                         Entity maintained        Entity maintained          Entity did not maintain
                            assessment methodology that includes                            documentation            documentation              documentation
                            procedures and evaluation criteria.                             describing its risk-     describing its risk-       describing its risk-
                                                                                            based assessment         based assessment           based assessment
                                                                                            methodology which        methodology that           methodology that
                                                                                            includes evaluation      includes procedures        includes procedures
                                                                                            criteria, but does not   but does not include       and evaluation criteria.
                                                                                            include procedures. .    evaluation criteria.
CIP-002-1    R1.2           The risk-based assessment shall consider      N/A               N/A                      N/A                        The Responsible
                            the following assets:                                                                                               Entity did not consider
                                                                                                                                                all of the asset types
                                                                                                                                                listed in R1.2.1
                                                                                                                                                through R1.2.7 in its
                                                                                                                                                risk-based assessment.
CIP-002-1    R1.2.1.        Control centers and backup control centers    N/A               N/A                      N/A                        N/A

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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                         Lower VSL     Moderate VSL         High VSL                  Severe VSL
 Number        Number
                           performing the functions of the entities
                           listed in the Applicability section of this
                           standard.
CIP-002-1   R1.2.2.        Transmission substations that support the        N/A               N/A              N/A                       N/A
                           reliable operation of the Bulk Electric
                           System.
CIP-002-1   R1.2.3.        Generation resources that support the            N/A               N/A              N/A                       N/A
                           reliable operation of the Bulk Electric
                           System.
CIP-002-1   R1.2.4.        Systems and facilities critical to system        N/A               N/A              N/A                       N/A
                           restoration, including blackstart generators
                           and substations in the electrical path of
                           transmission lines used for initial system
                           restoration.
CIP-002-1   R1.2.5.        Systems and facilities critical to automatic     N/A               N/A              N/A                       N/A
                           load shedding under a common control
                           system capable of shedding 300 MW or
                           more.
CIP-002-1   R1.2.6.        Special Protection Systems that support the      N/A               N/A              N/A                       N/A
                           reliable operation of the Bulk Electric
                           System.
CIP-002-1   R1.2.7.        Any additional assets that support the           N/A               N/A              N/A                       N/A
                           reliable operation of the Bulk Electric
                           System that the Responsible Entity deems
                           appropriate to include in its assessment.
CIP-002-1   R2.            Critical Asset Identification — The              N/A               N/A              The Responsible           The Responsible
                           Responsible Entity shall develop a list of its                                      Entity has developed a    Entity did not develop
                           identified Critical Assets determined                                               list of Critical Assets   a list of its identified
                           through an annual application of the risk-                                          but the list has not      Critical Assets even if
                           based assessment methodology required in                                            been reviewed and         such list is null.
                           R1. The Responsible Entity shall review                                             updated annually as
                           this list at least annually, and update it as                                       required.
                           necessary.
CIP-002-1   R3.            Critical Cyber Asset Identification —            N/A               N/A              The Responsible           The Responsible
                           Using the list of Critical Assets developed                                         Entity has developed a    Entity did not develop
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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                         Lower VSL     Moderate VSL         High VSL                Severe VSL
 Number        Number
                           pursuant to Requirement R2, the                                                     list of associated       a list of associated
                           Responsible Entity shall develop a list of                                          Critical Cyber Assets    Critical Cyber Assets
                           associated Critical Cyber Assets essential to                                       essential to the         essential to the
                           the operation of the Critical Asset.                                                operation of the         operation of the
                           Examples at control centers and backup                                              Critical Asset list as   Critical Asset list as
                           control centers include systems and                                                 per requirement R2       per requirement R2
                           facilities at master and remote sites that                                          but the list has not     even if such list is
                           provide monitoring and control, automatic                                           been reviewed and        null.
                           generation control, real-time power system                                          updated annually as
                           modeling, and real-time inter utility data                                          required.
                           exchange. The Responsible Entity shall
                           review this list at least annually, and update
                           it as necessary. For the purpose of Standard
                           CIP-002, Critical Cyber Assets are further
                           qualified to be those having at least one of
                           the following characteristics:
CIP-002-1   R3.1           The Cyber Asset uses a routable protocol to      N/A               N/A              N/A                      A Cyber Asset
                           communicate outside the Electronic                                                                           essential to the
                           Security Perimeter; or,                                                                                      operation of the
                                                                                                                                        Critical Asset was
                                                                                                                                        identified that met the
                                                                                                                                        criteria in this
                                                                                                                                        requirement but was
                                                                                                                                        not included in the
                                                                                                                                        Critical Cyber Asset
                                                                                                                                        List.
CIP-002-1   R3.2.          The Cyber Asset uses a routable protocol         N/A               N/A              N/A                      A Cyber Asset
                           within a control center; or,                                                                                 essential to the
                                                                                                                                        operation of the
                                                                                                                                        Critical Asset was
                                                                                                                                        identified that met the
                                                                                                                                        criteria in this
                                                                                                                                        requirement but was
                                                                                                                                        not included in the
                                                                                                                                        Critical Cyber Asset
                                                                                                                                        List.
CIP-002-1   R3.3.          The Cyber Asset is dial-up accessible.           N/A               N/A              N/A                      A Cyber Asset

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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                     Text of Requirement                       Lower VSL     Moderate VSL         High VSL                 Severe VSL
 Number        Number
                                                                                                                                      essential to the
                                                                                                                                      operation of the
                                                                                                                                      Critical Asset was
                                                                                                                                      identified that met the
                                                                                                                                      criteria in this
                                                                                                                                      requirement but was
                                                                                                                                      not included in the
                                                                                                                                      Critical Cyber Asset
                                                                                                                                      List.
CIP-002-1   R4.            Annual Approval — A senior manager or         N/A               N/A              The Responsible           The Responsible
                           delegate(s) shall approve annually the list                                      Entity does not have a    Entity does not have a
                           of Critical Assets and the list of Critical                                      signed and dated          signed and dated
                           Cyber Assets. Based on Requirements R1,                                          record of the senior      record of the senior
                           R2, and R3 the Responsible Entity may                                            manager or                manager or
                           determine that it has no Critical Assets or                                      delegate(s)’s annual      delegate(s)’s annual
                           Critical Cyber Assets. The Responsible                                           approval of the list of   approval of both the
                           Entity shall keep a signed and dated record                                      Critical Assets.          list of Critical Assets
                           of the senior manager or delegate(s)’s                                           OR                        and the list of Critical
                           approval of the list of Critical Assets and                                                                Cyber Assets (even if
                                                                                                            The Responsible
                           the list of Critical Cyber Assets (even if                                                                 such lists are null.)
                                                                                                            Entity does not have a
                           such lists are null.)
                                                                                                            signed and dated
                                                                                                            record of the senior
                                                                                                            manager or
                                                                                                            delegate(s)’s annual
                                                                                                            approval of the list of
                                                                                                            Critical Cyber Assets
                                                                                                            (even if such lists are
                                                                                                            null.)
CIP-003-1   R1.            Cyber Security Policy — The Responsible       N/A               N/A              The Responsible           The Responsible
                           Entity shall document and implement a                                            Entity has documented     Entity has not
                           cyber security policy that represents                                            but not implemented a     documented nor
                           management’s commitment and ability to                                           cyber security policy.    implemented a cyber
                           secure its Critical Cyber Assets. The                                                                      security policy.
                           Responsible Entity shall, at minimum,
                           ensure the following:
CIP-003-1   R1.1.          The cyber security policy addresses the       N/A               N/A              N/A                       The Responsible
                           requirements in Standards CIP-002 through                                                                  Entity's cyber security
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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                     Text of Requirement                       Lower VSL      Moderate VSL               High VSL                Severe VSL
 Number        Number
                           CIP-009, including provision for                                                                                 policy does not
                           emergency situations.                                                                                            address all the
                                                                                                                                            requirements in
                                                                                                                                            Standards CIP-002
                                                                                                                                            through CIP-009,
                                                                                                                                            including provision for
                                                                                                                                            emergency situations.
CIP-003-1   R1.2.          The cyber security policy is readily          N/A               N/A                     N/A                      The Responsible
                           available to all personnel who have access                                                                       Entity's cyber security
                           to, or are responsible for, Critical Cyber                                                                       policy is not readily
                           Assets.                                                                                                          available to all
                                                                                                                                            personnel who have
                                                                                                                                            access to, or are
                                                                                                                                            responsible for,
                                                                                                                                            Critical Cyber Assets.
CIP-003-1   R1.3           Annual review and approval of the cyber       N/A               N/A                     The Responsible          The Responsible
                           security policy by the senior manager                                                   Entity's senior          Entity's senior
                           assigned pursuant to R2.                                                                manager, assigned        manager, assigned
                                                                                                                   pursuant to R2,          pursuant to R2, did not
                                                                                                                   annually reviewed but    annually review nor
                                                                                                                   did not annually         approve its cyber
                                                                                                                   approve its cyber        security policy.
                                                                                                                   security policy.
CIP-003-1   R2.            Leadership — The Responsible Entity shall     N/A               N/A                     N/A                      The Responsible
                           assign a senior manager with overall                                                                             Entity has not assigned
                           responsibility for leading and managing the                                                                      a senior manager with
                           entity’s implementation of, and adherence                                                                        overall responsibility
                           to, Standards CIP-002 through CIP-009.                                                                           for leading and
                                                                                                                                            managing the entity’s
                                                                                                                                            implementation of,
                                                                                                                                            and adherence to,
                                                                                                                                            Standards CIP-002
                                                                                                                                            through CIP-009.
CIP-003-1   R2.1.          The senior manager shall be identified by     N/A               The senior manager is   The senior manager is    The senior manager is
                           name, title, business phone, business                           identified by name,     identified by business   not identified by
                           address, and date of designation.                               title, and date of      phone and business       name, title, business
                                                                                           designation but the     address but the          phone, business
                                                                                                                                                         Page 30
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                     Text of Requirement                       Lower VSL            Moderate VSL                High VSL                 Severe VSL
 Number        Number
                                                                                                 designation is missing   designation is missing    address, and date of
                                                                                                 business phone or        one of the following:     designation.
                                                                                                 business address         name, title, or date of
                                                                                                                          designation
CIP-003-1   R2.2.          Changes to the senior manager must be         Changes to the senior   Changes to the senior    Changes to the senior     Changes to the senior
                           documented within thirty calendar days of     manager were            manager were             manager were              manager were
                           the effective date.                           documented in           documented in 60 or      documented in 90 or       documented in 120 or
                                                                         greater than 30 but     more but less than 90    more but less than 120    more days of the
                                                                         less than 60 days of    days of the effective    days of the effective     effective date.
                                                                         the effective date.     date.                    date.
CIP-003-1   R2.3.          The senior manager or delegate(s), shall      N/A                     N/A                      N/A                       The senior manager or
                           authorize and document any exception from                                                                                delegate(s) did not
                           the requirements of the cyber security                                                                                   authorize and
                           policy.                                                                                                                  document any
                                                                                                                                                    exception from the
                                                                                                                                                    requirements of the
                                                                                                                                                    cyber security policy
                                                                                                                                                    as required.
CIP-003-1   R3.            Exceptions — Instances where the              N/A                     N/A                      In Instances where the    In Instances where the
                           Responsible Entity cannot conform to its                                                       Responsible Entity        Responsible Entity
                           cyber security policy must be documented                                                       cannot conform to its     cannot conform to its
                           as exceptions and authorized by the senior                                                     cyber security policy     cyber security policy
                           manager or delegate(s).                                                                        (pertaining to CIP 002    (pertaining to CIP 002
                                                                                                                          through CIP 009),         through CIP 009),
                                                                                                                          exceptions were           exceptions were not
                                                                                                                          documented, but were      documented, and were
                                                                                                                          not authorized by the     not authorized by the
                                                                                                                          senior manager or         senior manager or
                                                                                                                          delegate(s).              delegate(s).
CIP-003-1   R3.1.          Exceptions to the Responsible Entity’s        Exceptions to the       Exceptions to the        Exceptions to the         Exceptions to the
                           cyber security policy must be documented      Responsible Entity’s    Responsible Entity’s     Responsible Entity’s      Responsible Entity’s
                           within thirty days of being approved by the   cyber security policy   cyber security policy    cyber security policy     cyber security policy
                           senior manager or delegate(s).                were documented in      were documented in       were documented in        were documented in
                                                                         more than 30 but less   60 or more but less      90 or more but less       120 or more days of
                                                                         than 60 days of being   than 90 days of being    than 120 days of being    being approved by the
                                                                         approved by the         approved by the senior   approved by the senior    senior manager or
                                                                         senior manager or       manager or               manager or                delegate(s).
                                                                                                                                                                 Page 31
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                         Lower VSL      Moderate VSL                High VSL                  Severe VSL
 Number        Number
                                                                            delegate(s).      delegate(s).             delegate(s).
CIP-003-1   R3.2.          Documented exceptions to the cyber               N/A               N/A                      The Responsible            The Responsible
                           security policy must include an explanation                                                 Entity has a               Entity has a
                           as to why the exception is necessary and                                                    documented exception       documented exception
                           any compensating measures, or a statement                                                   to the cyber security      to the cyber security
                           accepting risk.                                                                             policy (pertaining to      policy (pertaining to
                                                                                                                       CIP 002 through CIP        CIP 002 through CIP
                                                                                                                       009) but did not           009) but did not
                                                                                                                       include either:            include both:
                                                                                                                        1) an explanation as      1) an explanation as to
                                                                                                                       to why the exception       why the exception is
                                                                                                                       is necessary, or           necessary, and
                                                                                                                        2) any compensating       2) any compensating
                                                                                                                       measures or a              measures or a
                                                                                                                       statement accepting        statement accepting
                                                                                                                       risk.                      risk.
CIP-003-1   R3.3.          Authorized exceptions to the cyber security      N/A               N/A                      Exceptions to the          Exceptions to the
                           policy must be reviewed and approved                                                        cyber security policy      cyber security policy
                           annually by the senior manager or                                                           (pertaining to CIP 002     (pertaining to CIP 002
                           delegate(s) to ensure the exceptions are still                                              through CIP 009) were      through CIP 009) were
                           required and valid. Such review and                                                         reviewed but not           not reviewed nor
                           approval shall be documented.                                                               approved annually by       approved annually by
                                                                                                                       the senior manager or      the senior manager or
                                                                                                                       delegate(s) to ensure      delegate(s) to ensure
                                                                                                                       the exceptions are still   the exceptions are still
                                                                                                                       required and valid.        required and valid.
CIP-003-1   R4.            Information Protection — The Responsible         N/A               The Responsible          The Responsible            The Responsible
                           Entity shall implement and document a                              Entity implemented       Entity documented but      Entity did not
                           program to identify, classify, and protect                         but did not document a   did not implement a        implement nor
                           information associated with Critical Cyber                         program to identify,     program to identify,       document a program
                           Assets.                                                            classify, and protect    classify, and protect      to identify, classify,
                                                                                              information associated   information associated     and protect
                                                                                              with Critical Cyber      with Critical Cyber        information associated
                                                                                              Assets.                  Assets.                    with Critical Cyber
                                                                                                                                                  Assets.
CIP-003-1   R4.1.          The Critical Cyber Asset information to be       N/A               N/A                      The information            The information

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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                      Lower VSL      Moderate VSL                 High VSL                 Severe VSL
 Number        Number
                           protected shall include, at a minimum and                                                 protection program        protection program
                           regardless of media type, operational                                                     does not include one      does not include two
                           procedures, lists as required in Standard                                                 of the minimum            or more of the
                           CIP-002, network topology or similar                                                      information types to      minimum information
                           diagrams, floor plans of computing centers                                                be protected as           types to be protected
                           that contain Critical Cyber Assets,                                                       detailed in R4.1.         as detailed in R4.1.
                           equipment layouts of Critical Cyber Assets,
                           disaster recovery plans, incident response
                           plans, and security configuration
                           information.
CIP-003-1   R4.2.          The Responsible Entity shall classify         N/A               N/A                       N/A                       The Responsible
                           information to be protected under this                                                                              Entity did not classify
                           program based on the sensitivity of the                                                                             the information to be
                           Critical Cyber Asset information.                                                                                   protected under this
                                                                                                                                               program based on the
                                                                                                                                               sensitivity of the
                                                                                                                                               Critical Cyber Asset
                                                                                                                                               information.
CIP-003-1   R4.3.          The Responsible Entity shall, at least        N/A               The Responsible           The Responsible           The Responsible
                           annually, assess adherence to its Critical                      Entity annually           Entity annually           Entity did not
                           Cyber Asset information protection                              assessed adherence to     assessed adherence to     annually, assess
                           program, document the assessment results,                       its Critical Cyber        its Critical Cyber        adherence to its
                           and implement an action plan to remediate                       Asset information         Asset information         Critical Cyber Asset
                           deficiencies identified during the                              protection program,       protection program,       information protection
                           assessment.                                                     documented the            did not document the      program, document
                                                                                           assessment results,       assessment results, and   the assessment results,
                                                                                           which included            did not implement a       nor implement an
                                                                                           deficiencies identified   remediation plan.         action plan to
                                                                                           during the assessment                               remediate deficiencies
                                                                                           but did not implement                               identified during the
                                                                                           a remediation plan.                                 assessment.
CIP-003-1   R5.            Access Control — The Responsible Entity       N/A               The Responsible           The Responsible           The Responsible
                           shall document and implement a program                          Entity implemented        Entity documented but     Entity did not
                           for managing access to protected Critical                       but did not document a    did not implement a       implement nor
                           Cyber Asset information.                                        program for managing      program for managing      document a program
                                                                                           access to protected       access to protected       for managing access to
                                                                                           Critical Cyber Asset      Critical Cyber Asset      protected Critical

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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                        Lower VSL      Moderate VSL         High VSL                  Severe VSL
 Number        Number
                                                                                             information.      information.               Cyber Asset
                                                                                                                                          information.
CIP-003-1   R5.1.          The Responsible Entity shall maintain a list    N/A               N/A               The Responsible            The Responsible
                           of designated personnel who are                                                     Entity maintained a        Entity did not maintain
                           responsible for authorizing logical or                                              list of designated         a list of designated
                           physical access to protected information.                                           personnel for              personnel who are
                                                                                                               authorizing either         responsible for
                                                                                                               logical or physical        authorizing logical or
                                                                                                               access but not both.       physical access to
                                                                                                                                          protected information.
CIP-003-1   R5.1.1.        Personnel shall be identified by name, title,   N/A               N/A               The Responsible            The Responsible
                           business phone and the information for                                              Entity did identify the    Entity did not identify
                           which they are responsible for authorizing                                          personnel by name,         the personnel by
                           access.                                                                             title, business phone      name, title, business
                                                                                                               but did not identify the   phone nor the
                                                                                                               information for which      information for which
                                                                                                               they are responsible       they are responsible
                                                                                                               for authorizing access.    for authorizing access.
CIP-003-1   R5.1.2.        The list of personnel responsible for           N/A               N/A               N/A                        The Responsible
                           authorizing access to protected information                                                                    Entity did not verify at
                           shall be verified at least annually.                                                                           least annually the list
                                                                                                                                          of personnel
                                                                                                                                          responsible for
                                                                                                                                          authorizing access to
                                                                                                                                          protected information.
CIP-003-1   R5.2.          The Responsible Entity shall review at least    N/A               N/A               N/A                        The Responsible
                           annually the access privileges to protected                                                                    Entity did not review
                           information to confirm that access                                                                             at least annually the
                           privileges are correct and that they                                                                           access privileges to
                           correspond with the Responsible Entity’s                                                                       protected information
                           needs and appropriate personnel roles and                                                                      to confirm that access
                           responsibilities.                                                                                              privileges are correct
                                                                                                                                          and that they
                                                                                                                                          correspond with the
                                                                                                                                          Responsible Entity’s
                                                                                                                                          needs and appropriate
                                                                                                                                          personnel roles and
                                                                                                                                                         Page 34
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                     Text of Requirement                        Lower VSL             Moderate VSL                High VSL                 Severe VSL
 Number        Number
                                                                                                                                                      responsibilities.
CIP-003-1   R5.3.          The Responsible Entity shall assess and        N/A                      N/A                      N/A                       The Responsible
                           document at least annually the processes for                                                                               Entity did not assess
                           controlling access privileges to protected                                                                                 and document at least
                           information.                                                                                                               annually the processes
                                                                                                                                                      for controlling access
                                                                                                                                                      privileges to protected
                                                                                                                                                      information.
CIP-003-1   R6.            Change Control and Configuration               The Responsible          The Responsible          The Responsible           The Responsible
                           Management — The Responsible Entity            Entity has established   Entity has established   Entity has not            Entity has not
                           shall establish and document a process of      but not documented a     but not documented       established and           established and
                           change control and configuration               change control           both a change control    documented a change       documented a change
                           management for adding, modifying,              process                  process and              control process           control process
                           replacing, or removing Critical Cyber Asset    OR                       configuration            OR                        AND
                           hardware or software, and implement                                     management process.
                                                                          The Responsible                                   The Responsible           The Responsible
                           supporting configuration management
                                                                          Entity has established                            Entity has not            Entity has not
                           activities to identify, control and document
                                                                          but not documented a                              established and           established and
                           all entity or vendor related changes to
                                                                          configuration                                     documented a              documented a
                           hardware and software components of
                                                                          management process.                               configuration             configuration
                           Critical Cyber Assets pursuant to the
                                                                                                                            management process.       management process.
                           change control process.
CIP-004-1   R1.            Awareness — The Responsible Entity shall       The Responsible          The Responsible          The Responsible           The Responsible
                           establish, maintain, and document a            Entity established       Entity established and   Entity did document       Entity did not
                           security awareness program to ensure           and maintained but       maintained but did not   but did not establish     establish, maintain,
                           personnel having authorized cyber or           did not document a       document a security      nor maintain a security   nor document a
                           authorized unescorted physical access          security awareness       awareness program to     awareness program to      security awareness
                           receive on-going reinforcement in sound        program to ensure        ensure personnel         ensure personnel          program to ensure
                           security practices. The program shall          personnel having         having authorized        having authorized         personnel having
                           include security awareness reinforcement       authorized cyber or      cyber or authorized      cyber or authorized       authorized cyber or
                           on at least a quarterly basis using            authorized unescorted    unescorted physical      unescorted physical       authorized unescorted
                           mechanisms such as:                            physical access          access receive on-       access receive on-        physical access
                           • Direct communications (e.g., emails,         receive on-going         going reinforcement in   going reinforcement in    receive on-going
                           memos, computer based training, etc.);         reinforcement in         sound security           sound security            reinforcement in
                                                                          sound security           practices.               practices.                sound security
                           • Indirect communications (e.g., posters,
                                                                          practices.               AND                                                practices.
                           intranet, brochures, etc.);
                           • Management support and reinforcement                                   The Responsible
                                                                                                   Entity did not provide
                                                                                                                                                                    Page 35
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                      Lower VSL             Moderate VSL                  High VSL                 Severe VSL
 Number        Number
                           (e.g., presentations, meetings, etc.).                                 security awareness
                                                                                                  reinforcement on at
                                                                                                  least a quarterly basis.
CIP-004-1   R2.            Training — The Responsible Entity shall       The Responsible          The Responsible            The Responsible           The Responsible
                           establish, maintain, and document an          Entity established       Entity established and     Entity did document       Entity did not
                           annual cyber security training program for    and maintained but       maintained but did not     but did not establish     establish, maintain,
                           personnel having authorized cyber or          did not document an      document an annual         nor maintain an annual    nor document an
                           authorized unescorted physical access to      annual cyber security    cyber security training    cyber security training   annual cyber security
                           Critical Cyber Assets, and review the         training program for     program for personnel      program for personnel     training program for
                           program annually and update as necessary.     personnel having         having authorized          having authorized         personnel having
                                                                         authorized cyber or      cyber or authorized        cyber or authorized       authorized cyber or
                                                                         authorized unescorted    unescorted physical        unescorted physical       authorized unescorted
                                                                         physical access to       access to Critical         access to Critical        physical access to
                                                                         Critical Cyber Assets.   Cyber Assets               Cyber Assets.             Critical Cyber Assets.
                                                                                                  AND
                                                                                                  The Responsible
                                                                                                  Entity did not review
                                                                                                  the training program
                                                                                                  on an annual basis.
CIP-004-1   R2.1.          This program will ensure that all personnel   At least one             At least 5% but less       At least 10% but less     15% or more of all
                           having such access to Critical Cyber          individual but less      than 10% of all            than 15% of all           personnel having
                           Assets, including contractors and service     than 5% of personnel     personnel having           personnel having          access to Critical
                           vendors, are trained within ninety calendar   having access to         access to Critical         access to Critical        Cyber Assets,
                           days of such authorization.                   Critical Cyber Assets,   Cyber Assets,              Cyber Assets,             including contractors
                                                                         including contractors    including contractors      including contractors     and service vendors,
                                                                         and service vendors,     and service vendors,       and service vendors,      were not trained
                                                                         were not trained         were not trained           were not trained          within ninety calendar
                                                                         within ninety            within ninety calendar     within ninety calendar    days of such
                                                                         calendar days of such    days of such               days of such              authorization.
                                                                         authorization.           authorization.             authorization.
CIP-004-1   R2.2.          Training shall cover the policies, access     N/A                      The training does not      The training does not     The training does not
                           controls, and procedures as developed for                              include one of the         include two of the        include three or more
                           the Critical Cyber Assets covered by CIP-                              minimum topics as          minimum topics as         of the minimum topics
                           004, and include, at a minimum, the                                    detailed in R2.2.1,        detailed in R2.2.1,       as detailed in R2.2.1,
                           following required items appropriate to                                R2.2.2, R2.2.3, R2.2.4.    R2.2.2, R2.2.3, R2.2.4.   R2.2.2, R2.2.3, R2.2.4.
                           personnel roles and responsibilities:

                                                                                                                                                                    Page 36
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                      Lower VSL      Moderate VSL                High VSL                   Severe VSL
 Number        Number
CIP-004-1   R2.2.1.        The proper use of Critical Cyber Assets;      N/A               N/A                      N/A                        N/A
CIP-004-1   R2.2.2.        Physical and electronic access controls to    N/A               N/A                      N/A                        N/A
                           Critical Cyber Assets;
CIP-004-1   R2.2.3.        The proper handling of Critical Cyber Asset   N/A               N/A                      N/A                        N/A
                           information; and,
CIP-004-1   R2.2.4.        Action plans and procedures to recover or     N/A               N/A                      N/A                        N/A
                           re-establish Critical Cyber Assets and
                           access thereto following a Cyber Security
                           Incident.
CIP-004-1   R2.3.          The Responsible Entity shall maintain         N/A               N/A                      The Responsible            The Responsible
                           documentation that training is conducted at                                              Entity did maintain        Entity did not maintain
                           least annually, including the date the                                                   documentation that         documentation that
                           training was completed and attendance                                                    training is conducted      training is
                           records.                                                                                 at least annually, but      conducted at least
                                                                                                                    did not include either     annually, including the
                                                                                                                    the date the training      date the training was
                                                                                                                    was completed or           completed or
                                                                                                                    attendance records.        attendance records.
CIP-004-1   R3.            Personnel Risk Assessment —The                N/A               The Responsible          The Responsible            The Responsible
                           Responsible Entity shall have a                                 Entity has a personnel   Entity has a personnel     Entity does not have a
                           documented personnel risk assessment                            risk assessment          risk assessment            documented personnel
                           program, in accordance with federal, state,                     program, in              program as stated in       risk assessment
                           provincial, and local laws, and subject to                      accordance with          R3, but conducted the      program, in
                           existing collective bargaining unit                             federal, state,          personnel risk             accordance with
                           agreements, for personnel having                                provincial, and local    assessment pursuant to     federal, state,
                           authorized cyber or authorized unescorted                       laws, and subject to     that program in more       provincial, and local
                           physical access. A personnel risk                               existing collective      than thirty (30) days of   laws, and subject to
                           assessment shall be conducted pursuant to                       bargaining unit          such personnel being       existing collective
                           that program within thirty days of such                         agreements, for          granted such access.       bargaining unit
                           personnel being granted such access. Such                       personnel having                                    agreements, for
                           program shall at a minimum include:                             authorized cyber or                                 personnel having
                                                                                           authorized unescorted                               authorized cyber or
                                                                                           physical access, but                                authorized unescorted
                                                                                           the program is not                                  physical access.
                                                                                           documented.

                                                                                                                                                           Page 37
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL           Moderate VSL                 High VSL                 Severe VSL
 Number        Number
                                                                                                                                                     OR

                                                                                                                                                     The Responsible
                                                                                                                                                     Entity did not conduct
                                                                                                                                                     the personnel risk
                                                                                                                                                     assessment pursuant to
                                                                                                                                                     that program for
                                                                                                                                                     personnel granted such
                                                                                                                                                     access.
CIP-004-1   R3.1.          The Responsible Entity shall ensure that       N/A                    N/A                       The Responsible           The Responsible
                           each assessment conducted include, at least,                                                    Entity did not ensure     Entity did not ensure
                           identity verification (e.g., Social Security                                                    that an assessment        that each assessment
                           Number verification in the U.S.) and seven                                                      conducted included an     conducted include, at
                           year criminal check. The Responsible                                                            identity verification     least, identity
                           Entity may conduct more detailed reviews,                                                       (e.g., Social Security    verification (e.g.,
                           as permitted by law and subject to existing                                                     Number verification in    Social Security
                           collective bargaining unit agreements,                                                          the U.S.) or a seven-     Number verification in
                           depending upon the criticality of the                                                           year criminal check.      the U.S.) and seven-
                           position.                                                                                                                 year criminal check.
CIP-004-1   R3.2.          The Responsible Entity shall update each       N/A                    The Responsible           The Responsible           The Responsible
                           personnel risk assessment at least every                              Entity did not update     Entity did not update     Entity did not update
                           seven years after the initial personnel risk                          each personnel risk       each personnel risk       each personnel risk
                           assessment or for cause.                                              assessment at least       assessment for cause      assessment at least
                                                                                                 every seven years after   (when applicable) but     every seven years after
                                                                                                 the initial personnel     did at least updated it   the initial personnel
                                                                                                 risk assessment but did   every seven years after   risk assessment nor
                                                                                                 update it for cause       the initial personnel     was it updated for
                                                                                                 when applicable.          risk assessment.          cause when applicable.
CIP-004-1   R3.3.          The Responsible Entity shall document the      The Responsible        The Responsible           The Responsible           The Responsible
                           results of personnel risk assessments of its   Entity did not         Entity did not            Entity did not            Entity did not
                           personnel having authorized cyber or           document the results   document the results      document the results      document the results
                           authorized unescorted physical access to       of personnel risk      of personnel risk         of personnel risk         of personnel risk
                           Critical Cyber Assets, and that personnel      assessments for at     assessments for 5% or     assessments for 10%       assessments for 15%
                           risk assessments of contractor and service     least one individual   more but less than        or more but less than     or more of all
                           vendor personnel with such access are          but less than 5% of    10% of all personnel      15% of all personnel      personnel with
                           conducted pursuant to Standard CIP-004.        all personnel with     with authorized cyber     with authorized cyber     authorized cyber or
                                                                          authorized cyber or    or authorized             or authorized             authorized unescorted
                                                                                                                                                                 Page 38
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL             Moderate VSL                  High VSL                  Severe VSL
 Number        Number
                                                                          authorized unescorted    unescorted physical        unescorted physical        physical access to
                                                                          physical access to       access to Critical         access to Critical         Critical Cyber Assets,
                                                                          Critical Cyber Assets,   Cyber Assets, pursuant     Cyber Assets, pursuant     pursuant to Standard
                                                                          pursuant to Standard     to Standard CIP-004.       to Standard CIP-004.       CIP-004.
                                                                          CIP-004.
CIP-004-1   R4.            Access — The Responsible Entity shall          The Responsible          The Responsible            The Responsible            The Responsible
                           maintain list(s) of personnel with             Entity did not           Entity did not maintain    Entity did not maintain    Entity did not maintain
                           authorized cyber or authorized unescorted      maintain complete        complete list(s) of        complete list(s) of        complete list(s) of
                           physical access to Critical Cyber Assets,      list(s) of personnel     personnel with             personnel with             personnel with
                           including their specific electronic and        with authorized cyber    authorized cyber or        authorized cyber or        authorized cyber or
                           physical access rights to Critical Cyber       or authorized            authorized unescorted      authorized unescorted      authorized unescorted
                           Assets.                                        unescorted physical      physical access to         physical access to         physical access to
                                                                          access to Critical       Critical Cyber Assets,     Critical Cyber Assets,     Critical Cyber Assets,
                                                                          Cyber Assets,            including their specific   including their specific   including their specific
                                                                          including their          electronic and physical    electronic and physical    electronic and physical
                                                                          specific electronic      access rights to           access rights to           access rights to
                                                                          and physical access      Critical Cyber Assets,     Critical Cyber Assets,     Critical Cyber Assets,
                                                                          rights to Critical       missing 5% or more         missing 10% or more        missing 15% or more
                                                                          Cyber Assets,            but less than 10% of       but less than 15%of        of the authorized
                                                                          missing at least one     the authorized             the authorized             personnel.
                                                                          individual but less      personnel.                 personnel.
                                                                          than 5% of the
                                                                          authorized personnel.
CIP-004-1   R4.1.          The Responsible Entity shall review the        N/A                      The Responsible            The Responsible            The Responsible
                           list(s) of its personnel who have such                                  Entity did not review      Entity did not update      Entity did not review
                           access to Critical Cyber Assets quarterly,                              the list(s) of its         the list(s) within seven   the list(s) of all
                           and update the list(s) within seven calendar                            personnel who have         calendar days of any       personnel who have
                           days of any change of personnel with such                               access to Critical         change of personnel        access to Critical
                           access to Critical Cyber Assets, or any                                 Cyber Assets               with such access to        Cyber Assets
                           change in the access rights of such                                     quarterly.                 Critical Cyber Assets,     quarterly, nor update
                           personnel. The Responsible Entity shall                                                            nor any change in the      the list(s) within seven
                           ensure access list(s) for contractors and                                                          access rights of such      calendar days of any
                           service vendors are properly maintained.                                                           personnel.                 change of personnel
                                                                                                                                                         with such access to
                                                                                                                                                         Critical Cyber Assets,
                                                                                                                                                         nor any change in the
                                                                                                                                                         access rights of such
                                                                                                                                                         personnel.
                                                                                                                                                                      Page 39
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                     Text of Requirement                      Lower VSL             Moderate VSL                High VSL                 Severe VSL
 Number        Number
CIP-004-1   R4.2.          The Responsible Entity shall revoke such     N/A                      The Responsible          The Responsible           The Responsible
                           access to Critical Cyber Assets within 24                             Entity did not revoke    Entity did not revoke     Entity did not revoke
                           hours for personnel terminated for cause                              access within seven      access to Critical        access to Critical
                           and within seven calendar days for                                    calendar days for        Cyber Assets within       Cyber Assets within
                           personnel who no longer require such                                  personnel who no         24 hours for personnel    24 hours for personnel
                           access to Critical Cyber Assets.                                      longer require such      terminated for cause.     terminated for cause
                                                                                                 access to Critical                                 nor within seven
                                                                                                 Cyber Assets.                                      calendar days for
                                                                                                                                                    personnel who no
                                                                                                                                                    longer require such
                                                                                                                                                    access to Critical
                                                                                                                                                    Cyber Assets.
CIP-005-1   R1.            Electronic Security Perimeter — The          The Responsible          The Responsible          The Responsible           The Responsible
                           Responsible Entity shall ensure that every   Entity did not           Entity identified but    Entity did not ensure     Entity did not ensure
                           Critical Cyber Asset resides within an       document one or          did not document one     that one or more of the   that one or more
                           Electronic Security Perimeter. The           more access points to    or more Electronic       Critical Cyber Assets     Critical Cyber Assets
                           Responsible Entity shall identify and        the electronic           Security Perimeter(s).   resides within an         resides within an
                           document the Electronic Security             security perimeter(s).                            Electronic Security       Electronic Security
                           Perimeter(s) and all access points to the                                                      Perimeter.                Perimeter, and the
                           perimeter(s).                                                                                  OR                        Responsible Entity did
                                                                                                                                                    not identify and
                                                                                                                          The Responsible
                                                                                                                                                    document the
                                                                                                                          Entity did not identify
                                                                                                                                                    Electronic Security
                                                                                                                          nor document one or
                                                                                                                                                    Perimeter(s) and all
                                                                                                                          more Electronic
                                                                                                                                                    access points to the
                                                                                                                          Security Perimeter(s).
                                                                                                                                                    perimeter(s) for all
                                                                                                                                                    Critical Cyber Assets.
CIP-005-1   R1.1.          Access points to the Electronic Security     N/A                      N/A                      N/A                       Access points to the
                           Perimeter(s) shall include any externally                                                                                Electronic Security
                           connected communication end point (for                                                                                   Perimeter(s) do not
                           example, dial-up modems) terminating at                                                                                  include all externally
                           any device within the Electronic Security                                                                                connected
                           Perimeter(s).                                                                                                            communication end
                                                                                                                                                    point (for example,
                                                                                                                                                    dial-up modems)
                                                                                                                                                    terminating at any
                                                                                                                                                    device within the
                                                                                                                                                    Electronic Security
                                                                                                                                                                  Page 40
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                        Lower VSL            Moderate VSL                High VSL                 Severe VSL
 Number        Number
                                                                                                                                                      Perimeter(s).
CIP-005-1   R1.2.          For a dial-up accessible Critical Cyber         N/A                     N/A                      N/A                       For one or more dial-
                           Asset that uses a non-routable protocol, the                                                                               up accessible Critical
                           Responsible Entity shall define an                                                                                         Cyber Assets that use
                           Electronic Security Perimeter for that single                                                                              a non-routable
                           access point at the dial-up device.                                                                                        protocol, the
                                                                                                                                                      Responsible Entity did
                                                                                                                                                      not define an
                                                                                                                                                      Electronic Security
                                                                                                                                                      Perimeter for that
                                                                                                                                                      single access point at
                                                                                                                                                      the dial-up device.
CIP-005-1   R1.3.          Communication links connecting discrete         N/A                     N/A                      N/A                       At least one end point
                           Electronic Security Perimeters shall not be                                                                                of a communication
                           considered part of the Electronic Security                                                                                 link within the
                           Perimeter. However, end points of these                                                                                    Electronic Security
                           communication links within the Electronic                                                                                  Perimeter(s)
                           Security Perimeter(s) shall be considered                                                                                  connecting discrete
                           access points to the Electronic Security                                                                                   Electronic Security
                           Perimeter(s).                                                                                                              Perimeters was not
                                                                                                                                                      considered an access
                                                                                                                                                      point to the Electronic
                                                                                                                                                      Security Perimeter.
CIP-005-1   R1.4.          Any non-critical Cyber Asset within a           N/A                     One or more non-         One or more non-          One or more non-
                           defined Electronic Security Perimeter shall                             critical Cyber Asset     critical Cyber Asset      critical Cyber Asset
                           be identified and protected pursuant to the                             within a defined         within a defined          within a defined
                           requirements of Standard CIP-005.                                       Electronic Security      Electronic Security       Electronic Security
                                                                                                   Perimeter is not         Perimeter is identified   Perimeter is not
                                                                                                   identified but is        but not protected         identified and is not
                                                                                                   protected pursuant to    pursuant to the           protected pursuant to
                                                                                                   the requirements of      requirements of           the requirements of
                                                                                                   Standard CIP-005.        Standard CIP-005.         Standard CIP-005.
CIP-005-1   R1.5.          Cyber Assets used in the access control and     A Cyber Asset used      A Cyber Asset used in    A Cyber Asset used in     A Cyber Asset used in
                           monitoring of the Electronic Security           in the access control   the access control and   the access control and    the access control and
                           Perimeter(s) shall be afforded the protective   and monitoring of the   monitoring of the        monitoring of the         monitoring of the
                           measures as a specified in Standard CIP-        Electronic Security     Electronic Security      Electronic Security       Electronic Security
                           003, Standard CIP-004 Requirement R3,           Perimeter(s) is         Perimeter(s) is          Perimeter(s) is           Perimeter(s) is not
                                                                                                                                                                      Page 41
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                        Lower VSL            Moderate VSL                High VSL                 Severe VSL
 Number        Number
                           Standard CIP-005 Requirements R2 and            provided with all but   provided with all but    provided all but three    provided four (4) or
                           R3, Standard CIP-006 Requirements R2            one (1) of the          two (2) of the           (3) of the protective     more of the protective
                           and R3, Standard CIP-007, Requirements          protective measures     protective measures as   measures as specified     measures as specified
                           R1 and R3 through R9, Standard CIP-008,         as specified in         specified in Standard    in Standard CIP-003,      in Standard CIP-003,
                           and Standard CIP-009.                           Standard CIP-003,       CIP-003, Standard        Standard CIP-004          Standard CIP-004
                                                                           Standard CIP-004        CIP-004 Requirement      Requirement R3,           Requirement R3,
                                                                           Requirement R3,         R3, Standard CIP-005     Standard CIP-005          Standard CIP-005
                                                                           Standard CIP-005        Requirements R2 and      Requirements R2 and       Requirements R2 and
                                                                           Requirements R2 and     R3, Standard CIP-006     R3, Standard CIP-006      R3, Standard CIP-006
                                                                           R3, Standard CIP-       Requirements R2 and      Requirements R2 and       Requirements R2 and
                                                                           006 Requirements R2     R3, Standard CIP-007,    R3, Standard CIP-007,     R3, Standard CIP-007,
                                                                           and R3, Standard        Requirements R1 and      Requirements R1 and       Requirements R1 and
                                                                           CIP-007,                R3 through R9,           R3 through R9,            R3 through R9,
                                                                           Requirements R1 and     Standard CIP-008, and    Standard CIP-008, and     Standard CIP-008, and
                                                                           R3 through R9,          Standard CIP-009.        Standard CIP-009.         Standard CIP-009.
                                                                           Standard CIP-008,
                                                                           and Standard CIP-
                                                                           009.
CIP-005-1   R1.6.          The Responsible Entity shall maintain           N/A                     N/A                      The Responsible           The Responsible
                           documentation of Electronic Security                                                             Entity did not maintain   Entity did not maintain
                           Perimeter(s), all interconnected Critical and                                                    documentation of one      documentation of two
                           non-critical Cyber Assets within the                                                             of the following:         or more of the
                           Electronic Security Perimeter(s), all                                                            Electronic Security       following: Electronic
                           electronic access points to the Electronic                                                       Perimeter(s),             Security Perimeter(s),
                           Security Perimeter(s) and the Cyber Assets                                                       interconnected Critical   interconnected Critical
                           deployed for the access control and                                                              and non-critical Cyber    and non-critical Cyber
                           monitoring of these access points.                                                               Assets within the         Assets within the
                                                                                                                            Electronic Security       Electronic Security
                                                                                                                            Perimeter(s),             Perimeter(s),
                                                                                                                            electronic access point   electronic access
                                                                                                                            to the Electronic         points to the
                                                                                                                            Security Perimeter(s)     Electronic Security
                                                                                                                            or Cyber Asset            Perimeter(s) and
                                                                                                                            deployed for the          Cyber Assets deployed
                                                                                                                            access control and        for the access control
                                                                                                                            monitoring of these       and monitoring of
                                                                                                                            access points.            these access points.
CIP-005-1   R2.            Electronic Access Controls — The                N/A                     The Responsible          The Responsible           The Responsible
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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                         Lower VSL      Moderate VSL                  High VSL                  Severe VSL
 Number        Number
                           Responsible Entity shall implement and                             Entity implemented         Entity documented but      Entity did not
                           document the organizational processes and                          but did not document       did not implement the      implement nor
                           technical and procedural mechanisms for                            the organizational         organizational             document the
                           control of electronic access at all electronic                     processes and              processes and              organizational
                           access points to the Electronic Security                           technical and              technical and              processes and
                           Perimeter(s).                                                      procedural                 procedural                 technical and
                                                                                              mechanisms for             mechanisms for             procedural
                                                                                              control of electronic      control of electronic      mechanisms for
                                                                                              access at all electronic   access at all electronic   control of electronic
                                                                                              access points to the       access points to the       access at all electronic
                                                                                              Electronic Security        Electronic Security        access points to the
                                                                                              Perimeter(s).              Perimeter(s).              Electronic Security
                                                                                                                                                    Perimeter(s).
CIP-005-1   R2.1.          These processes and mechanisms shall use         N/A               N/A                        N/A                        The processes and
                           an access control model that denies access                                                                               mechanisms did not
                           by default, such that explicit access                                                                                    use an access control
                           permissions must be specified.                                                                                           model that denies
                                                                                                                                                    access by default, such
                                                                                                                                                    that explicit access
                                                                                                                                                    permissions must be
                                                                                                                                                    specified.
CIP-005-1   R2.2.          At all access points to the Electronic           N/A               At one or more access      At one or more access      At one or more access
                           Security Perimeter(s), the Responsible                             points to the              points to the              points to the
                           Entity shall enable only ports and services                        Electronic Security        Electronic Security        Electronic Security
                           required for operations and for monitoring                         Perimeter(s), the          Perimeter(s), the          Perimeter(s), the
                           Cyber Assets within the Electronic Security                        Responsible Entity did     Responsible Entity         Responsible Entity
                           Perimeter, and shall document, individually                        not document,              enabled ports and          enabled ports and
                           or by specified grouping, the configuration                        individually or by         services not required      services not required
                           of those ports and services.                                       specified grouping, the    for operations and for     for operations and for
                                                                                              configuration of those     monitoring Cyber           monitoring Cyber
                                                                                              ports and services         Assets within the          Assets within the
                                                                                              required for operation     Electronic Security        Electronic Security
                                                                                              and for monitoring         Perimeter but did          Perimeter, and did not
                                                                                              Cyber Assets within        document,                  document,
                                                                                              the Electronic Security    individually or by         individually or by
                                                                                              Perimeter.                 specified grouping, the    specified grouping, the
                                                                                                                         configuration of those     configuration of those
                                                                                                                         ports and services.        ports and services.
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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL             Moderate VSL                High VSL                Severe VSL
 Number        Number
CIP-005-1   R2.3.          The Responsible Entity shall maintain a        N/A                      N/A                      N/A                     The Responsible
                           procedure for securing dial-up access to the                                                                             Entity did not maintain
                           Electronic Security Perimeter(s).                                                                                        a procedure for
                                                                                                                                                    securing dial-up
                                                                                                                                                    access to the
                                                                                                                                                    Electronic Security
                                                                                                                                                    Perimeter(s) where
                                                                                                                                                    applicable.
CIP-005-1   R2.4.          Where external interactive access into the     N/A                      N/A                      N/A                     Where external
                           Electronic Security Perimeter has been                                                                                   interactive access into
                           enabled, the Responsible Entity shall                                                                                    the Electronic Security
                           implement strong procedural or technical                                                                                 Perimeter has been
                           controls at the access points to ensure                                                                                  enabled the
                           authenticity of the accessing party, where                                                                               Responsible Entity did
                           technically feasible.                                                                                                    not implement strong
                                                                                                                                                    procedural or technical
                                                                                                                                                    controls at the access
                                                                                                                                                    points to ensure
                                                                                                                                                    authenticity of the
                                                                                                                                                    accessing party, where
                                                                                                                                                    technically feasible.
CIP-005-1   R2.5.          The required documentation shall, at least,    The required             The required             The required            The required
                           identify and describe:                         documentation for R2     documentation for R2     documentation for R2    documentation for R2
                                                                          did not include one of   did not include two of   did not include three   did not include any of
                                                                          the elements             the elements described   of the elements         the elements described
                                                                          described in R2.5.1      in R2.5.1 through        described in R2.5.1     in R2.5.1 through
                                                                          through R2.5.4           R2.5.4                   through R2.5.4          R2.5.4
CIP-005-1   R2.5.1.        The processes for access request and           N/A                      N/A                      N/A                     N/A
                           authorization.
CIP-005-1   R2.5.2.        The authentication methods.                    N/A                      N/A                      N/A                     N/A
CIP-005-1   R2.5.3.        The review process for authorization rights,   N/A                      N/A                      N/A                     N/A
                           in accordance with Standard CIP-004
                           Requirement R4.
CIP-005-1   R2.5.4.        The controls used to secure dial-up            N/A                      N/A                      N/A                     N/A
                           accessible connections.

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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                     Lower VSL               Moderate VSL                High VSL                 Severe VSL
 Number        Number
CIP-005-1   R2.6.          Appropriate Use Banner — Where                 The Responsible          Where technically        Where technically         Where technically
                           technically feasible, electronic access        Entity did not           feasible 5% but less     feasible 10% but less     feasible, 15% or more
                           control devices shall display an appropriate   maintain a document      than 10% of electronic   than 15% of electronic    electronic access
                           use banner on the user screen upon all         identifying the          access control devices   access control devices    control devices did not
                           interactive access attempts. The               content of the banner.   did not display an       did not display an        display an appropriate
                           Responsible Entity shall maintain a            OR                       appropriate use banner   appropriate use banner    use banner on the user
                           document identifying the content of the                                 on the user screen       on the user screen        screen upon all
                                                                          Where technically
                           banner.                                                                 upon all interactive     upon all interactive      interactive access
                                                                          feasible less than 5%
                                                                                                   access attempts.         access attempts.          attempts.
                                                                          electronic access
                                                                          control devices did
                                                                          not display an
                                                                          appropriate use
                                                                          banner on the user
                                                                          screen upon all
                                                                          interactive access
                                                                          attempts.
CIP-005-1   R3.            Monitoring Electronic Access — The             The Responsible          The Responsible          The Responsible           The Responsible
                           Responsible Entity shall implement and         Entity did not           Entity did not           Entity did not            Entity did not
                           document an electronic or manual               document the             implement electronic     implement electronic      implement electronic
                           process(es) for monitoring and logging         electronic or manual     or manual processes      or manual processes       or manual processes
                           access at access points to the Electronic      processes for            monitoring and           monitoring and            monitoring and
                           Security Perimeter(s) twenty-four hours a      monitoring and           logging at 5% or more    logging at 10% or         logging at 15% or
                           day, seven days a week.                        logging access to        but less than 10% of     more but less than 15     more of the access
                                                                          access points.           the access points.       % of the access points.   points.
                                                                          OR
                                                                          The Responsible
                                                                          Entity did not
                                                                          implement electronic
                                                                          or manual processes
                                                                          monitoring and
                                                                          logging at less than
                                                                          5% of the access
                                                                          points.
CIP-005-1   R3.1.          For dial-up accessible Critical Cyber Assets   The Responsible          Where technically        Where technically         Where technically
                           that use non-routable protocols, the           Entity did not           feasible, the            feasible, the             feasible, the
                           Responsible Entity shall implement and         document the             Responsible Entity did   Responsible Entity did    Responsible Entity did
                           document monitoring process(es) at each        electronic or manual     not implement            not implement             not implement
                                                                                                                                                                    Page 45
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                        Lower VSL            Moderate VSL                High VSL                 Severe VSL
 Number        Number
                           access point to the dial-up device, where       processes for           electronic or manual     electronic or manual      electronic or manual
                           technically feasible.                           monitoring access       processes for            processes for             processes for
                                                                           points to dial-up       monitoring at 5% or      monitoring at 10% or      monitoring at 15% or
                                                                           devices.                more but less than       more but less than        more of the access
                                                                           OR                      10% of the access        15% of the access         points to dial-up
                                                                                                   points to dial-up        points to dial-up         devices.
                                                                           Where technically
                                                                                                   devices.                 devices.
                                                                           feasible, the
                                                                           Responsible Entity
                                                                           did not implement
                                                                           electronic or manual
                                                                           processes for
                                                                           monitoring at less
                                                                           than 5% of the access
                                                                           points to dial-up
                                                                           devices.
CIP-005-1   R3.2.          Where technically feasible, the security        N/A                     N/A                      Where technically         Where technically
                           monitoring process(es) shall detect and                                                          feasible, the             feasible, the
                           alert for attempts at or actual unauthorized                                                     Responsible Entity        Responsible Entity did
                           accesses. These alerts shall provide for                                                         implemented security      not implement security
                           appropriate notification to designated                                                           monitoring process(es)    monitoring process(es)
                           response personnel. Where alerting is not                                                        to detect and alert for   to detect and alert for
                           technically feasible, the Responsible Entity                                                     attempts at or actual     attempts at or actual
                           shall review or otherwise assess access logs                                                     unauthorized accesses,    unauthorized accesses.
                           for attempts at or actual unauthorized                                                           however the alerts do     OR
                           accesses at least every ninety calendar days.                                                    not provide for
                                                                                                                                                      Where alerting is not
                                                                                                                            appropriate
                                                                                                                                                      technically feasible,
                                                                                                                            notification to
                                                                                                                                                      the Responsible Entity
                                                                                                                            designated response
                                                                                                                                                      did not review or
                                                                                                                            personnel.
                                                                                                                                                      otherwise assess
                                                                                                                                                      access logs for
                                                                                                                                                      attempts at or actual
                                                                                                                                                      unauthorized accesses
                                                                                                                                                      at least every ninety
                                                                                                                                                      calendar days
CIP-005-1   R4.            Cyber Vulnerability Assessment — The            The Responsible         The Responsible          The Responsible           The Responsible
                           Responsible Entity shall perform a cyber        Entity did not          Entity did not perform   Entity did not perform    Entity did not perform
                           vulnerability assessment of the electronic      perform a               a Vulnerability          a Vulnerability           a Vulnerability
                                                                                                                                                                  Page 46
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL             Moderate VSL                High VSL                 Severe VSL
 Number        Number
                           access points to the Electronic Security       Vulnerability            Assessment at least      Assessment at least      Assessment at least
                           Perimeter(s) at least annually. The            Assessment at least      annually for 5% or       annually for 10% or      annually for 15% or
                           vulnerability assessment shall include, at a   annually for less than   more but less than       more but less than       more of access points
                           minimum, the following:                        5% of access points      10% of access points     15% of access points     to the Electronic
                                                                          to the Electronic        to the Electronic        to the Electronic        Security Perimeter(s).
                                                                          Security Perimeter(s).   Security Perimeter(s).   Security Perimeter(s).   OR
                                                                                                                                                     The vulnerability
                                                                                                                                                     assessment did not
                                                                                                                                                     include one (1) or
                                                                                                                                                     more of the
                                                                                                                                                     subrequirements R
                                                                                                                                                     4.1, R4.2, R4.3, R4.4,
                                                                                                                                                     R4.5.
CIP-005-1   R4.1.          A document identifying the vulnerability       N/A                      N/A                      N/A                      N/A
                           assessment process;
CIP-005-1   R4.2.          A review to verify that only ports and         N/A                      N/A                      N/A                      N/A
                           services required for operations at these
                           access points are enabled;
CIP-005-1   R4.3.          The discovery of all access points to the      N/A                      N/A                      N/A                      N/A
                           Electronic Security Perimeter;
CIP-005-1   R4.4.          A review of controls for default accounts,     N/A                      N/A                      N/A                      N/A
                           passwords, and network management
                           community strings; and,
CIP-005-1   R4.5.          Documentation of the results of the            N/A                      N/A                      N/A                      N/A
                           assessment, the action plan to remediate or
                           mitigate vulnerabilities identified in the
                           assessment, and the execution status of that
                           action plan.
CIP-005-1   R5.            Documentation Review and Maintenance           The Responsible          The Responsible          The Responsible          The Responsible
                           — The Responsible Entity shall review,         Entity did not review,   Entity did not review,   Entity did not review,   Entity did not review,
                           update, and maintain all documentation to      update, and maintain     update, and maintain     update, and maintain     update, and maintain
                           support compliance with the requirements       at least one but less    greater than 5% but      greater than 10% but     greater than 15% of
                           of Standard CIP-005.                           than or equal to 5%      less than or equal to    less than or equal to    the documentation to
                                                                          of the documentation     10% of the               15% of the               support compliance
                                                                          to support               documentation to         documentation to         with the requirements

                                                                                                                                                                  Page 47
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                        Lower VSL             Moderate VSL                High VSL                 Severe VSL
 Number        Number
                                                                           compliance with the      support compliance       support compliance        of Standard CIP-005.
                                                                           requirements of          with the requirements    with the requirements
                                                                           Standard CIP-005.        of Standard CIP-005.     of Standard CIP-005.
CIP-005-1   R5.1.          The Responsible Entity shall ensure that all    N/A                      The Responsible          The Responsible           The Responsible
                           documentation required by Standard CIP-                                  Entity did not provide   Entity did not            Entity did not
                           005 reflect current configurations and                                   evidence of an annual    document current          document current
                           processes and shall review the documents                                 review of the            configurations and        configurations and
                           and procedures referenced in Standard CIP-                               documents and            processes referenced      processes and did not
                           005 at least annually.                                                   procedures referenced    in Standard CIP-005.      review the documents
                                                                                                    in Standard CIP-005.                               and procedures
                                                                                                                                                       referenced in Standard
                                                                                                                                                       CIP-005 at least
                                                                                                                                                       annually.
CIP-005-1   R5.2.          The Responsible Entity shall update the         For less than 5% of      For 5% or more but       For 10% or more but       For 15% or more of
                           documentation to reflect the modification       the applicable           less than 10% of the     less than 15% of the      the applicable
                           of the network or controls within ninety        changes, the             applicable changes,      applicable changes,       changes, the
                           calendar days of the change.                    Responsible Entity       the Responsible Entity   the Responsible Entity    Responsible Entity did
                                                                           did not update the       did not update the       did not update the        not update the
                                                                           documentation to         documentation to         documentation to          documentation to
                                                                           reflect the              reflect the              reflect the               reflect the
                                                                           modification of the      modification of the      modification of the       modification of the
                                                                           network or controls      network or controls      network or controls       network or controls
                                                                           within ninety            within ninety calendar   within ninety calendar    within ninety calendar
                                                                           calendar days of the     days of the change.      days of the change.       days of the change.
                                                                           change.
CIP-005-1   R5.3.          The Responsible Entity shall retain             The Responsible          The Responsible          The Responsible           The Responsible
                           electronic access logs for at least ninety      Entity retained          Entity retained          Entity retained           Entity retained
                           calendar days. Logs related to reportable       electronic access logs   electronic access logs   electronic access logs    electronic access logs
                           incidents shall be kept in accordance with      for 75 or more           for 60 or more           for 45 or more            for less than 45
                           the requirements of Standard CIP-008.           calendar days, but for   calendar days, but for   calendar days , but for   calendar days.
                                                                           less than 90 calendar    less than 75 calendar    less than 60 calendar
                                                                           days.                    days.                    days.
CIP-006-1   R1.            Physical Security Plan — The Responsible        N/A                      N/A                      The Responsible           The Responsible
                           Entity shall create and maintain a physical                                                       Entity created a          Entity did not create
                           security plan, approved by a senior                                                               physical security plan    and maintain a
                           manager or delegate(s) that shall address, at                                                     but did not gain          physical security plan.
                           a minimum, the following:                                                                         approval by a senior
                                                                                                                                                                    Page 48
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                     Text of Requirement                      Lower VSL      Moderate VSL                 High VSL                 Severe VSL
 Number        Number
                                                                                                                    manager or
                                                                                                                    delegate(s).
                                                                                                                    OR
                                                                                                                    The Responsible
                                                                                                                    Entity created but did
                                                                                                                    not maintain a
                                                                                                                    physical security plan.
CIP-006-1   R1.1.          Processes to ensure and document that all    N/A               Where a completely        Where a completely        The Responsible
                           Cyber Assets within an Electronic Security                     enclosed (“six-wall”)     enclosed (“six-wall”)     Entity's physical
                           Perimeter also reside within an identified                     border cannot be          border cannot be          security plan does not
                           Physical Security Perimeter. Where a                           established, the          established, the          include processes to
                           completely enclosed (“six-wall”) border                        Responsible Entity has    Responsible Entity has    ensure and document
                           cannot be established, the Responsible                         deployed but not          not deployed              that all Cyber Assets
                           Entity shall deploy and document                               documented                alternative measures to   within an Electronic
                           alternative measures to control physical                       alternative measures to   control physical access   Security Perimeter
                           access to the Critical Cyber Assets.                           control physical access   to the Critical Cyber     also reside within an
                                                                                          to the Critical Cyber     Assets.                   identified Physical
                                                                                          Assets.                                             Security Perimeter.
                                                                                                                                               OR
                                                                                                                                              Where a completely
                                                                                                                                              enclosed (“six-wall”)
                                                                                                                                              border cannot be
                                                                                                                                              established, the
                                                                                                                                              Responsible Entity has
                                                                                                                                              not deployed and
                                                                                                                                              documented
                                                                                                                                              alternative measures to
                                                                                                                                              control physical access
                                                                                                                                              to the Critical Cyber
                                                                                                                                              Assets.
CIP-006-1   R1.2.          Processes to identify all access points      N/A               The Responsible           The Responsible           The Responsible
                           through each Physical Security Perimeter                       Entity's physical         Entity's physical         Entity's physical
                           and measures to control entry at those                         security plan includes    security plan includes    security plan does not
                           access points.                                                 measures to control       processes to identify     include processes to
                                                                                          entry at access points    all access points         identify all access
                                                                                          but not processes to      through each Physical     points through each
                                                                                          identify all access       Security Perimeter but    Physical Security
                                                                                                                                                           Page 49
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL      Moderate VSL             High VSL                 Severe VSL
 Number        Number
                                                                                            points through each   not measures to           Perimeter nor
                                                                                            Physical Security     control entry at those    measures to control
                                                                                            Perimeter.            access points.            entry at those access
                                                                                                                                            points.
CIP-006-1   R1.3           Processes, tools, and procedures to monitor    N/A               N/A                   N/A                       The Responsible
                           physical access to the perimeter(s).                                                                             Entity's physical
                                                                                                                                            security plan does not
                                                                                                                                            include processes,
                                                                                                                                            tools, and procedures
                                                                                                                                            to monitor physical
                                                                                                                                            access to the
                                                                                                                                            perimeter(s).
CIP-006-1   R1.4           Procedures for the appropriate use of          N/A               N/A                   N/A                       The Responsible
                           physical access controls as described in                                                                         Entity's physical
                           Requirement R3 including visitor pass                                                                            security plan does not
                           management, response to loss, and                                                                                include procedures for
                           prohibition                                                                                                      the appropriate use of
                                                                                                                                            physical access
                           of inappropriate use of physical access
                                                                                                                                            controls as described
                           controls.
                                                                                                                                            in Requirement R3.
CIP-006-1   R1.5           Procedures for reviewing access                N/A               N/A                   The Responsible           The Responsible
                           authorization requests and revocation of                                               Entity's physical         Entity's physical
                           access authorization, in accordance with                                               security plan does not    security plan does not
                           CIP-004 Requirement R4.                                                                include either the        include procedures for
                                                                                                                  procedures for            reviewing access
                                                                                                                  reviewing access          authorization requests
                                                                                                                  authorization requests    and revocation of
                                                                                                                  or revocation of access   access authorization,
                                                                                                                  authorization, in         in accordance with
                                                                                                                  accordance with CIP-      CIP-004 Requirement
                                                                                                                  004 Requirement R4.       R4.
CIP-006-1   R1.6           Procedures for escorted access within the      N/A               N/A                   N/A                       The Responsible
                           physical security perimeter of personnel not                                                                     Entity's physical
                           authorized for unescorted access.                                                                                security plan does not
                                                                                                                                            include procedures for
                                                                                                                                            escorted access within
                                                                                                                                            the physical security
                                                                                                                                                         Page 50
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                        Lower VSL            Moderate VSL                High VSL                Severe VSL
 Number        Number
                                                                                                                                                     perimeter.
CIP-006-1   R1.7           Process for updating the physical security      N/A                     N/A                      The Responsible          The Responsible
                           plan within ninety calendar days of any                                                          Entity's physical        Entity's physical
                           physical security system redesign or                                                             security plan includes   security plan does not
                           reconfiguration, including, but not limited                                                      a process for updating   include a process for
                           to, addition or removal of access points                                                         the physical security    updating the physical
                           through the physical security perimeter,                                                         plan within ninety       security plan within
                           physical access controls, monitoring                                                             calendar days of any     ninety calendar days
                           controls, or logging controls.                                                                   physical security        of any physical
                                                                                                                            system redesign or       security system
                                                                                                                            reconfiguration but      redesign or
                                                                                                                            the plan was not         reconfiguration.
                                                                                                                            updated within 90
                                                                                                                            calendar days of any
                                                                                                                            physical security
                                                                                                                            system redesign or
                                                                                                                            reconfiguration.
CIP-006-1   R1.8           Cyber Assets used in the access control and     A Cyber Asset used      A Cyber Asset used in    A Cyber Asset used in    A Cyber Asset used in
                           monitoring of the Physical Security             in the access control   the access control and   the access control and   the access control and
                           Perimeter(s) shall be afforded the protective   and monitoring of the   monitoring of the        monitoring of the        monitoring of the
                           measures specified in Standard CIP-003,         Physical Security       Physical Security        Physical Security        Physical Security
                           Standard CIP-004 Requirement R3,                Perimeter(s) is         Perimeter(s) is          Perimeter(s) is          Perimeter(s) is not
                           Standard CIP-005 Requirements R2 and            provided all but one    provided all but two     provided all but three   provided four (4) or
                           R3, Standard CIP-006 Requirement R2 and         (1) of the protective   (2) of the protective    (3) of the protective    more of the protective
                           R3, Standard CIP-007, Standard CIP-008          measures as specified   measures as specified    measures as specified    measures as specified
                           and Standard CIP-009.                           in Standard CIP-003,    in Standard CIP-003,     in Standard CIP-003,     in Standard CIP-003,
                                                                           Standard CIP-004        Standard CIP-004         Standard CIP-004         Standard CIP-004
                                                                           Requirement R3,         Requirement R3,          Requirement R3,          Requirement R3,
                                                                           Standard CIP-005        Standard CIP-005         Standard CIP-005         Standard CIP-005
                                                                           Requirements R2 and     Requirements R2 and      Requirements R2 and      Requirements R2 and
                                                                           R3, Standard CIP-       R3, Standard CIP-006     R3, Standard CIP-006     R3, Standard CIP-006
                                                                           006 Requirements R2     Requirements R2 and      Requirements R2 and      Requirements R2 and
                                                                           and R3, Standard        R3, Standard CIP-007,    R3, Standard CIP-007,    R3, Standard CIP-007,
                                                                           CIP-007, Standard       Standard CIP-008, and    Standard CIP-008, and    Standard CIP-008, and
                                                                           CIP-008, and            Standard CIP-009.        Standard CIP-009.        Standard CIP-009.
                                                                           Standard CIP-009.
CIP-006-1   R1.9           Process for ensuring that the physical          N/A                     N/A                      N/A                      The Responsible

                                                                                                                                                                  Page 51
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL      Moderate VSL                High VSL                 Severe VSL
 Number        Number
                           security plan is reviewed at least annually.                                                                       Entity's physical
                                                                                                                                              security plan does not
                                                                                                                                              include a process for
                                                                                                                                              ensuring that the
                                                                                                                                              physical security plan
                                                                                                                                              is reviewed at least
                                                                                                                                              annually.
CIP-006-1   R2             Physical Access Controls — The                 N/A               The Responsible          The Responsible          The Responsible
                           Responsible Entity shall document and                            Entity has               Entity has               Entity has not
                           implement the operational and procedural                         implemented but not      documented but not       documented nor
                           controls to manage physical access at all                        documented the           implemented the          implemented the
                           access points to the Physical Security                           operational and          operational and          operational and
                           Perimeter(s) twenty-four hours a day, seven                      procedural controls to   procedural controls to   procedural controls to
                           days a week. The Responsible Entity shall                        manage physical          manage physical          manage physical
                           implement one or more of the following                           access at all access     access at all access     access at all access
                           physical access methods:                                         points to the Physical   points to the Physical   points to the Physical
                                                                                            Security Perimeter(s)    Security Perimeter(s)    Security Perimeter(s)
                                                                                            twenty-four hours a      twenty-four hours a      twenty-four hours a
                                                                                            day, seven days a        day, seven days a        day, seven days a
                                                                                            week using at least      week using at least      week using at least
                                                                                            one of the access        one of the access        one of the access
                                                                                            control methods          control methods          control methods
                                                                                            identified in R2.1,      identified in R2.1,      identified in R2.1,
                                                                                            R2.2, R2.3, or R2.4.     R2.2, R2.3, or R2.4      R2.2, R2.3, or R2.4.
CIP-006-1   R2.1.          Card Key: A means of electronic access         N/A               N/A                      N/A                      N/A
                           where the access rights of the card holder
                           are predefined in a computer database.
                           Access rights may differ from one
                           perimeter to another.
CIP-006-1   R2.2.          Special Locks: These include, but are not      N/A               N/A                      N/A                      N/A
                           limited to, locks with “restricted key”
                           systems, magnetic locks that can be
                           operated remotely, and “man-trap” systems.
CIP-006-1   R2.3.          Security Personnel: Personnel responsible      N/A               N/A                      N/A                      N/A
                           for controlling physical access who may
                           reside on-site or at a monitoring station.

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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL      Moderate VSL                 High VSL                  Severe VSL
 Number        Number
CIP-006-1   R2.4.          Other Authentication Devices: Biometric,       N/A               N/A                       N/A                       N/A
                           keypad, token, or other equivalent devices
                           that control physical access to the Critical
                           Cyber Assets.
CIP-006-1   R3             Monitoring Physical Access — The               N/A               The Responsible           The Responsible           The Responsible
                           Responsible Entity shall document and                            Entity has                Entity has                Entity has not
                           implement the technical and procedural                           implemented but not       documented but not        documented nor
                           controls for monitoring physical access at                       documented the            implemented the           implemented the
                           all access points to the Physical Security                       technical and             technical and             technical and
                           Perimeter(s) twenty-four hours a day, seven                      procedural controls for   procedural controls for   procedural controls for
                           days a week. Unauthorized access attempts                        monitoring physical       monitoring physical       monitoring physical
                           shall be reviewed immediately and handled                        access at all access      access at all access      access at all access
                           in accordance with the procedures specified                      points to the Physical    points to the Physical    points to the Physical
                           in Requirement CIP-008. One or more of                           Security Perimeter(s)     Security Perimeter(s)     Security Perimeter(s)
                           the following monitoring methods shall be                        twenty-four hours a       twenty-four hours a       twenty-four hours a
                           used:                                                            day, seven days a         day, seven days a         day, seven days a
                                                                                            week using at least       week using at least       week using at least
                                                                                            one of the monitoring     one of the monitoring     one of the monitoring
                                                                                            methods identified in     methods identified in     methods identified in
                                                                                            Requirements R3.1 or      Requirements R3.1 or      Requirements R3.1 or
                                                                                            R3.2.                     R3.2.                     R3.2.
                                                                                                                                                OR
                                                                                                                                                One or more
                                                                                                                                                unauthorized access
                                                                                                                                                attempts have not been
                                                                                                                                                reviewed immediately
                                                                                                                                                and handled in
                                                                                                                                                accordance with the
                                                                                                                                                procedures specified
                                                                                                                                                in CIP-008.
CIP-006-1   R3.1.          Alarm Systems: Systems that alarm to           N/A               N/A                       N/A                       N/A
                           indicate a door, gate or window has been
                           opened without authorization. These alarms
                           must provide for immediate notification to
                           personnel responsible for response.
CIP-006-1   R3.2.          Human Observation of Access Points:            N/A               N/A                       N/A                       N/A
                           Monitoring of physical access points by
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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                      Lower VSL              Moderate VSL                 High VSL                  Severe VSL
 Number        Number
                           authorized personnel as specified in
                           Requirement R2.3.
CIP-006-1   R4             Logging Physical Access — Logging shall       The Responsible           The Responsible           The Responsible           The Responsible
                           record sufficient information to uniquely     Entity has                Entity has                Entity has                Entity has not
                           identify individuals and the time of access   implemented but           implemented the           documented but not        implemented nor
                           twenty-four hours a day, seven days a         not documented the        technical and             implemented the           documented the
                           week. The Responsible Entity shall            technical and             procedural                technical and             technical and
                           implement and document the technical and      procedural                mechanisms for            procedural                procedural
                           procedural mechanisms for logging             mechanisms for            logging physical entry    mechanisms for            mechanisms for
                           physical entry at all access points to the    logging physical          at all access points to   logging physical entry    logging physical entry
                           Physical Security Perimeter(s) using one or   entry at all access       the Physical Security     at all access points to   at all access points to
                           more of the following logging methods or      points to the Physical    Perimeter(s) using one    the Physical Security     the Physical Security
                           their equivalent:                             Security Perimeter(s)     or more of the logging    Perimeter(s) using one    Perimeter(s) using one
                                                                         using one or more of      methods identified in     or more of the logging    or more of the logging
                                                                         the logging methods       Requirements R4.1,        methods identified in     methods identified in
                                                                         identified in             R4.2, or R4.3, but has    Requirements R4.1,        Requirements R4.1,
                                                                         Requirements R4.1,        not provided logging      R4.2, or R4.3.            R4.2, or R4.3.
                                                                         R4.2, or R4.3, and        that records sufficient
                                                                         has provided logging      information to
                                                                         that records sufficient   uniquely identify
                                                                         information to            individuals and the
                                                                         uniquely identify         time of access twenty-
                                                                         individuals and the       four hours a day,
                                                                         time of access            seven days a week.
                                                                         twenty-four hours a
                                                                         day, seven days a
                                                                         week.
CIP-006-1   R4.1.          Computerized Logging: Electronic logs         N/A                       N/A                       N/A                       N/A
                           produced by the Responsible Entity’s
                           selected access control and monitoring
                           method.
CIP-006-1   R4.2.          Video Recording: Electronic capture of        N/A                       N/A                       N/A                       N/A
                           video images of sufficient quality to
                           determine identity.
CIP-006-1   R4.3.          Manual Logging: A log book or sign-in         N/A                       N/A                       N/A                       N/A
                           sheet, or other record of physical access
                           maintained by security or other personnel
                                                                                                                                                                    Page 54
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                          Lower VSL             Moderate VSL                  High VSL                   Severe VSL
 Number        Number
                           authorized to control and monitor physical
                           access as specified in Requirement R2.3.
CIP-006-1   R5             Access Log Retention — The responsible            The Responsible          The Responsible            The Responsible            The Responsible
                           entity shall retain physical access logs for at   Entity retained          Entity retained            Entity retained            Entity retained
                           least ninety calendar days. Logs related to       physical access logs     physical access logs       physical access logs       physical access logs
                           reportable incidents shall be kept in             for 75 or more           for 60 or more             for 45 or more             for less than 45
                           accordance with the requirements of               calendar days, but for   calendar days, but for     calendar days , but for    calendar days.
                           Standard CIP-008.                                 less than 90 calendar    less than 75 calendar      less than 60 calendar
                                                                             days.                    days.                      days.
CIP-006-1   R6             Maintenance and Testing — The                     The Responsible          The Responsible            The Responsible            The Responsible
                           Responsible Entity shall implement a              Entity has               Entity has                 Entity has                 Entity has not
                           maintenance and testing program to ensure         implemented a            implemented a              implemented a              implemented a
                           that all physical security systems under          maintenance and          maintenance and            maintenance and            maintenance and
                           Requirements R2, R3, and R4 function              testing program to       testing program to         testing program to         testing program to
                           properly. The program must include, at a          ensure that all          ensure that all physical   ensure that all physical   ensure that all physical
                           minimum, the following:                           physical security        security systems under     security systems under     security systems under
                                                                             systems under            Requirements R2, R3,       Requirements R2, R3,       Requirements R2, R3,
                                                                             Requirements R2,         and R4 function            and R4 function            and R4 function
                                                                             R3, and R4 function      properly but the           properly but the           properly.
                                                                             properly but the         program does not           program does not
                                                                             program does not         include two of the         include any of the
                                                                             include one of the       requirements R6.1,         requirements R6.1,
                                                                             requirements R6.1,       R6.2, and R6.3.            R6.2, and R6.3.
                                                                             R6.2, and R6.3.
CIP-006-1   R6.1.          Testing and maintenance of all physical           N/A                      N/A                        N/A                        N/A
                           security mechanisms on a cycle no longer
                           than three years.
CIP-006-1   R6.2.          Retention of testing and maintenance              N/A                      N/A                        N/A                        N/A
                           records for the cycle determined by the
                           Responsible Entity in Requirement R6.1.
CIP-006-1   R6.3.          Retention of outage records regarding             N/A                      N/A                        N/A                        N/A
                           access controls, logging, and monitoring for
                           a minimum of one calendar year.
CIP-007-1   R1.            Test Procedures — The Responsible Entity          N/A                      The Responsible            The Responsible            The Responsible
                           shall ensure that new Cyber Assets and                                     Entity did create,         Entity did not create,     Entity did not create,
                           significant changes to existing Cyber                                      implement and              implement and              implement and
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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                     Text of Requirement                       Lower VSL      Moderate VSL                 High VSL                 Severe VSL
 Number        Number
                           Assets within the Electronic Security                           maintain the test         maintain the test        maintain the test
                           Perimeter do not adversely affect existing                      procedures as required    procedures as required   procedures as required
                           cyber security controls. For purposes of                        in R1.1, but did not      in R1.1.                 in R1.1,
                           Standard CIP-007, a significant change                          document that testing                              AND
                           shall, at a minimum, include                                    is performed as
                                                                                                                                              The Responsible
                           implementation of security patches,                             required in R1.2.
                                                                                                                                              Entity did not
                           cumulative service packs, vendor releases,                      OR                                                 document that testing
                           and version upgrades of operating systems,
                                                                                           The Responsible                                    was performed as
                           applications, database platforms, or other
                                                                                           Entity did not                                     required in R1.2
                           third-party software or firmware.
                                                                                           document the test                                  AND
                                                                                           results as required in
                                                                                                                                              The Responsible
                                                                                           R1.3.
                                                                                                                                              Entity did not
                                                                                                                                              document the test
                                                                                                                                              results as required in
                                                                                                                                              R1.3.
CIP-007-1   R1.1.          The Responsible Entity shall create,          N/A               N/A                       N/A                      N/A
                           implement, and maintain cyber security test
                           procedures in a manner that minimizes
                           adverse effects on the production system or
                           its operation.
CIP-007-1   R1.2.          The Responsible Entity shall document that    N/A               N/A                       N/A                      N/A
                           testing is performed in a manner that
                           reflects the production environment.
CIP-007-1   R1.3.          The Responsible Entity shall document test    N/A               N/A                       N/A                      N/A
                           results.
CIP-007-1   R2.            Ports and Services — The Responsible          N/A               The Responsible           The Responsible          The Responsible
                           Entity shall establish and document a                           Entity established but    Entity documented        Entity did not establish
                           process to ensure that only those ports and                     did not document a        but did not establish    nor document a
                           services required for normal and emergency                      process to ensure that    a process to ensure      process to ensure that
                           operations are enabled.                                         only those ports and      that only those ports    only those ports and
                                                                                           services required for     and services required    services required for
                                                                                           normal and emergency      for normal and           normal and emergency
                                                                                           operations are enabled.   emergency operations     operations are enabled.
                                                                                                                     are enabled.
CIP-007-1   R2.1.          The Responsible Entity shall enable only      The Responsible   The Responsible           The Responsible          The Responsible

                                                                                                                                                           Page 56
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                        Lower VSL              Moderate VSL                High VSL                Severe VSL
 Number        Number
                           those ports and services required for normal    Entity enabled ports      Entity enabled ports     Entity enabled ports     Entity enabled ports
                           and emergency operations.                       and services not          and services not         and services not         and services not
                                                                           required for normal       required for normal      required for normal      required for normal
                                                                           and emergency             and emergency            and emergency            and emergency
                                                                           operations on at least    operations on 5% or      operations on 10% or     operations on 15% or
                                                                           one but less than 5%      more but less than       more but less than       more of the Cyber
                                                                           of the Cyber Assets       10% of the Cyber         15% of the Cyber         Assets inside the
                                                                           inside the Electronic     Assets inside the        Assets inside the        Electronic Security
                                                                           Security Perimeter(s).    Electronic Security      Electronic Security      Perimeter(s).
                                                                                                     Perimeter(s).            Perimeter(s).
CIP-007-1   R2.2.          The Responsible Entity shall disable other      The Responsible           The Responsible          The Responsible          The Responsible
                           ports and services, including those used for    Entity did not disable    Entity did not disable   Entity did not disable   Entity did not disable
                           testing purposes, prior to production use of    other ports and           other ports and          other ports and          other ports and
                           all Cyber Assets inside the Electronic          services, including       services, including      services, including      services, including
                           Security Perimeter(s).                          those used for testing    those used for testing   those used for testing   those used for testing
                                                                           purposes, prior to        purposes, prior to       purposes, prior to       purposes, prior to
                                                                           production use for at     production use for 5%    production use for       production use for
                                                                           least one but less than   or more but less than    10% or more but less     15% or more of the
                                                                           5% of the Cyber           10% of the Cyber         than 15% of the Cyber    Cyber Assets inside
                                                                           Assets inside the         Assets inside the        Assets inside the        the Electronic Security
                                                                           Electronic Security       Electronic Security      Electronic Security      Perimeter(s).
                                                                           Perimeter(s).             Perimeter(s).            Perimeter(s).
CIP-007-1   R2.3.          In the case where unused ports and services     N/A                       N/A                      N/A                      For cases where
                           cannot be disabled due to technical                                                                                         unused ports and
                           limitations, the Responsible Entity shall                                                                                   services cannot be
                           document compensating measure(s) applied                                                                                    disabled due to
                           to mitigate risk exposure or an acceptance                                                                                  technical limitations,
                           of risk.                                                                                                                    the Responsible Entity
                                                                                                                                                       did not document
                                                                                                                                                       compensating
                                                                                                                                                       measure(s) applied to
                                                                                                                                                       mitigate risk exposure
                                                                                                                                                       or state an acceptance
                                                                                                                                                       of risk.
CIP-007-1   R3.            Security Patch Management — The                 The Responsible           The Responsible          The Responsible          The Responsible
                           Responsible Entity, either separately or as a   Entity established        Entity established but   Entity documented        Entity did not
                           component of the documented                     and documented,           did not document,        but did not establish,   establish nor

                                                                                                                                                                    Page 57
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                         Lower VSL              Moderate VSL                 High VSL                   Severe VSL
 Number        Number
                           configuration management process                 either separately or as   either separately or as   either separately or as     document, either
                           specified in CIP-003 Requirement R6, shall       a component of the        a component of the        a component of the          separately or as a
                           establish and document a security patch          documented                documented                documented                  component of the
                           management program for tracking,                 configuration             configuration             configuration               documented
                           evaluating, testing, and installing applicable   management process        management process        management process          configuration
                           cyber security software patches for all          specified in CIP-003      specified in CIP-003      specified in CIP-003        management process
                           Cyber Assets within the Electronic Security      Requirement R6, a         Requirement R6, a         Requirement R6, a           specified in CIP-003
                           Perimeter(s).                                    security patch            security patch            security patch              Requirement R6, a
                                                                            management program        management program        management program          security patch
                                                                            but did not include       for tracking,             for tracking,               management program
                                                                            one or more of the        evaluating, testing,      evaluating, testing,        for tracking,
                                                                            following: tracking,      and installing            and installing              evaluating, testing,
                                                                            evaluating, testing,      applicable cyber          applicable cyber            and installing
                                                                            and installing            security software         security software           applicable cyber
                                                                            applicable cyber          patches for all Cyber     patches for all Cyber       security software
                                                                            security software         Assets within the         Assets within the           patches for all Cyber
                                                                            patches for all Cyber     Electronic Security       Electronic Security         Assets within the
                                                                            Assets within the         Perimeter(s).             Perimeter(s).               Electronic Security
                                                                            Electronic Security                                                             Perimeter(s).
                                                                            Perimeter(s).
CIP-007-1   R3.1.          The Responsible Entity shall document the        The Responsible           The Responsible           The Responsible             The Responsible
                           assessment of security patches and security      Entity documented         Entity documented the     Entity documented the       Entity documented the
                           upgrades for applicability within thirty         the assessment of         assessment of security    assessment of security      assessment of security
                           calendar days of availability of the patches     security patches and      patches and security      patches and security        patches and security
                           or upgrades.                                     security upgrades for     upgrades for              upgrades for                upgrades for
                                                                            applicability as          applicability as          applicability as            applicability as
                                                                            required in               required in               required in                 required in
                                                                            Requirement R3 in         Requirement R3 in 60      Requirement R3 in 90        Requirement R3 in
                                                                            more than 30 but less     or more but less than     or more but less than       120 calendar days or
                                                                            than 60 calendar days     90 calendar days after    120 calendar days           more after the
                                                                            after the availability    the availability of the   after the availability of   availability of the
                                                                            of the patches and        patches and upgrades.     the patches and             patches and upgrades.
                                                                            upgrades.                                           upgrades.
CIP-007-1   R3.2.          The Responsible Entity shall document the        N/A                       N/A                       N/A                         The Responsible
                           implementation of security patches. In any                                                                                       Entity did not
                           case where the patch is not installed, the                                                                                       document the
                           Responsible Entity shall document                                                                                                implementation of
                           compensating measure(s) applied to                                                                                               applicable security
                                                                                                                                                                         Page 58
Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                     Text of Requirement                       Lower VSL             Moderate VSL                 High VSL                 Severe VSL
 Number        Number
                           mitigate risk exposure or an acceptance of                                                                                 patches as required in
                           risk.                                                                                                                      R3.
                                                                                                                                                      OR
                                                                                                                                                      Where an applicable
                                                                                                                                                      patch was not
                                                                                                                                                      installed, the
                                                                                                                                                      Responsible Entity did
                                                                                                                                                      not document the
                                                                                                                                                      compensating
                                                                                                                                                      measure(s) applied to
                                                                                                                                                      mitigate risk exposure
                                                                                                                                                      or an acceptance of
                                                                                                                                                      risk.
CIP-007-1   R4.            Malicious Software Prevention — The           The Responsible          The Responsible           The Responsible           The Responsible
                           Responsible Entity shall use anti-virus       Entity, as technically   Entity, as technically    Entity, as technically    Entity, as technically
                           software and other malicious software         feasible, did not use    feasible, did not use     feasible, did not use     feasible, did not use
                           (“malware”) prevention tools, where           anti-virus software      anti-virus software and   anti-virus software and   anti-virus software and
                           technically feasible, to detect, prevent,     and other malicious      other malicious           other malicious           other malicious
                           deter, and mitigate the introduction,         software (“malware”)     software (“malware”)      software (“malware”)      software (“malware”)
                           exposure, and propagation of malware on       prevention tools, nor    prevention tools, nor     prevention tools, nor     prevention tools, nor
                           all                                           implemented              implemented               implemented               implemented
                           Cyber Assets within the Electronic Security   compensating             compensating              compensating              compensating
                           Perimeter(s).                                 measures, on at least    measures, on at least     measures, on at least     measures, on 15% or
                                                                         one but less than 5%     5% but less than 10%      10% but less than 15%     more Cyber Assets
                                                                         of Cyber Assets          of Cyber Assets within    of Cyber Assets within    within the Electronic
                                                                         within the Electronic    the Electronic Security   the Electronic Security   Security Perimeter(s).
                                                                         Security Perimeter(s).   Perimeter(s).             Perimeter(s).
CIP-007-1   R4.1.          The Responsible Entity shall document and     N/A                      N/A                       N/A                       The Responsible
                           implement anti-virus and malware                                                                                           Entity did not
                           prevention tools. In the case where anti-                                                                                  document the
                           virus software and malware prevention                                                                                      implementation of
                           tools are not installed, the Responsible                                                                                   antivirus and malware
                           Entity shall document compensating                                                                                         prevention tools for
                           measure(s) applied to mitigate risk                                                                                        cyber assets within the
                           exposure or an acceptance of risk.                                                                                         electronic security
                                                                                                                                                      perimeter.
                                                                                                                                                      OR

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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                          Lower VSL             Moderate VSL                 High VSL                 Severe VSL
 Number        Number
                                                                                                                                                          The Responsible
                                                                                                                                                          Entity did not
                                                                                                                                                          document the
                                                                                                                                                          implementation of
                                                                                                                                                          compensating
                                                                                                                                                          measure(s) applied to
                                                                                                                                                          mitigate risk exposure
                                                                                                                                                          or an acceptance of
                                                                                                                                                          risk where antivirus
                                                                                                                                                          and malware
                                                                                                                                                          prevention tools are
                                                                                                                                                          not installed.
CIP-007-1   R4.2.          The Responsible Entity shall document and         The Responsible          The Responsible           The Responsible           The Responsible
                           implement a process for the update of anti-       Entity, as technically   Entity, as technically    Entity, as technically    Entity, as technically
                           virus and malware prevention “signatures.”        feasible, documented     feasible, did not         feasible, documented      feasible, did not
                           The process must address testing and              and implemented a        document but              but did not               document nor
                           installing the signatures.                        process for the update   implemented a             implement a process,      implement a process
                                                                             of anti-virus and        process, including        including addressing      including addressing
                                                                             malware prevention       addressing testing and    testing and installing    testing and installing
                                                                             “signatures.”, but the   installing the            the signatures, for the   the signatures for the
                                                                             process did not          signatures, for the       update of anti-virus      update of anti-virus
                                                                             address testing and      update of anti-virus      and malware               and malware
                                                                             installation of the      and malware               prevention                prevention
                                                                             signatures.              prevention                “signatures.”             “signatures.”
                                                                                                      “signatures.”
CIP-007-1   R5.            Account Management — The Responsible              N/A                      The Responsible           The Responsible           The Responsible
                           Entity shall establish, implement, and                                     Entity implemented        Entity documented but     Entity did not
                           document technical and procedural controls                                 but did not document      did not implement         document nor
                           that enforce access authentication of, and                                 technical and             technical and             implement technical
                           accountability for, all user activity, and that                            procedural controls       procedural controls       and procedural
                           minimize the risk of unauthorized system                                   that enforce access       that enforce access       controls that enforce
                           access.                                                                    authentication of, and    authentication of, and    access authentication
                                                                                                      accountability for, all   accountability for, all   of, and accountability
                                                                                                      user activity.            user activity.            for, all user activity.
CIP-007-1   R5.1.          The Responsible Entity shall ensure that          N/A                      N/A                       N/A                       The Responsible
                           individual and shared system accounts and                                                                                      Entity did not ensure
                           authorized access permissions are                                                                                              that individual and

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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL            Moderate VSL                High VSL                  Severe VSL
 Number        Number
                           consistent with the concept of “need to                                                                                    shared system
                           know” with respect to work functions                                                                                       accounts and
                           performed.                                                                                                                 authorized access
                                                                                                                                                      permissions are
                                                                                                                                                      consistent with the
                                                                                                                                                      concept of “need to
                                                                                                                                                      know” with respect to
                                                                                                                                                      work functions
                                                                                                                                                      performed.
CIP-007-1   R5.1.1.        The Responsible Entity shall ensure that       At least one user       One (1) % or more of     Three (3) % or more        Five (5) % or more of
                           user accounts are implemented as approved      account but less than   user accounts but less   of user accounts but       user accounts
                           by designated personnel. Refer to Standard     1% of user accounts     than 3% of user          less than 5% of user       implemented by the
                           CIP-003 Requirement R5.                        implemented by the      accounts implemented     accounts implemented       Responsible Entity
                                                                          Responsible Entity,     by the Responsible       by the Responsible         were not approved by
                                                                          were not approved by    Entity were not          Entity were not            designated personnel.
                                                                          designated personnel.   approved by              approved by
                                                                                                  designated personnel.    designated personnel.
CIP-007-1   R5.1.2.        The Responsible Entity shall establish         N/A                     The Responsible          The Responsible            The Responsible
                           methods, processes, and procedures that                                Entity generated logs    Entity generated logs      Entity did not generate
                           generate logs of sufficient detail to create                           with sufficient detail   with insufficient detail   logs of individual user
                           historical audit trails of individual user                             to create historical     to create historical       account access
                           account access activity for a minimum of                               audit trails of          audit trails of            activity.
                           ninety days.                                                           individual user          individual user
                                                                                                  account access           account access
                                                                                                  activity, however the    activity.
                                                                                                  logs do not contain
                                                                                                  activity for a minimum
                                                                                                  of 90 days.
CIP-007-1   R5.1.3.        The Responsible Entity shall review, at        N/A                     N/A                      N/A                        The Responsible
                           least annually, user accounts to verify                                                                                    Entity did not review,
                           access privileges are in accordance with                                                                                   at least annually, user
                           Standard CIP-003 Requirement R5 and                                                                                        accounts to verify
                           Standard CIP-004 Requirement R4.                                                                                           access privileges are in
                                                                                                                                                      accordance with
                                                                                                                                                      Standard CIP-003
                                                                                                                                                      Requirement R5 and
                                                                                                                                                      Standard CIP-004

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 Standard    Requirement
                                      Text of Requirement                       Lower VSL      Moderate VSL                High VSL                 Severe VSL
 Number        Number
                                                                                                                                               Requirement R4.
CIP-007-1   R5.2.          The Responsible Entity shall implement a       N/A               N/A                      N/A                       The Responsible
                           policy to minimize and manage the scope                                                                             Entity did not
                           and acceptable use of administrator, shared,                                                                        implement a policy to
                           and other generic account privileges                                                                                minimize and manage
                           including factory default accounts.                                                                                 the scope and
                                                                                                                                               acceptable use of
                                                                                                                                               administrator, shared,
                                                                                                                                               and other generic
                                                                                                                                               account privileges
                                                                                                                                               including factory
                                                                                                                                               default accounts.
CIP-007-1   R5.2.1.        The policy shall include the removal,          N/A               N/A                      The Responsible           For accounts that must
                           disabling, or renaming of such accounts                                                   Entity's policy did not   remain enabled, the
                           where possible. For such accounts that must                                               include the removal,      Responsible Entity did
                           remain enabled, passwords shall be                                                        disabling, or renaming    not change passwords
                           changed prior to putting any system into                                                  of such accounts          prior to putting any
                           service.                                                                                  where possible,           system into service.
                                                                                                                     however for accounts
                                                                                                                     that must remain
                                                                                                                     enabled, passwords
                                                                                                                     were changed prior to
                                                                                                                     putting any system
                                                                                                                     into service.
CIP-007-1   R5.2.2.        The Responsible Entity shall identify those    N/A               N/A                      N/A                       The Responsible
                           individuals with access to shared accounts.                                                                         Entity did not identify
                                                                                                                                               all individuals with
                                                                                                                                               access to shared
                                                                                                                                               accounts.
CIP-007-1   R5.2.3.        Where such accounts must be shared, the        N/A               Where such accounts      Where such accounts       Where such accounts
                           Responsible Entity shall have a policy for                       must be shared, the      must be shared, the       must be shared, the
                           managing the use of such accounts that                           Responsible Entity has   Responsible Entity has    Responsible Entity
                           limits access to only those with                                 a policy for managing    a policy for managing     does not have a policy
                           authorization, an audit trail of the account                     the use of such          the use of such           for managing the use
                           use (automated or manual), and steps for                         accounts, but is         accounts, but is          of such accounts that
                           securing the account in the event of                             missing 1 of the         missing 2 of the          limits access to only
                           personnel changes (for example, change in                        following 3 items:       following 3 items:        those with
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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                     Text of Requirement                       Lower VSL             Moderate VSL                  High VSL                    Severe VSL
 Number        Number
                           assignment or termination).                                            a) limits access to only   a) limits access to only    authorization, an audit
                                                                                                  those with                 those with                  trail of the account use
                                                                                                  authorization,             authorization,              (automated or
                                                                                                  b) has an audit trail of    b) has an audit trail of   manual), and steps for
                                                                                                  the account use            the account use             securing the account in
                                                                                                  (automated or              (automated or               the event of personnel
                                                                                                  manual),                   manual),                    changes (for example,
                                                                                                                                                         change in assignment
                                                                                                  c) has specified steps     c) has specified steps
                                                                                                                                                         or termination).
                                                                                                  for securing the           for securing the
                                                                                                  account in the event of    account in the event of
                                                                                                  personnel changes (for     personnel changes (for
                                                                                                  example, change in         example, change in
                                                                                                  assignment or              assignment or
                                                                                                  termination).              termination).
CIP-007-1   R5.3.          At a minimum, the Responsible Entity shall    The Responsible          The Responsible            The Responsible             The Responsible
                           require and use passwords, subject to the     Entity requires and      Entity requires and        Entity requires but         Entity does not
                           following, as technically feasible:           uses passwords as        uses passwords as          does not use                require nor use
                                                                         technically feasible,    technically feasible       passwords as required       passwords as required
                                                                         but only addresses 2     but only addresses 1 of    in R5.3.1, R5.3.2.,         in R5.3.1, R5.3.2.,
                                                                         of the requirements in   the requirements in        R5.3.3 and did not          R5.3.3 and did not
                                                                         R5.3.1, R5.3.2.,         R5.3.1, R5.3.2.,           demonstrate why it is       demonstrate why it is
                                                                         R5.3.3.                  R5.3.3.                    not technically             not technically
                                                                                                                             feasible.                   feasible.


CIP-007-1   R5.3.1.        Each password shall be a minimum of six       N/A                      N/A                        N/A                         N/A
                           characters.
CIP-007-1   R5.3.2.        Each password shall consist of a              N/A                      N/A                        N/A                         N/A
                           combination of alpha, numeric, and
                           “special” characters.
CIP-007-1   R5.3.3.        Each password shall be changed at least       N/A                      N/A                        N/A                         N/A
                           annually, or more frequently based on risk.
CIP-007-1   R6.            Security Status Monitoring — The              The Responsible          The Responsible            The Responsible             The Responsible
                           Responsible Entity shall ensure that all      Entity, as technically   Entity, as technically     Entity did not              Entity did not
                           Cyber Assets within the Electronic Security   feasible, did not        feasible, did not          implement automated         implement automated
                           Perimeter, as technically feasible,           implement automated      implement automated        tools or organizational     tools or organizational
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Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL              Moderate VSL                 High VSL                  Severe VSL
 Number        Number
                           implement automated tools or                   tools or                  tools or organizational   process controls, as       process controls, as
                           organizational process controls to monitor     organizational            process controls to       technically feasible, to   technically feasible, to
                           system events that are related to cyber        process controls to       monitor system events     monitor system events      monitor system events
                           security.                                      monitor system            that are related to       that are related to        that are related to
                                                                          events that are related   cyber security for 5%     cyber security for 10%     cyber security for 15%
                                                                          to cyber security for     or more but less than     or more but less than      or more of Cyber
                                                                          at least one but less     10% of Cyber Assets       15% of Cyber Assets        Assets inside the
                                                                          than 5% of Cyber          inside the Electronic     inside the Electronic      Electronic Security
                                                                          Assets inside the         Security Perimeter(s).    Security Perimeter(s).     Perimeter(s).
                                                                          Electronic Security
                                                                          Perimeter(s).
CIP-007-1   R6.1.          The Responsible Entity shall implement         N/A                       The Responsible           The Responsible            The Responsible
                           and document the organizational processes                                Entity implemented        Entity documented          Entity did not
                           and technical and procedural mechanisms                                  but did not document      but did not                implement nor
                           for monitoring for security events on all                                the organizational        implement the              document the
                           Cyber Assets within the Electronic Security                              processes and             organizational             organizational
                           Perimeter.                                                               technical and             processes and              processes and
                                                                                                    procedural                technical and              technical and
                                                                                                    mechanisms for            procedural                 procedural
                                                                                                    monitoring for            mechanisms for             mechanisms for
                                                                                                    security events on all    monitoring for             monitoring for
                                                                                                    Cyber Assets within       security events on all     security events on all
                                                                                                    the Electronic Security   Cyber Assets within        Cyber Assets within
                                                                                                    Perimeter.                the Electronic Security    the Electronic Security
                                                                                                                              Perimeter.                 Perimeter.
CIP-007-1   R6.2.          The security monitoring controls shall issue   N/A                       N/A                       N/A                        The Responsible
                           automated or manual alerts for detected                                                                                       entity's security
                           Cyber Security Incidents.                                                                                                     monitoring controls do
                                                                                                                                                         not issue automated or
                                                                                                                                                         manual alerts for
                                                                                                                                                         detected Cyber
                                                                                                                                                         Security Incidents.
CIP-007-1   R6.3.          The Responsible Entity shall maintain logs     N/A                       N/A                       N/A                        The Responsible
                           of system events related to cyber security,                                                                                   Entity did not maintain
                           where technically feasible, to support                                                                                        logs of system events
                           incident response as required in Standard                                                                                     related to cyber
                           CIP-008.                                                                                                                      security, where

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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL            Moderate VSL                 High VSL                   Severe VSL
 Number        Number
                                                                                                                                                       technically feasible, to
                                                                                                                                                       support incident
                                                                                                                                                       response as required in
                                                                                                                                                       Standard CIP-008.
CIP-007-1   R6.4.          The Responsible Entity shall retain all logs   The Responsible         The Responsible           The Responsible            The Responsible
                           specified in Requirement R6 for ninety         Entity retained the     Entity retained the       Entity retained the        Entity did not retain
                           calendar days.                                 logs specified in       logs specified in         logs specified in          any logs specified in
                                                                          Requirement R6, for     Requirement R6, for at    Requirement R6, for at     Requirement R6.
                                                                          at least 60 days, but   least 30 days, but less   least one day, but less
                                                                          less than 90 days.      than 60 days.             than 30 days.
CIP-007-1   R6.5.          The Responsible Entity shall review logs of    N/A                     N/A                       N/A                        The Responsible
                           system events related to cyber security and                                                                                 Entity did not review
                           maintain records documenting review of                                                                                      logs of system events
                           logs.                                                                                                                       related to cyber
                                                                                                                                                       security nor maintain
                                                                                                                                                       records documenting
                                                                                                                                                       review of logs.
CIP-007-1   R7.            Disposal or Redeployment — The                 The Responsible         The Responsible           The Responsible            The Responsible
                           Responsible Entity shall establish formal      Entity established      Entity established        Entity established         Entity did not establish
                           methods, processes, and procedures for         formal methods,         formal methods,           formal methods,            formal methods,
                           disposal or redeployment of Cyber Assets       processes, and          processes, and            processes, and             processes, and
                           within the Electronic Security Perimeter(s)    procedures for          procedures for            procedures for             procedures for
                           as identified and documented in Standard       disposal and            disposal of Cyber         redeployment of            disposal or
                           CIP-005.                                       redeployment of         Assets within the         Cyber Assets within        redeployment of
                                                                          Cyber Assets within     Electronic Security       the Electronic Security    Cyber Assets within
                                                                          the Electronic          Perimeter(s) as           Perimeter(s) as            the Electronic Security
                                                                          Security Perimeter(s)   identified and            identified and             Perimeter(s) as
                                                                          as identified and       documented in             documented in              identified and
                                                                          documented in           Standard CIP-005 but      Standard CIP-005 but       documented in
                                                                          Standard CIP-005        did not address           did not address            Standard CIP-005.
                                                                          but did not maintain    redeployment as           disposal as specified in
                                                                          records as specified    specified in R7.2.        R7.1.
                                                                          in R7.3.
CIP-007-1   R7.1.          Prior to the disposal of such assets, the      N/A                     N/A                       N/A                        N/A
                           Responsible Entity shall destroy or erase
                           the data storage media to prevent
                           unauthorized retrieval of sensitive cyber
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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                       Text of Requirement                      Lower VSL          Moderate VSL                 High VSL                  Severe VSL
 Number        Number
                           security or reliability data.
CIP-007-1   R7.2.          Prior to redeployment of such assets, the      N/A                   N/A                       N/A                       N/A
                           Responsible Entity shall, at a minimum,
                           erase the data storage media to prevent
                           unauthorized retrieval of sensitive cyber
                           security or reliability data.
CIP-007-1   R7.3.          The Responsible Entity shall maintain          N/A                   N/A                       N/A                       N/A
                           records that such assets were disposed of or
                           redeployed in accordance with documented
                           procedures.
CIP-007-1   R8             Cyber Vulnerability Assessment — The           The Responsible       The Responsible           The Responsible           The Responsible
                           Responsible Entity shall perform a cyber       Entity performed at   Entity performed at       Entity performed at       Entity performed at
                           vulnerability assessment of all Cyber          least annually a      least annually a          least annually a          least annually a
                           Assets within the Electronic Security          Vulnerability         Vulnerability             Vulnerability             Vulnerability
                           Perimeter at least annually. The               Assessment that       Assessment that           Assessment that           Assessment for 85%
                           vulnerability assessment shall include, at a   included 95% or       included 90% or more      included more than        or less of Cyber Assets
                           minimum, the following:                        more but less than    but less than 95% of      85% but less than 90%     within the Electronic
                                                                          100% of Cyber         Cyber Assets within       of Cyber Assets within    Security Perimeter.
                                                                          Assets within the     the Electronic Security   the Electronic Security   OR
                                                                          Electronic Security   Perimeter.                Perimeter.
                                                                                                                                                    The vulnerability
                                                                          Perimeter.
                                                                                                                                                    assessment did not
                                                                                                                                                    include one (1) or
                                                                                                                                                    more of the
                                                                                                                                                    subrequirements 8.1,
                                                                                                                                                    8.2, 8.3, 8.4.
CIP-007-1   R8.1.          A document identifying the vulnerability       N/A                   N/A                       N/A                       N/A
                           assessment process;
CIP-007-1   R8.2.          A review to verify that only ports and         N/A                   N/A                       N/A                       N/A
                           services required for operation of the Cyber
                           Assets within the Electronic Security
                           Perimeter are enabled;
CIP-007-1   R8.3.          A review of controls for default accounts;     N/A                   N/A                       N/A                       N/A
                           and,
CIP-007-1   R8.4.          Documentation of the results of the            N/A                   N/A                       N/A                       N/A
                           assessment, the action plan to remediate or
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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL      Moderate VSL                 High VSL                 Severe VSL
 Number        Number
                           mitigate vulnerabilities identified in the
                           assessment, and the execution status of that
                           action plan.
CIP-007-1   R9             Documentation Review and Maintenance           N/A               N/A                       The Responsible          The Responsible
                           — The Responsible Entity shall review and                                                  Entity did not review    Entity did not review
                           update the documentation specified in                                                      and update the           and update the
                           Standard CIP-007 at least annually.                                                        documentation            documentation
                           Changes resulting                                                                          specified in Standard    specified in Standard
                           from modifications to the systems or                                                       CIP-007 at least         CIP-007 at least
                           controls shall be documented within ninety                                                 annually or the          annually nor were
                           calendar                                                                                   Responsible Entity did   Changes resulting
                                                                                                                      not document Changes     from modifications to
                           days of the change.
                                                                                                                      resulting from           the systems or controls
                                                                                                                      modifications to the     documented within
                                                                                                                      systems or controls      ninety calendar days
                                                                                                                      within ninety calendar   of the change.
                                                                                                                      days of the change.
CIP-008-1   R1.            Cyber Security Incident Response Plan —        N/A               The Responsible           The Responsible          The Responsible
                           The Responsible Entity shall develop and                         Entity has developed      Entity has developed a   Entity has not
                           maintain a                                                       but not maintained a      Cyber Security           developed a Cyber
                           Cyber Security Incident response plan. The                       Cyber Security            Incident response plan   Security Incident
                           Cyber Security Incident Response plan                            Incident response plan.   but the plan does not    response plan.
                           shall                                                                                      address one or more of
                                                                                                                      the subrequirements
                           address, at a minimum, the following:
                                                                                                                      R1.1 through R1.6
CIP-008-1   R1.1.          Procedures to characterize and classify        N/A               N/A                       N/A                      N/A
                           events as reportable Cyber Security
                           Incidents.
CIP-008-1   R1.2.          Response actions, including roles and          N/A               N/A                       N/A                      N/A
                           responsibilities of incident response teams,
                           incident handling procedures, and
                           communication plans.
CIP-008-1   R1.3.          Process for reporting Cyber Security           N/A               N/A                       N/A                      N/A
                           Incidents to the Electricity Sector
                           Information Sharing and Analysis Center
                           (ES ISAC). The Responsible Entity must

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 Standard    Requirement
                                      Text of Requirement                       Lower VSL            Moderate VSL                 High VSL                Severe VSL
 Number        Number
                           ensure that all reportable Cyber Security
                           Incidents are reported to the ES ISAC
                           either directly or through an intermediary.
CIP-008-1   R1.4.          Process for updating the Cyber Security        N/A                     N/A                       N/A                     N/A
                           Incident response plan within ninety
                           calendar days of any changes.
CIP-008-1   R1.5.          Process for ensuring that the Cyber Security   N/A                     N/A                       N/A                     N/A
                           Incident response plan is reviewed at least
                           annually.
CIP-008-1   R1.6.          Process for ensuring the Cyber Security        N/A                     N/A                       N/A                     N/A
                           Incident response plan is tested at least
                           annually. A test of the incident response
                           plan can range from a paper drill, to a full
                           operational exercise, to the response to an
                           actual incident.
CIP-008-1   R2             Cyber Security Incident Documentation —        The Responsible         The Responsible           The Responsible         The Responsible
                           The Responsible Entity shall keep relevant     Entity has kept         Entity has kept           Entity has kept         Entity has not kept
                           documentation related to Cyber Security        relevant                relevant                  relevant                relevant
                           Incidents reportable per Requirement R1.1      documentation           documentation related     documentation related   documentation related
                           for three calendar years.                      related to Cyber        to Cyber Security         to Cyber Security       to Cyber Security
                                                                          Security Incidents      Incidents reportable      Incidents reportable    Incidents reportable
                                                                          reportable per          per Requirement R1.1      per Requirement R1.1    per Requirement R1.1.
                                                                          Requirement R1.1 for    for less than two         for less than one
                                                                          two but less than       calendar years.           calendar year.
                                                                          three calendar years.
CIP-009-1   R1             Recovery Plans — The Responsible Entity        N/A                     The Responsible           The Responsible         The Responsible
                           shall create and annually review recovery                              Entity has not annually   Entity has created      Entity has not created
                           plan(s) for Critical Cyber Assets. The                                 reviewed recovery         recovery plan(s) for    recovery plan(s) for
                           recovery plan(s) shall address at a                                    plan(s) for Critical      Critical Cyber Assets   Critical Cyber Assets
                           minimum the following:                                                 Cyber Assets.             but did not address     that address at a
                                                                                                                            one of the              minimum both
                                                                                                                            requirements CIP-009-   requirements CIP-009-
                                                                                                                            1 R1.1 or R1.2.         1 R1.1 and R1.2.
CIP-009-1   R1.1.          Specify the required actions in response to    N/A                     N/A                       N/A                     N/A
                           events or conditions of varying duration
                           and severity that would activate the
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Complete Violation Severity Level Matrix (CIP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL             Moderate VSL                 High VSL                  Severe VSL
 Number        Number
                           recovery plan(s).
CIP-009-1   R1.2.          Define the roles and responsibilities of       N/A                      N/A                       N/A                       N/A
                           responders.
CIP-009-1   R2             Exercises — The recovery plan(s) shall be      N/A                      N/A                       N/A                       The Responsible
                           exercised at least annually. An exercise of                                                                                 Entity's recovery
                           the recovery plan(s) can range from a paper                                                                                 plan(s) have not been
                           drill, to a full operational exercise, to                                                                                   exercised at least
                           recovery from an actual incident.                                                                                           annually.
CIP-009-1   R3             Change Control — Recovery plan(s) shall        The Responsible          The Responsible           The Responsible           The Responsible
                           be updated to reflect any changes or lessons   Entity's recovery        Entity's recovery         Entity's recovery         Entity's recovery
                           learned as a result of an exercise or the      plan(s) have been        plan(s) have been         plan(s) have been         plan(s) have not been
                           recovery from an actual incident. Updates      updated to reflect any   updated to reflect any    updated to reflect any    updated to reflect any
                           shall be communicated to personnel             changes or lessons       changes or lessons        changes or lessons        changes or lessons
                           responsible for the activation and             learned as a result of   learned as a result of    learned as a result of    learned as a result of
                           implementation of the recovery plan(s)         an exercise or the       an exercise or the        an exercise or the        an exercise or the
                           within ninety calendar days of the change.     recovery from an         recovery from an          recovery from an          recovery from an
                                                                          actual incident but      actual incident but the   actual incident but the   actual incident.
                                                                          the updates were         updates were              updates were              OR
                                                                          communicated to          communicated to           communicated to
                                                                                                                                                       The Responsible
                                                                          personnel responsible    personnel responsible     personnel responsible
                                                                                                                                                       Entity's recovery
                                                                          for the activation and   for the activation and    for the activation and
                                                                                                                                                       plan(s) have been
                                                                          implementation of        implementation of the     implementation of the
                                                                                                                                                       updated to reflect any
                                                                          the recovery plan(s)     recovery plan(s) in       recovery plan(s) in
                                                                                                                                                       changes or lessons
                                                                          in more than 90 but      more than 120 but less    more than 150 but less
                                                                                                                                                       learned as a result of
                                                                          less than or equal to    than or equal to 150      than or equal to 180
                                                                                                                                                       an exercise or the
                                                                          120 calendar days of     calendar days of the      calendar days of the
                                                                                                                                                       recovery from an
                                                                          the change.              change.                   change.
                                                                                                                                                       actual incident but the
                                                                                                                                                       updates were
                                                                                                                                                       communicated to
                                                                                                                                                       personnel responsible
                                                                                                                                                       for the activation and
                                                                                                                                                       implementation of the
                                                                                                                                                       recovery plan(s) in
                                                                                                                                                       more than 180
                                                                                                                                                       calendar days of the
                                                                                                                                                       change.

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 Standard   Requirement
                                     Text of Requirement                        Lower VSL     Moderate VSL         High VSL        Severe VSL
 Number       Number
CIP-009-1   R4            Backup and Restore — The recovery               N/A               N/A              N/A              The Responsible
                          plan(s) shall include processes and                                                                 Entity's recovery
                          procedures for the backup and storage of                                                            plan(s) do not include
                          information required to successfully restore                                                        processes and
                          Critical Cyber Assets. For example,                                                                 procedures for the
                          backups may include spare electronic                                                                backup and storage of
                          components or equipment, written                                                                    information required
                          documentation of configuration settings,                                                            to successfully restore
                          tape backup, etc.                                                                                   Critical Cyber Assets.
CIP-009-1   R5            Testing Backup Media — Information              N/A               N/A              N/A              The Responsible
                          essential to recovery that is stored on                                                             Entity's information
                          backup media shall be tested at least                                                               essential to recovery
                          annually to ensure that the information is                                                          that is stored on
                          available. Testing can be completed off site.                                                       backup media has not
                                                                                                                              been tested at least
                                                                                                                              annually to ensure that
                                                                                                                              the information is
                                                                                                                              available.




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Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                         Text of Requirement                   Lower VSL             Moderate VSL               High VSL               Severe VSL
 Number        Number
COM-001-    R1.            Each Reliability Coordinator, Transmission    The responsible          The responsible         The responsible         The responsible
1.1                        Operator, and Balancing Authority shall       entity's                 entity's                entity's                entity's
                           provide adequate and reliable                 telecommunications       telecommunications is   telecommunications is   telecommunications is
                           telecommunications facilities for the         is not redundant or      not redundant or        not redundant or        not redundant or
                           exchange of Interconnection and operating     diversely routed as      diversely routed as     diversely routed as     diversely routed as
                           information:                                  applicable by other      applicable and has      applicable and has      applicable and has
                                                                         operating entities for   failed to establish     failed to establish     failed to establish
                                                                         the exchange of          telecommunications      telecommunications      telecommunications
                                                                         interconnection or       internally for the      internally and with     internally and with
                                                                         operating data.          exchange of             other Reliability       both other and its
                                                                                                  interconnection or      Coordinators,           Reliability
                                                                                                  operating data needed   Transmission            Coordinators,
                                                                                                  to maintain BES         Operators, or           Transmission
                                                                                                  reliability.            Balancing Authorities   Operators, or
                                                                                                                          for the exchange of     Balancing Authorities
                                                                                                                          interconnection or      for the exchange of
                                                                                                                          operating data needed   interconnection or
                                                                                                                          to maintain BES         operating data needed
                                                                                                                          reliability.            to maintain BES
                                                                                                                                                  reliability.
COM-001-    R1.1.          Internally.                                   N/A                      N/A                     N/A                     The responsible entity
1.1                                                                                                                                               has failed to establish
                                                                                                                                                  telecommunications
                                                                                                                                                  internally for the
                                                                                                                                                  exchange of
                                                                                                                                                  interconnection or
                                                                                                                                                  operating data needed
                                                                                                                                                  to maintain BES
                                                                                                                                                  reliability.
COM-001-    R1.2.          Between the Reliability Coordinator and its   N/A                      N/A                     N/A                     The responsible entity
1.1                        Transmission Operators and Balancing                                                                                   has failed to establish
                           Authorities.                                                                                                           telecommunications
                                                                                                                                                  with its Reliability
                                                                                                                                                  Coordinator,
                                                                                                                                                  Transmission
                                                                                                                                                  Operators, or
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Complete Violation Severity Level Matrix (COM)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL      Moderate VSL                High VSL                Severe VSL
 Number        Number
                                                                                                                                              Balancing Authorities
                                                                                                                                              for the exchange of
                                                                                                                                              interconnection or
                                                                                                                                              operating data needed
                                                                                                                                              to maintain BES
                                                                                                                                              reliability.
COM-001-    R1.3.          With other Reliability Coordinators,           N/A               N/A                      NA                       The responsible entity
1.1                        Transmission Operators, and Balancing                                                                              has failed to establish
                           Authorities as necessary to maintain                                                                               telecommunications
                           reliability.                                                                                                       with other Reliability
                                                                                                                                              Coordinators,
                                                                                                                                              Transmission
                                                                                                                                              Operators, or
                                                                                                                                              Balancing Authorities
                                                                                                                                              for the exchange of
                                                                                                                                              interconnection or
                                                                                                                                              operating data needed
                                                                                                                                              to maintain BES
                                                                                                                                              reliability.
COM-001-    R1.4.          Where applicable, these facilities shall be    N/A               N/A                      N/A                      The responsible
1.1                        redundant and diversely routed.                                                                                    entity's
                                                                                                                                              telecommunications is
                                                                                                                                              not redundant or
                                                                                                                                              diversely routed where
                                                                                                                                              applicable for the
                                                                                                                                              exchange of
                                                                                                                                              interconnection or
                                                                                                                                              operating data.
COM-001-    R2.            Each Reliability Coordinator, Transmission     N/A               The responsible entity   The responsible entity   The responsible entity
1.1                        Operator, and Balancing Authority shall                          has failed to manage,    has failed to manage,    has failed to manage,
                           manage, alarm, test and/or actively monitor                      alarm, and test or       alarm, and test or       alarm, and test or
                           vital telecommunications facilities. Special                     actively monitor its     actively monitor its     actively monitor its
                           attention shall be given to emergency                            emergency                primary                  primary and
                           telecommunications facilities and                                telecommunications       telecommunications       emergency
                           equipment not used for routine                                   facilities.              facilities.              telecommunications
                           communications.                                                                                                    facilities.
COM-001-    R3.            Each Reliability Coordinator, Transmission     N/A               N/A                      The responsible entity   The responsible entity
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Complete Violation Severity Level Matrix (COM)
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  Standard    Requirement
                                       Text of Requirement                       Lower VSL     Moderate VSL         High VSL                 Severe VSL
  Number        Number
1.1                         Operator and Balancing Authority shall                                            failed to assist in the   failed to provide a
                            provide a means to coordinate                                                     investigation and         means to coordinate
                            telecommunications among their respective                                         recommending of           telecommunications
                            areas. This coordination shall include the                                        solutions to              among their respective
                            ability to investigate and recommend                                              telecommunications        areas including
                            solutions to telecommunications problems                                          problems within the       assisting in the
                            within the area and with other areas.                                             area and with other       investigation and
                                                                                                              areas.                    recommending of
                                                                                                                                        solutions to
                                                                                                                                        telecommunications
                                                                                                                                        problems within the
                                                                                                                                        area and with other
                                                                                                                                        areas.
COM-001-     R4.            Unless agreed to otherwise, each Reliability   N/A               N/A              N/A                       If using a language
1.1                         Coordinator, Transmission Operator, and                                                                     other than English, the
                            Balancing Authority shall use English as the                                                                responsible entity
                            language for all communications between                                                                     failed to provide
                            and among operating personnel responsible                                                                   documentation of
                            for the real-time generation control and                                                                    agreement to use a
                            operation of the interconnected Bulk                                                                        language other than
                            Electric System. Transmission Operators                                                                     English for all
                            and Balancing Authorities may use an                                                                        communications
                            alternate language for internal operations.                                                                 between and among
                                                                                                                                        operating personnel
                                                                                                                                        responsible for the
                                                                                                                                        real-time generation
                                                                                                                                        control and operation
                                                                                                                                        of the interconnected
                                                                                                                                        Bulk Electric System.
COM-001-     R5.            Each Reliability Coordinator, Transmission     N/A               N/A              N/A                       The responsible entity
1.1                         Operator, and Balancing Authority shall                                                                     did not have written
                            have written operating instructions and                                                                     operating instructions
                            procedures to enable continued operation of                                                                 and procedures to
                            the system during the loss of                                                                               enable continued
                            telecommunications facilities.                                                                              operation of the
                                                                                                                                        system during the loss
                                                                                                                                        of telecommunications
                                                                                                                                        facilities.
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Complete Violation Severity Level Matrix (COM)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                        Lower VSL             Moderate VSL                  High VSL                    Severe VSL
 Number        Number
COM-001-    R6.            Each NERCNet User Organization shall            The NERCNet User         The NERCNet User          The NERCNet User             The NERCNet User
1.1                        adhere to the requirements in Attachment 1-     Organization failed to   Organization failed to    Organization failed to       Organization failed to
                           COM-001-0, “NERCNet Security Policy.”           adhere to less than      adhere to 25% or more     adhere to 50% or more        adhere to 75% or more
                                                                           25% of the               but less than 50% of      but less than 75% of         of the requirements
                                                                           requirements listed in   the requirements listed   the requirements listed      listed in COM-001-0,
                                                                           COM-001-0,               in COM-001-0,             in COM-001-0,                Attachment 1,
                                                                           Attachment 1,            Attachment 1,             Attachment 1,                "NERCNet Security
                                                                           "NERCNet Security        "NERCNet Security         "NERCNet Security            Policy".
                                                                           Policy".                 Policy".                  Policy".
COM-002-2   R1.            Each Transmission Operator, Balancing           N/A                      The responsible entity    The responsible entity       The responsible entity
                           Authority, and Generator Operator shall                                  did not have data links   did not staff the            failed to have
                           have communications (voice and data links)                               with appropriate          communications               communications
                           with appropriate Reliability Coordinators,                               Reliability               (voice and data links)       (voice and data links)
                           Balancing Authorities, and Transmission                                  Coordinators,             on a 24 hour basis.          with appropriate
                           Operators. Such communications shall be                                  Balancing Authorities,                                 Reliability
                           staffed and available for addressing a real-                             and Transmission                                       Coordinators,
                           time emergency condition.                                                Operators.                                             Balancing Authorities,
                                                                                                                                                           and Transmission
                                                                                                                                                           Operators.
COM-002-2   R1.1.          Each Balancing Authority and Transmission       N/A                      N/A                       The responsible entity       The responsible entity
                           Operator shall notify its Reliability                                                              failed to notify all         failed to notify its
                           Coordinator, and all other potentially                                                             other potentially            Reliability
                           affected Balancing Authorities and                                                                 affected Balancing           Coordinator, and all
                           Transmission Operators through                                                                     Authorities and              other potentially
                           predetermined communication paths of any                                                           Transmission                 affected Balancing
                           condition that could threaten the reliability                                                      Operators through            Authorities and
                           of its area or when firm load shedding is                                                          predetermined                Transmission
                           anticipated.                                                                                       communication paths          Operators through
                                                                                                                              of any condition that        predetermined
                                                                                                                              could threaten the           communication paths
                                                                                                                              reliability of its area or   of any condition that
                                                                                                                              when firm load               could threaten the
                                                                                                                              shedding is                  reliability of its area or
                                                                                                                              anticipated.                 when firm load
                                                                                                                                                           shedding is
                                                                                                                                                           anticipated.
COM-002-2   R2.            Each Reliability Coordinator, Transmission      N/A                      The responsible entity    The responsible entity       The responsible entity
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Complete Violation Severity Level Matrix (COM)
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Standard   Requirement
                                    Text of Requirement                  Lower VSL      Moderate VSL                 High VSL                  Severe VSL
Number       Number
                         Operator, and Balancing Authority shall                     provided a clear          provided a clear           failed to provide a
                         issue directives in a clear, concise, and                   directive in a clear,     directive in a clear,      clear directive in a
                         definitive manner; shall ensure the recipient               concise and definitive    concise and definitive     clear, concise and
                         of the directive repeats the information back               manner and required       manner, but did not        difinitive manner
                         correctly; and shall acknowledge the                        the recipient to repeat   require the recipient to   when required.
                         response as correct or repeat the original                  the directive, but did    repeat the directive.
                         statement to resolve any misunderstandings.                 not acknowledge the
                                                                                     recipient was correct
                                                                                     in the repeated
                                                                                     directive.




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Complete Violation Severity Level Matrix (EOP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                     Lower VSL             Moderate VSL              High VSL                 Severe VSL
 Number        Number
EOP-001-0   R1.            Balancing Authorities shall have operating    The Balancing            The Balancing         The Balancing             The Balancing
                           agreements with adjacent Balancing            Authority failed to      Authority failed to   Authority failed to       Authority failed to
                           Authorities that shall, at a minimum,         demonstrate the          demonstrate the       demonstrate the           demonstrate the
                           contain provisions for emergency              existence of the         existence of the      existence of the          existence of the
                           assistance, including provisions to obtain    necessary operating      necessary operating   necessary operating       necessary operating
                           emergency assistance from remote              agreements for less      agreements for 25%    agreements for 50% to     agreements for 75% or
                           Balancing Authorities.                        than 25% of the          to 50% of the         75% of the adjacent       more of the adjacent
                                                                         adjacent BAs. Or less    adjacent BAs. Or 25   BAs. Or 50% to 75% of     BAs. Or more than
                                                                         than 25% of those        to 50% of those       those agreements do not   75% of those
                                                                         agreements do not        agreements do not     contain provisions for    agreements do not
                                                                         contain provisions for   contain provisions    emergency assistance.     contain provisions for
                                                                         emergency assistance.    for emergency                                   emergency assistance.
                                                                                                  assistance.
EOP-001-0   R2.            The Transmission Operator shall have an       The Transmission         N/A                   The Transmission          The Transmission
                           emergency load reduction plan for all         Operator has                                   Operator fails to         Operator failed to
                           identified IROLs. The plan shall include      demonstrated the                               include details on how    demonstrate the
                           the details on how the Transmission           existence of the                               load reduction is to be   existence of
                           Operator will implement load reduction in     emergency load                                 implemented in            emergency load
                           sufficient amount and time to mitigate the    reduction plan but the                         sufficient amount and     reduction plans for all
                           IROL violation before system separation or    plan will take longer                          time to mitigate IROL     identified IROLs.
                           collapse would occur. The load reduction      than 30 minutes.                               violation.
                           plan must be capable of being implemented
                           within 30 minutes.
EOP-001-0   R3.            Each Transmission Operator and Balancing      The Transmission         The Transmission      The Transmission          The Transmission
                           Authority shall:                              Operator or Balancing    Operator or           Operator or Balancing     Operator or Balancing
                                                                         Authority failed to      Balancing Authority   Authority has failed to   Authority has failed to
                                                                         comply with one (1)      failed to comply      comply with three (3)     comply with four (4)
                                                                         of the sub-              with two (2) of the   of the sub-components.    of the sub-
                                                                         components.              sub-components.                                 components.
EOP-001-0   R3.1.          Develop, maintain, and implement a set of     The Transmission         The Transmission      The Transmission          The Transmission
                           plans to mitigate operating emergencies for   Operator or Balancing    Operator or           Operator or Balancing     Operator or Balancing
                           insufficient generating capacity.             Authority’s              Balancing             Authority's emergency     Authority has failed to
                                                                         emergency plans to       Authority's has       plans to mitigate         develop emergency
                                                                         mitigate insufficient    demonstrated the      insufficient generating   mitigation plans for
                                                                         generating capacity      existence of          capacity emergency        insufficient generating

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Complete Violation Severity Level Matrix (EOP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                     Text of Requirement                    Lower VSL             Moderate VSL                High VSL                  Severe VSL
 Number        Number
                                                                        are missing minor       emergency plans to      plans are not              capacity.
                                                                        details or minor        mitigate insufficient   maintained nor
                                                                        program/procedural      generating capacity     implemented.
                                                                        elements.               emergency plans but
                                                                                                the plans are not
                                                                                                maintained.
EOP-001-0   R3.2.          Develop, maintain, and implement a set of    The Transmission        The Transmission        The Transmission           The Transmission
                           plans to mitigate operating emergencies on   Operator or Balancing   Operator or             Operator or Balancing      Operator or Balancing
                           the transmission system.                     Authority’s plans to    Balancing               Authority's                Authority has failed to
                                                                        mitigate transmission   Authority's has         transmission system        develop, maintain, and
                                                                        system emergencies      demonstrated the        emergency plans are        implement operating
                                                                        are missing minor       existence of            not maintained nor         emergency mitigation
                                                                        details or minor        transmission system     implemented.               plans for emergencies
                                                                        program/procedural      emergency plans but                                on the transmission
                                                                        elements.               are not maintained.                                system.
EOP-001-0   R3.3.          Develop, maintain, and implement a set of    The Transmission        The Transmission        The Transmission           The Transmission
                           plans for load shedding.                     Operator or Balancing   Operator or             Operator or Balancing      Operator or Balancing
                                                                        Authority’s load        Balancing               Authority's load           Authority has failed to
                                                                        shedding plans are      Authority's has         shedding plans are         develop, maintain, and
                                                                        missing minor details   demonstrated the        partially compliant with   implement load
                                                                        or minor                existence of load       the requirement but are    shedding plans.
                                                                        program/procedural      shedding plans but      not maintained nor
                                                                        elements.               are not maintained.     implemented.
EOP-001-0   R3.4.          Develop, maintain, and implement a set of    The Transmission        The Transmission        The Transmission           The Transmission
                           plans for system restoration.                Operator or Balancing   Operator or             Operator or Balancing      Operator or Balancing
                                                                        Authority’s system      Balancing               Authority's restoration    Authority has failed to
                                                                        restoration plans are   Authority's system      plans are not              develop, maintain, and
                                                                        missing minor details   restoration plans are   maintained nor             implement operating
                                                                        or minor                partially compliant     implemented.               emergency mitigation
                                                                        program/procedural      with the requirement                               plans for system
                                                                        elements.               but are not                                        restoration.
                                                                                                maintained.
EOP-001-0   R4.            Each Transmission Operator and Balancing     The Transmission        The Transmission        The Transmission           The Transmission
                           Authority shall have emergency plans that    Operator or Balancing   Operator or             Operator or Balancing      Operator or Balancing
                           will enable it to mitigate operating         Authority failed to     Balancing Authority     Authority has failed to    Authority has failed to
                           emergencies. At a minimum, Transmission      comply with one (1)     failed to comply        comply with three (3)      comply with all four
                           Operator and Balancing Authority             of the sub-             with two (2) of the     of the sub-components.     (4) of the sub-

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Complete Violation Severity Level Matrix (EOP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL             Moderate VSL          High VSL                 Severe VSL
 Number        Number
                           emergency plans shall include:                 components.               sub-components.                             components.
EOP-001-0   R4.1.          Communications protocols to be used            The Transmission          N/A               N/A                       The Transmission
                           during emergencies.                            Operator or Balancing                                                 Operator or Balancing
                                                                          Authority’s                                                           Authority has failed to
                                                                          communication                                                         include
                                                                          protocols included in                                                 communication
                                                                          the emergency plan                                                    protocols in its
                                                                          are missing minor                                                     emergency plans to
                                                                          program/procedural                                                    mitigate operating
                                                                          elements.                                                             emergencies.
EOP-001-0   R4.2.          A list of controlling actions to resolve the   The Transmission          N/A               The Transmission          The Transmission
                           emergency. Load reduction, in sufficient       Operator or Balancing                       Operator or Balancing     Operator or Balancing
                           quantity to resolve the emergency within       Authority’s list of                         Authority provided a      Authority has failed to
                           NERC-established timelines, shall be one of    controlling actions has                     list of controlling       provide a list of
                           the controlling actions.                       resulted in meeting the                     actions; however the      controlling actions to
                                                                          intent of the                               actions fail to resolve   resolve the
                                                                          requirement but is                          the emergency within      emergency.
                                                                          missing minor                               NERC-established
                                                                          program/procedural                          timelines.
                                                                          elements.
EOP-001-0   R4.3.          The tasks to be coordinated with and among     The Transmission          N/A               N/A                       The Transmission
                           adjacent Transmission Operators and            Operator or Balancing                                                 Operator or Balancing
                           Balancing Authorities.                         Authority has                                                         Authority has failed to
                                                                          demonstrated                                                          demonstrate the tasks
                                                                          coordination with                                                     to be coordinated with
                                                                          Transmission                                                          adjacent Transmission
                                                                          Operators and                                                         Operator and
                                                                          Balancing Authorities                                                 Balancing Authorities
                                                                          but is missing minor                                                  as directed by the
                                                                          program/procedural                                                    requirement.
                                                                          elements.
EOP-001-0   R4.4.          Staffing levels for the emergency.             N/A                       N/A               N/A                       The Transmission
                                                                                                                                                Operator or Balancing
                                                                                                                                                Authority’s
                                                                                                                                                emergency plan does
                                                                                                                                                not include staffing
                                                                                                                                                levels for the

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Complete Violation Severity Level Matrix (EOP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                      Lower VSL            Moderate VSL              High VSL                  Severe VSL
 Number        Number
                                                                                                                                                   emergency
EOP-001-0   R5.            Each Transmission Operator and Balancing      The Transmission         The Transmission      The Transmission           The Transmission
                           Authority shall include the applicable        Operator and             Operator and          Operator and Balancing     Operator and
                           elements in Attachment 1-EOP-001-0 when       Balancing Authority      Balancing Authority   Authority emergency        Balancing Authority
                           developing an emergency plan.                 emergency plan has       emergency plan has    plan has complied with     emergency plan has
                                                                         complied with 90% or     complied with 70%     between 50% to 70% of      complied with 50% or
                                                                         more of the number of    to 90% of the         the number of sub-         less of the number of
                                                                         sub-components.          number of sub-        components.                sub-components
                                                                                                  components.
EOP-001-0   R6.            The Transmission Operator and Balancing       The Transmission         The Transmission      The Transmission           The Transmission
                           Authority shall annually review and update    Operator and             Operator and          Operator and Balancing     Operator and
                           each emergency plan. The Transmission         Balancing Authority is   Balancing Authority   Authority has failed to    Balancing Authority
                           Operator and Balancing Authority shall        missing minor            has failed to         annually review 2 of its   has failed to annually
                           provide a copy of its updated emergency       program/procedural       annually review one   emergency plans or         review and/or
                           plans to its Reliability Coordinator and to   elements.                of it's emergency     communicate with 1 of      communicate any
                           neighboring Transmission Operators and                                 plans                 its neighboring            emergency plans with
                           Balancing Authorities.                                                                       Balancing Authorities.     its Reliability
                                                                                                                                                   Coordinator,
                                                                                                                                                   neighboring
                                                                                                                                                   Transmission
                                                                                                                                                   Operators or
                                                                                                                                                   Balancing Authorities.
EOP-001-0   R7.            The Transmission Operator and Balancing       The Transmission         The Transmission      The Transmission           The Transmission
                           Authority shall coordinate its emergency      Operator and/or the      Operator and/or the   Operator and/or the        Operator and/or the
                           plans with other Transmission Operators       Balancing Authority      Balancing Authority   Balancing Authority        Balancing Authority
                           and Balancing Authorities as appropriate.     failed to comply with    failed to comply      has failed to comply       has failed to comply
                           This coordination includes the following      one (1) of the sub-      with two (2) of the   with three (3) of the      with four (4) or more
                           steps, as applicable:                         components.              sub-components.       sub-components.            of the sub-
                                                                                                                                                   components.
EOP-001-0   R7.1.          The Transmission Operator and Balancing       N/A                      N/A                   N/A                        The Transmission
                           Authority shall establish and maintain                                                                                  Operator or Balancing
                           reliable communications between                                                                                         Authority has failed to
                           interconnected systems.                                                                                                 establish and maintain
                                                                                                                                                   reliable
                                                                                                                                                   communication
                                                                                                                                                   between
                                                                                                                                                   interconnected

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Complete Violation Severity Level Matrix (EOP)
Encompassing All Commission-Approved Reliability Standards
 Standard      Requirement
                                        Text of Requirement                       Lower VSL    Moderate VSL         High VSL        Severe VSL
 Number          Number
                                                                                                                               systems.
EOP-001-0     R7.2.          The Transmission Operator and Balancing        N/A               N/A             N/A              The Transmission
                             Authority shall arrange new interchange                                                           Operator or Balancing
                             agreements to provide for emergency                                                               Authority has failed to
                             capacity or energy transfers if existing                                                          arrange new
                             agreements cannot be used.                                                                        interchange
                                                                                                                               agreements to provide
                                                                                                                               for emergency
                                                                                                                               capacity or energy
                                                                                                                               transfers with required
                                                                                                                               entities when existing
                                                                                                                               agreements could not
                                                                                                                               be used.
EOP-001-0     R7.3.          The Transmission Operator and Balancing        N/A               N/A             N/A              The Transmission
                             Authority shall coordinate transmission and                                                       Operator or Balancing
                             generator maintenance schedules to                                                                Authority has failed to
                             maximize capacity or conserve the fuel in                                                         coordinate
                             short supply. (This includes water for                                                            transmission and
                             hydro generators.)                                                                                generator maintenance
                                                                                                                               schedules to maximize
                                                                                                                               capacity or conserve
                                                                                                                               fuel in short supply.
EOP-001-0     R7.4.          The Transmission Operator and Balancing        N/A               N/A             N/A              The Transmission
                             Authority shall arrange deliveries of                                                             Operator or Balancing
                             electrical energy or fuel from remote                                                             Authority has failed to
                             systems through normal operating channels.                                                        arrange for deliveries
                                                                                                                               of electrical energy or
                                                                                                                               fuel from remote
                                                                                                                               systems through
                                                                                                                               normal operating
                                                                                                                               channels.
EOP-002-2.1   R1.            Each Balancing Authority and Reliability       N/A               N/A             N/A              The Balancing
                             Coordinator shall have the responsibility                                                         Authority or
                             and clear decision-making authority to take                                                       Reliability
                             whatever actions are needed to ensure the                                                         Coordinator does not
                             reliability of its respective area and shall                                                      have responsibility
                             exercise specific authority to alleviate                                                          and clear decision-

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Complete Violation Severity Level Matrix (EOP)
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 Standard      Requirement
                                       Text of Requirement                       Lower VSL    Moderate VSL         High VSL                  Severe VSL
 Number          Number
                             capacity and energy emergencies.                                                                           making authority to
                                                                                                                                        take whatever actions
                                                                                                                                        are needed to ensure
                                                                                                                                        the reliability of its
                                                                                                                                        respective area OR
                                                                                                                                        The Balancing
                                                                                                                                        Authority or
                                                                                                                                        Reliability
                                                                                                                                        Coordinator did not
                                                                                                                                        exercise its authority
                                                                                                                                        to alleviate capacity
                                                                                                                                        and energy
                                                                                                                                        emergencies.
EOP-002-2.1   R2.            Each Balancing Authority shall implement      N/A               N/A             N/A                        The Balancing
                             its capacity and energy emergency plan,                                                                    Authority did not
                             when required and as appropriate, to reduce                                                                implement its capacity
                             risks to the interconnected system.                                                                        and energy emergency
                                                                                                                                        plan, when required
                                                                                                                                        and as appropriate, to
                                                                                                                                        reduce risks to the
                                                                                                                                        interconnected system.
EOP-002-2.1   R3.            A Balancing Authority that is experiencing    N/A               N/A             The Balancing              The Balancing
                             an operating capacity or energy emergency                                       Authority                  Authority has failed to
                             shall communicate its current and future                                        communicated its           communicate its
                             system conditions to its Reliability                                            current and future         current and future
                             Coordinator and neighboring Balancing                                           system conditions to its   system conditions to
                             Authorities.                                                                    Reliability Coordinator    its Reliability
                                                                                                             but did not                Coordinator and
                                                                                                             communicate to one or      neighboring Balancing
                                                                                                             more of its neighboring    Authorities.
                                                                                                             Balancing Authorities.
EOP-002-2.1   R4.            A Balancing Authority anticipating an         N/A               N/A             N/A                        The Balancing
                             operating capacity or energy emergency                                                                     Authority has failed to
                             shall perform all actions necessary                                                                        perform the necessary
                             including bringing on all available                                                                        actions as required
                             generation, postponing equipment                                                                           and stated in the
                             maintenance, scheduling interchange                                                                        requirement.
                             purchases in advance, and being prepared to
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Complete Violation Severity Level Matrix (EOP)
Encompassing All Commission-Approved Reliability Standards
 Standard      Requirement
                                        Text of Requirement                       Lower VSL         Moderate VSL               High VSL                 Severe VSL
 Number          Number
                             reduce firm load.
EOP-002-2.1   R5.            A deficient Balancing Authority shall only     N/A                   N/A                    The Balancing             The Balancing
                             use the assistance provided by the                                                          Authority used the        Authority used the
                             Interconnection’s frequency bias for the                                                    assistance provided by    assistance provided by
                             time needed to implement corrective                                                         the Interconnection’s     the Interconnection’s
                             actions. The Balancing Authority shall not                                                  frequency bias for more   frequency bias for
                             unilaterally adjust generation in an attempt                                                time than needed to       more time than needed
                             to return Interconnection frequency to                                                      implement corrective      to implement
                             normal beyond that supplied through                                                         actions.                  corrective actions and
                             frequency bias action and Interchange                                                                                 unilaterally adjust
                             Schedule changes. Such unilateral                                                                                     generation in an
                             adjustment may overload transmission                                                                                  attempt to return
                             facilities.                                                                                                           Interconnection
                                                                                                                                                   frequency to normal
                                                                                                                                                   beyond that supplied
                                                                                                                                                   through frequency
                                                                                                                                                   bias action and
                                                                                                                                                   Interchange Schedule
                                                                                                                                                   changes.
EOP-002-2.1   R6.            If the Balancing Authority cannot comply       The Balancing         The Balancing          The Balancing             The Balancing
                             with the Control Performance and               Authority failed to   Authority failed to    Authority failed to       Authority failed to
                             Disturbance Control Standards, then it shall   comply with one of    comply with 2 of the   comply with 3 of the      comply with more
                             immediately implement remedies to do so.       the sub-components.   sub-components.        sub-components.           than 3 of the sub-
                             These remedies include, but are not limited                                                                           components.
                             to:
EOP-002-2.1   R6.1.          Loading all available generating capacity.     N/A                   N/A                    N/A                       The Balancing
                                                                                                                                                   Authority did not use
                                                                                                                                                   all available
                                                                                                                                                   generating capacity.
EOP-002-2.1   R6.2.          Deploying all available operating reserve      N/A                   N/A                    N/A                       The Balancing
                                                                                                                                                   Authority did not
                                                                                                                                                   deploy all of its
                                                                                                                                                   available operating
                                                                                                                                                   reserve.
EOP-002-2.1   R6.3.          Interrupting interruptible load and exports.   N/A                   N/A                    N/A                       The Balancing
                                                                                                                                                   Authority did not
                                                                                                                                                   interrupt interruptible
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 Standard      Requirement
                                        Text of Requirement                         Lower VSL         Moderate VSL         High VSL                Severe VSL
 Number          Number
                                                                                                                                              load and exports.
EOP-002-2.1   R6.4.          Requesting emergency assistance from             N/A                    N/A             N/A                      The Balancing
                             other Balancing Authorities.                                                                                     Authority did not
                                                                                                                                              request emergency
                                                                                                                                              assistance from other
                                                                                                                                              Balancing Authorities.
EOP-002-2.1   R6.5.          Declaring an Energy Emergency through its        N/A                    N/A             N/A                      The Balancing
                             Reliability Coordinator; and                                                                                     Authority did not
                                                                                                                                              declare an Energy
                                                                                                                                              Emergency through its
                                                                                                                                              Reliability
                                                                                                                                              Coordinator.
EOP-002-2.1   R6.6.          Reducing load, through procedures such as        N/A                    N/A             N/A                      The Balancing
                             public appeals, voltage reductions,                                                                              Authority did not
                             curtailing interruptible loads and firm loads.                                                                   implement one or
                                                                                                                                              more of the
                                                                                                                                              procedures stated in
                                                                                                                                              the requirement.
EOP-002-2.1   R7.            Once the Balancing Authority has                 N/A                    N/A             The Balancing            The Balancing
                             exhausted the steps listed in Requirement 6,                                            Authority has met only   Authority has not met
                             or if these steps cannot be completed in                                                one of the two           either of the two
                             sufficient time to resolve the emergency                                                requirements             requirements
                             condition, the Balancing Authority shall:
EOP-002-2.1   R7.1.          Manually shed firm load without delay to         N/A                    N/A             N/A                      The Balancing
                             return its ACE to zero; and                                                                                      Authority did not
                                                                                                                                              manually shed firm
                                                                                                                                              load without delay to
                                                                                                                                              return it’s ACE to
                                                                                                                                              zero.
EOP-002-2.1   R7.2.          Request the Reliability Coordinator to           The Balancing          N/A             N/A                      The Balancing
                             declare an Energy Emergency Alert in             Authority’s                                                     Authority has failed to
                             accordance with Attachment 1-EOP-002-0           implementation of an                                            meet one or more of
                             “Energy Emergency Alert Levels.”                 Energy Emergency                                                the requirements of
                                                                              Alert has missed                                                Attachment 1-EOP-
                                                                              minor                                                           002-0.
                                                                              program/procedural

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 Standard      Requirement
                                        Text of Requirement                          Lower VSL           Moderate VSL                High VSL                  Severe VSL
 Number          Number
                                                                               elements in
                                                                               Attachment 1-EOP-
                                                                               002-0.
EOP-002-2.1   R8.            A Reliability Coordinator that has any            The Reliability         N/A                     N/A                        The Reliability
                             Balancing Authority within its Reliability        Coordinator’s                                                              Coordinator has failed
                             Coordinator area experiencing a potential or      implementation of an                                                       to meet one or more of
                             actual Energy Emergency shall initiate an         Energy Emergency                                                           the requirements of
                             Energy Emergency Alert as detailed in             Alert has missed                                                           Attachment 1-EOP-
                             Attachment 1-EOP-002-0 “Energy                    minor                                                                      002-0.
                             Emergency Alert Levels.” The Reliability          program/procedural
                             Coordinator shall act to mitigate the             elements in
                             emergency condition, including a request          Attachment 1-EOP-
                             for emergency assistance if required.             002-0.
EOP-002-2.1   R9.            When a Transmission Service Provider              The Reliability         The Reliability         The Reliability            The Reliability
                             expects to elevate the transmission service       Coordinator failed to   Coordinator failed to   Coordinator has failed     Coordinator has failed
                             priority of an Interchange Transaction from       comply with one (1)     comply with two (2)     to comply with three (3)   to comply with all
                             Priority 6 (Network Integration                   of the sub-             of the sub-             of the sub-components.     four (4) of the sub-
                             Transmission Service from Non-designated          components.             components.                                        components.
                             Resources) to Priority 7 (Network
                             Integration Transmission Service from
                             designated Network Resources) as
                             permitted in its transmission tariff (See
                             Attachment 1-IRO-006-0 “Transmission
                             Loading Relief Procedure” for explanation
                             of Transmission Service Priorities):
EOP-002-2.1   R9.1.          The deficient Load-Serving Entity shall           N/A                     N/A                     N/A                        The Load-Serving
                             request its Reliability Coordinator to initiate                                                                              Entity failed to request
                             an Energy Emergency Alert in accordance                                                                                      its Reliability
                             with Attachment 1-EOP-002-0.                                                                                                 Coordinator to initiate
                                                                                                                                                          an Energy Emergency
                                                                                                                                                          Alert.
EOP-002-2.1   R9.2.          The Reliability Coordinator shall submit the      N/A                     N/A                     N/A                        The Reliability
                             report to NERC for posting on the NERC                                                                                       Coordinator has failed
                             Website, noting the expected total MW that                                                                                   to report to NERC as
                             may have its transmission service priority                                                                                   directed in the
                             changed.                                                                                                                     requirement.
EOP-002-2.1   R9.3.          The Reliability Coordinator shall use EEA 1       N/A                     N/A                     N/A                        The Reliability
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 Standard      Requirement
                                        Text of Requirement                        Lower VSL            Moderate VSL                High VSL                 Severe VSL
 Number          Number
                             to forecast the change of the priority of                                                                                  Coordinator failed to
                             transmission service of an Interchange                                                                                     use EEA 1 to forecast
                             Transaction on the system from Priority 6 to                                                                               the change of the
                             Priority 7.                                                                                                                priority of
                                                                                                                                                        transmission service
                                                                                                                                                        as directed in the
                                                                                                                                                        requirement.
EOP-002-2.1   R9.4.          The Reliability Coordinator shall use EEA 2     N/A                      N/A                     N/A                       The Reliability
                             to announce the change of the priority of                                                                                  Coordinator failed to
                             transmission service of an Interchange                                                                                     use EEA 2 to
                             Transaction on the system from Priority 6 to                                                                               announce the change
                             Priority 7.                                                                                                                of the priority of
                                                                                                                                                        transmission service
                                                                                                                                                        as directed in the
                                                                                                                                                        requirement.
EOP-003-1     R1.            After taking all other remedial steps, a        N/A                      N/A                     N/A                       The Transmission
                             Transmission Operator or Balancing                                                                                         Operator or Balancing
                             Authority operating with insufficient                                                                                      Authority has failed
                             generation or transmission capacity shall                                                                                  shed customer load.
                             shed customer load rather than risk an
                             uncontrolled failure of components or
                             cascading outages of the Interconnection.
EOP-003-1     R2.            Each Transmission Operator and Balancing        N/A                      N/A                     N/A                       The applicable entity
                             Authority shall establish plans for automatic                                                                              did not establish plans
                             load shedding for underfrequency or                                                                                        for automatic load-
                             undervoltage conditions.                                                                                                   shedding, as directed
                                                                                                                                                        by the requirement.
EOP-003-1     R3.            Each Transmission Operator and Balancing        The applicable entity    The applicable entity   The applicable entity     The applicable entity
                             Authority shall coordinate load shedding        did not coordinate       did not coordinate      did not coordinate load   did not coordinate
                             plans among other interconnected                load shedding plans,     load shedding plans,    shedding plans, as        load shedding plans,
                             Transmission Operators and Balancing            as directed by the       as directed by the      directed by the           as directed by the
                             Authorities.                                    requirement, affecting   requirement,            requirement, affecting    requirement, affecting
                                                                             5% or less of its        affecting between 5-    10-15%, inclusive, of     greater than 15% of its
                                                                             required entities.       10% of its required     its required entities.    required entities.
                                                                                                      entities.
EOP-003-1     R4.            A Transmission Operator or Balancing            N/A                      N/A                     N/A                       The applicable entity
                             Authority shall consider one or more of                                                                                    did not consider one
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 Standard    Requirement
                                      Text of Requirement                         Lower VSL             Moderate VSL                High VSL                  Severe VSL
 Number        Number
                           these factors in designing an automatic load                                                                                  of the five required
                           shedding scheme: frequency, rate of                                                                                           elements, as directed
                           frequency decay, voltage level, rate of                                                                                       by the requirement.
                           voltage decay, or power flow levels.
EOP-003-1   R5.            A Transmission Operator or Balancing             N/A                       N/A                     N/A                        The Transmission
                           Authority shall implement load shedding in                                                                                    Operator or Balancing
                           steps established to minimize the risk of                                                                                     Authority has failed to
                           further uncontrolled separation, loss of                                                                                      implement load
                           generation, or system shutdown.                                                                                               shedding as directed
                                                                                                                                                         in the requirement.
EOP-003-1   R6.            After a Transmission Operator or Balancing       N/A                       N/A                     N/A                        The Transmission
                           Authority Area separates from the                                                                                             Operator or Balancing
                           Interconnection, if there is insufficient                                                                                     Authority did not shed
                           generating capacity to restore system                                                                                         load.
                           frequency following automatic
                           underfrequency load shedding, the
                           Transmission Operator or Balancing
                           Authority shall shed additional load.
EOP-003-1   R7.            The Transmission Operator and Balancing          The applicable entity     The applicable entity   The applicable entity      The applicable entity
                           Authority shall coordinate automatic load        did not coordinate        did not coordinate      did not coordinate         did not coordinate
                           shedding throughout their areas with             automatic load            automatic load          automatic load             automatic load
                           underfrequency isolation of generating           shedding, as directed     shedding, as directed   shedding, as directed by   shedding, as directed
                           units, tripping of shunt capacitors, and other   by the requirement,       by the requirement,     the requirement,           by the requirement,
                           automatic actions that will occur under          affecting 5% or less of   affecting between 5 -   affecting 10-15%,          affecting greater than
                           abnormal frequency, voltage, or power flow       its automatic actions.    10% of its automatic    inclusive, of its          15% of its automatic
                           conditions.                                                                actions.                automatic actions.         actions.
EOP-003-1   R8.            Each Transmission Operator or Balancing          N/A                       The applicable entity   The applicable entity      The applicable entity
                           Authority shall have plans for operator-                                   did not have plans      did not have the           did not have plans for
                           controlled manual load shedding to respond                                 for operator            capability to implement    operator controlled
                           to real-time emergencies. The                                              controlled manual       the load shedding, as      manual load shedding,
                           Transmission Operator or Balancing                                         load shedding, as       directed by the            as directed by the
                           Authority shall be capable of implementing                                 directed by the         requirement.               requirement nor had
                           the load shedding in a timeframe adequate                                  requirement.                                       the capability to
                           for responding to the emergency.                                                                                              implement the load
                                                                                                                                                         shedding, as directed
                                                                                                                                                         by the requirement.
EOP-004-1   R1.            Each Regional Reliability Organization           The Regional              The Regional            The Regional               The Regional
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 Standard    Requirement
                                      Text of Requirement                        Lower VSL             Moderate VSL                 High VSL                  Severe VSL
 Number        Number
                           shall establish and maintain a Regional         Reliability               Reliability              Reliability Organization   Reliability
                           reporting procedure to facilitate preparation   Organization has          Organization             Regional has a regional    Organization does not
                           of preliminary and final disturbance reports.   demonstrated the          Regional reporting       reporting procedure but    have a regional
                                                                           existence of a regional   procedure have been      the procedure is not       reporting procedure.
                                                                           reporting procedure,      is missing one           current.
                                                                           but the procedure is      element that would
                                                                           missing minor details     make the procedure
                                                                           or minor                  meet the
                                                                           program/procedural        requirement.
                                                                           elements.
EOP-004-1   R2.            A Reliability Coordinator, Balancing            N/A                       The responsible          The responsible entities   The responsible
                           Authority, Transmission Operator,                                         entities has failed to   has failed to analyze      entities has failed to
                           Generator Operator or Load-Serving Entity                                 analyze 1% to 25%        26% to 50% of its          analyze more than
                           shall promptly analyze Bulk Electric                                      of its disturbances      disturbances on the        50% of its
                           System disturbances on its system or                                      on the BES or was        BES or was negligent       disturbances on the
                           facilities.                                                               negligent in the         in the timeliness of       BES or negligent in
                                                                                                     timeliness of            analyzing the              the timeliness of
                                                                                                     analyzing the            disturbances 26% to        analyzing the
                                                                                                     disturbances 1% to       50% of the time.           disturbances more
                                                                                                     25% of the time.                                    than 50% of the time
EOP-004-1   R3.            A Reliability Coordinator, Balancing            N/A                       N/A                      N/A                        The responsible
                           Authority, Transmission Operator,                                                                                             entities failed to
                           Generator Operator or Load-Serving Entity                                                                                     provide a preliminary
                           experiencing a reportable incident shall                                                                                      written report as
                           provide a preliminary written report to its                                                                                   directed by the
                           Regional Reliability Organization and                                                                                         requirement.
                           NERC.
EOP-004-1   R3.1.          The affected Reliability Coordinator,                                     The responsible          The responsible entities   The responsible
                           Balancing Authority, Transmission                                         entities submitted       submitted the report       entities submitted the
                           Operator, Generator Operator or Load-                                     the report within 25     within 36 to 48 hours of   report more than 48
                           Serving Entity shall submit within 24 hours                               to 36 hours of the       the disturbance or         hours after the
                           of the disturbance or unusual occurrence                                  disturbance or           discovery of the           disturbance or
                           either a copy of the report submitted to                                  discovery of the         disturbance.               discovery of the
                           DOE, or, if no DOE report is required, a                                  disturbance.                                        disturbance.
                           copy of the NERC Interconnection
                           Reliability Operating Limit and Preliminary
                           Disturbance Report form. Events that are
                           not identified until some time after they
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 Standard    Requirement
                                      Text of Requirement                       Lower VSL              Moderate VSL                High VSL                   Severe VSL
 Number        Number
                           occur shall be reported within 24 hours of
                           being recognized.
EOP-004-1   R3.2.          Applicable reporting forms are provided in     N/A                        N/A                     N/A                        N/A
                           Attachments 022-1 and 022-2.
EOP-004-1   R3.3.          Under certain adverse conditions, e.g.,        The responsible entity     N/A                     N/A                        The responsible entity
                           severe weather, it may not be possible to      provided its                                                                  did not provide its
                           assess the damage caused by a disturbance      Reliability                                                                   Reliability
                           and issue a written Interconnection            Coordinator and                                                               Coordinator and
                           Reliability Operating Limit and Preliminary    NERC with periodic,                                                           NERC with verbal
                           Disturbance Report within 24 hours. In         verbal updates about a                                                        updates about a
                           such cases, the affected Reliability           disturbance, but the                                                          disturbance as
                           Coordinator, Balancing Authority,              updates did not                                                               specified in R3.3.
                           Transmission Operator, Generator Operator,     include all
                           or Load-Serving Entity shall promptly          information that was
                           notify its Regional Reliability                available at the time.
                           Organization(s) and NERC, and verbally
                           provide as much information as is available
                           at that time. The affected Reliability
                           Coordinator, Balancing Authority,
                           Transmission Operator, Generator Operator,
                           or Load-Serving Entity shall then provide
                           timely, periodic verbal updates until
                           adequate information is available to issue a
                           written Preliminary Disturbance Report.
EOP-004-1   R3.4.          If, in the judgment of the Regional            The responsible            The responsible         The responsible entities   The responsible
                           Reliability Organization, after consultation   entities final report is   entities final report   final report was more      entities final report
                           with the Reliability Coordinator, Balancing    missing minor details      was 30 days late or     than 30 days late or was   was not submitted or
                           Authority, Transmission Operator,              or minor                   was missing one of      missing two of the         was missing more
                           Generator Operator, or Load-Serving Entity     program/procedural         the elements            elements specified in      than two of the
                           in which a disturbance occurred, a final       elements.                  specified in the        the requirement.           elements specified in
                           report is required, the affected Reliability                              requirement.                                       the requirement.
                           Coordinator, Balancing Authority,
                           Transmission Operator, Generator Operator,
                           or Load-Serving Entity shall prepare this
                           report within 60 days. As a minimum, the
                           final report shall have a discussion of the
                           events and its cause, the conclusions
                           reached, and recommendations to prevent
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                                      Text of Requirement                          Lower VSL            Moderate VSL                High VSL                  Severe VSL
 Number        Number
                           recurrence of this type of event. The report
                           shall be subject to Regional Reliability
                           Organization approval.
EOP-004-1   R4.            When a Bulk Electric System disturbance           N/A                      N/A                     N/A                        The RRO did not
                           occurs, the Regional Reliability                                                                                              make its
                           Organization shall make its representatives                                                                                   representatives on the
                           on the NERC Operating Committee and                                                                                           NERC Operating
                           Disturbance Analysis Working Group                                                                                            Committee and
                           available to the affected Reliability                                                                                         Disturbance Analysis
                           Coordinator, Balancing Authority,                                                                                             Working Group
                           Transmission Operator, Generator Operator,                                                                                    available for the
                           or Load-Serving Entity immediately                                                                                            purpose of providing
                           affected by the disturbance for the purpose                                                                                   any needed assistance
                           of providing any needed assistance in the                                                                                     in the investigation
                           investigation and to assist in the preparation                                                                                and to assist in the
                           of a final report.                                                                                                            preparation of a final
                                                                                                                                                         report.
EOP-004-1   R5.            The Regional Reliability Organization shall       The Regional             The Regional            The Regional               The Regional
                           track and review the status of all final report   Reliability              Reliability             Reliability Organization   Reliability
                           recommendations at least twice each year to       Organization reviewed    Organization            has not reported on any    Organization has not
                           ensure they are being acted upon in a timely      all final report         reviewed 75% or         recommendation has         reviewed the final
                           manner. If any recommendation has not             recommendations less     more final report       not been acted on          report
                           been acted on within two years, or if             than twice a year.       recommendations         within two years to the    recommendations or
                           Regional Reliability Organization tracking                                 twice a year.           NERC Planning and          did not notify the
                           and review indicates at any time that any                                                          Operating Committees.      NERC Planning and
                           recommendation is not being acted on with                                                                                     Operating
                           sufficient diligence, the Regional Reliability                                                                                Committees.
                           Organization shall notify the NERC
                           Planning Committee and Operating
                           Committee of the status of the
                           recommendation(s) and the steps the
                           Regional Reliability Organization has taken
                           to accelerate implementation.
EOP-005-1   R1.            Each Transmission Operator shall have a           The responsible entity   The responsible         The responsible entity     The responsible entity
                           restoration plan to reestablish its electric      has a restoration plan   entity has a            has a restoration plan     has a restoration plan
                           system in a stable and orderly manner in the      that includes 75 % or    restoration plan that   that includes 25% -        that includes less than
                           event of a partial or total shutdown of its       more but less than       includes 50% to         50% of the applicable      25% of the applicable
                           system, including necessary operating             100% of the              75% of the              elements listed in         elements listed in
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 Standard    Requirement
                                      Text of Requirement                         Lower VSL             Moderate VSL                   High VSL                  Severe VSL
 Number        Number
                           instructions and procedures to cover             applicable elements       applicable elements       Attachment 1.               Attachment 1 OR the
                           emergency conditions, and the loss of vital      listed in Attachment 1.   listed in Attachment                                  responsible entity has
                           telecommunications channels. Each                                          1.                                                    no restoration plan.
                           Transmission Operator shall include the
                           applicable elements listed in Attachment 1-
                           EOP-005 in developing a restoration plan.
EOP-005-1   R2.            Each Transmission Operator shall review          The Transmission          The Transmission          The Transmission            The Transmission
                           and update its restoration plan at least         Operator failed to        Operator failed to        Operator failed to          Operator failed to
                           annually and whenever it makes changes in        review or update its      review and update         review and update its       review and update its
                           the power system network, and shall correct      restoration plan when     its restoration plan at   restoration plan at least   restoration plan at
                           deficiencies found during the simulated          it made changes in the    least annually.           annually or whenever it     least annually and
                           restoration exercises.                           power system                                        made changes in the         whenever it made
                                                                            network.                                            power system network,       changes in the power
                                                                                                                                and failed to correct       system network, and
                                                                                                                                deficiencies found          failed to correct
                                                                                                                                during the simulated        deficiencies found
                                                                                                                                restoration exercises.      during the simulated
                                                                                                                                                            restoration exercises.
EOP-005-1   R3.            Each Transmission Operator shall develop         N/A                       N/A                       N/A                         The Transmission
                           restoration plans with a priority of restoring                                                                                   Operator's restoration
                           the integrity of the Interconnection.                                                                                            plans failed to make
                                                                                                                                                            restoration of the
                                                                                                                                                            integrity of the
                                                                                                                                                            Interconnection a top
                                                                                                                                                            priority.
EOP-005-1   R4.            Each Transmission Operator shall                 The Transmission          The Transmission          The Transmission            The Transmission
                           coordinate its restoration plans with the        Operator failed to        Operator failed to        Operator failed to          Operator failed to
                           Generator Owners and Balancing                   coordinate its            coordinate its            coordinate its              coordinate its
                           Authorities within its area, its Reliability     restoration plans with    restoration plans         restoration plans with      restoration plans with
                           Coordinator, and neighboring Transmission        one of the entities       with two of the           three of the entities       four or more of the
                           Operators and Balancing Authorities.             listed in the             entities listed in the    listed in the               entities listed in the
                                                                            requirement.              requirement.              requirement.                requirement.
EOP-005-1   R5.            Each Transmission Operator and Balancing         N/A                       N/A                       N/A                         The responsible entity
                           Authority shall periodically test its                                                                                            failed to periodically
                           telecommunication facilities needed to                                                                                           test its
                           implement the restoration plan.                                                                                                  telecommunication
                                                                                                                                                            facilities needed to

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                                      Text of Requirement                        Lower VSL             Moderate VSL                High VSL                Severe VSL
 Number        Number
                                                                                                                                                      implement the
                                                                                                                                                      restoration plan.
EOP-005-1   R6.            Each Transmission Operator and Balancing        The responsible entity    The responsible         The responsible entity   The responsible entity
                           Authority shall train its operating personnel   only trained less than    entity only trained     only trained less than   did not trained any of
                           in the implementation of the restoration        100% but greater than     less than 67 % but      33 % of its operating    its operating personnel
                           plan. Such training shall include simulated     or equal to 67 % of its   greater than or equal   personnel in the         in the implementation
                           exercises, if practicable.                      operating personnel in    to 33 % of its          implementation of the    of the restoration plan.
                                                                           the implementation of     operating personnel     restoration plan.
                                                                           the restoration plan.     in the
                                                                                                     implementation of
                                                                                                     the restoration plan.
EOP-005-1   R7.            Each Transmission Operator and Balancing        The responsible entity    The responsible         The responsible entity   The responsible entity
                           Authority shall verify the restoration          verified 76% to 99%       entity verified 51%     verified 26% to 50% of   verified less than 26%
                           procedure by actual testing or by               of the restoration        to 75% of the           the restoration          of the restoration
                           simulation.                                     procedure by actual       restoration             procedure by actual      procedure by actual
                                                                           testing or by             procedure by actual     testing or by            testing or by
                                                                           simulation.               testing or by           simulation.              simulation.
                                                                                                     simulation.
EOP-005-1   R8.            Each Transmission Operator shall verify         N/A                       N/A                     N/A                      The Transmission
                           that the number, size, availability, and                                                                                   Operator failed to
                           location of system blackstart generating                                                                                   verify that the number,
                           units are sufficient to meet Regional                                                                                      size, availability, and
                           Reliability Organization restoration plan                                                                                  location of system
                           requirements for the Transmission                                                                                          blackstart generating
                           Operator’s area.                                                                                                           units are sufficient to
                                                                                                                                                      meet Regional
                                                                                                                                                      Reliability
                                                                                                                                                      Organization
                                                                                                                                                      restoration plan
                                                                                                                                                      requirements for the
                                                                                                                                                      Transmission
                                                                                                                                                      Operator’s area.
EOP-005-1   R9.            The Transmission Operator shall document        N/A                       N/A                     N/A                      The Transmission
                           the Cranking Paths, including initial                                                                                      Operator shall
                           switching requirements, between each                                                                                       document the
                           blackstart generating unit and the unit(s) to                                                                              Cranking Paths,
                           be started and shall provide this                                                                                          including initial

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Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                         Lower VSL             Moderate VSL               High VSL                  Severe VSL
 Number        Number
                           documentation for review by the Regional                                                                                     switching
                           Reliability Organization upon request.                                                                                       requirements, between
                           Such documentation may include Cranking                                                                                      each blackstart
                           Path diagrams.                                                                                                               generating unit and
                                                                                                                                                        the unit(s) to be
                                                                                                                                                        started and shall
                                                                                                                                                        provide this
                                                                                                                                                        documentation for
                                                                                                                                                        review by the
                                                                                                                                                        Regional Reliability
                                                                                                                                                        Organization upon
                                                                                                                                                        request.
EOP-005-1   R10.           The Transmission Operator shall                  The Transmission          The Transmission       The Transmission           The Transmission
                           demonstrate, through simulation or testing,      Operator only             Operator only          Operator only              Operator did not
                           that the blackstart generating units in its      demonstrated, through     demonstrated,          demonstrated, through      demonstrate, through
                           restoration plan can perform their intended      simulation or testing,    through simulation     simulation or testing,     simulation or testing,
                           functions as required in the regional            that between 67 and       or testing, that       that less than 33% of      that any of the
                           restoration plan.                                99% of the blackstart     between 33 and 66%     the blackstart             blackstart generating
                                                                            generating units in its   of the blackstart      generating units in its    units in its restoration
                                                                            restoration plan can      generating units in    restoration plan can       plan can perform their
                                                                            perform their intended    its restoration plan   perform their intended     intended functions as
                                                                            functions as required     can perform their      functions as required in   required in the
                                                                            in the regional           intended functions     the regional restoration   regional restoration
                                                                            restoration plan.         as required in the     plan.                      plan.
                                                                                                      regional restoration
                                                                                                      plan.
EOP-005-1   R10.1.         The Transmission Operator shall perform          N/A                       N/A                    N/A                        The Transmission
                           this simulation or testing at least once every                                                                               Operator failed to
                           five years.                                                                                                                  perform the required
                                                                                                                                                        simulation or testing
                                                                                                                                                        at least once every
                                                                                                                                                        five years.
EOP-005-1   R11.           Following a disturbance in which one or          The responsible entity    The responsible        The responsible entity     The responsible entity
                           more areas of the Bulk Electric System           failed to comply with     entity failed to       failed to comply with      failed to comply with
                           become isolated or blacked out, the affected     less than 25% of the      comply with 25% or     50% or more and less       more than 75% of the
                           Transmission Operators and Balancing             number of sub-            more and less than     than 75% of the number     number of sub-
                           Authorities shall begin immediately to           components.               50% of the number      of sub-components.         components.
                           return the Bulk Electric System to normal.                                 of sub-components.
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Complete Violation Severity Level Matrix (EOP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                        Lower VSL    Moderate VSL         High VSL                Severe VSL
 Number        Number
EOP-005-1   R11.1.         The affected Transmission Operators and         N/A               N/A             N/A                      The responsible entity
                           Balancing Authorities shall work in                                                                        failed to work in
                           conjunction with their Reliability                                                                         conjunction with their
                           Coordinator(s) to determine the extent and                                                                 Reliability
                           condition of the isolated area(s).                                                                         Coordinator to
                                                                                                                                      determine the extent
                                                                                                                                      and condition of the
                                                                                                                                      isolated area(s)
EOP-005-1   R11.2.         The affected Transmission Operators and         N/A               N/A             N/A                      The affected
                           Balancing Authorities shall take the                                                                       Transmission
                           necessary actions to restore Bulk Electric                                                                 Operators and
                           System frequency to normal, including                                                                      Balancing Authorities
                           adjusting generation, placing additional                                                                   failed to take the
                           generators on line, or load shedding.                                                                      necessary actions to
                                                                                                                                      restore Bulk Electric
                                                                                                                                      System frequency to
                                                                                                                                      normal.
EOP-005-1   R11.3.         The affected Balancing Authorities,             N/A               N/A             The responsible entity   The responsible entity
                           working with their Reliability                                                    failed to make all       failed to immediately
                           Coordinator(s), shall immediately review                                          attempts to maintain     review the Interchange
                           the Interchange Schedules between those                                           adjusted Interchange     Schedules between
                           Balancing Authority Areas or fragments of                                         Schedules as required    those Balancing
                           those Balancing Authority Areas within the                                        in R11.3                 Authority Areas or
                           separated area and make adjustments as                                                                     fragments of those
                           needed to facilitate the restoration. The                                                                  Balancing Authority
                           affected Balancing Authorities shall make                                                                  Areas within the
                           all attempts to maintain the adjusted                                                                      separated area and
                           Interchange Schedules, whether generation                                                                  make adjustments to
                           control is manual or automatic.                                                                            facilitate the
                                                                                                                                      restoration as required
                                                                                                                                      in R11.3.
EOP-005-1   R11.4.         The affected Transmission Operators shall       N/A               N/A             N/A                      The affected
                           give high priority to restoration of off-site                                                              Transmission
                           power to nuclear stations.                                                                                 Operators failed to
                                                                                                                                      give high priority to
                                                                                                                                      restoration of off-site
                                                                                                                                      power to nuclear

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Complete Violation Severity Level Matrix (EOP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL            Moderate VSL                High VSL                 Severe VSL
 Number        Number
                                                                                                                                                     stations.
EOP-005-1   R11.5.         The affected Transmission Operators may        The responsible entity   The responsible         The responsible entity    The responsible entity
                           resynchronize the isolated area(s) with the    failed to include one    entity failed to        failed to include three   failed to include four
                           surrounding area(s) when the following         of the                   include two of the      of the subrequirements.   of the
                           conditions are met:                            subrequirements.         subrequirements.                                  subrequirements.
EOP-005-1   R11.5.1.       Voltage, frequency, and phase angle permit.    N/A                      N/A                     N/A                       The responsible entity
                                                                                                                                                     failed to meet this
                                                                                                                                                     requirement before
                                                                                                                                                     resynchronizing
                                                                                                                                                     isolated areas.
EOP-005-1   R11.5.2.       The size of the area being reconnected and     N/A                      N/A                     N/A                       The responsible entity
                           the capacity of the transmission lines                                                                                    failed to meet this
                           effecting the reconnection and the number                                                                                 requirement before
                           of synchronizing points across the system                                                                                 resynchronizing
                           are considered.                                                                                                           isolated areas.
EOP-005-1   R11.5.3.       Reliability Coordinator(s) and adjacent        N/A                      N/A                     N/A                       The responsible entity
                           areas are notified and Reliability                                                                                        failed to meet this
                           Coordinator approval is given.                                                                                            requirement before
                                                                                                                                                     resynchronizing
                                                                                                                                                     isolated areas.
EOP-005-1   R11.5.4.       Load is shed in neighboring areas, if          N/A                      N/A                     N/A                       The responsible entity
                           required, to permit successful                                                                                            failed to meet this
                           interconnected system restoration.                                                                                        requirement before
                                                                                                                                                     resynchronizing
                                                                                                                                                     isolated areas.
EOP-006-1   R1.            Each Reliability Coordinator shall be aware    The Reliability          The Reliability         The Reliability           The Reliability
                           of the restoration plan of each Transmission   Coordinator is aware     Coordinator is aware    Coordinator is aware of   Coordinator is not
                           Operator in its Reliability Coordinator Area   of more than 75% of      of more than 50%        more than 25% but less    aware of any of its
                           in accordance with NERC and regional           its Transmission         but less than 75%of     than 50% of its           Transmission
                           requirements.                                  Operators restoration    its Transmission        Transmission Operators    Operators restoration
                                                                          plans.                   Operators restoration   restoration plans.        plans.
                                                                                                   plans.
EOP-006-1   R2.            The Reliability Coordinator shall monitor      N/A                      N/A                     The Reliability           The Reliability
                           restoration progress and coordinate any                                                         Coordinator failed to     Coordinator failed to
                           needed assistance.                                                                              monitor restoration       monitor restoration
                                                                                                                           progress or failed to     progress and failed to
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Complete Violation Severity Level Matrix (EOP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                         Lower VSL           Moderate VSL                High VSL                  Severe VSL
 Number        Number
                                                                                                                            coordinate assistance.     coordinate assistance.
EOP-006-1   R3.            The Reliability Coordinator shall have a         N/A                     The Reliability         The Reliability            The Reliability
                           Reliability Coordinator Area restoration                                 Coordinator's           Coordinator's              Coordinator does not
                           plan that provides coordination between                                  Reliability             Reliability Coordinator    have a Reliability
                           individual Transmission Operator                                         Coordinator Area        Area restoration plan      Coordinator Area
                           restoration plans and that ensures reliability                           restoration plan did    did not coordinate with    restoration plan.
                           is maintained during system restoration                                  not coordinate with     more than one
                           events.                                                                  one individual          individual Transmission
                                                                                                    Transmission            Operator restoration
                                                                                                    Operator restoration    plans.
                                                                                                    plans.
EOP-006-1   R4.            The Reliability Coordinator shall serve as       The Reliability         The Reliability         The Reliability            The Reliability
                           the primary contact for disseminating            Coordinator failed to   Coordinator failed to   Coordinator failed to      Coordinator failed to
                           information regarding restoration to             disseminate             disseminate             disseminate information    disseminate
                           neighboring Reliability Coordinators and         information regarding   information             regarding restoration to   information regarding
                           Transmission Operators or Balancing              restoration to one      regarding restoration   three neighboring          restoration to four or
                           Authorities not immediately involved in          neighboring             to two neighboring      Reliability Coordinators   more neighboring
                           restoration.                                     Reliability             Reliability             or Transmission            Reliability
                                                                            Coordinator or          Coordinators or         Operators or Balancing     Coordinators or
                                                                            Transmission            Transmission            Authorities not            Transmission
                                                                            Operator or Balancing   Operators or            immediately involved       Operators or
                                                                            Authority not           Balancing               in restoration.            Balancing Authorities
                                                                            immediately involved    Authorities not                                    not immediately
                                                                            in restoration.         immediately                                        involved in
                                                                                                    involved in                                        restoration.
                                                                                                    restoration.
EOP-006-1   R5.            Reliability Coordinators shall approve,          N/A                     N/A                     N/A                        The Reliability
                           communicate, and coordinate the re-                                                                                         Coordinators failed to
                           synchronizing of major system islands or                                                                                    approve,
                           synchronizing points so as not to cause a                                                                                   communicate, and
                           Burden on adjacent Transmission Operator,                                                                                   coordinate the re-
                           Balancing Authority, or Reliability                                                                                         synchronizing of
                           Coordinator Areas.                                                                                                          major system islands
                                                                                                                                                       or synchronizing
                                                                                                                                                       points and caused a
                                                                                                                                                       Burden on adjacent
                                                                                                                                                       Transmission
                                                                                                                                                       Operator, Balancing
                                                                                                                                                                  Page 95
Complete Violation Severity Level Matrix (EOP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                        Lower VSL             Moderate VSL                 High VSL                  Severe VSL
 Number        Number
                                                                                                                                                         Authority, or
                                                                                                                                                         Reliability
                                                                                                                                                         Coordinator Areas.
EOP-006-1   R6.            The Reliability Coordinator shall take          N/A                       N/A                      N/A                        The Reliability
                           actions to restore normal operations once an                                                                                  Coordinator failed to
                           operating emergency has been mitigated in                                                                                     take actions to restore
                           accordance with its restoration plan.                                                                                         normal operations
                                                                                                                                                         once an operating
                                                                                                                                                         emergency has been
                                                                                                                                                         mitigated in
                                                                                                                                                         accordance with its
                                                                                                                                                         restoration plan.
EOP-008-0   R1.            Each Reliability Coordinator, Transmission      The Reliability           The Reliability          The Reliability            The Reliability
                           Operator and Balancing Authority shall          Coordinator,              Coordinator,             Coordinator,               Coordinator,
                           have a plan to continue reliability             Transmission              Transmission             Transmission Operator      Transmission
                           operations in the event its control center      Operator and              Operator and             and Balancing              Operator and
                           becomes inoperable. The contingency plan        Balancing Authority       Balancing Authority      Authority failed to        Balancing Authority
                           must meet the following requirements:           failed to comply with     failed to comply         comply with three or       failed to comply with
                                                                           one of the sub-           with two of the sub-     four of the sub-           more than four of the
                                                                           requirements.             requirements.            requirements.              sub-requirements.
EOP-008-0   R1.1.          The contingency plan shall not rely on data     The responsible           The responsible          The responsible entity’s   The responsible
                           or voice communication from the primary         entity’s contingency      entity’s contingency     contingency plan relies    entity’s contingency
                           control facility to be viable.                  plan relies on data or    plan relies on data or   on data or voice           plan relies on data and
                                                                           voice communication       voice                    communication from         voice communication
                                                                           from the primary          communication from       the primary control        from the primary
                                                                           control facility for up   the primary control      facility for 50% to 75%    control facility for
                                                                           to 25% of the             facility for 25% to      of the functions           more than 75% of the
                                                                           functions identified in   50% of the functions     identified in R1.2 and     functions identified in
                                                                           R1.2 and R1.3.            identified in R1.2       R1.3.                      R1.2 and R1.3.
                                                                                                     and R1.3.
EOP-008-0   R1.2.          The plan shall include procedures and           N/A                       N/A                      N/A                        The responsible
                           responsibilities for providing basic tie line                                                                                 entity's plan failed to
                           control and procedures and for maintaining                                                                                    include procedures
                           the status of all inter-area schedules, such                                                                                  and responsibilities
                           that there is an hourly accounting of all                                                                                     for providing basic tie
                           schedules.                                                                                                                    line control and
                                                                                                                                                         procedures and for

                                                                                                                                                                     Page 96
Complete Violation Severity Level Matrix (EOP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                       Text of Requirement                          Lower VSL            Moderate VSL                 High VSL                  Severe VSL
 Number        Number
                                                                                                                                                           maintaining the status
                                                                                                                                                           of all inter-area
                                                                                                                                                           schedules, such that
                                                                                                                                                           there is an hourly
                                                                                                                                                           accounting of all
                                                                                                                                                           schedules.
EOP-008-0   R1.3.          The contingency plan must address                  The responsible          The responsible          The responsible entity's   The responsible
                           monitoring and control of critical                 entity's contingency     entity's contingency     contingency plan failed    entity's contingency
                           transmission facilities, generation control,       plan failed to address   plan failed to           to address three of the    plan failed to address
                           voltage control, time and frequency control,       one of the elements      address two of the       elements listed in the     four or more of the
                           control of critical substation devices, and        listed in the            elements listed in the   requirement.               elements listed in the
                           logging of significant power system events.        requirement.             requirement.                                        requirement.
                           The plan shall list the critical facilities.
EOP-008-0   R1.4.          The plan shall include procedures and              N/A                      N/A                      N/A                        The responsible
                           responsibilities for maintaining basic voice                                                                                    entity's plan failed to
                           communication capabilities with other                                                                                           include procedures
                           areas.                                                                                                                          and responsibilities
                                                                                                                                                           for maintaining basic
                                                                                                                                                           voice communication
                                                                                                                                                           capabilities with other
                                                                                                                                                           areas.
EOP-008-0   R1.5.          The plan shall include procedures and              N/A                      N/A                      N/A                        The responsible
                           responsibilities for conducting periodic                                                                                        entity's plan failed to
                           tests, at least annually, to ensure viability of                                                                                include procedures
                           the plan.                                                                                                                       and responsibilities
                                                                                                                                                           for conducting
                                                                                                                                                           periodic tests, at least
                                                                                                                                                           annually, to ensure
                                                                                                                                                           viability of the plan.
EOP-008-0   R1.6.          The plan shall include procedures and              N/A                      N/A                      N/A                        The responsible
                           responsibilities for providing annual                                                                                           entity's plan failed to
                           training to ensure that operating personnel                                                                                     include procedures
                           are able to implement the contingency                                                                                           and responsibilities
                           plans.                                                                                                                          for providing annual
                                                                                                                                                           training to ensure that
                                                                                                                                                           operating personnel
                                                                                                                                                           are able to implement

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Complete Violation Severity Level Matrix (EOP)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL            Moderate VSL                 High VSL                  Severe VSL
 Number        Number
                                                                                                                                                       the contingency plans.
EOP-008-0   R1.7.          The plan shall be reviewed and updated         The responsible          The responsible         The responsible entity’s    The responsible
                           annually.                                      entity’s plan was        entity’s plan was       plan was reviewed           entity’s plan was
                                                                          reviewed within 3        reviewed within 6       within 9 months of          reviewed more than 9
                                                                          months of passing its    months of passing its   passing its annual          months of passing its
                                                                          annual review date.      annual review date.     review date.                annual review date.
EOP-008-0   R1.8.          Interim provisions must be included if it is   N/A                      N/A                     N/A                         The responsible entity
                           expected to take more than one hour to                                                                                      failed to make interim
                           implement the contingency plan for loss of                                                                                  provisions when it is
                           primary control facility.                                                                                                   took more than one
                                                                                                                                                       hour to implement the
                                                                                                                                                       contingency plan for
                                                                                                                                                       loss of primary control
                                                                                                                                                       facility.
EOP-009-0   R1.            The Generator Operator of each blackstart      The Generator            Startup and testing     The Generator               The Generator
                           generating unit shall test the startup and     Operator Blackstart      of each Blackstart      Operator's failed to test   Operator failed to test
                           operation of each system blackstart            unit testing and         unit was performed,     25% or less of the          more than 25% of its
                           generating unit identified in the BCP as       recording is missing     but the testing         Blackstart units or         Blackstart units or
                           required in the Regional BCP (Reliability      minor                    records are             testing records are         does not have
                           Standard EOP-007-0_R1). Testing records        program/procedural       incomplete. The         incomplete. The testing     Blackstart testing
                           shall include the dates of the tests, the      elements.                testing records are     records are missing         records or is missing
                           duration of the tests, and an indication of                             missing 25% or less     between 25% and 50%         more than 50% of the
                           whether the tests met Regional BCP                                      of data requested in    of data requested in the    required data.
                           requirements.                                                           the requirement'.       requirement.
EOP-009-0   R2.            The Generator Owner or Generator               The Generator            N/A                     N/A                         The Generator
                           Operator shall provide documentation of the    Operator has provided                                                        Operator did not
                           test results of the startup and operation of   the Blackstart testing                                                       provide the required
                           each blackstart generating unit to the         documentation to its                                                         Blackstart
                           Regional Reliability Organizations and         Regional Reliability                                                         documentation to its
                           upon request to NERC.                          Organization.                                                                Regional Reliability
                                                                          However the                                                                  Organization.
                                                                          documentation
                                                                          provided had missing
                                                                          minor
                                                                          program/procedural
                                                                          elements or failed to
                                                                          provide the

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Complete Violation Severity Level Matrix (EOP)
Encompassing All Commission-Approved Reliability Standards
Standard   Requirement
                         Text of Requirement       Lower VSL          Moderate VSL   High VSL   Severe VSL
Number       Number
                                               documentation
                                               requested to NERC in
                                               30 days.




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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                   Lower VSL               Moderate VSL               High VSL                 Severe VSL
 Number        Number
FAC-001-0   R1.            The Transmission Owner shall document,      Not Applicable.            The Transmission       The Transmission          The Transmission
                           maintain, and publish facility connection                              Owner’s facility       Owner’s facility          Owner’s facility
                           requirements to ensure compliance with                                 connection             connection                connection
                           NERC Reliability Standards and applicable                              requirements failed    requirements failed to    requirements failed to
                           Regional Reliability Organization,                                     to address             address connection        address connection
                           subregional, Power Pool, and individual                                connection             requirements for two of   requirements for three
                           Transmission Owner planning criteria and                               requirements for one   the subrequirements.      of the
                           facility connection requirements. The                                  of the                                           subrequirements.
                           Transmission Owner’s facility connection                               subrequirements.
                           requirements shall address connection
                           requirements for:
FAC-001-0   R1.1.          Generation facilities,                      The Transmission           The Transmission       The Transmission          The Transmission
                                                                       Owner has Generation       Owner has              Owner has Generation      Owner does not have
                                                                       facility connection        Generation facility    facility connection       Generation facility
                                                                       requirements, but they     connection             requirements, but they    connection
                                                                       have not been updated      requirements, but      have not been updated     requirements.
                                                                       to include changes that    they have not been     to include changes that
                                                                       are currently in effect,   updated to include     were effective more
                                                                       but have not been in       changes that were      than six months ago.
                                                                       effect for more than       effective more than
                                                                       one month.                 one month ago, but
                                                                                                  not more than six
                                                                                                  months ago.
FAC-001-0   R1.2.          Transmission facilities, and                The Transmission           The Transmission       The Transmission          The Transmission
                                                                       Owner has                  Owner has              Owner has                 Owner does not have
                                                                       Transmission facility      Transmission           Transmission facility     Transmission facility
                                                                       connection                 facility connection    connection                connection
                                                                       requirements, but they     requirements, but      requirements, but they    requirements.
                                                                       have not been updated      they have not been     have not been updated
                                                                       to include changes that    updated to include     to include changes that
                                                                       are currently in effect,   changes that were      were effective more
                                                                       but have not been in       effective more than    than six months ago.
                                                                       effect for more than       one month ago, but
                                                                       one month.                 not more than six
                                                                                                  months ago.

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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                     Lower VSL               Moderate VSL                High VSL                 Severe VSL
 Number        Number
FAC-001-0   R1.3.          End-user facilities                           The Transmission           The Transmission        The Transmission          The Transmission
                                                                         Owner has End-user         Owner has End-user      Owner has End-user        Owner does not have
                                                                         facility connection        facility connection     facility connection       End-user facility
                                                                         requirements, but they     requirements, but       requirements, but they    connection
                                                                         have not been updated      they have not been      have not been updated     requirements.
                                                                         to include changes that    updated to include      to include changes that
                                                                         are currently in effect,   changes that were       were effective more
                                                                         but have not been in       effective more than     than six months ago.
                                                                         effect for more than       one month ago, but
                                                                         one month.                 not more than six
                                                                                                    months ago.
FAC-001-0   R2.            The Transmission Owner’s facility             The Transmission           The Transmission        The Transmission          The Transmission
                           connection requirements shall address, but    Owner's facility           Owner's facility        Owner's facility          Owner’s facility
                           are not limited to, the following items:      connection                 connection              connection                connection
                                                                         requirements do not        requirements do not     requirements do not       requirements do not
                                                                         address one to four of     address five to eight   address nine to twelve    address thirteen or
                                                                         the sub-components.        of the sub-             of the sub-components.    more of the sub-
                                                                         (R2.1.1 to R2.1.16)        components. (R2.1.1     (R2.1.1 to R2.1.16)       components. (R2.1.1
                                                                                                    to R2.1.16)                                       to R2.1.16)
FAC-001-0   R2.1.          Provide a written summary of its plans to     The Transmission           The Transmission        The Transmission          The Transmission
                           achieve the required system performance as    Owner's facility           Owner's facility        Owner's facility          Owner’s facility
                           described above throughout the planning       connection                 connection              connection                connection
                           horizon:                                      requirements do not        requirements do not     requirements do not       requirements do not
                                                                         address one to four of     address five to eight   address nine to twelve    address thirteen or
                                                                         the sub-components.        of the sub-             of the sub-components.    more of the sub-
                                                                         (R2.1.1 to R2.1.16)        components. (R2.1.1     (R2.1.1 to R2.1.16)       components. (R2.1.1
                                                                                                    to R2.1.16)                                       to R2.1.16)
FAC-001-0   R2.1.1.        Procedures for coordinated joint studies of   Not Applicable.            Not Applicable.         Not Applicable.           The Transmission
                           new facilities and their impacts on the                                                                                    owner's procedures for
                           interconnected transmission systems.                                                                                       coordinated joint
                                                                                                                                                      studies of new
                                                                                                                                                      facilities and their
                                                                                                                                                      impacts on the
                                                                                                                                                      interconnected
                                                                                                                                                      transmission systems
                                                                                                                                                      failed to include this
                                                                                                                                                      subrequirement.
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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                     Text of Requirement                  Lower VSL      Moderate VSL          High VSL         Severe VSL
 Number        Number
FAC-001-0   R2.1.2.        Procedures for notification of new or     Not Applicable.   Not Applicable.   Not Applicable.   The Transmission
                           modified facilities to others (those                                                            owner's procedures for
                           responsible for the reliability of the                                                          coordinated joint
                           interconnected transmission systems) as                                                         studies of new
                           soon as feasible.                                                                               facilities and their
                                                                                                                           impacts on the
                                                                                                                           interconnected
                                                                                                                           transmission systems
                                                                                                                           failed to include this
                                                                                                                           subrequirement.
FAC-001-0   R2.1.3.        Voltage level and MW and MVAR capacity    Not Applicable.   Not Applicable.   Not Applicable.   The Transmission
                           or demand at point of connection.                                                               owner's procedures for
                                                                                                                           coordinated joint
                                                                                                                           studies of new
                                                                                                                           facilities and their
                                                                                                                           impacts on the
                                                                                                                           interconnected
                                                                                                                           transmission systems
                                                                                                                           failed to include this
                                                                                                                           subrequirement.
FAC-001-0   R2.1.4.        Breaker duty and surge protection.        Not Applicable.   Not Applicable.   Not Applicable.   The Transmission
                                                                                                                           owner's procedures for
                                                                                                                           coordinated joint
                                                                                                                           studies of new
                                                                                                                           facilities and their
                                                                                                                           impacts on the
                                                                                                                           interconnected
                                                                                                                           transmission systems
                                                                                                                           failed to include this
                                                                                                                           subrequirement.
FAC-001-0   R2.1.5.        System protection and coordination.       Not Applicable.   Not Applicable.   Not Applicable.   The Transmission
                                                                                                                           owner's procedures for
                                                                                                                           coordinated joint
                                                                                                                           studies of new
                                                                                                                           facilities and their
                                                                                                                           impacts on the
                                                                                                                           interconnected
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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                   Lower VSL      Moderate VSL          High VSL         Severe VSL
 Number        Number
                                                                                                                             transmission systems
                                                                                                                             failed to include this
                                                                                                                             subrequirement.
FAC-001-0   R2.1.6.        Metering and telecommunications.            Not Applicable.   Not Applicable.   Not Applicable.   The Transmission
                                                                                                                             owner's procedures for
                                                                                                                             coordinated joint
                                                                                                                             studies of new
                                                                                                                             facilities and their
                                                                                                                             impacts on the
                                                                                                                             interconnected
                                                                                                                             transmission systems
                                                                                                                             failed to include this
                                                                                                                             subrequirement.
FAC-001-0   R2.1.7.        Grounding and safety issues.                Not Applicable.   Not Applicable.   Not Applicable.   The Transmission
                                                                                                                             owner's procedures for
                                                                                                                             coordinated joint
                                                                                                                             studies of new
                                                                                                                             facilities and their
                                                                                                                             impacts on the
                                                                                                                             interconnected
                                                                                                                             transmission systems
                                                                                                                             failed to include this
                                                                                                                             subrequirement.
FAC-001-0   R2.1.8.        Insulation and insulation coordination.     Not Applicable.   Not Applicable.   Not Applicable.   The Transmission
                                                                                                                             owner's procedures for
                                                                                                                             coordinated joint
                                                                                                                             studies of new
                                                                                                                             facilities and their
                                                                                                                             impacts on the
                                                                                                                             interconnected
                                                                                                                             transmission systems
                                                                                                                             failed to include this
                                                                                                                             subrequirement.
FAC-001-0   R2.1.9.        Voltage, Reactive Power, and power factor   Not Applicable.   Not Applicable.   Not Applicable.   The Transmission
                           control.                                                                                          owner's procedures for
                                                                                                                             coordinated joint
                                                                                                                             studies of new
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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement        Lower VSL      Moderate VSL          High VSL         Severe VSL
 Number        Number
                                                                                                                  facilities and their
                                                                                                                  impacts on the
                                                                                                                  interconnected
                                                                                                                  transmission systems
                                                                                                                  failed to include this
                                                                                                                  subrequirement.
FAC-001-0   R2.1.10.       Power quality impacts.           Not Applicable.   Not Applicable.   Not Applicable.   The Transmission
                                                                                                                  owner's procedures for
                                                                                                                  coordinated joint
                                                                                                                  studies of new
                                                                                                                  facilities and their
                                                                                                                  impacts on the
                                                                                                                  interconnected
                                                                                                                  transmission systems
                                                                                                                  failed to include this
                                                                                                                  subrequirement.
FAC-001-0   R2.1.11.       Equipment Ratings.               Not Applicable.   Not Applicable.   Not Applicable.   The Transmission
                                                                                                                  owner's procedures for
                                                                                                                  coordinated joint
                                                                                                                  studies of new
                                                                                                                  facilities and their
                                                                                                                  impacts on the
                                                                                                                  interconnected
                                                                                                                  transmission systems
                                                                                                                  failed to include this
                                                                                                                  subrequirement.
FAC-001-0   R2.1.12.       Synchronizing of facilities.     Not Applicable.   Not Applicable.   Not Applicable.   The Transmission
                                                                                                                  owner's procedures for
                                                                                                                  coordinated joint
                                                                                                                  studies of new
                                                                                                                  facilities and their
                                                                                                                  impacts on the
                                                                                                                  interconnected
                                                                                                                  transmission systems
                                                                                                                  failed to include this
                                                                                                                  subrequirement.
FAC-001-0   R2.1.13.       Maintenance coordination.        Not Applicable.   Not Applicable.   Not Applicable.   The Transmission
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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                     Lower VSL      Moderate VSL          High VSL         Severe VSL
 Number        Number
                                                                                                                               owner's procedures for
                                                                                                                               coordinated joint
                                                                                                                               studies of new
                                                                                                                               facilities and their
                                                                                                                               impacts on the
                                                                                                                               interconnected
                                                                                                                               transmission systems
                                                                                                                               failed to include this
                                                                                                                               subrequirement.
FAC-001-0   R2.1.14.       Operational issues (abnormal frequency and    Not Applicable.   Not Applicable.   Not Applicable.   The Transmission
                           voltages).                                                                                          owner's procedures for
                                                                                                                               coordinated joint
                                                                                                                               studies of new
                                                                                                                               facilities and their
                                                                                                                               impacts on the
                                                                                                                               interconnected
                                                                                                                               transmission systems
                                                                                                                               failed to include this
                                                                                                                               subrequirement.
FAC-001-0   R2.1.15.       Inspection requirements for existing or new   Not Applicable.   Not Applicable.   Not Applicable.   The Transmission
                           facilities.                                                                                         owner's procedures for
                                                                                                                               coordinated joint
                                                                                                                               studies of new
                                                                                                                               facilities and their
                                                                                                                               impacts on the
                                                                                                                               interconnected
                                                                                                                               transmission systems
                                                                                                                               failed to include this
                                                                                                                               subrequirement.
FAC-001-0   R2.1.16.       Communications and procedures during          Not Applicable.   Not Applicable.   Not Applicable.   The Transmission
                           normal and emergency operating                                                                      owner's procedures for
                           conditions.                                                                                         coordinated joint
                                                                                                                               studies of new
                                                                                                                               facilities and their
                                                                                                                               impacts on the
                                                                                                                               interconnected
                                                                                                                               transmission systems

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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                         Lower VSL               Moderate VSL                 High VSL                   Severe VSL
 Number        Number
                                                                                                                                                             failed to include this
                                                                                                                                                             subrequirement.
FAC-001-0   R3.            The Transmission Owner shall maintain and         The Transmission           The Transmission        The Transmission             The Transmission
                           update its facility connection requirements       Owner made the             Owner made the          Owner made the               Owner made the
                           as required. The Transmission Owner shall         requirements available     requirements            requirements available       requirements available
                           make documentation of these requirements          more than five             available more than     more than twenty             more than thirty
                           available to the users of the transmission        business days after a      ten business days       business days after a        business days after a
                           system, the Regional Reliability                  request, but not more      after a request, but    request, but not more        request.
                           Organization, and NERC on request (five           than ten business days     not more than           than thirty business
                           business days).                                   after a request.           twenty business         days after a request.
                                                                                                        days after a request.
FAC-002-0   R1.            The Generator Owner, Transmission                 The Responsible            The Responsible         The Responsible Entity       The Responsible
                           Owner, Distribution Provider, and Load-           Entity failed to include   Entity failed to        failed to include in their   Entity failed to include
                           Serving Entity seeking to integrate               in their assessment one    include in their        assessment three of the      in their assessment
                           generation facilities, transmission facilities,   of the                     assessment two of       subrequirements.             four or more of the
                           and electricity end-user facilities shall each    subrequirements.           the subrequirements.                                 subrequirements.
                           coordinate and cooperate on its assessments
                           with its Transmission Planner and Planning
                           Authority. The assessment shall include:
FAC-002-0   R1.1.          Evaluation of the reliability impact of the       Not Applicable.            Not Applicable.         Not Applicable.              The responsible
                           new facilities and their connections on the                                                                                       entity's assessment did
                           interconnected transmission systems.                                                                                              not include the
                                                                                                                                                             evaluation.
FAC-002-0   R1.2.          Ensurance of compliance with NERC                 Not Applicable.            Not Applicable.         Not Applicable.              The responsible
                           Reliability Standards and applicable                                                                                              entity’s assessment did
                           Regional, subregional, Power Pool, and                                                                                            not include the
                           individual system planning criteria and                                                                                           ensurance of
                           facility connection requirements.                                                                                                 compliance.
FAC-002-0   R1.3.          Evidence that the parties involved in the         Not Applicable.            Not Applicable.         Not Applicable.              The responsible
                           assessment have coordinated and                                                                                                   entity’s assessment did
                           cooperated on the assessment of the                                                                                               not include the
                           reliability impacts of new facilities on the                                                                                      evidence of
                           interconnected transmission systems. While                                                                                        coordination.
                           these studies may be performed
                           independently, the results shall be jointly
                           evaluated and coordinated by the entities

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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                       Text of Requirement                      Lower VSL             Moderate VSL                 High VSL                  Severe VSL
 Number        Number
                           involved.
FAC-002-0   R1.4.          Evidence that the assessment included          Not Applicable.           Not Applicable.          Not Applicable.            The responsible
                           steady-state, short-circuit, and dynamics                                                                                    entity's assessment did
                           studies as necessary to evaluate system                                                                                      not include the
                           performance in accordance with Reliability                                                                                   evidence of the
                           Standard TPL-001-0.                                                                                                          studies.
FAC-002-0   R1.5.          Documentation that the assessment included     Not Applicable.           Not Applicable.          Not Applicable.            The responsible
                           study assumptions, system performance,                                                                                       entity's assessment did
                           and alternatives considered, and jointly                                                                                     not include the
                           coordinated recommendations.                                                                                                 documentation.
FAC-002-0   R2.            The Planning Authority, Transmission           The responsible entity    The responsible          The responsible entity     The responsible entity
                           Planner, Generator Owner, Transmission         provided the              entity provided the      provided the               provided the
                           Owner, Load-Serving Entity, and                documentation more        documentation more       documentation more         documentation more
                           Distribution Provider shall each retain its    than 30 calendar days,    than 45 calendar         than 60 calendar days,     than 120 calendar days
                           documentation (of its evaluation of the        but not more than 45      days, but not more       but not more than 120      after a request or was
                           reliability impact of the new facilities and   calendar days, after a    than 60 calendar         calendar days, after a     unable to provide the
                           their connections on the interconnected        request.                  days, after a request.   request.                   documentation.
                           transmission systems) for three years and
                           shall provide the documentation to the
                           Regional Reliability Organization(s)
                           Regional Reliability Organization(s) and
                           NERC on request (within 30 calendar days).
FAC-003-1   R1.            The Transmission owner shall prepare, and      The applicable entity     The applicable           The applicable entity      The applicable entity
                           keep current, a formal transmission            did not include and       entity did not           did not include and        did not include and
                           vegetation management program (TVMP).          keep current one of the   include and keep         keep current three of      keep current four of
                           The TVMP shall include the Transmission        four required elements    current two of the       the four required          the four required
                           Owner's objectives, practices, approved        of its TVMP, as           four required            elements of its TVMP,      elements of the
                           procedures, and work Specifications. 1.        directed by the           elements of its          as directed by the         TVMP, as directed by
                           ANSI A300, Tree Care Operations – Tree,        requirement.              TVMP, as directed        requirement.               the requirement.
                           Shrub, and Other Woody Plant Maintenance                                 by the requirement.
                           – Standard Practices, while not a
                           requirement of this standard, is considered
                           to be an industry best practice.
FAC-003-1   R1.1.          The TVMP shall define a schedule for and       N/A                       N/A                      The applicable entity      The applicable entity
                           the type (aerial, ground) of ROW vegetation                                                       TVMP did not define a      TVMP did not define
                           inspections. This schedule should be                                                              schedule, as directed by   a schedule, as directed

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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL      Moderate VSL          High VSL                 Severe VSL
 Number        Number
                           flexible enough to adjust for changing                                              the requirement, or the   by the requirement,
                           conditions. The inspection schedule shall                                           type of ROW               nor the type of ROW
                           be based on the anticipated growth of                                               vegetation inspections,   vegetation inspections,
                           vegetation and any other environmental or                                           as directed by the        as directed by the
                           operational factors that could impact the                                           requirement.              requirement.
                           relationship of vegetation to the
                           Transmission Owner’s transmission lines.
FAC-003-1   R1.2.          The Transmission Owner, in the TVMP,            Not Applicable.   Not Applicable.   Not Applicable.           The Transmission
                           shall identify and document clearances                                                                        Owner's TVMP does
                           between vegetation and any overhead,                                                                          not specify clearances.
                           ungrounded supply conductors, taking into
                           consideration transmission line voltage, the
                           effects of ambient temperature on conductor
                           sag under maximum design loading, and the
                           effects of wind velocities on conductor
                           sway. Specifically, the Transmission
                           Owner shall establish clearances to be
                           achieved at the time of vegetation
                           management work identified herein as
                           Clearance 1, and shall also establish and
                           maintain a set of clearances identified
                           herein as Clearance 2 to prevent flashover
                           between vegetation and overhead
                           ungrounded supply conductors.
FAC-003-1   R1.2.1.        Clearance 1 — The Transmission Owner            Not Applicable.   Not Applicable.   Not Applicable.           The Transmission
                           shall determine and document appropriate                                                                      Owner's TVMP does
                           clearance distances to be achieved at the                                                                     not specify Clearance
                           time of transmission vegetation                                                                               1 values.
                           management work based upon local
                           conditions and the expected time frame in
                           which the Transmission Owner plans to
                           return for future vegetation management
                           work. Local conditions may include, but
                           are not limited to: operating voltage,
                           appropriate vegetation management
                           techniques, fire risk, reasonably anticipated
                           tree and conductor movement, species types
                           and growth rates, species failure
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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                        Lower VSL      Moderate VSL          High VSL         Severe VSL
 Number        Number
                           characteristics, local climate and rainfall
                           patterns, line terrain and elevation, location
                           of the vegetation within the span, and
                           worker approach distance requirements.
                           Clearance 1 distances shall be greater than
                           those defined by Clearance 2 below.
FAC-003-1   R1.2.2.        Clearance 2 — The Transmission Owner             Not Applicable.   Not Applicable.   Not Applicable.   The Transmission
                           shall determine and document specific                                                                  Owner's TVMP does
                           radial clearances to be maintained between                                                             not specify Clearance
                           vegetation and conductors under all rated                                                              2 values.
                           electrical operating conditions. These
                           minimum clearance distances are necessary
                           to prevent flashover between vegetation and
                           conductors and will vary due to such factors
                           as altitude and operating voltage. These
                           Transmission Owner-specific minimum
                           clearance distances shall be no less than
                           those set forth in the Institute of Electrical
                           and Electronics Engineers (IEEE) Standard
                           516-2003 (Guide for Maintenance Methods
                           on Energized Power Lines) and as specified
                           in its Section 4.2.2.3, Minimum Air
                           Insulation Distances without Tools in the
                           Air Gap.
FAC-003-1   R1.2.2.1.      Where transmission system transient              Not Applicable.   Not Applicable.   Not Applicable.   Where transmission
                           overvoltage factors are not known,                                                                     system transient
                           clearances shall be derived from Table 5,                                                              overvoltage factors are
                           IEEE 516-2003, phase-to-ground distances,                                                              known,
                           with appropriate altitude correction factors                                                           clearances were not
                           applied.                                                                                               derived from Table 5,
                                                                                                                                  IEEE 516-2003,
                                                                                                                                  phase-to-phase
                                                                                                                                  voltages, with
                                                                                                                                  appropriate altitude
                                                                                                                                  correction factors
                                                                                                                                  applied.
FAC-003-1   R1.2.2.2.      Where transmission system transient              Not Applicable.   Not Applicable.   Not Applicable.   Where transmission

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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                     Lower VSL           Moderate VSL               High VSL                   Severe VSL
 Number        Number
                           overvoltage factors are known, clearances                                                                               system transient
                           shall be derived from Table 7, IEEE 516-                                                                                overvoltage factors are
                           2003, phase-to-phase voltages, with                                                                                     known,
                           appropriate altitude correction factors                                                                                 clearances were not
                           applied.                                                                                                                derived from Table 7,
                                                                                                                                                   IEEE 516-2003,
                                                                                                                                                   phase-to-phase
                                                                                                                                                   voltages, with
                                                                                                                                                   appropriate altitude
                                                                                                                                                   correction factors
                                                                                                                                                   applied.
FAC-003-1   R1.3.          All personnel directly involved in the       One or more persons     More than 35% of       More than 70% of all        None of the persons
                           design and implementation of the TVMP        directly involved in    all personnel          personnel directly          directly involved in
                           shall hold appropriate qualifications and    the design and          directly involved in   involved in the design      the design and
                           training, as defined by the Transmission     implementation of the   the design and         and implementation of       implementation of the
                           Owner, to perform their duties.              TVMP (but not more      implementation of      the TVMP (but not           Transmission Owner's
                                                                        than 35% of the all     the TVMP (but not      100% of all personnel       TVMP held
                                                                        personnel involved),    more than 70% of       involved), did not hold     appropriate
                                                                        did not hold            all personnel          appropriate                 qualifications and
                                                                        appropriate             involved), did not     qualifications and          training to perform
                                                                        qualifications and      hold appropriate       training to perform their   their duties.
                                                                        training to perform     qualifications and     duties.
                                                                        their duties.           training to perform
                                                                                                their duties.
FAC-003-1   R1.4.          Each Transmission Owner shall develop        Not Applicable.         Not Applicable.        Not Applicable.             The Transmission
                           mitigation measures to achieve sufficient                                                                               Owner's TVMP does
                           clearances for the protection of the                                                                                    not include mitigation
                           transmission facilities when it identifies                                                                              measures to achieve
                           locations on the ROW where the                                                                                          sufficient clearances
                           Transmission Owner is restricted from                                                                                   where restrictions to
                           attaining the clearances specified in                                                                                   the ROW are in effect.
                           Requirement 1.2.1.
FAC-003-1   R1.5.          Each Transmission Owner shall establish      N/A                     N/A                    N/A                         The applicable entity
                           and document a process for the immediate                                                                                did not establish or did
                           communication of vegetation conditions                                                                                  not document a
                           that present an imminent threat of a                                                                                    process, as directed by
                           transmission line outage. This is so that                                                                               the requirement.

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Complete Violation Severity Level Matrix (FAC)
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 Standard    Requirement
                                      Text of Requirement                       Lower VSL                Moderate VSL               High VSL                  Severe VSL
 Number        Number
                           action (temporary reduction in line rating,
                           switching line out of service, etc.) may be
                           taken until the threat is relieved.
FAC-003-1   R2.            The Transmission Owner shall create and         The Transmission            The Transmission       The Transmission           The Transmission
                           implement an annual plan for vegetation         Owner did not meet          Owner did not meet     Owner did not meet the     Owner does not have
                           management work to ensure the reliability       one of the three            two of the three       three required elements    an annual plan for
                           of the system. The plan shall describe the      required elements           required elements      (including in the annual   vegetation
                           methods used, such as manual clearing,          (including in the           (including in the      plan a description of      management, or the
                           mechanical clearing, herbicide treatment, or    annual plan a               annual plan a          methods used for           Transmission Owner
                           other actions. The plan should be flexible      description of methods      description of         vegetation                 has not implemented
                           enough to adjust to changing conditions,        used for vegetation         methods used for       management,                the annual plan for
                           taking into consideration anticipated growth    management,                 vegetation             maintaining                vegetation
                           of vegetation and all other environmental       maintaining                 management,            documentation of           management.
                           factors that may have an impact on the          documentation of            maintaining            adjustments to the
                           reliability of the transmission systems.        adjustments to the          documentation of       annual plan, or having
                           Adjustments to the plan shall be                annual plan, or having      adjustments to the     systems and procedures
                           documented as they occur. The plan should       systems and                 annual plan, or        for tracking work
                           take into consideration the time required to    procedures for              having systems and     performed as part of the
                           obtain permissions or permits from              tracking work               procedures for         annual plan) specified
                           landowners or regulatory authorities. Each      performed as part of        tracking work          in the requirement.
                           Transmission Owner shall have systems and       the annual plan)            performed as part of
                           procedures for documenting and tracking         specified in the            the annual plan)
                           the planned vegetation management work          requirement.                specified in the
                           and ensuring that the vegetation                                            requirement.
                           management work was completed
                           according to work specifications.
FAC-003-1   R3.            The Transmission Owner shall report             The Transmission            The Transmission       The Transmission           The Transmission
                           quarterly to its RRO, or the RRO’s              Owner did not submit        Owner did not          Owner did not report       Owner did not report
                           designee, sustained transmission line           a quarterly report to its   report an outage       multiple outages           one or more outages
                           outages determined by the Transmission          RRO and did not have        specified as           specified as reportable    specified as reportable
                           Owner to have been caused by vegetation.        any outages to report       reportable in R3 to    in R3 to its RRO           in R3 to its RRO for
                                                                                                       its RRO                                           two consecutive
                                                                                                                                                         quarters
FAC-003-1   R3.1.          Multiple sustained outages on an individual     Not applicable.             Not applicable.        Not applicable.            The Transmission
                           line, if caused by the same vegetation, shall                                                                                 Owner failed to report,
                           be reported as one outage regardless of the                                                                                   as a single outage,
                           actual number of outages within a 24-hour                                                                                     multiple sustained

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                                      Text of Requirement                       Lower VSL             Moderate VSL              High VSL                Severe VSL
 Number        Number
                           period.                                                                                                                 outages within a 24-
                                                                                                                                                   hour period on an
                                                                                                                                                   individual line, if
                                                                                                                                                   caused by the same
                                                                                                                                                   vegetation.
FAC-003-1   R3.2.          The Transmission Owner is not required to       Not applicable.          Not applicable.       Not applicable.          The Transmission
                           report to the RRO, or the RRO’s designee,                                                                               Owner made reports
                           certain sustained transmission line outages                                                                             for outages not
                           caused by vegetation: (1) Vegetation-related                                                                            considered reportable
                           outages that result from vegetation falling                                                                             based on the
                           into lines from outside the ROW that result                                                                             categories listed in this
                           from natural disasters shall not be                                                                                     requirement.
                           considered reportable (examples of disasters
                           that could create non-reportable outages
                           include, but are not limited to, earthquakes,
                           fires, tornados, hurricanes, landslides, wind
                           shear, major storms as defined either by the
                           Transmission Owner or an applicable
                           regulatory body, ice storms, and floods),
                           and (2) Vegetation-related outages due to
                           human or animal activity shall not be
                           considered reportable (examples of human
                           or animal activity that could cause a non-
                           reportable outage include, but are not
                           limited to, logging, animal severing tree,
                           vehicle contact with tree, arboricultural
                           activities or horticultural or agricultural
                           activities, or removal or digging of
                           vegetation).
FAC-003-1   R3.3.          The outage information provided by the          The outage               The outage            The outage information   The outage
                           Transmission Owner to the RRO, or the           information provided     information           provided by the          information provided
                           RRO’s designee, shall include at a              by the Transmission      provided by the       Transmission Owner to    by the Transmission
                           minimum: the name of the circuit(s)             Owner to the RRO, or     Transmission Owner    the RRO, or the RRO’s    Owner to the RRO, or
                           outaged, the date, time and duration of the     the RRO’s designee,      to the RRO, or the    designee, did not        the RRO’s designee,
                           outage; a description of the cause of the       did not include one of   RRO’s designee, did   include three of the     did not include four or
                           outage; other pertinent comments; and any       the required elements.   not include two of    required elements.       more of the required
                           countermeasures taken by the Transmission                                the required                                   elements.
                           Owner.                                                                   elements.
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 Number        Number
FAC-003-1   R3.4.          An outage shall be categorized as one of the     Not applicable.            Not applicable.   Not applicable.        The outage was not
                           following:                                                                                                           classified in the
                                                                                                                                                correct category.
FAC-003-1   R3.4.1.        Category 1 — Grow-ins: Outages caused by         Not applicable.            Not applicable.   Not applicable.        The outage was not
                           vegetation growing into lines from                                                                                   classified in the
                           vegetation inside and/or outside of the                                                                              correct category.
                           ROW;
FAC-003-1   R3.4.2.        Category 2 — Fall-ins: Outages caused by         Not applicable.            Not applicable.   Not applicable.        The outage was not
                           vegetation falling into lines from inside the                                                                        classified in the
                           ROW;                                                                                                                 correct category.
FAC-003-1   R3.4.3.        Category 3 — Fall-ins: Outages caused by         Not applicable.            Not applicable.   Not applicable.        The outage was not
                           vegetation falling into lines from outside the                                                                       classified in the
                           ROW.                                                                                                                 correct category.
FAC-003-1   R4.            The RRO shall report the outage                  Not applicable.            Not applicable.   The RRO did not        The RRO did not
                           information provided to it by Transmission                                                    submit a quarterly     submit a quarterly
                           Owner’s, as required by Requirement 3,                                                        report to NERC for a   report to NERC for
                           quarterly to NERC, as well as any actions                                                     single quarter.        more than two
                           taken by the RRO as a result of any of the                                                                           consecutive quarters.
                           reported outages.
FAC-008-1   R1.            The Transmission Owner and Generator             Not applicable.            Not applicable.   Not applicable.        The Transmission
                           Owner shall each document its current                                                                                Owner or Generation
                           methodology used for developing Facility                                                                             Owner does not have a
                           Ratings (Facility Ratings Methodology) of                                                                            documented Facility
                           its solely and jointly owned Facilities. The                                                                         Ratings Methodology
                           methodology shall include all of the                                                                                 for use in developing
                           following:                                                                                                           facility ratings.
FAC-008-1   R1.1.          A statement that a Facility Rating shall         The Facility Rating        Not applicable.   Not applicable.        The Transmission
                           equal the most limiting applicable               methodology respects                                                Owner or Generator
                           Equipment Rating of the individual               the most limiting                                                   Owner has failed to
                           equipment that comprises that Facility.          applicable Equipment                                                demonstrate that its
                                                                            Rating of the                                                       Facility Rating
                                                                            individual equipment                                                Methodology respects
                                                                            that comprises that                                                 the most limiting
                                                                            Facility but there is no                                            applicable Equipment
                                                                            statement in the                                                    Rating of the

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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                      Lower VSL           Moderate VSL                 High VSL                Severe VSL
 Number        Number
                                                                          documentation of the                                                      individual equipment
                                                                          methodology that                                                          that comprises that
                                                                          states this.                                                              Facility.
FAC-008-1   R1.2.          The method by which the Rating (of major       Not applicable.        Not applicable.          Not applicable.           The Transmission
                           BES equipment that comprises a Facility) is                                                                              Owner's or Generation
                           determined.                                                                                                              Owner's Facility
                                                                                                                                                    Ratings Methodology
                                                                                                                                                    does not specify the
                                                                                                                                                    manner in which a
                                                                                                                                                    rating is determined.
FAC-008-1   R1.2.1.        The scope of equipment addressed shall         Not applicable.        The Transmission         The Transmission          The Transmission
                           include, but not be limited to, generators,                           Owner or Generator       Owner or Generator        Owner or Generator
                           transmission conductors, transformers, relay                          Owner has                Owner has                 Owner has
                           protective devices, terminal equipment, and                           demonstrated that it     demonstrated the          demonstrated the
                           series and shunt compensation devices.                                has a Facility Rating    existence of methods of   existence of methods
                                                                                                 Methodology that         rating equipment but      of rating equipment
                                                                                                 includes methods of      the equipment rating      but the equipment
                                                                                                 rating BES               methods don't address     rating methods don't
                                                                                                 equipment but the        two of the applicable     address more than two
                                                                                                 equipment rating         required devices.         of the applicable
                                                                                                 methods don't                                      required devices.
                                                                                                 address one of the
                                                                                                 applicable required
                                                                                                 devices.
FAC-008-1   R1.2.2.        The scope of Ratings addressed shall           Not applicable.        The Transmission         The Transmission          The Transmission
                           include, as a minimum, both Normal and                                Owner or Generator       Owner or Generator        Owner or Generator
                           Emergency Ratings.                                                    Owner's equipment        Owner's equipment         Owner's equipment
                                                                                                 Ratings                  Ratings methodology       Ratings methodology
                                                                                                 methodology does         fails to include a        fails to demonstrate
                                                                                                 address a                methodology for           the inclusion of any
                                                                                                 methodology for          determining emergency     method for
                                                                                                 determining              ratings for of its BES    determining normal or
                                                                                                 emergency ratings        equipment.                emergency ratings for
                                                                                                 but fails to include a                             of its BES equipment.
                                                                                                 methodology for
                                                                                                 determining normal
                                                                                                 ratings for its BES

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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                      Lower VSL          Moderate VSL              High VSL                  Severe VSL
 Number        Number
                                                                                                equipment.
FAC-008-1   R1.3.          Consideration of the following:                The rating            The rating            The rating methodology     The rating
                                                                          methodology did not   methodology did not   did not consider three     methodology did not
                                                                          consider one of the   consider two of the   of the sub requirements.   consider four or more
                                                                          sub requirements.     sub requirements.                                of the sub
                                                                                                                                                 requirements.
FAC-008-1   R1.3.1.        Ratings provided by equipment                  Not applicable.       Not applicable.       Not applicable.            The Transmission
                           manufacturers.                                                                                                        Owner or Generator
                                                                                                                                                 Owner has failed to
                                                                                                                                                 demonstrate the
                                                                                                                                                 existence (in its
                                                                                                                                                 Facility Rating
                                                                                                                                                 Methodology) of how
                                                                                                                                                 it considered ratings
                                                                                                                                                 provided by
                                                                                                                                                 equipment
                                                                                                                                                 manufacturers.
FAC-008-1   R1.3.2.        Design criteria (e.g., including applicable    Not applicable.       Not applicable.       Not applicable.            The Transmission
                           references to industry Rating practices such                                                                          Owner or Generator
                           as manufacturer’s warranty, IEEE, ANSI or                                                                             Owner has failed to
                           other standards).                                                                                                     demonstrate how it
                                                                                                                                                 considered design
                                                                                                                                                 criteria in developing
                                                                                                                                                 its equipment Ratings.
FAC-008-1   R1.3.3.        Ambient conditions.                            Not applicable.       Not applicable.       Not applicable.            The Transmission
                                                                                                                                                 Owner or Generator
                                                                                                                                                 Owner has failed to
                                                                                                                                                 demonstrate how it
                                                                                                                                                 considered ambient
                                                                                                                                                 conditions in
                                                                                                                                                 developing its
                                                                                                                                                 equipment Ratings.
FAC-008-1   R1.3.4.        Operating limitations.                         Not applicable.       Not applicable.       Not applicable.            The Transmission
                                                                                                                                                 Owner or Generator
                                                                                                                                                 Owner has failed to
                                                                                                                                                 demonstrate how it

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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                      Lower VSL               Moderate VSL                 High VSL                 Severe VSL
 Number        Number
                                                                                                                                                        considered operating
                                                                                                                                                        limitations in
                                                                                                                                                        developing its
                                                                                                                                                        equipment Ratings.
FAC-008-1   R1.3.5.        Other assumptions.                             Not applicable.            Not applicable.          Not applicable.           The Transmission
                                                                                                                                                        Owner or Generator
                                                                                                                                                        Owner has failed to
                                                                                                                                                        demonstrate how it
                                                                                                                                                        considered other
                                                                                                                                                        assumptions in
                                                                                                                                                        developing its
                                                                                                                                                        equipment Ratings.
FAC-008-1   R2.            The Transmission Owner and Generator           The Transmission           The Transmission         The Transmission          The Transmission
                           Owner shall each make its Facility Ratings     Owner or Generator         Owner or Generator       Owner or Generator        Owner or Generator
                           Methodology available for inspection and       Owner has made its         Owner has not made       Owner fails to provide    Owner has not made
                           technical review by those Reliability          Facility Ratings           its Facility Ratings     its Facility Ratings      its Facility Rating
                           Coordinators, Transmission Operators,          Methodology available      Methodology              Methodology available     Methodology available
                           Transmission Planners, and Planning            to all required entities   available to one of      to two or more of the     to any of the required
                           Authorities that have responsibility for the   but not within 15          the required entities,   required entities.        entities in accordance
                           area in which the associated Facilities are    business days of a         but did make the                                   with Requirement R2
                           located, within 15 business days of receipt    request.                   methodology                                        within 60 business
                           of a request.                                                             available to all other                             days of receipt of a
                                                                                                     required entities.                                 request.
FAC-008-1   R3.            If a Reliability Coordinator, Transmission     The responsible entity     The responsible          The responsible entity    The responsible entity
                           Operator, Transmission Planner, or             provided a response as     entity provided a        provided a response but   did not provide any
                           Planning Authority provides written            required but took          response and the         the response did not      evidence to
                           comments on its technical review of a          longer than 45             response indicated       indicate whether a        demonstrate that it
                           Transmission Owner’s or Generator              business days.             that a change will       change will be made to    provided a response to
                           Owner’s Facility Ratings Methodology, the                                 not be made to the       the Facility Ratings      a comment on its
                           Transmission Owner or Generator Owner                                     Facility Ratings         Methodology.              Facility Ratings
                           shall provide a written response to that                                  Methodology but                                    Methodology in
                           commenting entity within 45 calendar days                                 did not indicate why                               accordance with
                           of receipt of those comments. The response                                no change will be                                  Requirement R3
                           shall indicate whether a change will be                                   made.                                              within 90 business
                           made to the Facility Ratings Methodology                                                                                     days.
                           and, if no change will be made to that
                           Facility Ratings Methodology, the reason

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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard      Requirement
                                         Text of Requirement                         Lower VSL               Moderate VSL                 High VSL                   Severe VSL
 Number          Number
                             why.
FAC-009-1     R1.            The Transmission Owner and Generator               The Transmission           The Transmission         The Transmission            The Transmission
                             Owner shall each establish Facility Ratings        Owner or Generator         Owner or Generator       Owner or Generator          Owner or Generator
                             for its solely and jointly owned Facilities        Owner developed            Owner developed          Owner developed             Owner has failed to
                             that are consistent with the associated            Facility Ratings for all   Facility Ratings for     Facility Ratings            demonstrate that it
                             Facility Ratings Methodology.                      its solely owned and       most, but not all of     following the associated    developed any Facility
                                                                                jointly owned              its solely and jointly   Facility Ratings            Ratings using its
                                                                                Facilities, but the        owned Facilities         Methodology but failed      Facility Rating
                                                                                ratings weren't            following the            to develop any Facility     Methodology
                                                                                consistent with the        associated Facility      Ratings for a significant
                                                                                associated Facility        Ratings                  number of its solely and
                                                                                Rating Methodology         Methodology              jointly owned Facilities
                                                                                in one minor area.         OR                       OR
                                                                                                           the Transmission         the Transmission
                                                                                                           Owner or Generator       Owner or Generator
                                                                                                           Owner developed          Owner has developed
                                                                                                           Facility Ratings for     Facility Ratings for all
                                                                                                           all its solely and       its solely owned and
                                                                                                           jointly owned            jointly owned Facilities,
                                                                                                           Facilities but failed    but failed to follow the
                                                                                                           to follow the            associated Facility
                                                                                                           associated Facility      Ratings Methodology
                                                                                                           Ratings                  in more than one
                                                                                                           Methodology in one       significant area.
                                                                                                           significant area.
FAC-009-1     R2.            The Transmission Owner and Generator               The Transmission           The Transmission         The Transmission            The Transmission
                             Owner shall each provide Facility Ratings          Owner or Generator         Owner or Generator       Owner or Generator          Owner or Generator
                             for its solely and jointly owned Facilities        Owner provided its         Owner provided its       Owner provided its          Owner has provided
                             that are existing Facilities, new Facilities,      Facility Ratings to all    Facility Ratings to      Facility Ratings to two     its Facility Ratings to
                             modifications to existing Facilities and re-       of the requesting          all but one of the       of the requesting           none of the requesting
                             ratings of existing Facilities to its associated   entities but missed        requesting entities.     entities.                   entities within 30
                             Reliability Coordinator(s), Planning               meeting the schedules                                                           calendar days of the
                             Authority(ies), Transmission Planner(s),           by up to 15 calendar                                                            associated schedules.
                             and Transmission Operator(s) as scheduled          days.
                             by such requesting entities.
FAC-010-2.1   R1             The Planning Authority shall have a                Not applicable.            The Planning             The Planning Authority      The Planning
                             documented SOL Methodology for use in                                         Authority has a          has a documented SOL        Authority has a
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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard      Requirement
                                        Text of Requirement                      Lower VSL      Moderate VSL                High VSL                Severe VSL
 Number          Number
                             developing SOLs within its Planning                              documented SOL          Methodology for use in   documented SOL
                             Authority Area. This SOL Methodology                             Methodology for         developing SOLs          Methodology for use
                             shall:                                                           use in developing       within its Planning      in developing SOLs
                                                                                              SOLs within its         Authority Area, but it   within its Planning
                                                                                              Planning Authority      does not address R1.3.   Authority Area, but it
                                                                                              Area, but it does not                            does not address R1.1.
                                                                                              address R1.2                                     OR
                                                                                                                                               The Planning
                                                                                                                                               Authority has no
                                                                                                                                               documented SOL
                                                                                                                                               Methodology for use
                                                                                                                                               in developing SOLs
                                                                                                                                               within its Planning
                                                                                                                                               Authority Area.
FAC-010-2.1   R1.1.          Be applicable for developing SOLs used in      Not applicable.   Not applicable.         Not applicable.          Planning Authority
                             the planning horizon.                                                                                             SOL methodology is
                                                                                                                                               not applicable for
                                                                                                                                               developing SOL in the
                                                                                                                                               planning horizon.
FAC-010-2.1   R1.2.          State that SOLs shall not exceed associated    Not applicable.   Not applicable.         Not applicable.          Planning Authority
                             Facility Ratings.                                                                                                 SOL Methodology did
                                                                                                                                               not state that SOLs
                                                                                                                                               shall not exceed
                                                                                                                                               associated Facility
                                                                                                                                               Ratings
FAC-010-2.1   R1.3.          Include a description of how to identify the   Not applicable.   Not applicable.         Not applicable.          Planning Authority
                             subset of SOLs that qualify as IROLs.                                                                             SOL Methodology did
                                                                                                                                               not include a
                                                                                                                                               description of how to
                                                                                                                                               identify the subset of
                                                                                                                                               SOLs that qualify as
                                                                                                                                               IROLs.
FAC-010-2.1   R2.            The Planning Authority’s SOL
                             Methodology shall include a requirement
                             that SOLs provide BES performance
                             consistent with the following

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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard      Requirement
                                         Text of Requirement                        Lower VSL      Moderate VSL          High VSL         Severe VSL
 Number          Number
FAC-010-2.1   R2.1.          In the pre-contingency state and with all         Not applicable.   Not applicable.   Not applicable.   The Planning
                             Facilities in service, the BES shall                                                                    Authority’s
                             demonstrate transient, dynamic and voltage                                                              methodology does not
                             stability; all Facilities shall be within their                                                         include a requirement
                             Facility Ratings and within their thermal,                                                              that SOLs provide
                             voltage and stability limits. In the                                                                    BES performance
                             determination of SOLs, the BES condition                                                                consistent with sub-
                             used shall reflect expected system                                                                      requirement R2.1.
                             conditions and shall reflect changes to
                             system topology such as Facility outages.
FAC-010-2.1   R2.2.          Following the single Contingencies                Not applicable.   Not applicable.   Not applicable.   The Planning
                             identified in Requirement 2.2.1 through                                                                 Authority’s
                             Requirement 2.2.3, the system shall                                                                     methodology does not
                             demonstrate transient, dynamic and voltage                                                              include a requirement
                             stability; all Facilities shall be operating                                                            that SOLs provide
                             within their Facility Ratings and within                                                                BES performance
                             their thermal, voltage and stability limits;                                                            consistent with sub-
                             and Cascading or uncontrolled separation                                                                requirement R2.2.
                             shall not occur.
FAC-010-2.1   R2.2.1.        Single line to ground or three-phase Fault        Not applicable.   Not applicable.   Not applicable.   The methodology does
                             (whichever is more severe), with Normal                                                                 not address single line
                             Clearing, on any Faulted generator, line,                                                               to ground or 3-phase
                             transformer, or shunt device.                                                                           Fault (whichever is
                                                                                                                                     more severe), with
                                                                                                                                     Normal Clearing, on
                                                                                                                                     any Faulted generator,
                                                                                                                                     line, transformer, or
                                                                                                                                     shunt device.
FAC-010-2.1   R2.2.2.        Loss of any generator, line, transformer, or      Not applicable.   Not applicable.   Not applicable.   The methodology does
                             shunt device without a Fault.                                                                           not address the loss of
                                                                                                                                     any generator, line,
                                                                                                                                     transformer, or shunt
                                                                                                                                     device without a Fault.
FAC-010-2.1   R2.2.3.        Single pole block, with Normal Clearing, in       Not applicable.   Not applicable.   Not applicable.   The methodology does
                             a monopolar or bipolar high voltage direct                                                              not address single pole
                             current system.                                                                                         block, with Normal

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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard      Requirement
                                        Text of Requirement                      Lower VSL      Moderate VSL          High VSL         Severe VSL
 Number          Number
                                                                                                                                  Clearing, in a
                                                                                                                                  monopolar or bipolar
                                                                                                                                  high voltage direct
                                                                                                                                  current system.
FAC-010-2.1   R2.3.          Starting with all Facilities in service, the   Not applicable.   Not applicable.   Not applicable.   The methodology does
                             system’s response to a single Contingency,                                                           not include one or
                             may include any of the following:                                                                    more of the following:
                                                                                                                                  2.3.1. through 2.3.3.
FAC-010-2.1   R2.3.1.        Planned or controlled interruption of          Not applicable.   Not applicable.   Not applicable.   The SOL
                             electric supply to radial customers or some                                                          Methodology does not
                             local network customers connected to or                                                              provide that starting
                             supplied by the Faulted Facility or by the                                                           with all Facilities in
                             affected area.                                                                                       service, the system’s
                                                                                                                                  response to a single
                                                                                                                                  Contingency may
                                                                                                                                  include planned or
                                                                                                                                  controlled interruption
                                                                                                                                  of electric supply to
                                                                                                                                  radial customers or
                                                                                                                                  some local network
                                                                                                                                  customers connected
                                                                                                                                  to or supplied by the
                                                                                                                                  Faulted Facility or by
                                                                                                                                  the affected area.
FAC-010-2.1   R2.3.2.        System reconfiguration through manual or       Not applicable.   Not applicable.   Not applicable.   The SOL
                             automatic control or protection actions.                                                             Methodology does not
                                                                                                                                  provide that starting
                                                                                                                                  with all Facilities in
                                                                                                                                  service, the system’s
                                                                                                                                  response to a single
                                                                                                                                  Contingency may
                                                                                                                                  include System
                                                                                                                                  reconfiguration
                                                                                                                                  through manual or
                                                                                                                                  automatic control or
                                                                                                                                  protection actions.


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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard      Requirement
                                        Text of Requirement                       Lower VSL      Moderate VSL          High VSL         Severe VSL
 Number          Number
FAC-010-2.1   R2.4.          To prepare for the next Contingency,            Not applicable.   Not applicable.   Not applicable.   The SOL
                             system adjustments may be made, including                                                             Methodology does not
                             changes to generation, uses of the                                                                    provide that in order to
                             transmission system, and the transmission                                                             prepare for the next
                             system topology.                                                                                      Contingency, system
                                                                                                                                   adjustments may be
                                                                                                                                   made, including
                                                                                                                                   changes to generation,
                                                                                                                                   uses of the
                                                                                                                                   transmission system,
                                                                                                                                   and the transmission
                                                                                                                                   system topology.
FAC-010-2.1   R2.5.          Starting with all Facilities in service and     Not applicable.   Not applicable.   Not applicable.   The SOL methodology
                             following any of the multiple Contingencies                                                           does not include a
                             identified in Reliability Standard TPL-003                                                            requirement that SOLs
                             the system shall demonstrate transient,                                                               provide BES
                             dynamic and voltage stability; all Facilities                                                         performance
                             shall be operating within their Facility                                                              consistent with sub-
                             Ratings and within their thermal, voltage                                                             requirement R2.5.
                             and stability limits; and Cascading or
                             uncontrolled separation shall not occur.
FAC-010-2.1   R2.6.          In determining the system’s response to any     Not applicable.   Not applicable.   Not applicable.   Not applicable.
                             of the multiple Contingencies, identified in
                             Reliability Standard TPL-003, in addition to
                             the actions identified in R2.3.1 and R2.3.2,
                             the following shall be acceptable:
FAC-010-2.1   R2.6.1.        Planned or controlled interruption of           Not applicable.   Not applicable.   Not applicable.   The SOL
                             electric supply to customers (load                                                                    Methodology does not
                             shedding), the planned removal from                                                                   provide that in
                             service of certain generators, and/or the                                                             determining the
                             curtailment of contracted Firm (non-                                                                  system’s response to
                             recallable reserved) electric power                                                                   any of the multiple
                             Transfers.                                                                                            Contingencies,
                                                                                                                                   identified in
                                                                                                                                   Reliability Standard
                                                                                                                                   TPL-003, in addition
                                                                                                                                   to the actions
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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard      Requirement
                                        Text of Requirement                    Lower VSL             Moderate VSL              High VSL                  Severe VSL
 Number          Number
                                                                                                                                                    identified in R2.3.1
                                                                                                                                                    and R2.3.2, Planned or
                                                                                                                                                    controlled interruption
                                                                                                                                                    of electric supply to
                                                                                                                                                    customers (load
                                                                                                                                                    shedding), the planned
                                                                                                                                                    removal from service
                                                                                                                                                    of certain generators,
                                                                                                                                                    and/or the curtailment
                                                                                                                                                    of contracted Firm
                                                                                                                                                    (non-recallable
                                                                                                                                                    reserved) electric
                                                                                                                                                    power Transfers shall
                                                                                                                                                    be acceptable.
FAC-010-2.1   R3.            The Planning Authority’s methodology for     The Planning             The Planning          The Planning Authority     The Planning
                             determining SOLs, shall include, as a        Authority has a          Authority has a       has a methodology for      Authority has a
                             minimum, a description of the following,     methodology for          methodology for       determining SOLs that      methodology for
                             along with any reliability margins applied   determining SOLs that    determining SOLs      includes a description     determining SOLs that
                             for each:                                    includes a description   that includes a       for all but three of the   is missing a
                                                                          for all but one of the   description for all   following: R3.1 through    description of four or
                                                                          following: R3.1          but two of the        R3.6.                      more of the following:
                                                                          through R3.6.            following: R3.1                                  R3.1 through R3.6.
                                                                                                   through R3.6.
FAC-010-2.1   R3.1.          Study model (must include at least the       Not applicable.          Not applicable.       Not applicable.            The methodology does
                             entire Planning Authority Area as well as                                                                              not include a study
                             the critical modeling details from other                                                                               model that includes
                             Planning Authority Areas that would impact                                                                             the entire Planning
                             the Facility or Facilities under study).                                                                               Authority Area, and
                                                                                                                                                    the critical modeling
                                                                                                                                                    details of other
                                                                                                                                                    Planning Authority
                                                                                                                                                    Areas that would
                                                                                                                                                    impact the facility or
                                                                                                                                                    facilities under study.
FAC-010-2.1   R3.2.          Selection of applicable Contingencies.       Not applicable.          Not applicable.       Not applicable.            The methodology does
                                                                                                                                                    not include the
                                                                                                                                                    selection of applicable

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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard      Requirement
                                        Text of Requirement                       Lower VSL         Moderate VSL          High VSL                Severe VSL
 Number          Number
                                                                                                                                             Contingencies.
FAC-010-2.1   R3.3           Level of detail of system models used to        Not applicable.      Not applicable.   Not applicable.          The methodology does
                             determine SOLs.                                                                                                 not describe the level
                                                                                                                                             of detail of system
                                                                                                                                             models used to
                                                                                                                                             determine SOLs.
FAC-010-2.1   R3.4.          Allowed uses of Special Protection Systems      Not applicable.      Not applicable.   Not applicable.          The methodology does
                             or Remedial Action Plans.                                                                                       not describe the
                                                                                                                                             allowed uses of
                                                                                                                                             Special Protection
                                                                                                                                             Systems or Remedial
                                                                                                                                             Action Plans.
FAC-010-2.1   R3.5.          Anticipated transmission system                 Not applicable.      Not applicable.   Not applicable.          The methodology does
                             configuration, generation dispatch and Load                                                                     not include the
                             level.                                                                                                          description of
                                                                                                                                             anticipated
                                                                                                                                             transmission system
                                                                                                                                             configuration,
                                                                                                                                             generation dispatch
                                                                                                                                             and Load level.
FAC-010-2.1   R3.6.          Criteria for determining when violating a       Not applicable.      Not applicable.   Not applicable.          The methodology does
                             SOL qualifies as an Interconnection                                                                             not include a
                             Reliability Operating Limit (IROL) and                                                                          description of the
                             criteria for developing any associated IROL                                                                     criteria for
                             Tv.                                                                                                             determining when
                                                                                                                                             violating a SOL
                                                                                                                                             qualifies as an
                                                                                                                                             Interconnection
                                                                                                                                             Reliability Operating
                                                                                                                                             Limit (IROL) and
                                                                                                                                             criteria for developing
                                                                                                                                             any associated IROL
                                                                                                                                             Tv.
FAC-010-2.1   R4.            The Planning Authority shall issue its SOL      One or both of the   One of the        One of the following:    One of the following:
                             Methodology, and any change to that             following:           following:        The Planning Authority   The Planning
                             methodology, to all of the following prior to   The Planning                           issued its SOL           Authority failed to
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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
Standard   Requirement
                                    Text of Requirement          Lower VSL              Moderate VSL               High VSL                 Severe VSL
Number       Number
                         the effectiveness of the change:   Authority issued its      The Planning           Methodology and           issue its SOL
                                                            SOL Methodology and       Authority issued its   changes to that           Methodology and
                                                            changes to that           SOL Methodology        methodology to all but    changes to that
                                                            methodology to all but    and changes to that    one of the required       methodology to more
                                                            one of the required       methodology to all     entities AND for a        than three of the
                                                            entities.                 but one of the         change in methodology,    required entities.
                                                                                      required entities      the changed
                                                                                      AND for a change       methodology was
                                                            For a change in                                                            The Planning
                                                                                      in methodology, the    provided 60 calendar
                                                            methodology, the                                                           Authority issued its
                                                                                      changed                days or more, but less
                                                            changed methodology                                                        SOL Methodology and
                                                                                      methodology was        than 90 calendar days
                                                            was provided up to 30                                                      changes to that
                                                                                      provided 30            after the effectiveness
                                                            calendar days after the                                                    methodology to all but
                                                                                      calendar days or       of the change.
                                                            effectiveness of the                                                       one of the required
                                                                                      more, but less than    OR
                                                            change.                                                                    entities AND for a
                                                                                      60 calendar days
                                                                                                             The Planning Authority    change in
                                                                                      after the
                                                                                                             issued its SOL            methodology, the
                                                                                      effectiveness of the
                                                                                                             Methodology and           changed methodology
                                                                                      change.
                                                                                                             changes to that           was provided 90
                                                                                      OR                     methodology to all but    calendar days or more
                                                                                      The Planning           two of the required       after the effectiveness
                                                                                      Authority issued its   entities AND for a        of the change.
                                                                                      SOL Methodology        change in methodology,    OR
                                                                                      and changes to that    the changed
                                                                                                                                       The Planning
                                                                                      methodology to all     methodology was
                                                                                                                                       Authority issued its
                                                                                      but two of the         provided 30 calendar
                                                                                                                                       SOL Methodology and
                                                                                      required entities      days or more, but less
                                                                                                                                       changes to that
                                                                                      AND for a change       than 60 calendar days
                                                                                                                                       methodology to all but
                                                                                      in methodology, the    after the effectiveness
                                                                                                                                       two of the required
                                                                                      changed                of the change.
                                                                                                                                       entities AND for a
                                                                                      methodology was        OR                        change in
                                                                                      provided up to 30
                                                                                                             The Planning Authority    methodology, the
                                                                                      calendar days after
                                                                                                             issued its SOL            changed methodology
                                                                                      the effectiveness of
                                                                                                             Methodology and           was provided 60
                                                                                      the change.
                                                                                                             changes to that           calendar days or more,
                                                                                                             methodology to all but    but less than 90
                                                                                                             three of the required     calendar days after the
                                                                                                             entities AND for a        effectiveness of the
                                                                                                             change in methodology,    change.
                                                                                                                                                 Page 124
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard      Requirement
                                        Text of Requirement                       Lower VSL      Moderate VSL          High VSL                 Severe VSL
 Number          Number
                                                                                                                 the changed               OR
                                                                                                                 methodology was           The Planning
                                                                                                                 provided up to 30         Authority issued its
                                                                                                                 calendar days after the   SOL Methodology and
                                                                                                                 effectiveness of the      changes to that
                                                                                                                 change.                   methodology to all but
                                                                                                                                           three of the required
                                                                                                                                           entities AND for a
                                                                                                                                           change in
                                                                                                                                           methodology, the
                                                                                                                                           changed methodology
                                                                                                                                           was provided 30
                                                                                                                                           calendar days or more,
                                                                                                                                           but less than 60
                                                                                                                                           calendar days after the
                                                                                                                                           effectiveness of the
                                                                                                                                           change. The Planning
                                                                                                                                           Authority issued its
                                                                                                                                           SOL Methodology and
                                                                                                                                           changes to that
                                                                                                                                           methodology to all but
                                                                                                                                           four of the required
                                                                                                                                           entities AND for a
                                                                                                                                           change in
                                                                                                                                           methodology, the
                                                                                                                                           changed methodology
                                                                                                                                           was provided up to 30
                                                                                                                                           calendar days after the
                                                                                                                                           effectiveness of the
                                                                                                                                           change.
FAC-010-2.1   R4.1.          Each adjacent Planning Authority and each       Not applicable.   Not applicable.   Not applicable.           The Planning
                             Planning Authority that indicated it has a                                                                    Authority did not issue
                             reliability-related need for the methodology.                                                                 its SOL Methodology
                                                                                                                                           and any change to that
                                                                                                                                           methodology, prior to
                                                                                                                                           the effectiveness of the
                                                                                                                                           change, to each
                                                                                                                                           adjacent Planning

                                                                                                                                                     Page 125
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard      Requirement
                                       Text of Requirement                      Lower VSL           Moderate VSL             High VSL                Severe VSL
 Number          Number
                                                                                                                                                Authority and each
                                                                                                                                                Planning Authority
                                                                                                                                                that indicated it has a
                                                                                                                                                reliability-related need
                                                                                                                                                for the methodology.
FAC-010-2.1   R4.2.          Each Reliability Coordinator and              Not applicable.        Not applicable.      Not applicable.          The Planning
                             Transmission Operator that operates any                                                                            Authority did not issue
                             portion of the Planning Authority’s                                                                                its SOL Methodology
                             Planning Authority Area.                                                                                           and any change to that
                                                                                                                                                methodology, prior to
                                                                                                                                                the effectiveness of the
                                                                                                                                                change, to each
                                                                                                                                                Reliability
                                                                                                                                                Coordinator and
                                                                                                                                                Transmission Operator
                                                                                                                                                that operates any
                                                                                                                                                portion of the Planning
                                                                                                                                                Authority’s Planning
                                                                                                                                                Authority Area.
FAC-010-2.1   R4.3.          Each Transmission Planner that works in       Not applicable.        Not applicable.      Not applicable.          The Planning
                             the Planning Authority’s Planning                                                                                  Authority did not issue
                             Authority Area.                                                                                                    its SOL Methodology
                                                                                                                                                and any change to that
                                                                                                                                                methodology, prior to
                                                                                                                                                the effectiveness of the
                                                                                                                                                change, to each
                                                                                                                                                Transmission Planner
                                                                                                                                                that works in the
                                                                                                                                                Planning Authority’s
                                                                                                                                                Planning Authority
                                                                                                                                                Area prior to the
                                                                                                                                                effectiveness of the
                                                                                                                                                change.
FAC-010-2.1   R5.            If a recipient of the SOL Methodology         The Planning           The Planning         The Planning Authority   The Planning
                             provides documented technical comments        Authority received     Authority received   received documented      Authority received
                             on the methodology, the Planning Authority    documented technical   documented           technical comments on    documented technical
                             shall provide a documented response to that   comments on its SOL    technical comments   its SOL Methodology      comments on its SOL

                                                                                                                                                           Page 126
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL             Moderate VSL               High VSL                  Severe VSL
 Number        Number
                           recipient within 45 calendar days of receipt    Methodology and          on its SOL             and provided a             Methodology and
                           of those comments. The response shall           provided a complete      Methodology and        complete response in a     provided a complete
                           indicate whether a change will be made to       response in a time       provided a complete    time period that was 75    response in a time
                           the SOL Methodology and, if no change           period that was longer   response in a time     calendar days or longer    period that was 90
                           will be made to that SOL Methodology, the       than 45 calendar days    period that was 60     but less than 90           calendar days or
                           reason why.                                     but less than 60         calendar days or       calendar days. OR          longer.
                                                                           calendar days.           longer but less than   The Planning               OR
                                                                                                    75 calendar days.      Authority’s response to    The Planning
                                                                                                                           documented technical       Authority’s response
                                                                                                                           comments on its SOL        to documented
                                                                                                                           Methodology indicated      technical comments on
                                                                                                                           that a change will not     its SOL Methodology
                                                                                                                           be made, but did not       did not indicate
                                                                                                                           include an explanation     whether a change will
                                                                                                                           of why the change will     be made to the SOL
                                                                                                                           not be made.               Methodology.
FAC-011-2   R1.            The Reliability Coordinator shall have a        Not applicable.          The Reliability        The Reliability            The Reliability
                           documented methodology for use in                                        Coordinator has a      Coordinator has a          Coordinator has a
                           developing SOLs (SOL Methodology)                                        documented SOL         documented SOL             documented SOL
                           within its Reliability Coordinator Area. This                            Methodology for        Methodology for use in     Methodology for use
                           SOL Methodology shall:                                                   use in developing      developing SOLs            in developing SOLs
                                                                                                    SOLs within its        within its Reliability     within its Reliability
                                                                                                    Reliability            Coordinator Area, but it   Coordinator Area, but
                                                                                                    Coordinator Area,      does not address R1.3.     it does not address
                                                                                                    but it does not                                   R1.1.
                                                                                                    address R1.2                                      OR
                                                                                                                                                      The Reliability
                                                                                                                                                      Coordinator has no
                                                                                                                                                      documented SOL
                                                                                                                                                      Methodology for use
                                                                                                                                                      in developing SOLs
                                                                                                                                                      within its Reliability
                                                                                                                                                      Coordinator Area.
FAC-011-2   R1.1.          Be applicable for developing SOLs used in       Not applicable.          Not applicable.        Not applicable.            The Reliability
                           the operations horizon.                                                                                                    Coordinator’s SOL
                                                                                                                                                      methodology is not
                                                                                                                                                      applicable for
                                                                                                                                                                Page 127
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                         Lower VSL      Moderate VSL          High VSL         Severe VSL
 Number        Number
                                                                                                                                   developing SOL in the
                                                                                                                                   operations horizon.
FAC-011-2   R1.2.          State that SOLs shall not exceed associated       Not applicable.   Not applicable.   Not applicable.   The Reliability
                           Facility Ratings.                                                                                       Coordinator’s SOL
                                                                                                                                   Methodology did not
                                                                                                                                   state that SOLs shall
                                                                                                                                   not exceed associated
                                                                                                                                   Facility Ratings
FAC-011-2   R1.3           Include a description of how to identify the      Not applicable.   Not applicable.   Not applicable.   The Reliability
                           subset of SOLs that qualify as IROLs                                                                    Coordinator’s SOL
                                                                                                                                   Methodology did not
                                                                                                                                   include a description
                                                                                                                                   of how to identify the
                                                                                                                                   subset of SOLs that
                                                                                                                                   qualify as IROLs.
FAC-011-2   R2.            The Reliability Coordinator’s SOL
                           Methodology shall include a requirement
                           that SOLs provide BES performance
                           consistent with the following:
FAC-011-2   R2.1.          In the pre-contingency state, the BES shall       Not applicable.   Not applicable.   Not applicable.   The SOL methodology
                           demonstrate transient, dynamic and voltage                                                              does not include a
                           stability; all Facilities shall be within their                                                         requirement that SOLs
                           Facility Ratings and within their thermal,                                                              provide BES
                           voltage and stability limits. In the                                                                    performance
                           determination of SOLs, the BES condition                                                                consistent with sub-
                           used shall reflect current or expected system                                                           requirement R2.1.
                           conditions and shall reflect changes to
                           system topology such as Facility outages.
FAC-011-2   R2.2.          Following the single Contingencies1               Not applicable.   Not applicable.   Not applicable.   The SOL methodology
                           identified in Requirement 2.2.1 through                                                                 does not include a
                           Requirement 2.2.3, the system shall                                                                     requirement that SOLs
                           demonstrate transient, dynamic and voltage                                                              provide BES
                           stability; all Facilities shall be operating                                                            performance
                           within their Facility Ratings and within                                                                consistent with sub-
                           their thermal, voltage and stability limits;                                                            requirement R2.2.
                           and Cascading or uncontrolled separation
                                                                                                                                             Page 128
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                      Lower VSL      Moderate VSL          High VSL         Severe VSL
 Number        Number
                           shall not occur.
FAC-011-2   R2.2.1.        Single line to ground or 3-phase Fault         Not applicable.   Not applicable.   Not applicable.   The methodology does
                           (whichever is more severe), with Normal                                                              not require that SOLs
                           Clearing, on any Faulted generator, line,                                                            provide BES
                           transformer, or shunt device                                                                         performance
                                                                                                                                consistent with: single
                                                                                                                                line to ground or 3-
                                                                                                                                phase Fault
                                                                                                                                (whichever is more
                                                                                                                                severe), with Normal
                                                                                                                                Clearing, on any
                                                                                                                                Faulted generator,
                                                                                                                                line, transformer, or
                                                                                                                                shunt device.
FAC-011-2   R2.2.2.        Loss of any generator, line, transformer, or   Not applicable.   Not applicable.   Not applicable.   The methodology does
                           shunt device without a Fault.                                                                        not address the loss of
                                                                                                                                any generator, line,
                                                                                                                                transformer, or shunt
                                                                                                                                device without a Fault.
FAC-011-2   R2.2.3.        Single pole block, with Normal Clearing, in    Not applicable.   Not applicable.   Not applicable.   The methodology does
                           a monopolar or bipolar high voltage direct                                                           not address single pole
                           current system.                                                                                      block, with Normal
                                                                                                                                Clearing, in a
                                                                                                                                monopolar or bipolar
                                                                                                                                high voltage direct
                                                                                                                                current system.
FAC-011-2   R2.3.          In determining the system’s response to a      Not applicable.   Not applicable.   Not applicable.   The methodology does
                           single Contingency, the following shall be                                                           not include one or
                           acceptable:                                                                                          more of the following
                                                                                                                                2.3.1. through 2.3.3.
FAC-011-2   R2.3.1.        Planned or controlled interruption of          Not applicable.   Not applicable.   Not applicable.   The methodology does
                           electric supply to radial customers or some                                                          not address that, in
                           local network customers connected to or                                                              determining the
                           supplied by the Faulted Facility or by the                                                           systems response to a
                           affected area.                                                                                       single contingency,
                                                                                                                                Planned or controlled
                                                                                                                                          Page 129
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                         Lower VSL      Moderate VSL          High VSL         Severe VSL
 Number        Number
                                                                                                                                   interruption of electric
                                                                                                                                   supply to radial
                                                                                                                                   customers or some
                                                                                                                                   local network
                                                                                                                                   customers connected
                                                                                                                                   to or supplied by the
                                                                                                                                   Faulted Facility or by
                                                                                                                                   the affected area is
                                                                                                                                   acceptable.
FAC-011-2   R2.3.2.        Interruption of other network customers, (a)      Not applicable.   Not applicable.   Not applicable.   The methodology does
                           only if the system has already been                                                                     not address that, in
                           adjusted, or is being adjusted, following at                                                            determining the
                           least one prior outage, or (b) if the real-time                                                         systems response to a
                           operating conditions are more adverse than                                                              single contingency,
                           anticipated in the corresponding studies                                                                Interruption of other
                                                                                                                                   network customers is
                                                                                                                                   acceptable, (a) only if
                                                                                                                                   the system has already
                                                                                                                                   been adjusted, or is
                                                                                                                                   being adjusted,
                                                                                                                                   following at least one
                                                                                                                                   prior outage, or (b) if
                                                                                                                                   the real-time operating
                                                                                                                                   conditions are more
                                                                                                                                   adverse than
                                                                                                                                   anticipated in the
                                                                                                                                   corresponding studies.
FAC-011-2   R2.3.3.        System reconfiguration through manual or          Not applicable.   Not applicable.   Not applicable.   The methodology does
                           automatic control or protection actions.                                                                not address that, in
                                                                                                                                   determining the
                                                                                                                                   systems response to a
                                                                                                                                   single contingency,
                                                                                                                                   system reconfiguration
                                                                                                                                   through manual or
                                                                                                                                   automatic control or
                                                                                                                                   protection actions is
                                                                                                                                   acceptable.

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Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                     Lower VSL             Moderate VSL              High VSL                  Severe VSL
 Number        Number
FAC-011-2   R2.4.          To prepare for the next Contingency,          Not applicable.          Not applicable.       Not applicable.            The methodology does
                           system adjustments may be made, including                                                                               not provide that to
                           changes to generation, uses of the                                                                                      prepare for the next
                           transmission system, and the transmission                                                                               Contingency, system
                           system topology.                                                                                                        adjustments may be
                                                                                                                                                   made, including
                                                                                                                                                   changes to generation,
                                                                                                                                                   uses of the
                                                                                                                                                   transmission system,
                                                                                                                                                   and the transmission
                                                                                                                                                   system topology.
FAC-011-2   R3.            The Reliability Coordinator’s methodology     The Reliability          The Reliability       The Reliability            The Reliability
                           for determining SOLs, shall include, as a     Coordinator has a        Coordinator has a     Coordinator has a          Coordinator has a
                           minimum, a description of the following,      methodology for          methodology for       methodology for            methodology for
                           along with any reliability margins applied    determining SOLs that    determining SOLs      determining SOLs that      determining SOLs that
                           for each:                                     includes a description   that includes a       includes a description     is missing a
                                                                         for all but one of the   description for all   for all but three of the   description of four or
                                                                         following: R3.1          but two of the        following: R3.1 through    more of the following:
                                                                         through R3.7.            following: R3.1       R3.7.                      R3.1 through R3.7.
                                                                                                  through R3.7.
FAC-011-2   R3.1.          Study model (must include at least the        Not applicable.          Not applicable.       Not applicable.            The methodology does
                           entire Reliability Coordinator Area as well                                                                             not include a
                           as the critical modeling details from other                                                                             description of the
                           Reliability Coordinator Areas that would                                                                                study model to be used
                           impact the Facility or Facilities under                                                                                 which must include
                           study.)                                                                                                                 the entire Reliability
                                                                                                                                                   Coordinator area, and
                                                                                                                                                   the critical details of
                                                                                                                                                   other Reliability
                                                                                                                                                   Coordinator areas that
                                                                                                                                                   would impact the
                                                                                                                                                   facility or facilities
                                                                                                                                                   under study
FAC-011-2   R3.2.          Selection of applicable Contingencies         Not applicable.          Not applicable.       Not applicable.            The methodology does
                                                                                                                                                   not include the
                                                                                                                                                   selection of applicable
                                                                                                                                                   Contingencies.
                                                                                                                                                             Page 131
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL      Moderate VSL          High VSL         Severe VSL
 Number        Number
FAC-011-2   R3.3.          A process for determining which of the          Not applicable.   Not applicable.   Not applicable.   The methodology does
                           stability limits associated with the list of                                                          not include a
                           multiple contingencies (provided by the                                                               description of a
                           Planning Authority in accordance with                                                                 process for
                           FAC-014 Requirement 6) are applicable for                                                             determining which of
                           use in the operating horizon given the actual                                                         the stability limits
                           or expected system conditions.                                                                        associated with the list
                                                                                                                                 of multiple
                                                                                                                                 contingencies
                                                                                                                                 (provided by the
                                                                                                                                 Planning Authority in
                                                                                                                                 accordance with FAC-
                                                                                                                                 014 Requirement 6)
                                                                                                                                 are applicable for use
                                                                                                                                 in the operating
                                                                                                                                 horizon given the
                                                                                                                                 actual or expected
                                                                                                                                 system conditions.
FAC-011-2   R3.3.1.        This process shall address the need to          Not applicable.   Not applicable.   Not applicable.   The methodology for
                           modify these limits, to modify the list of                                                            determining SOL's
                           limits, and to modify the list of associated                                                          does not address the
                           multiple contingencies                                                                                need to modify the
                                                                                                                                 limits described in
                                                                                                                                 R3.3, the list of limits,
                                                                                                                                 or the list of
                                                                                                                                 associated multiple
                                                                                                                                 contingencies.
FAC-011-2   R3.4.          Level of detail of system models used to        Not applicable.   Not applicable.   Not applicable.   Methodology does not
                           determine SOLs.                                                                                       describe the level of
                                                                                                                                 detail of system
                                                                                                                                 models used to
                                                                                                                                 determine SOLs.
FAC-011-2   R3.5.          Allowed uses of Special Protection Systems      Not applicable.   Not applicable.   Not applicable.   The methodology does
                           or Remedial Action Plans.                                                                             not describe the
                                                                                                                                 allowed uses of
                                                                                                                                 Special Protection
                                                                                                                                 Systems or Remedial
                                                                                                                                            Page 132
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                     Lower VSL              Moderate VSL               High VSL                  Severe VSL
 Number        Number
                                                                                                                                                     Action Plans.
FAC-011-2   R3.6.          Not applicable.                               Not applicable.           Not applicable.        The methodology does
                                                                                                                          not describe the
                                                                                                                          anticipated transmission
                                                                                                                          system configuration,
                                                                                                                          generation dispatch and
                                                                                                                          Load level.
FAC-011-2   R3.7.          Criteria for determining when violating a     Not applicable.           Not applicable.        Not applicable.            The methodology does
                           SOL qualifies as an Interconnection                                                                                       not describe criteria
                           Reliability Operating Limit (IROL) and                                                                                    for determining when
                           criteria for developing any associated IROL                                                                               violating a SOL
                           Tv.                                                                                                                       qualifies as an
                                                                                                                                                     Interconnection
                                                                                                                                                     Reliability Operating
                                                                                                                                                     Limit and criteria for
                                                                                                                                                     developing any
                                                                                                                                                     associated IROL Tv.
FAC-011-2   R4             The Reliability Coordinator shall issue its   One or both of the        One of the two         One of the following :     One of the following:
                           SOL Methodology and any changes to that       following :               following :            The Reliability            The Reliability
                           methodology, prior to the effectiveness of    The Reliability           The Reliability        Coordinator issued its     Coordinator failed to
                           the Methodology or of a change to the         Coordinator issued its    Coordinator issued     SOL Methodology and        issue its SOL
                           Methodology, to all of the following:         SOL Methodology and       its SOL                changes to that            Methodology and
                                                                         changes to that           Methodology and        methodology to all but     changes to that
                                                                         methodology to all but    changes to that        one of the required        methodology to more
                                                                         one of the required       methodology to all     entities AND for a         than three of the
                                                                         entities.                 but one of the         change in methodology,     required entities.
                                                                         For a change in           required entities      the changed                The Planning
                                                                         methodology, the          AND for a change       methodology was            Authority issued its
                                                                         changed methodology       in methodology, the    provided 60 calendar       SOL Methodology and
                                                                         was provided up to 30     changed                days or more, but less     changes to that
                                                                         calendar days after the   methodology was        than 90 calendar days      methodology to all but
                                                                         effectiveness of the      provided 30            after the effectiveness    one of the required
                                                                         change.                   calendar days or       of the change. OR          entities AND for a
                                                                                                   more, but less than    The Reliability            change in
                                                                                                   60 calendar days       Coordinator issued its     methodology, the
                                                                                                   after the              SOL Methodology and        changed methodology
                                                                                                   effectiveness of the   changes to that            was provided 90
                                                                                                                                                               Page 133
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
Standard   Requirement
                         Text of Requirement   Lower VSL     Moderate VSL               High VSL                 Severe VSL
Number       Number
                                                           change. OR             methodology to all but    calendar days or more
                                                           The Reliability        two of the required       after the effectiveness
                                                           Coordinator issued     entities AND for a        of the change.
                                                           its SOL                change in methodology,    OR
                                                           Methodology and        the changed
                                                                                                            The Reliability
                                                           changes to that        methodology was
                                                                                                            Coordinator issued its
                                                           methodology to all     provided 30 calendar
                                                                                                            SOL Methodology and
                                                           but two of the         days or more, but less
                                                                                                            changes to that
                                                           required entities      than 60 calendar days
                                                                                                            methodology to all but
                                                           AND for a change       after the effectiveness
                                                                                                            two of the required
                                                           in methodology, the    of the change. OR
                                                                                                            entities AND for a
                                                           changed                The Reliability           change in
                                                           methodology was        Coordinator issued its    methodology, the
                                                           provided up to 30      SOL Methodology and       changed methodology
                                                           calendar days after    changes to that           was provided 60
                                                           the effectiveness of   methodology to all but    calendar days or more,
                                                           the change.            three of the required     but less than 90
                                                                                  entities AND for a        calendar days after the
                                                                                  change in methodology,    effectiveness of the
                                                                                  the changed               change.
                                                                                  methodology was
                                                                                                            OR
                                                                                  provided up to 30
                                                                                  calendar days after the   The Reliability
                                                                                  effectiveness of the      Coordinator issued its
                                                                                  change.                   SOL Methodology and
                                                                                                            changes to that
                                                                                                            methodology to all but
                                                                                                            three of the required
                                                                                                            entities AND for a
                                                                                                            change in
                                                                                                            methodology, the
                                                                                                            changed methodology
                                                                                                            was provided 30
                                                                                                            calendar days or more,
                                                                                                            but less than 60
                                                                                                            calendar days after the
                                                                                                            effectiveness of the
                                                                                                            change.

                                                                                                                      Page 134
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                     Lower VSL      Moderate VSL          High VSL         Severe VSL
 Number        Number
                                                                                                                               OR
                                                                                                                               The Reliability
                                                                                                                               Coordinator issued its
                                                                                                                               SOL Methodology and
                                                                                                                               changes to that
                                                                                                                               methodology to all but
                                                                                                                               four of the required
                                                                                                                               entities AND for a
                                                                                                                               change in
                                                                                                                               methodology, the
                                                                                                                               changed methodology
                                                                                                                               was provided up to 30
                                                                                                                               calendar days after the
                                                                                                                               effectiveness of the
                                                                                                                               change
FAC-011-2   R4.1.          Each adjacent Reliability Coordinator and     Not applicable.   Not applicable.   Not applicable.   The Reliability
                           each Reliability Coordinator that indicated                                                         Coordinator did not
                           it has a reliability-related need for the                                                           issue its SOL
                           methodology.                                                                                        Methodology or any
                                                                                                                               changes to that
                                                                                                                               methodology to each
                                                                                                                               adjacent Reliability
                                                                                                                               Coordinator and each
                                                                                                                               Reliability
                                                                                                                               Coordinator that
                                                                                                                               indicated it has a
                                                                                                                               reliability-related need
                                                                                                                               for the methodology.
FAC-011-2   R4.2.          Each Planning Authority and Transmission      Not applicable.   Not applicable.   Not applicable.   The Reliability
                           Planner that models any portion of the                                                              Coordinator did not
                           Reliability Coordinator’s Reliability                                                               issue its SOL
                           Coordinator Area.                                                                                   Methodology or any
                                                                                                                               changes to that
                                                                                                                               methodology to each
                                                                                                                               Planning Authority or
                                                                                                                               Transmission Planner
                                                                                                                               that models any
                                                                                                                               portion of the
                                                                                                                                          Page 135
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL             Moderate VSL               High VSL                Severe VSL
 Number        Number
                                                                                                                                                     Reliability
                                                                                                                                                     Coordinator’s
                                                                                                                                                     Reliability
                                                                                                                                                     Coordinator Area.

FAC-011-2   R4.3.          Each Transmission Operator that operates in     Not applicable.          Not applicable.        Not applicable.           The Reliability
                           the Reliability Coordinator Area.                                                                                         Coordinator did not
                                                                                                                                                     issue its SOL
                                                                                                                                                     Methodology or any
                                                                                                                                                     changes to that
                                                                                                                                                     methodology to each
                                                                                                                                                     Transmission Operator
                                                                                                                                                     that operates in the
                                                                                                                                                     Reliability
                                                                                                                                                     Coordinator Area.
FAC-011-2   R5.            If a recipient of the SOL Methodology           The Reliability          The Reliability        The Reliability            The Reliability
                           provides documented technical comments          Coordinator received     Coordinator            Coordinator received      Coordinator received
                           on the methodology, the Reliability             documented technical     received               documented technical      documented technical
                           Coordinator shall provide a documented          comments on its SOL      documented             comments on its SOL       comments on its SOL
                           response to that recipient within 45 calendar   Methodology and          technical comments     Methodology and           Methodology and
                           days of receipt of those comments. The          provided a complete      on its SOL             provided a complete       provided a complete
                           response shall indicate whether a change        response in a time       Methodology and        response in a time        response in a time
                           will be made to the SOL Methodology and,        period that was longer   provided a complete    period that was 75        period that was 90
                           if no change will be made to that SOL           than 45 calendar days    response in a time     calendar days or longer   calendar days or
                           Methodology, the reason why.                    but less than 60         period that was 60     but less than 90          longer.
                                                                           calendar days.           calendar days or       calendar days. OR         OR
                                                                                                    longer but less than   The Reliability           The Reliability
                                                                                                    75 calendar days.      Coordinator’s response    Coordinator’s
                                                                                                                           to documented             response to
                                                                                                                           technical comments on     documented technical
                                                                                                                           its SOL Methodology       comments on its SOL
                                                                                                                           indicated that a change   Methodology did not
                                                                                                                           will not be made, but     indicate whether a
                                                                                                                           did not include an        change will be made
                                                                                                                           explanation of why the    to the SOL
                                                                                                                           change will not be        Methodology.
                                                                                                                           made.

                                                                                                                                                              Page 136
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                        Lower VSL               Moderate VSL                High VSL                  Severe VSL
 Number        Number
FAC-013-1   R1.            The Reliability Coordinator and Planning         The Reliability            The Reliability         The Reliability            The Reliability
                           Authority shall each establish a set of inter-   Coordinator or             Coordinator or          Coordinator or             Coordinator or
                           regional and intra-regional Transfer             Planning Authority         Planning Authority      Planning Authority has     Planning Authority
                           Capabilities that is consistent with its         has established a set of   has established a set   established a set of       has established a set of
                           current Transfer Capability Methodology.         Transfer Capabilities,     of Transfer             Transfer Capabilities,     Transfer Capabilities,
                                                                            but one or more            Capabilities, but       but more than 50% of       but more than 75% of
                                                                            Transfer Capabilities,     more than 25% of        those Transfer             those Transfer
                                                                            but not more than 25%      those Transfer          Capabilities, but not      Capabilities are not
                                                                            of all Transfer            Capabilities, but not   more than 75% of all       consistent with the
                                                                            Capabilities required      more than 50% of        Transfer Capabilities      current Transfer
                                                                            to be established, are     all Transfer            required to be             Capability
                                                                            not consistent with the    Capabilities required   established, are not       Methodology
                                                                            current Transfer           to be established,      consistent with the        OR
                                                                            Capability                 are not consistent      current Transfer
                                                                                                                                                          The Reliability
                                                                            Methodology.               with the current        Capability
                                                                                                                                                          Coordinator or
                                                                                                       Transfer Capability     Methodology.
                                                                                                                                                          Planning Authority
                                                                                                       Methodology.
                                                                                                                                                          has not established a
                                                                                                                                                          set of Transfer
                                                                                                                                                          Capabilities.
FAC-013-1   R2.            The Reliability Coordinator and Planning         The Reliability            The Reliability         The Reliability            The Reliability
                           Authority shall each provide its inter-          Coordinator or             Coordinator or          Coordinator or             Coordinator or
                           regional and intra-regional Transfer             Planning Authority         Planning Authority      Planning Authority has     Planning Authority
                           Capabilities to those entities that have a       has provided its           has provided its        provided its Transfer      has provided its
                           reliability-related need for such Transfer       Transfer Capabilities      Transfer                Capabilities but missed    Transfer Capabilities
                           Capabilities and make a written request that     but missed meeting         Capabilities but        meeting more than two      but missed meeting all
                           includes a schedule for delivery of such         one schedule by up to      missed meeting two      schedules.                 schedules within 30
                           Transfer Capabilities as follows:                15 calendar days.          schedules.                                         calendar days of the
                                                                                                                                                          associated schedules.
FAC-013-1   R2.1.          The Reliability Coordinator shall provide its    Not applicable.            The Reliability         The Reliability            The Reliability
                           Transfer Capabilities to its associated                                     Coordinator             Coordinator failed to      Coordinator provided
                           Regional Reliability Organization(s), to its                                provided its            provide its Transfer       its Transfer
                           adjacent Reliability Coordinators, and to the                               Transfer                Capabilities to more       Capabilities to none of
                           Transmission Operators, Transmission                                        Capabilities to all     than one of the required   the required entities.
                           Service Providers and Planning Authorities                                  but one of the          entities.
                           that work in its Reliability Coordinator                                    required entities.
                           Area.


                                                                                                                                                                    Page 137
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL              Moderate VSL                 High VSL                  Severe VSL
 Number        Number
FAC-013-1   R2.2.          The Planning Authority shall provide its        Not applicable.           The Planning             The Planning Authority     The Planning
                           Transfer Capabilities to its associated                                   Authority provided       failed to provide its      Authority provided its
                           Reliability Coordinator(s) and Regional                                   its Transfer             Transfer Capabilities to   Transfer Capabilities
                           Reliability Organization(s), and to the                                   Capabilities to all      more than one of the       to none of the required
                           Transmission Planners and Transmission                                    but one of the           required entities.         entities.
                           Service Provider(s) that work in its                                      required entities.
                           Planning Authority Area.
FAC-014-2   R1.            The Reliability Coordinator shall ensure        There are SOLs, for       There are SOLs, for      There are SOLs, for the    There are SOLs for the
                           that SOLs, including Interconnection            the Reliability           the Reliability          Reliability Coordinator    Reliability
                           Reliability Operating Limits (IROLs), for       Coordinator Area, but     Coordinator Area,        Area, but 50% or more,     Coordinator Area, but
                           its Reliability Coordinator Area are            from 1% up to but less    but 25% or more,         but less than 75% of       one or more of these
                           established and that the SOLs (including        than 25% of these         but less than 50% of     these SOLs are             the SOLs are
                           Interconnection Reliability Operating           SOLs are inconsistent     these SOLs are           inconsistent with the      inconsistent with the
                           Limits) are consistent with its SOL             with the Reliability      inconsistent with the    Reliability                Reliability
                           Methodology.                                    Coordinator’s SOL         Reliability              Coordinator’s SOL          Coordinator’s SOL
                                                                           Methodology. (R1)         Coordinator’s SOL        Methodology. (R1)          Methodology. (R1)
                                                                                                     Methodology. (R1)
FAC-014-2   R2.            The Transmission Operator shall establish       The Transmission          The Transmission         The Transmission           The Transmission
                           SOLs (as directed by its Reliability            Operator has              Operator has             Operator has               Operator has
                           Coordinator) for its portion of the             established SOLs for      established SOLs         established SOLs for its   established SOLs for
                           Reliability Coordinator Area that are           its portion of the        for its portion of the   portion of the             its portion of the
                           consistent with its Reliability Coordinator’s   Reliability               Reliability              Reliability Coordinator    Reliability
                           SOL Methodology                                 Coordinator Area, but     Coordinator Area,        Area, but 50% or more,     Coordinator Area, but
                                                                           from 1% up to but less    but 25% or more,         but less than 75% of       75% or more of these
                                                                           than 25% of these         but less than 50% of     these SOLs are             SOLs are inconsistent
                                                                           SOLs are inconsistent     these SOLs are           inconsistent with the      with the Reliability
                                                                           with the Reliability      inconsistent with the    Reliability                Coordinator’s SOL
                                                                           Coordinator’s SOL         Reliability              Coordinator’s SOL          Methodology. (R2)
                                                                           Methodology. (R2)         Coordinator’s SOL        Methodology. (R2)
                                                                                                     Methodology. (R2)
FAC-014-2   R3.            The Planning Authority shall establish          There are SOLs, for       There are SOLs, for      There are Sols for the     There are SOLs, for
                           SOLs, including IROLs, for its Planning         the Planning              the Planning             Planning Coordinator       the Planning
                           Authority Area that are consistent with its     Coordinator Area, but     Coordinator Area,        Area, but 10% or more,     Coordinator Area, but
                           SOL Methodology                                 from 1% up to, but        but 25% or more,         but less than 75% of       75% or more of these
                                                                           less than, 25% of these   but less than 50% of     these SOLs are             SOLs are inconsistent
                                                                           SOLs are inconsistent     these SOLs are           inconsistent with the      with the Planning
                                                                           with the Planning         inconsistent with the    Planning Coordinator’s     Coordinator’s SOL
                                                                                                                                                                   Page 138
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                       Lower VSL             Moderate VSL                 High VSL                  Severe VSL
 Number        Number
                                                                           Coordinator’s SOL        Planning                 SOL Methodology.           Methodology. (R3)
                                                                           Methodology. (R3)        Coordinator’s SOL        (R3)
                                                                                                    Methodology. (R3)
FAC-014-2   R4.            The Transmission Planner shall establish        The Transmission         The Transmission         The Transmission           The Transmission
                           SOLs, including IROLs, for its                  Planner has              Planner has              Planner has established    Planner has
                           Transmission Planning Area that are             established SOLs for     established SOLs         SOLs for its portion of    established SOLs for
                           consistent with its Planning Authority’s        its portion of the       for its portion of the   the Reliability            its portion of the
                           SOL Methodology.                                Planning Coordinator     Planning                 Coordinator Area, but      Planning Coordinator
                                                                           Area, but up to 25% of   Coordinator Area,        50% or more, but less      Area, but one or more
                                                                           these SOLs are           but 25% or more,         than 75% of these          of these SOLs are
                                                                           inconsistent with the    but less than 50% of     SOLs are inconsistent      inconsistent with the
                                                                           Planning                 these SOLs are           with the Planning          Planning
                                                                           Coordinator’s SOL        inconsistent with the    Coordinator’s SOL          Coordinator’s SOL
                                                                           Methodology. (R4)        Planning                 Methodology. (R4)          Methodology. (R4)
                                                                                                    Coordinator’s SOL
                                                                                                    Methodology. (R4)
FAC-014-2   R5.            The Reliability Coordinator, Planning           The responsible entity   One of the               One of the following:      One of the following:
                           Authority and Transmission Planner shall        provided its SOLs to     following:               The responsible entity     The responsible entity
                           each provide its SOLs and IROLs to those        all the requesting       The responsible          provided its SOLs to all   failed to provide its
                           entities that have a reliability-related need   entities but missed      entity provided its      but two of the             SOLs to more than
                           for those limits and provide a written          meeting one or more      SOLs to all but one      requesting entities        two of the requesting
                           request that includes a schedule for delivery   of the schedules by      of the requesting        within the schedules       entities within 45
                           of those limits as follows                      less than 15 calendar    entities within the      provided. (R5)             calendar days of the
                                                                           days. (R5)               schedules provided.                                 associated schedules.
                                                                                                                             OR
                                                                                                    (R5)                                                (R5)
                                                                                                                             The responsible entity
                                                                                                    OR                       provided its SOLs to all   OR
                                                                                                    The responsible          the requesting entities    The supporting
                                                                                                    entity provided its      but missed meeting one     information provided
                                                                                                    SOLs to all the          or more of the             with the IROLs does
                                                                                                    requesting entities      schedules for 30 or        not address 5.1.1 and
                                                                                                    but missed meeting       more but less than 45      5.1.2.
                                                                                                    one or more of the       calendar days. (R5)
                                                                                                    schedules for 15 or      OR
                                                                                                    more but less than
                                                                                                                             The supporting
                                                                                                    30 calendar days.
                                                                                                                             information provided
                                                                                                    (R5)
                                                                                                                             with the IROLs does
                                                                                                    OR
                                                                                                                                                                  Page 139
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                       Text of Requirement                        Lower VSL      Moderate VSL            High VSL           Severe VSL
 Number        Number
                                                                                               The supporting      not address 5.1.3
                                                                                               information
                                                                                               provided with the
                                                                                               IROLs does not
                                                                                               address 5.1.4
FAC-014-2   R5.1.          The Reliability Coordinator shall provide its     Not applicable.   Not applicable.     Not applicable.     The Reliability
                           SOLs (including the subset of SOLs that are                                                                 Coordinator did not
                           IROLs) to adjacent Reliability Coordinators                                                                 provide its SOLs
                           and Reliability Coordinators who indicate a                                                                 (including the subset
                           reliability-related need for those limits, and                                                              of SOLs that are
                           to the Transmission Operators,                                                                              IROLs) to adjacent
                           Transmission Planners, Transmission                                                                         Reliability
                           Service Providers and Planning Authorities                                                                  Coordinators and
                           within its Reliability Coordinator Area. For                                                                Reliability
                           each IROL, the Reliability Coordinator                                                                      Coordinators who
                           shall provide the following supporting                                                                      indicate a reliability-
                           information                                                                                                 related need for those
                                                                                                                                       limits, and to the
                                                                                                                                       Transmission
                                                                                                                                       Operators,
                                                                                                                                       Transmission
                                                                                                                                       Planners,
                                                                                                                                       Transmission Service
                                                                                                                                       Providers and
                                                                                                                                       Planning Authorities
                                                                                                                                       within its Reliability
                                                                                                                                       Coordinator Area.
FAC-014-2   R5.1.1.        Identification and status of the associated       Not applicable.   Not applicable.     Not applicable.     For any IROL, the
                           Facility (or group of Facilities) that is (are)                                                             Reliability
                           critical to the derivation of the IROL                                                                      Coordinator did not
                                                                                                                                       provide the
                                                                                                                                       Identification and
                                                                                                                                       status of the associated
                                                                                                                                       Facility (or group of
                                                                                                                                       Facilities) that is (are)
                                                                                                                                       critical to the
                                                                                                                                       derivation of the
                                                                                                                                       IROL.
                                                                                                                                                  Page 140
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                     Lower VSL      Moderate VSL          High VSL         Severe VSL
 Number        Number
FAC-014-2   R5.1.2.        The value of the IROL and its associated      Not applicable.   Not applicable.   Not applicable.   For any IROL, the
                           Tv.                                                                                                 Reliability
                                                                                                                               Coordinator did not
                                                                                                                               provide the value of
                                                                                                                               the IROL and its
                                                                                                                               associated Tv.
FAC-014-2   R5.1.3.        The associated Contingency (ies).             Not applicable.   Not applicable.   Not applicable.   For any IROL, the
                                                                                                                               Reliability
                                                                                                                               Coordinator did not
                                                                                                                               provide the associated
                                                                                                                               Contingency(ies).
FAC-014-2   R5.1.4.        The type of limitation represented by the     Not applicable.   Not applicable.   Not applicable.   For any IROL, the
                           IROL (e.g., voltage collapse, angular                                                               Reliability
                           stability).                                                                                         Coordinator did not
                                                                                                                               provide the type of
                                                                                                                               limitation represented
                                                                                                                               by the IROL (e.g.,
                                                                                                                               voltage collapse,
                                                                                                                               angular stability).
FAC-014-2   R5.2.          The Transmission Operator shall provide       Not applicable.   Not applicable.   Not applicable.   The Transmission
                           any SOLs it developed to its Reliability                                                            Operator did not
                           Coordinator and to the Transmission                                                                 provide the complete
                           Service Providers that share its portion of                                                         set of SOLs it
                           the Reliability Coordinator Area.                                                                   developed to its
                                                                                                                               Reliability
                                                                                                                               Coordinator and to the
                                                                                                                               Transmission Service
                                                                                                                               Providers that share its
                                                                                                                               portion of the
                                                                                                                               Reliability
                                                                                                                               Coordinator Area.
FAC-014-2   R5.3.          The Planning Authority shall provide its      Not applicable.   Not applicable.   Not applicable.   The Planning
                           SOLs (including the subset of SOLs that are                                                         Authority did not
                           IROLs) to adjacent Planning Authorities,                                                            provide its complete
                           and to Transmission Planners, Transmission                                                          set of SOLs (including
                           Service Providers, Transmission Operators                                                           the subset of SOLs

                                                                                                                                         Page 141
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                      Text of Requirement                     Lower VSL      Moderate VSL          High VSL         Severe VSL
 Number        Number
                           and Reliability Coordinators that work                                                              that are IROLs) to
                           within its Planning Authority Area.                                                                 adjacent Planning
                                                                                                                               Authorities, and to
                                                                                                                               Transmission
                                                                                                                               Planners,
                                                                                                                               Transmission Service
                                                                                                                               Providers,
                                                                                                                               Transmission
                                                                                                                               Operators and
                                                                                                                               Reliability
                                                                                                                               Coordinators that
                                                                                                                               work within its
                                                                                                                               Planning Authority
                                                                                                                               Area.
FAC-014-2   R5.4.          The Transmission Planner shall provide its    Not applicable.   Not applicable.   Not applicable.   The Transmission
                           SOLs (including the subset of SOLs that are                                                         Planner did not
                           IROLs) to its Planning Authority,                                                                   provide its complete
                           Reliability Coordinators, Transmission                                                              set of SOLs (including
                           Operators, and Transmission Service                                                                 the subset of SOLs
                           Providers that work within its Transmission                                                         that are IROLs) to its
                           Planning Area and to adjacent Transmission                                                          Planning Authority,
                           Planners.                                                                                           Reliability
                                                                                                                               Coordinators,
                                                                                                                               Transmission
                                                                                                                               Operators, and
                                                                                                                               Transmission Service
                                                                                                                               Providers that work
                                                                                                                               within its
                                                                                                                               Transmission Planning
                                                                                                                               Area and to adjacent
                                                                                                                               Transmission
                                                                                                                               Planners.
FAC-014-2   R6.            The Planning Authority shall identify the     Not applicable.   Not applicable.   Not applicable.   The Planning
                           subset of multiple contingencies (if any),                                                          Authority did not
                           from Reliability Standard TPL-003 which                                                             identify the subset of
                           result in stability limits.                                                                         multiple contingencies
                                                                                                                               which result in
                                                                                                                               stability limits. (R6)
                                                                                                                                         Page 142
Complete Violation Severity Level Matrix (FAC)
Encompassing All Commission-Approved Reliability Standards
 Standard    Requirement
                                       Text of Requirement                       Lower VSL      Moderate VSL          High VSL         Severe VSL
 Number        Number
FAC-014-2   R6.1.          The Planning Authority shall provide this        Not applicable.   Not applicable.   Not applicable.   The Planning
                           list of multiple contingencies and the                                                                 Authority did not
                           associated stability limits to the Reliability                                                         identify the subset of
                           Coordinators that monitor the facilities                                                               multiple
                           associated with these contingencies and                                                                contingencies, from
                           limits.                                                                                                TPL-003 that resulted
                                                                                                                                  in stability limits and
                                                                                                                                  provide the complete
                                                                                                                                  list of multiple
                                                                                                                                  contingencies and the
                                                                                                                                  associated stability
                                                                                                                                  limits to the Reliability
                                                                                                                                  Coordinators that
                                                                                                                                  monitor the facilities
                                                                                                                                  associated with these
                                                                                                                                  contingencies and
                                                                                                                                  limits.
FAC-014-2   R6.2.          If the Planning Authority does not identify      Not applicable.   Not applicable.   Not applicable.   The Planning
                           any stability-related multiple contingencies,                                                          Authority did not
                           the Planning Authority shall so notify the                                                             notify the Reliability
                           Reliability Coordinator.                                                                               Coordinator that it did
                                                                                                                                  not identify any
                                                                                                                                  stability-related
                                                                                                                                  multiple
                                                                                                                                  contingencies,




                                                                                                                                             Page 143
Complete Violation Severity Level Matrix (INT)
Encompassing All Commission-Approved Reliability Standards
Standard     Requirement
                                      Text of Requirement                       Lower VSL              Moderate VSL                 High VSL                Severe VSL
Number         Number
INT-001-3   R1.            The Load-Serving, Purchasing-Selling Entity     The Load-Serving,         The Load-Serving,        The Load-Serving,        The Load-Serving,
                           shall ensure that Arranged Interchange is       Purchasing-Selling        Purchasing-Selling       Purchasing-Selling       Purchasing-Selling
                           submitted to the Interchange Authority for:     Entity experienced one    Entity experienced       Entity experienced       Entity experienced
                                                                           instance of failing to    two instances of         three instances of       four instances of
                                                                           ensure that Arranged      failing to ensure that   failing to ensure that   failing to ensure that
                                                                           Interchange was           Arranged                 Arranged Interchange     Arranged Interchange
                                                                           submitted to the          Interchange was          was submitted to the     was submitted to the
                                                                           Interchange Authority     submitted to the         Interchange Authority    Interchange Authority
                                                                           for: (see below)          Interchange              for: (see below)         for: (see below)
                                                                                                     Authority for: (see
                                                                                                     below)
INT-001-3   R1.1.          All Dynamic Schedules at the expected           The Load-Serving,         The Load-Serving,        The Load-Serving,        The Load-Serving,
                           average MW profile for each hour.               Purchasing-Selling        Purchasing-Selling       Purchasing-Selling       Purchasing-Selling
                                                                           Entity experienced one    Entity experienced       Entity experienced       Entity experienced
                                                                           instance of failing to    two instances of         three instances of       four instances of
                                                                           ensure that Arranged      failing to ensure that   failing to ensure that   failing to ensure that
                                                                           Interchange was           Arranged                 Arranged Interchange     Arranged Interchange
                                                                           submitted to the          Interchange was          was submitted to the     was submitted to the
                                                                           Interchange Authority     submitted to the         Interchange Authority    Interchange Authority
                                                                           for all Dynamic           Interchange              for all Dynamic          for all Dynamic
                                                                           Schedules at the          Authority for all        Schedules at the         Schedules at the
                                                                           expected average MW       Dynamic Schedules        expected average MW      expected average MW
                                                                           profile for each hour.    at the expected          profile for each hour.   profile for each hour.
                                                                                                     average MW profile
                                                                                                     for each hour.
INT-001-3   R2.            The Sink Balancing Authority shall ensure       The Sink Balancing        The Sink Balancing       The Sink Balancing       The Sink Balancing
                           that Arranged Interchange is submitted to the   Authority experienced     Authority                Authority experienced    Authority experienced
                           Interchange Authority:                          one instance of failing   experienced two          three instances of       four instances of
                                                                           to ensure that            instances of failing     failing to ensure that   failing to ensure that
                                                                           Arranged Interchange      to ensure that           Arranged Interchange     Arranged Interchange
                                                                           was submitted to the      Arranged                 was submitted to the     was submitted to the
                                                                           Interchange Authority     Interchange was          Interchange Authority    Interchange Authority
                                                                           (see below)               submitted to the         (see below)              (see below)
                                                                                                     Interchange
                                                                                                     Authority (see
                                                                                                     below)
                                                                                                                                                                  Page 144
Complete Violation Severity Level Matrix (INT)
Encompassing All Commission-Approved Reliability Standards
Standard     Requirement
                                       Text of Requirement                       Lower VSL              Moderate VSL                High VSL                  Severe VSL
Number         Number
INT-001-3   R2.1.          If a Purchasing-Selling Entity is not involved   The Sink Balancing        The Sink Balancing      The Sink Balancing         The Sink Balancing
                           in the Interchange, such as delivery from a      Authority experienced     Authority               Authority experienced      Authority experienced
                           jointly owned generator.                         one instance of failing   experienced two         three instances of         four instances of
                                                                            to ensure that            instances of failing    failing to ensure that     failing to ensure that
                                                                            Arranged Interchange      to ensure that          Arranged Interchange       Arranged Interchange
                                                                            was submitted to the      Arranged                was submitted to the       was submitted to the
                                                                            Interchange Authority     Interchange was         Interchange Authority if   Interchange Authority
                                                                            if a Purchasing-Selling   submitted to the        a Purchasing-Selling       if a Purchasing-Selling
                                                                            Entity was not            Interchange             Entity was not involved    Entity was not
                                                                            involved in the           Authority if a          in the Interchange, such   involved in the
                                                                            Interchange, such as      Purchasing-Selling      as delivery from a         Interchange, such as
                                                                            delivery from a jointly   Entity was not          jointly owned              delivery from a jointly
                                                                            owned generator.          involved in the         generator.                 owned generator.
                                                                                                      Interchange, such as
                                                                                                      delivery from a
                                                                                                      jointly owned
                                                                                                      generator.
INT-001-3   R2.2.          For each bilateral Inadvertent Interchange       The Sink Balancing        The Sink Balancing      The Sink Balancing         The Sink Balancing
                           payback.                                         Authority experienced     Authority               Authority experienced      Authority experienced
                                                                            one instance of failing   experienced two         three instances of         four instances of
                                                                            to ensure that            instances of failing    failing to ensure that     failing to ensure that
                                                                            Arranged Interchange      to ensure that          Arranged Interchange       Arranged Interchange
                                                                            was submitted to the      Arranged                was submitted to the       was submitted to the
                                                                            Interchange Authority     Interchange was         Interchange Authority      Interchange Authority
                                                                            for each bilateral        submitted to the        for each bilateral         for each bilateral
                                                                            Inadvertent               Interchange             Inadvertent Interchange    Inadvertent
                                                                            Interchange payback.      Authority for each      payback.                   Interchange payback.
                                                                                                      bilateral Inadvertent
                                                                                                      Interchange
                                                                                                      payback.
INT-003-2   R1.            Each Receiving Balancing Authority shall         There shall be a          There shall be a        There shall be a           There shall be a
                           confirm Interchange Schedules with the           separate Lower VSL,       separate Moderate       separate High VSL, if      separate Severe VSL,
                           Sending Balancing Authority prior to             if either of the          VSL, if either of the   either of the following    if either of the
                           implementation in the Balancing Authority’s      following conditions      following conditions    conditions exists: Three   following conditions
                           ACE equation.                                    exists: One instance of   exists: Two             instances of entering a    exists: Four or more
                                                                            entering a schedule       instances of entering   schedule into its ACE      instances of entering a
                                                                            into its ACE equation     a schedule into its     equation without           schedule into its ACE
                                                                            without confirming the    ACE equation            confirming the schedule    equation without
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Complete Violation Severity Level Matrix (INT)
Encompassing All Commission-Approved Reliability Standards
Standard     Requirement
                                      Text of Requirement                      Lower VSL               Moderate VSL                High VSL                  Severe VSL
Number         Number
                                                                          schedule as specified      without confirming      as specified in R1,        confirming the
                                                                          in R1, R1.1, R1.1.1        the schedule as         R1.1, R1.1.1 and           schedule as specified
                                                                          and R1.1.2. One            specified in R1,        R1.1.2. Three instances    in R1, R1.1, R1.1.1
                                                                          instance of not            R1.1, R1.1.1 and        of not coordinating the    and R1.1.2. Four or
                                                                          coordinating the           R1.1.2. Two             Interchange Schedule       more instances of not
                                                                          Interchange Schedule       instances of not        with the Transmission      coordinating the
                                                                          with the Transmission      coordinating the        Operator of the HVDC       Interchange Schedule
                                                                          Operator of the HVDC       Interchange             tie as specified in R1.2   with the Transmission
                                                                          tie as specified in R1.2   Schedule with the                                  Operator of the HVDC
                                                                                                     Transmission                                       tie as specified in R1.2
                                                                                                     Operator of the
                                                                                                     HVDC tie as
                                                                                                     specified in R1.2
INT-003-2   R1.1.          The Sending Balancing Authority and                                       The Balancing
                           Receiving Balancing Authority shall agree on                              Authority
                           Interchange as received from the Interchange   The Balancing              experienced two         The Balancing              The Balancing
                           Authority, including:                          Authority experienced      instances of entering   Authority experienced      Authority experienced
                                                                          one instance of            a schedule into its     three instances of         four instances of
                                                                          entering a schedule        ACE equation            entering a schedule into   entering a schedule
                                                                          into its ACE equation      without confirming      its ACE equation           into its ACE equation
                                                                          without confirming the     the schedule as         without confirming the     without confirming the
                                                                          schedule as specified      specified in R1,        schedule as specified in   schedule as specified
                                                                          in R1, R1.1, R1.1.1        R1.1, R1.1.1 and        R1, R1.1, R1.1.1 and       in R1, R1.1, R1.1.1
                                                                          and R1.1.2.                R1.1.2.                 R1.1.2.                    and R1.1.2.
INT-003-2   R1.1.1.        Interchange Schedule start and end time.                                  The Balancing
                                                                                                     Authority
                                                                          The Balancing              experienced two         The Balancing              The Balancing
                                                                          Authority experienced      instances of entering   Authority experienced      Authority experienced
                                                                          one instance of            a schedule into its     three instances of         four instances of
                                                                          entering a schedule        ACE equation            entering a schedule into   entering a schedule
                                                                          into its ACE equation      without confirming      its ACE equation           into its ACE equation
                                                                          without confirming the     the schedule as         without confirming the     without confirming the
                                                                          schedule as specified      specified in R1,        schedule as specified in   schedule as specified
                                                                          in R1, R1.1, R1.1.1        R1.1, R1.1.1 and        R1, R1.1, R1.1.1 and       in R1, R1.1, R1.1.1
                                                                          and R1.1.2.                R1.1.2.                 R1.1.2.                    and R1.1.2.
INT-003-2   R1.1.2.        Energy profile.                                The Balancing              The Balancing           The Balancing              The Balancing
                                                                          Authority experienced      Authority               Authority experienced      Authority experienced

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Complete Violation Severity Level Matrix (INT)
Encompassing All Commission-Approved Reliability Standards
Standard     Requirement
                                       Text of Requirement                         Lower VSL               Moderate VSL                 High VSL                  Severe VSL
Number         Number
                                                                              one instance of            experienced two         three instances of         four instances of
                                                                              entering a schedule        instances of entering   entering a schedule into   entering a schedule
                                                                              into its ACE equation      a schedule into its     its ACE equation           into its ACE equation
                                                                              without confirming the     ACE equation            without confirming the     without confirming the
                                                                              schedule as specified      without confirming      schedule as specified in   schedule as specified
                                                                              in R1, R1.1, R1.1.1        the schedule as         R1, R1.1, R1.1.1 and       in R1, R1.1, R1.1.1
                                                                              and R1.1.2.                specified in R1,        R1.1.2.                    and R1.1.2.
                                                                                                         R1.1, R1.1.1 and
                                                                                                         R1.1.2.
INT-003-2   R1.2.          If a high voltage direct current (HVDC) tie is     The sending or             The sending or          The sending or             The sending or
                           on the Scheduling Path, then the Sending           receiving Balancing        receiving Balancing     receiving Balancing        receiving Balancing
                           Balancing Authorities and Receiving                Authority experienced      Authority               Authority experienced      Authority experienced
                           Balancing Authorities shall coordinate the         one instance of not        experienced two         three instances of not     four instances of not
                           Interchange Schedule with the Transmission         coordinating the           instances of not        coordinating the           coordinating the
                           Operator of the HVDC tie.                          Interchange Schedule       coordinating the        Interchange Schedule       Interchange Schedule
                                                                              with the Transmission      Interchange             with the Transmission      with the Transmission
                                                                              Operator of the HVDC       Schedule with the       Operator of the HVDC       Operator of the HVDC
                                                                              tie as specified in R1.2   Transmission            tie as specified in R1.2   tie as specified in R1.2
                                                                                                         Operator of the
                                                                                                         HVDC tie as
                                                                                                         specified in R1.2
INT-004-2   R1.            At such time as the reliability event allows       The entity that            The entity that         N/A                        N/A
                           for the reloading of the transaction, the entity   initiated the              initiated the
                           that initiated the curtailment shall release the   curtailment failed to      curtailment failed to
                           limit on the Interchange Transaction tag to        communicate the            reload the
                           allow reloading the transaction and shall          transaction reload to      transaction and
                           communicate the release of the limit to the        the Sink Balancing         failed to
                           Sink Balancing Authority.                          Authority                  communicate to the
                                                                                                         Sink Balancing
                                                                                                         Authority
INT-004-2   R2.            The Purchasing-Selling Entity responsible for      The Purchase-Selling       The Purchase-           The Purchase-Selling       The Purchase-Selling
                           tagging a Dynamic Interchange Schedule             entity failed to update    Selling entity failed   entity failed to update    entity failed to update
                           shall ensure the tag is updated for the next       the tags when required     to update the tags      the tags when required     the tags when required
                           available scheduling hour and future hours         less than 25% of times     when required 25%       50% or more but less       75% or more of the
                           when any one of the following occurs:              it was required, as        or more and less        than75% of the times it    times it was required,
                                                                              determined in R2.1,        than 50% of the         was required, as           as determined in R2.1,
                                                                              R2.2, or R2.3.             times it was            determined in R2.1,        R2.2, or R2.3.

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Complete Violation Severity Level Matrix (INT)
Encompassing All Commission-Approved Reliability Standards
Standard     Requirement
                                       Text of Requirement                        Lower VSL              Moderate VSL                High VSL                  Severe VSL
Number         Number
                                                                                                       required, as            R2.2, or R2.3.
                                                                                                       determined in R2.1,
                                                                                                       R2.2, or R2.3.
INT-004-2   R2.1.          The average energy profile in an hour is          The Purchase-Selling      The Purchase-           The Purchase-Selling       The Purchase-Selling
                           greater than 250 MW and in that hour the          entity failed to update   Selling entity failed   entity failed to update    entity failed to update
                           actual hourly integrated energy deviates from     the tags when required    to update the tags      the tags when required     the tags when required
                           the hourly average energy profile indicated       less than 25% of times    when required 25%       50% or more but less       75% or more of the
                           on the tag by more than +10%.                     it was required.          or more and less        than75% of the times it    times it was required.
                                                                                                       than 50% of the         was required.
                                                                                                       times it was
                                                                                                       required.
INT-004-2   R2.2.          The average energy profile in an hour is less     The Purchase-Selling      The Purchase-           The Purchase-Selling       The Purchase-Selling
                           than or equal to 250 MW and in that hour the      entity failed to update   Selling entity failed   entity failed to update    entity failed to update
                           actual hourly integrated energy deviates from     the tags when required    to update the tags      the tags when required     the tags when required
                           the hourly average energy profile indicated       less than 25% of times    when required 25%       50% or more but less       75% or more of the
                           on the tag by more than +25 megawatt-hours.       it was required.          or more and less        than75% of the times it    times it was required.
                                                                                                       than 50% of the         was required.
                                                                                                       times it was
                                                                                                       required.
INT-004-2   R2.3.          A Reliability Coordinator or Transmission         The Purchase-Selling      The Purchase-           The Purchase-Selling       The Purchase-Selling
                           Operator determines the deviation, regardless     entity failed to update   Selling entity failed   entity failed to update    entity failed to update
                           of magnitude, to be a reliability concern and     the tags when required    to update the tags      the tags when required     the tags when required
                           notifies the Purchasing-Selling Entity of that    less than 25% of times    when required 25%       50% or more but less       75% or more of the
                           determination and the reasons.                    it was required.          or more and less        than75% of the times it    times it was required.
                                                                                                       than 50% of the         was required.
                                                                                                       times it was
                                                                                                       required.
INT-005-3   R1.            Prior to the expiration of the time period        The Interchange           The Interchange         The Interchange            The Interchange
                           defined in the timing requirements tables in      Authority experienced     Authority               Authority experienced      Authority experienced
                           this standard, Column A, the Interchange          one occurrence of not     experienced two         three occurrences of not   four occurrences of
                           Authority shall distribute the Arranged           distributing              occurrences of not      distributing information   not distributing
                           Interchange information for reliability           information to all        distributing            to all involved            information to all
                           assessment to all reliability entities involved   involved reliability      information to all      reliability entities       involved reliability
                           in the Interchange.                               entities.                 involved reliability                               entities
                                                                                                       entities
INT-005-3   R1.1.          When a Balancing Authority or Reliability         The Interchange           The Interchange         The Interchange            The Interchange

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Complete Violation Severity Level Matrix (INT)
Encompassing All Commission-Approved Reliability Standards
Standard     Requirement
                                       Text of Requirement                        Lower VSL            Moderate VSL               High VSL                  Severe VSL
Number         Number
                           Coordinator initiates a Curtailment to           Authority experienced    Authority              Authority experienced      Authority experienced
                           Confirmed or Implemented Interchange for         one occurrence of not    experienced two        three occurrences of not   four occurrences of
                           reliability, the Interchange Authority shall     distributing             occurrences of not     distributing information   not distributing
                           distribute the Arranged Interchange              information to all       distributing           to all involved            information to all
                           information for reliability assessment only to   involved reliability     information to all     reliability entities       involved reliability
                           the Source Balancing Authority and the Sink      entities.                involved reliability                              entities
                           Balancing Authority.                                                      entities
INT-006-3   R1.            Prior to the expiration of the reliability       The Responsible          The Responsible        The Responsible Entity     The Responsible
                           assessment period defined in the timing          Entity failed on one     Entity failed on two   failed on three            Entity failed on four
                           requirements tables in this standard, Column     occasion to respond to   occasions to respond   occasions to respond to    occasions to respond
                           B, the Balancing Authority and Transmission      a request from an        to a request from an   a request from an          to a request from an
                           Service Provider shall respond to each On-       Interchange Authority    Interchange            Interchange Authority      Interchange Authority
                           time Request for Interchange (RFI), and to       to transition an         Authority to           to transition an           to transition an
                           each Emergency RFI and Reliability               Arranged Interchange     transition an          Arranged Interchange       Arranged Interchange
                           Adjustment RFI from an Interchange               to a Confirmed           Arranged               to a Confirmed             to a Confirmed
                           Authority to transition an Arranged              Interchange.             Interchange to a       Interchange.               Interchange.
                           Interchange to a Confirmed Interchange                                    Confirmed
                                                                                                     Interchange.
INT-006-3   R1.1.          Each involved Balancing Authority shall          The Balancing            N/A                    The Balancing              The Balancing
                           evaluate the Arranged Interchange with           Authority failed to                             Authority failed to        Authority failed to
                           respect to:                                      evaluate arranged                               evaluate arranged          evaluate arranged
                                                                            interchange with                                interchange with           interchange with
                                                                            respect to one of the                           respect to two of the      respect to three of the
                                                                            requirements in the 3                           requirements in the 3      requirements in the 3
                                                                            sub-components.                                 sub-components.            sub-components.
INT-006-3   R1.1.1.        Energy profile (ability to support the           N/A                      N/A                    N/A                        The Balancing
                           magnitude of the Interchange).                                                                                              Authority failed to
                                                                                                                                                       evaluate Energy
                                                                                                                                                       profile (ability to
                                                                                                                                                       support the magnitude
                                                                                                                                                       of the Interchange).
INT-006-3   R1.1.2.        Ramp (ability of generation maneuverability      N/A                      N/A                    N/A                        The Balancing
                           to accommodate).                                                                                                            Authority failed to
                                                                                                                                                       evaluate Ramp (ability
                                                                                                                                                       of generation
                                                                                                                                                       maneuverability to
                                                                                                                                                       accommodate).
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Complete Violation Severity Level Matrix (INT)
Encompassing All Commission-Approved Reliability Standards
Standard     Requirement
                                      Text of Requirement                         Lower VSL            Moderate VSL                 High VSL                  Severe VSL
Number         Number
INT-006-3   R1.1.3.        Scheduling path (proper connectivity of          N/A                      N/A                      N/A                        The Balancing
                           Adjacent Balancing Authorities).                                                                                              Authority failed to
                                                                                                                                                         evaluate Scheduling
                                                                                                                                                         path (proper
                                                                                                                                                         connectivity of
                                                                                                                                                         Adjacent Balancing
                                                                                                                                                         Authorities).
INT-006-3   R1.2.          Each involved Transmission Service Provider      The Transmission         The Transmission         The Transmission           The Transmission
                           shall confirm that the transmission service      Service Provider         Service Provider         Service Provider           Service Provider
                           arrangements associated with the Arranged        experienced one          experienced two          experienced three          experience four
                           Interchange have adjacent Transmission           instance of failing to   instances of failing     instances of failing to    instances of failing to
                           Service Provider connectivity, are valid and     confirm that the         to confirm that the      confirm that the           confirm that the
                           prevailing transmission system limits will not   transmission service     transmission service     transmission service       transmission service
                           be violated                                      arrangements             arrangements             arrangements               arrangements
                                                                            associated with the      associated with the      associated with the        associated with the
                                                                            Arranged Interchange     Arranged                 Arranged Interchange       Arranged Interchange
                                                                            had adjacent             Interchange had          had adjacent               had adjacent
                                                                            Transmission Service     adjacent                 Transmission Service       Transmission Service
                                                                            Provider connectivity,   Transmission             Provider connectivity,     Provider connectivity,
                                                                            were valid and           Service Provider         were valid and             were valid and
                                                                            prevailing               connectivity, were       prevailing transmission    prevailing
                                                                            transmission system      valid and prevailing     system limits would not    transmission system
                                                                            limits would not be      transmission system      be violated.               limits would not be
                                                                            violated.                limits would not be                                 violated.
                                                                                                     violated.
INT-007-1   R1.            The Interchange Authority shall verify that      The Interchange          The Interchange          The Interchange            The Interchange
                           Arranged Interchange is balanced and valid       Authority failed to      Authority failed to      Authority failed to        Authority failed to
                           prior to transitioning Arranged Interchange to   verify one time, as      verify two times, as     verify three times, as     verify four times, as
                           Confirmed Interchange by verifying the           indicated in R1.1,       indicated in R1.1,       indicated in R1.1, R1.2,   indicated in R1.1,
                           following:                                       R1.2, R1.3, R1.3.1,      R1.2, R1.3, R1.3.1,      R1.3, R1.3.1, R1.3.2,      R1.2, R1.3, R1.3.1,
                                                                            R1.3.2, R1.3.3, or       R1.3.2, R1.3.3, or       R1.3.3, or R1.3.4 that     R1.3.2, R1.3.3, or
                                                                            R1.3.4 that Arranged     R1.3.4 that              Arranged Interchange       R1.3.4 that Arranged
                                                                            Interchange was          Arranged                 was balanced and valid     Interchange was
                                                                            balanced and valid       Interchange was          prior to transitioning     balanced and valid
                                                                            prior to transitioning   balanced and valid       Arranged Interchange       prior to transitioning
                                                                            Arranged Interchange     prior to transitioning   to Confirmed               Arranged Interchange
                                                                            to Confirmed             Arranged                 Interchange.               to Confirmed
                                                                                                     Interchange to
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Complete Violation Severity Level Matrix (INT)
Encompassing All Commission-Approved Reliability Standards
Standard     Requirement
                                      Text of Requirement                    Lower VSL             Moderate VSL                 High VSL                Severe VSL
Number         Number
                                                                        Interchange.             Confirmed                                         Interchange.
                                                                                                 Interchange.
INT-007-1   R1.1.          Source Balancing Authority megawatts equal   The Interchange          The Interchange          The Interchange          The Interchange
                           sink Balancing Authority megawatts           Authority failed to      Authority failed to      Authority failed to      Authority failed to
                           (adjusted for losses, if appropriate).       verify one time, as      verify two times, as     verify three times, as   verify four times, as
                                                                        indicated in R1 that     indicated in R1 that     indicated in R1 that     indicated in R1 that
                                                                        Arranged Interchange     Arranged                 Arranged Interchange     Arranged Interchange
                                                                        was balanced and         Interchange was          was balanced and valid   was balanced and
                                                                        valid prior to           balanced and valid       prior to transitioning   valid prior to
                                                                        transitioning Arranged   prior to transitioning   Arranged Interchange     transitioning Arranged
                                                                        Interchange to           Arranged                 to Confirmed             Interchange to
                                                                        Confirmed                Interchange to           Interchange.             Confirmed
                                                                        Interchange.             Confirmed                                         Interchange.
                                                                                                 Interchange.
INT-007-1   R1.2.          All reliability entities involved in the     The Interchange          The Interchange          The Interchange          The Interchange
                           Arranged Interchange are currently in the    Authority failed to      Authority failed to      Authority failed to      Authority failed to
                           NERC registry.                               verify one time, as      verify two times, as     verify three times, as   verify four times, as
                                                                        indicated in R1 that     indicated in R1 that     indicated in R1 that     indicated in R1 that
                                                                        Arranged Interchange     Arranged                 Arranged Interchange     Arranged Interchange
                                                                        was balanced and         Interchange was          was balanced and valid   was balanced and
                                                                        valid prior to           balanced and valid       prior to transitioning   valid prior to
                                                                        transitioning Arranged   prior to transitioning   Arranged Interchange     transitioning Arranged
                                                                        Interchange to           Arranged                 to Confirmed             Interchange to
                                                                        Confirmed                Interchange to           Interchange.             Confirmed
                                                                        Interchange.             Confirmed                                         Interchange.
                                                                                                 Interchange.
INT-007-1   R1.3.          The following are defined:                   The Interchange          The Interchange          The Interchange          The Interchange
                                                                        Authority failed to      Authority failed to      Authority failed to      Authority failed to
                                                                        verify one time, as      verify two times, as     verify three times, as   verify four times, as
                                                                        indicated in R1 that     indicated in R1 that     indicated in R1 that     indicated in R1 that
                                                                        Arranged Interchange     Arranged                 Arranged Interchange     Arranged Interchange
                                                                        was balanced and         Interchange was          was balanced and valid   was balanced and
                                                                        valid prior to           balanced and valid       prior to transitioning   valid prior to
                                                                        transitioning Arranged   prior to transitioning   Arranged Interchange     transitioning Arranged
                                                                        Interchange to           Arranged                 to Confirmed             Interchange to
                                                                        Confirmed                Interchange to           Interchange.             Confirmed
                                                                        Interchange.             Confirmed                                         Interchange.

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Complete Violation Severity Level Matrix (INT)
Encompassing All Commission-Approved Reliability Standards
Standard     Requirement
                                      Text of Requirement          Lower VSL             Moderate VSL                 High VSL                Severe VSL
Number         Number
                                                                                       Interchange.
INT-007-1   R1.3.1.        Generation source and load sink.   The Interchange          The Interchange          The Interchange          The Interchange
                                                              Authority failed to      Authority failed to      Authority failed to      Authority failed to
                                                              verify one time, as      verify two times, as     verify three times, as   verify four times, as
                                                              indicated in R1 that     indicated in R1 that     indicated in R1 that     indicated in R1 that
                                                              Arranged Interchange     Arranged                 Arranged Interchange     Arranged Interchange
                                                              was balanced and         Interchange was          was balanced and valid   was balanced and
                                                              valid prior to           balanced and valid       prior to transitioning   valid prior to
                                                              transitioning Arranged   prior to transitioning   Arranged Interchange     transitioning Arranged
                                                              Interchange to           Arranged                 to Confirmed             Interchange to
                                                              Confirmed                Interchange to           Interchange.             Confirmed
                                                              Interchange.             Confirmed                                         Interchange.
                                                                                       Interchange.
INT-007-1   R1.3.2.        Megawatt profile.                  The Interchange          The Interchange          The Interchange          The Interchange
                                                              Authority failed to      Authority failed to      Authority failed to      Authority failed to
                                                              verify one time, as      verify two times, as     verify three times, as   verify four times, as
                                                              indicated in R1 that     indicated in R1 that     indicated in R1 that     indicated in R1 that
                                                              Arranged Interchange     Arranged                 Arranged Interchange     Arranged Interchange
                                                              was balanced and         Interchange was          was balanced and valid   was balanced and
                                                              valid prior to           balanced and valid       prior to transitioning   valid prior to
                                                              transitioning Arranged   prior to transitioning   Arranged Interchange     transitioning Arranged
                                                              Interchange to           Arranged                 to Confirmed             Interchange to
                                                              Confirmed                Interchange to           Interchange.             Confirmed
                                                              Interchange.             Confirmed                                         Interchange.
                                                                                       Interchange.
INT-007-1   R1.3.3.        Ramp start and stop times.         The Interchange          The Interchange          The Interchange          The Interchange
                                                              Authority failed to      Authority failed to      Authority failed to      Authority failed to
                                                              verify one time, as      verify two times, as     verify three times, as   verify four times, as
                                                              indicated in R1 that     indicated in R1 that     indicated in R1 that     indicated in R1 that
                                                              Arranged Interchange     Arranged                 Arranged Interchange     Arranged Interchange
                                                              was balanced and         Interchange was          was balanced and valid   was balanced and
                                                              valid prior to           balanced and valid       prior to transitioning   valid prior to
                                                              transitioning Arranged   prior to transitioning   Arranged Interchange     transitioning Arranged
                                                              Interchange to           Arranged                 to Confirmed             Interchange to
                                                              Confirmed                Interchange to           Interchange.             Confirmed
                                                              Interchange.             Confirmed                                         Interchange.
                                                                                       Interchange.

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Encompassing All Commission-Approved Reliability Standards
Standard     Requirement
                                       Text of Requirement                      Lower VSL                Moderate VSL                 High VSL                   Severe VSL
Number         Number
INT-007-1   R1.3.4.        Interchange duration.                           The Interchange             The Interchange          The Interchange             The Interchange
                                                                           Authority failed to         Authority failed to      Authority failed to         Authority failed to
                                                                           verify one time, as         verify two times, as     verify three times, as      verify four times, as
                                                                           indicated in R1 that        indicated in R1 that     indicated in R1 that        indicated in R1 that
                                                                           Arranged Interchange        Arranged                 Arranged Interchange        Arranged Interchange
                                                                           was balanced and            Interchange was          was balanced and valid      was balanced and
                                                                           valid prior to              balanced and valid       prior to transitioning      valid prior to
                                                                           transitioning Arranged      prior to transitioning   Arranged Interchange        transitioning Arranged
                                                                           Interchange to              Arranged                 to Confirmed                Interchange to
                                                                           Confirmed                   Interchange to           Interchange.                Confirmed
                                                                           Interchange.                Confirmed                                            Interchange.
                                                                                                       Interchange.
INT-007-1   R1.4.          Each Balancing Authority and Transmission       Each Balancing              Each Balancing           Each Balancing              Each Balancing
                           Service Provider that received the Arranged     Authority and               Authority and            Authority and               Authority and
                           Interchange information from the Interchange    Transmission Service        Transmission             Transmission Service        Transmission Service
                           Authority for reliability assessment has        Provider that received      Service Provider         Provider that received      Provider that received
                           provided approval.                              the Arranged                that received the        the Arranged                the Arranged
                                                                           Interchange                 Arranged                 Interchange information     Interchange
                                                                           information from the        Interchange              from the Interchange        information from the
                                                                           Interchange Authority       information from         Authority for reliability   Interchange Authority
                                                                           for reliability             the Interchange          assessment has              for reliability
                                                                           assessment has              Authority for            provided approval but       assessment did not
                                                                           provided approval,          reliability              was substantially           provided approval and
                                                                           with minor exception        assessment has           deficient in meeting the    failed to meet the
                                                                           and is substantially        provided approval,       directives of the           requirement.
                                                                           compliant with the          with some exception      requirement.
                                                                           directives of the           and is mostly
                                                                           requirement.                compliant with the
                                                                                                       directives of the
                                                                                                       requirement.
INT-008-3   R1.            Prior to the expiration of the time period      The Interchange             The Interchange          The Interchange             The Interchange
                           defined in the Timing Table, Column C, the      Authority experienced       Authority                Authority experienced       Authority experienced
                           Interchange Authority shall distribute to all   one occurrence of not       experienced two          three occurrences of not    four occurrences of
                           Balancing Authorities (including Balancing      distributing                occurrences of not       distributing information    not distributing
                           Authorities on both sides of a direct current   information to all          distributing             to all involved             information to all
                           tie), Transmission Service Providers and        involved reliability        information to all       reliability entities.       involved reliability
                           Purchasing-Selling Entities involved in the     entities as deliniated in   involved reliability                                 entities or no evidence
                           Arranged Interchange whether or not the         R1.1, R1.1.1 or
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Standard     Requirement
                                      Text of Requirement                    Lower VSL             Moderate VSL                 High VSL                  Severe VSL
Number         Number
                           Arranged Interchange has transitioned to a   R1.1.2.                  entities.                                           provided.
                           Confirmed Interchange.
INT-008-3   R1.1.          For Confirmed Interchange, the Interchange   The Interchange          The Interchange          The Interchange            The Interchange
                           Authority shall also communicate:            Authority experienced    Authority                Authority experienced      Authority experienced
                                                                        one occurrence of not    experienced two          three occurrences of not   four occurrences of
                                                                        distributing             occurrences of not       distributing information   not distributing
                                                                        information to all       distributing             to all involved            information to all
                                                                        involved reliability     information to all       reliability entities as    involved reliability
                                                                        entities as defined in   involved reliability     defined in R1.             entities as defined in
                                                                        R1.                      entities as defined in                              R1 or no evidence
                                                                                                 R1.                                                 provided.
INT-008-3   R1.1.1.        Start and stop times, ramps, and megawatt    The Interchange          The Interchange          The Interchange            The Interchange
                           profile to Balancing Authorities.            Authority experienced    Authority                Authority experienced      Authority experienced
                                                                        one occurrence of not    experienced two          three occurrences of not   four occurrences of
                                                                        distributing             occurrences of not       distributing information   not distributing
                                                                        information to all       distributing             to all involved            information to all
                                                                        involved reliability     information to all       reliability entities as    involved reliability
                                                                        entities as defined in   involved reliability     defined in R1.             entities as defined in
                                                                        R1.                      entities as defined in                              R1 or no evidence
                                                                                                 R1.                                                 provided.
INT-008-3   R1.1.2.        Necessary Interchange information to NERC-   The Interchange          The Interchange          The Interchange            The Interchange
                           identified reliability analysis services.    Authority experienced    Authority                Authority experienced      Authority experienced
                                                                        one occurrence of not    experienced two          three occurrences of not   four occurrences of
                                                                        distributing             occurrences of not       distributing information   not distributing
                                                                        information to all       distributing             to all involved            information to all
                                                                        involved reliability     information to all       reliability entities as    involved reliability
                                                                        entities as defined in   involved reliability     defined in R1.             entities as defined in
                                                                        R1.                      entities as defined in                              R1 or no evidence
                                                                                                 R1.                                                 provided.
INT-009-1   R1.            The Balancing Authority shall implement      The Balancing            The Balancing            The Balancing              The Balancing
                           Confirmed Interchange as received from the   Authority experienced    Authority                Authority experienced      Authority experienced
                           Interchange Authority.                       one occurrence of not    experienced two          three occurrences of not   four occurrences of
                                                                        implementing a           occurrences of not       implementing a             not implementing a
                                                                        Confirmed                implementing a           Confirmed Interchange      Confirmed
                                                                        Interchange as           Confirmed                as received from the       Interchange as
                                                                        received from the        Interchange as           Interchange Authority.     received from the
                                                                        Interchange Authority.   received from the                                   Interchange Authority.
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Standard     Requirement
                                      Text of Requirement                       Lower VSL             Moderate VSL                High VSL                  Severe VSL
Number         Number
                                                                                                    Interchange
                                                                                                    Authority.
INT-010-1   R1.            The Balancing Authority that experiences a      The Balancing            The Balancing           The Balancing              The Balancing
                           loss of resources covered by an energy          Authority that           Authority that          Authority that             Authority that
                           sharing agreement shall ensure that a request   experienced a loss of    experienced a loss      experienced a loss of      experienced a loss of
                           for an Arranged Interchange is submitted        resource covered by an   of resource covered     resource covered by an     resource covered by an
                           with a start time no more than 60 minutes       energy sharing           by an energy sharing    energy sharing             energy sharing
                           beyond the resource loss. If the use of the     agreement failed one     agreement failed        agreement failed three     agreement failed four
                           energy sharing agreement does not exceed 60     time to submit a         two times to submit     times to submit a          or more times to
                           minutes from the time of the resource loss,     request for an           request for an          request for an Arranged    submit a request for an
                           no request for Arranged Interchange is          Arranged Interchange     Arranged                Interchange within the     Arranged Interchange
                           required.                                       within the specified     Interchange within      specified time period.     within the specified
                                                                           time period.             the specified time                                 time period.
                                                                                                    period.
INT-010-1   R2.            For a modification to an existing Interchange   The Reliability          The Reliability         The Reliability            The Reliability
                           schedule that is directed by a Reliability      Coordinator failed one   Coordinator failed      Coordinator failed three   Coordinator failed
                           Coordinator for current or imminent             time to direct the       two times to direct     times to direct the        four times to direct
                           reliability-related reasons, the Reliability    submittal of a new or    the submittal of a      submittal of a new or      the submittal of a new
                           Coordinator shall direct a Balancing            modified Arranged        new or modified         modified Arranged          or modified Arranged
                           Authority to submit the modified Arranged       Interchange; or the      Arranged                Interchange; or the        Interchange; or the
                           Interchange reflecting that modification        Balancing Authority      Interchange; or the     Balancing Authority        Balancing Authority
                           within 60 minutes of the initiation of the      failed one time to       Balancing Authority     failed three times to      failed four times to
                           event.                                          submit the modified      failed two times to     submit the modified        submit the modified
                                                                           schedule as directed.    submit the modified     schedule as directed.      schedule as directed.
                                                                                                    schedule as directed.
INT-010-1   R3.            For a new Interchange schedule that is          The Reliability          The Reliability         The Reliability            The Reliability
                           directed by a Reliability Coordinator for       Coordinator failed one   Coordinator failed      Coordinator failed three   Coordinator failed
                           current or imminent reliability-related         time to direct the       two times to direct     times to direct the        four times to direct the
                           reasons, the Reliability Coordinator shall      submittal of a new or    the submittal of a      submittal of a new or      submittal of a new or
                           direct a Balancing Authority to submit an       modified Arranged        new or modified         modified Arranged          modified Arranged
                           Arranged Interchange reflecting that            Interchange; or the      Arranged                Interchange ; or the       Interchange; or the
                           Interchange schedule within 60 minutes of       Balancing Authority      Interchange ; or the    Balancing Authority        Balancing Authority
                           the initiation of the event.                    failed one time to       Balancing Authority     failed three times to      failed four times or
                                                                           submit a schedule as     failed two times to     submit a schedule as       more to submit a
                                                                           directed.                submit a schedule as    directed.                  schedule as directed.
                                                                                                    directed.


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Standard    Requirement
                                      Text of Requirement                        Lower VSL             Moderate VSL                 High VSL                  Severe VSL
Number        Number
IRO-001-   R1.            Each Regional Reliability Organization,          The RRO, subregion        The RRO, subregion      The RRO, subregion or       The RRO, subregion
1.1                       subregion, or interregional coordinating         or interregional          or interregional        interregional               or interregional
                          group shall establish one or more Reliability    coordinating group did    coordinating group      coordinating group did      coordinating group did
                          Coordinators to continuously assess              not communicate the       did not clearly         not coordinate              not assign any
                          transmission reliability and coordinate          assignment of the         identify the            assignment of the           Reliability
                          emergency operations among the operating         Reliability               coordination of         Reliability Coordinators    Coordinators.
                          entities within the region and across the        Coordinators to           Reliability             across regional
                          regional boundaries.                             operating entities        Coordinator areas       boundaries.
                                                                           clearly.                  within the region.
IRO-001-   R2.            The Reliability Coordinator shall comply         The Reliability           The Reliability         The Reliability             The Reliability
1.1                       with a regional reliability plan approved by     Coordinator has failed    Coordinator has         Coordinator does not        Coordinator does not
                          the NERC Operating Committee.                    to follow the             failed to follow        have a regional             have an unapproved
                                                                           administrative portions   steps in its regional   reliability plan            regional reliability
                                                                           of its regional           reliability plan that   approved by the NERC        plan.
                                                                           reliability plan.         requires operator       OC.
                                                                                                     interventions or
                                                                                                     actions.
IRO-001-   R3.            The Reliability Coordinator shall have clear     N/A                       N/A                     The Reliability             The Reliability
1.1                       decision-making authority to act and to direct                                                     Coordinator cannot          Coordinator failed to
                          actions to be taken by Transmission                                                                demonstrate that it has     take or direct to
                          Operators, Balancing Authorities, Generator                                                        clear authority to act or   preserve the reliability
                          Operators, Transmission Service Providers,                                                         direct actions to           and security of the
                          Load-Serving Entities, and Purchasing-                                                             preserve transmission       Bulk Electric System
                          Selling Entities within its Reliability                                                            security and reliability    within 30 minutes of
                          Coordinator Area to preserve the integrity                                                         of the Bulk Electric        identifying those
                          and reliability of the Bulk Electric System.                                                       System.                     actions.
                          These actions shall be taken without delay,
                          but no longer than 30 minutes.
IRO-001-   R4.            Reliability Coordinators that delegate tasks     1. Less than 25% of       1. More than 25%        1. More than 50% but        1. There is no formal
1.1                       to other entities shall have formal operating    the tasks are not         but 50% or less of      75% or less of the tasks    operating agreement
                          agreements with each entity to which tasks       documented in the         the tasks are not       are not documented in       for tasks delegated by
                          are delegated. The Reliability Coordinator       agreement or              documented in the       the agreement or            the Reliability
                          shall verify that all delegated tasks are        2. Less than 25% of       agreement or            2. More than 50% but        Coordinator,
                          understood, communicated, and addressed          the tasks are not         2. More than 25%        75% or less of the tasks    2. More than 75% of
                          within its Reliability Coordinator Area. All     performed according       but 50% or less of      are not performed           the tasks are not

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Standard    Requirement
                                      Text of Requirement                        Lower VSL           Moderate VSL                 High VSL                  Severe VSL
Number        Number
                          responsibilities for complying with NERC         to the agreement.       the tasks are not       according to the            documented in the
                          and regional standards applicable to                                     performed according     agreement.                  agreement or
                          Reliability Coordinators shall remain with                               to the agreement.                                   3. More than 75% of
                          the Reliability Coordinator.                                                                                                 the tasks are not
                                                                                                                                                       performed according
                                                                                                                                                       to the agreement.
IRO-001-   R5.            The Reliability Coordinator shall list within    25% or less of the      More than 25% but       More than 50% but           1. There is no
1.1                       its reliability plan all entities to which the   delegate entities are   50% or less of the      75% or less of the          reliability plan or
                          Reliability Coordinator has delegated            not identified in the   delegate entities are   delegate entities are not   2. More than 75% of
                          required tasks.                                  reliability plan.       not identified in the   identified in the           the delegate entities
                                                                                                   reliability plan.       reliability plan.           are not identified in
                                                                                                                                                       the reliability plan.
IRO-001-   R6.            The Reliability Coordinator shall verify that    N/A                     1. The Reliability      1. The Reliability          The Reliability
1.1                       all delegated tasks are carried out by NERC-                             Coordinator has         Coordinator has failed      Coordinator has failed
                          certified Reliability Coordinator operating                              failed to               to demonstrate at least     to demonstrate any
                          personnel.                                                               demonstrate at least    one delegated task was      delegated tasks were
                                                                                                   one delegated task      performed by NERC           performed by NERC
                                                                                                   was performed by        certified Reliability       certified Reliability
                                                                                                   NERC certified          Coordinator operating       Coordinator operating
                                                                                                   Reliability             personnel and did not       personnel and did not
                                                                                                   Coordinator             require the delegate        require the delegate
                                                                                                   operating personnel     entity to have NERC         entity to have NERC
                                                                                                   or                      certified Reliability       certified Reliability
                                                                                                   2. The Reliability      Coordinator operating       Coordinator operating
                                                                                                   Coordinator did not     personnel or                personnel.
                                                                                                   require the delegate    2. The Reliability
                                                                                                   entity to have NERC     Coordinator has failed
                                                                                                   certified Reliability   to demonstrate at least
                                                                                                   Coordinator             two delegated task were
                                                                                                   operating personnel.    performed by NERC
                                                                                                                           certified Reliability
                                                                                                                           Coordinator operating
                                                                                                                           personnel.
IRO-001-   R7.            The Reliability Coordinator shall have clear,    The Reliability         The Reliability         The Reliability             The Reliability
1.1                       comprehensive coordination agreements with       Coordinator has         Coordinator has         Coordinator has             Coordinator has failed
                          adjacent Reliability Coordinators to ensure      demonstrated the        demonstrated the        demonstrated the            to demonstrate the
                          that System Operating Limit or                   existence of            existence of the        existence of the            existence of any

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Standard    Requirement
                                      Text of Requirement                       Lower VSL            Moderate VSL                High VSL                  Severe VSL
Number        Number
                          Interconnection Reliability Operating Limit     coordination             coordination            coordination               coordination
                          violation mitigation requiring actions in       agreements with          agreements with         agreements with            agreements with
                          adjacent Reliability Coordinator Areas are      adjacent Reliability     adjacent Reliability    adjacent Reliability       adjacent Reliability
                          coordinated.                                    Coordinators but the     Coordinators but the    Coordinators but the       Coordinators.
                                                                          agreements are not       agreements do not       agreements do not
                                                                          clear or                 coordinate actions      coordinate actions
                                                                          comprehensive.           required in the         required in the adjacent
                                                                                                   adjacent Reliability    Reliability Coordinator
                                                                                                   Coordinator to          to mitigate SOL and
                                                                                                   mitigate SOL or         IROL violations in its
                                                                                                   IROL violations in      own Reliability
                                                                                                   its own Reliability     Coordinator area.
                                                                                                   Coordinator area.
IRO-001-   R8.            Transmission Operators, Balancing               Transmission             Transmission            Transmission               Transmission
1.1                       Authorities, Generator Operators,               Operators, Balancing     Operators,              Operators, Balancing       Operators, Balancing
                          Transmission Service Providers, Load-           Authorities, Generator   Balancing               Authorities, Generator     Authorities, Generator
                          Serving Entities, and Purchasing-Selling        Operators,               Authorities,            Operators,                 Operators,
                          Entities shall comply with Reliability          Transmission Service     Generator               Transmission Service       Transmission Service
                          Coordinator directives unless such actions      Providers, Load-         Operators,              Providers, Load-           Providers, Load-
                          would violate safety, equipment, or             Serving Entities, and    Transmission            Serving Entities, and      Serving Entities, and
                          regulatory or statutory requirements. Under     Purchasing-Selling       Service Providers,      Purchasing-Selling         Purchasing-Selling
                          these circumstances, the Transmission           Entities followed the    Load-Serving            Entities followed the      Entities did not follow
                          Operator, Balancing Authority, Generator        Reliability              Entities, and           majority of the            the Reliability
                          Operator, Transmission Service Provider,        Coordinators directive   Purchasing-Selling      Reliability Coordinators   Coordinators directive
                          Load-Serving Entity, or Purchasing-Selling      with a delay not         Entities followed the   directive and did not      and did not notify the
                          Entity shall immediately inform the             caused by equipment      Reliability             notify the Reliability     Reliability
                          Reliability Coordinator of the inability to     problems but did         Coordinators            Coordinator that it        Coordinator that it
                          perform the directive so that the Reliability   notify the Reliability   directive with a        could not fully follow     could not follow the
                          Coordinator may implement alternate             Coordinator of the       delay not caused by     the directive because it   directive because it
                          remedial actions.                               delay.                   equipment problems      would violate safety,      would violate safety,
                                                                                                   and did not notify      equipment, statutory or    equipment, statutory
                                                                                                   the Reliability         regulatory                 or regulatory
                                                                                                   Coordinator of the      requirements.              requirements.
                                                                                                   delay.
IRO-001-   R9.            The Reliability Coordinator shall act in the    N/A                      N/A                     N/A                        The Reliability
1.1                       interests of reliability for the overall                                                                                    Coordinator did not
                          Reliability Coordinator Area and the                                                                                        act in the interests of
                          Interconnection before the interests of any                                                                                 reliability for the
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Standard     Requirement
                                       Text of Requirement                         Lower VSL               Moderate VSL                 High VSL                   Severe VSL
Number         Number
                           other entity.                                                                                                                      overall Reliability
                                                                                                                                                              Coordinator Area and
                                                                                                                                                              the Interconnection
                                                                                                                                                              before the interests of
                                                                                                                                                              one or more other
                                                                                                                                                              entities.
IRO-002-1   R1.            Each Reliability Coordinator shall have            The Reliability            The Reliability         The Reliability              The Reliability
                           adequate communications facilities (voice          Coordinator has            Coordinator has         Coordinator has failed       Coordinator has failed
                           and data links) to appropriate entities within     demonstrated               failed to               to demonstrate that is       to demonstrate that is
                           its Reliability Coordinator Area. These            communication              demonstrate that is     has:                         has:
                           communications facilities shall be staffed         facilities for both        has:                    1) Voice                     1) Voice
                           and available to act in addressing a real-time     voice and data exist to    1) Voice                communication links          communication links
                           emergency condition.                               all appropriate entities   communication           with two appropriate         with more than two
                                                                              and that they are          links with one          entities or                  appropriate entities or
                                                                              staffed and available      appropriate entity or   2) Data links with two       2) Data links with
                                                                              but they are less than     2) Data links with      appropriate entities.        more than two
                                                                              adequate.                  one appropriate                                      appropriate entities or
                                                                                                         entity.                                              3) Communication
                                                                                                                                                              facilities are not
                                                                                                                                                              staffed or
                                                                                                                                                              4) Communication
                                                                                                                                                              facilities are not ready.
IRO-002-1   R2.            Each Reliability Coordinator shall determine       The Reliability            The Reliability         The Reliability              The Reliability
                           the data requirements to support its reliability   Coordinator                Coordinator             Coordinator                  Coordinator failed to
                           coordination tasks and shall request such          demonstrated that it       demonstrated that it    demonstrated that it         demonstrate that it
                           data from its Transmission Operators,              1) determined its data     determined the          determined                   1) determined its data
                           Balancing Authorities, Transmission                requirements and           majority but not all    1) some but less than        requirements
                           Owners, Generation Owners, Generation              requested that data        of its data             the majority of its data     necessary to support
                           Operators, and Load-Serving Entities, or           from its Transmission      requirements            requirements necessary       its reliability
                           adjacent Reliability Coordinators.                 Operators, Balancing       necessary to support    to support its reliability   coordination functions
                                                                              Authorities,               its reliability         coordination functions       and requested that data
                                                                              Transmission Owners,       coordination            and requested that data      from its Transmission
                                                                              Generation Owners,         functions and           from its Transmission        Operators, Balancing
                                                                              Generation Operators,      requested that data     Operators, Balancing         Authorities,
                                                                              and Load-Serving           from its                Authorities,                 Transmission Owners,
                                                                              Entities or Adjacent       Transmission            Transmission Owners,         Generation Owners,
                                                                              Reliability                Operators,              Generation Owners,           Generation Operators,
                                                                              Coordinators with a        Balancing               Generation Operators,        and Load-Serving
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Standard     Requirement
                                      Text of Requirement                    Lower VSL               Moderate VSL                High VSL                   Severe VSL
Number         Number
                                                                       material impact on the      Authorities,           and Load-Serving             Entities or Adjacent
                                                                       Bulk Electric System        Transmission           Entities or Adjacent         Reliability
                                                                       in its Reliability          Owners, Generation     Reliability Coordinators     Coordinators or
                                                                       Coordination Area but       Owners, Generation     or                           2) requested the data
                                                                       did not request the         Operators, and         2) all of its data           from three or more of
                                                                       data from                   Load-Serving           requirements necessary       its Transmission
                                                                       Transmission                Entities or Adjacent   to support its reliability   Operators, Balancing
                                                                       Operators, Balancing        Reliability            coordination functions       Authorities,
                                                                       Authorities,                Coordinators.          but failed to                Transmission Owners,
                                                                       Transmission Owners,                               demonstrate that it          Generation Owners,
                                                                       Generation Owners,                                 requested data from two      Generation Operators,
                                                                       Generation Operators,                              of its Transmission          and Load-Serving
                                                                       and Load-Serving                                   Operators, Balancing         Entities or Adjacent
                                                                       Entities or Adjacent                               Authorities,                 Reliability
                                                                       Reliability                                        Transmission Owners,         Coordinators.
                                                                       Coordinators with                                  Generation Owners,
                                                                       minimal impact on the                              Generation Operators,
                                                                       Bulk Electric System                               and Load-Serving
                                                                       in its Reliability                                 Entities or Adjacent
                                                                       Coordination Area or                               Reliability
                                                                       2) determined its data                             Coordinators.
                                                                       requirements
                                                                       necessary to perform
                                                                       its reliability functions
                                                                       with the exceptions of
                                                                       data that may be
                                                                       needed for
                                                                       administrative
                                                                       purposes such as data
                                                                       reporting.
IRO-002-1   R3.            Each Reliability Coordinator – or its       N/A                         The Reliability        The Reliability              The Reliability
                           Transmission Operators and Balancing                                    Coordinator or         Coordinator or               Coordinator or
                           Authorities – shall provide, or arrange                                 designated             designated                   designated
                           provisions for, data exchange to other                                  Transmission           Transmission Operator        Transmission Operator
                           Reliability Coordinators or Transmission                                Operator and           and Balancing                and Balancing
                           Operators and Balancing Authorities via a                               Balancing Authority    Authority has failed to      Authority has failed to
                           secure network.                                                         has failed to          demonstrate it provided      demonstrate it
                                                                                                   demonstrate it         or arranged provision        provided or arranged
                                                                                                   provided or            for the exchange of data     provision for the
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                                       Text of Requirement                         Lower VSL              Moderate VSL                 High VSL                  Severe VSL
Number         Number
                                                                                                        arranged provision       with two of the other      exchange of data with
                                                                                                        for the exchange of      Reliability Coordinators   three of the other
                                                                                                        data with one of the     or Transmission            Reliability
                                                                                                        other Reliability        Operators and              Coordinators or
                                                                                                        Coordinators or          Balancing Authorities.     Transmission
                                                                                                        Transmission                                        Operators and
                                                                                                        Operators and                                       Balancing Authorities.
                                                                                                        Balancing
                                                                                                        Authorities.
IRO-002-1   R4.            Each Reliability Coordinator shall have           N/A                        The Reliability          The Reliability            The Reliability
                           multi-directional communications                                             Coordinator has          Coordinator has failed     Coordinator has failed
                           capabilities with its Transmission Operators                                 failed to                to demonstrate multi-      to demonstrate multi-
                           and Balancing Authorities, and with                                          demonstrate multi-       directional                directional
                           neighboring Reliability Coordinators, for                                    directional              communication              communication
                           both voice and data exchange as required to                                  communication            capabilities to two or     capabilities to all of
                           meet reliability needs of the Interconnection.                               capabilities to one of   more of the                the Transmission
                                                                                                        the Transmission         Transmission Operators     Operators and
                                                                                                        Operators and            and Balancing              Balancing Authorities
                                                                                                        Balancing                Authorities in its         in its Reliability
                                                                                                        Authorities in its       Reliability Coordinator    Coordinator Area and
                                                                                                        Reliability              Area and with              with all neighboring
                                                                                                        Coordinator Area         neighboring Reliability    Reliability
                                                                                                        and with                 Coordinators.              Coordinators.
                                                                                                        neighboring
                                                                                                        Reliability
                                                                                                        Coordinators.
IRO-002-1   R5.            Each Reliability Coordinator shall have           The Reliability            The Reliability          The Reliability            The Reliability
                           detailed real-time monitoring capability of its   Coordinator's              Coordinator has          Coordinator has failed     Coordinator has failed
                           Reliability Coordinator Area and sufficient       monitoring systems         failed to                to demonstrate that is     to demonstrate that is
                           monitoring capability of its surrounding          provide information in     demonstrate that is      has detailed real-time     has detailed real-time
                           Reliability Coordinator Areas to ensure that      a way that is not easily   has detailed real-       monitoring capabilities    monitoring capabilities
                           potential or actual System Operating Limit or     understood and             time monitoring          in its Reliability         in its Reliability
                           Interconnection Reliability Operating Limit       interpreted by the         capabilities in its      Coordinator Area and       Coordinator Area and
                           violations are identified. Each Reliability       Reliability                Reliability              sufficient monitoring      sufficient monitoring
                           Coordinator shall have monitoring systems         Coordinator's              Coordinator Area         capabilities of its        capabilities of its
                           that provide information that can be easily       operating personnel or     and sufficient           surrounding Reliability    surrounding
                           understood and interpreted by the Reliability     particular emphasis        monitoring               Coordinator Areas to       Reliability
                           Coordinator’s operating personnel, giving         was not given to alarm     capabilities of its      ensure that two or more    Coordinator Areas to
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Complete Violation Severity Level Matrix (IRO)
Encompassing All Commission-Approved Reliability Standards
Standard     Requirement
                                      Text of Requirement                       Lower VSL             Moderate VSL                High VSL                  Severe VSL
Number         Number
                           particular emphasis to alarm management         management and           surrounding             potential and actual       ensure that all
                           and awareness systems, automated data           awareness systems,       Reliability             SOL and IROL               potential and actual
                           transfers, and synchronized information         automated data           Coordinator Areas       violations are not         SOL and IROL
                           systems, over a redundant and highly reliable   transfers and            to ensure that one      identified.                violations are
                           infrastructure.                                 synchronized             potential or actual                                identified.
                                                                           information systems.     SOL or IROL
                                                                                                    violation is not
                                                                                                    identified.
IRO-002-1   R6.            Each Reliability Coordinator shall monitor      The Reliability          The Reliability         The Reliability            The Reliability
                           Bulk Electric System elements (generators,      Coordinator failed to    Coordinator failed      Coordinator failed to      Coordinator failed to
                           transmission lines, buses, transformers,        monitor:                 to monitor:             monitor:                   monitor:
                           breakers, etc.) that could result in SOL or     1) the status, real      1) the status, real     1) the status, real        1) the status, real
                           IROL violations within its Reliability          power flow or reactive   power flow or           power flow or reactive     power flow or reactive
                           Coordinator Area. Each Reliability              power flow of Bulk       reactive power flow     power flow of Bulk         power flow of Bulk
                           Coordinator shall monitor both real and         Electric System          of Bulk Electric        Electric System            Electric System
                           reactive power system flows, and operating      elements that could      System elements         elements critical to       elements critical to
                           reserves, and the status of Bulk Electric       result in one SOL        critical to assessing   assessing two or more      assessing all IROLs
                           System elements that are or could be critical   violations or            one IROL or to          IROLs; or one IROL         and to system
                           to SOLs and IROLs and system restoration        2) or operating          system restoration,     and to system              restoration, or
                           requirements within its Reliability             reserves for a small     2) the status, real     restoration,               2) the status, real
                           Coordinator Area.                               portion of the           power flow or           2) the status, real        power flow or reactive
                                                                           Reliability Authority    reactive power flow     power flow or reactive     power flow of Bulk
                                                                           Area.                    of Bulk Electric        power flow of Bulk         Electric System
                                                                                                    System elements         Electric System            elements critical to
                                                                                                    that could result in    elements that could        assessing all SOL
                                                                                                    multiple SOL            result in multiple SOL     violations and
                                                                                                    violations, or          violations and operating   operating reserves.
                                                                                                    3) operating            reserves, or
                                                                                                    reserves.               3) the status, real
                                                                                                                            power flow or reactive
                                                                                                                            power flow of Bulk
                                                                                                                            Electric System
                                                                                                                            elements critical to
                                                                                                                            assessing one IROL or
                                                                                                                            system restoration and
                                                                                                                            operating reserves.
IRO-002-1   R7.            Each Reliability Coordinator shall have         The Reliability          The Reliability         The Reliability            The Reliability
                           adequate analysis tools such as state           Coordinator failed to    Coordinator failed      Coordinator failed to      Coordinator failed to
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Complete Violation Severity Level Matrix (IRO)
Encompassing All Commission-Approved Reliability Standards
Standard     Requirement
                                       Text of Requirement                       Lower VSL              Moderate VSL                High VSL                  Severe VSL
Number         Number
                           estimation, pre- and post-contingency            demonstrate that it       to demonstrate that     demonstrate that it has:   demonstrate that it
                           analysis capabilities (thermal, stability, and   has:                      it has:                 1) analysis tools          has:
                           voltage), and wide-area overview displays.       1) analysis tools         1) analysis tools       capable of assessing a     1) analysis tools
                                                                            capable of assessing      capable of assessing    minority of pre-           capable of assessing
                                                                            all pre-contingency       the majority of pre-    contingency flows,         any pre-contingency
                                                                            flows,                    contingency flows,      2) analysis tools          flows,
                                                                            2) analysis tools         2) analysis tools       capable of assessing a     2) analysis tools
                                                                            capable of assessing      capable of assessing    minority of post-          capable of assessing
                                                                            all post-contingency      the majority of post-   contingency flows, or      any post-contingency
                                                                            flows, or                 contingency flows,      3) a minority of           flows, or
                                                                            3) all necessary wide-    or                      necessary wide-area        3) any necessary
                                                                            area overview displays    3) the majority of      overview displays exist.   wide-area overview
                                                                            exist.                    necessary wide-area                                displays exist.
                                                                                                      overview displays
                                                                                                      exist.
IRO-002-1   R8.            Each Reliability Coordinator shall               The Reliability           The Reliability         The Reliability            The Reliability
                           continuously monitor its Reliability             Coordinator failed to     Coordinator failed      Coordinator failed to      Coordinator failed to
                           Coordinator Area. Each Reliability               demonstrate that:         to demonstrate that:    demonstrate that:          demonstrate that it
                           Coordinator shall have provisions for backup     1) it or a delegated      1) it or a delegated    1) it or a delegated       continuously
                           facilities that shall be exercised if the main   entity monitored SOLs     entity monitored one    entity monitored two or    monitored its
                           monitoring system is unavailable. Each           when the main             IROL when the           more IROLs when the        Reliability Authority
                           Reliability Coordinator shall ensure SOL and     monitoring system         main monitoring         main monitoring            Area.
                           IROL monitoring and derivations continue if      was unavailable or        system was              system was unavailable,
                           the main monitoring system is unavailable.       2) it has provisions to   unavailable or          2) it or a delegated
                                                                            monitor SOLs when         2) it has provisions    entity monitored SOLs
                                                                            the main monitoring       to monitor one          and one IROL when the
                                                                            system is not             IROL when the           main monitoring
                                                                            available.                main monitoring         system was unavailable
                                                                                                      system is not           3) it has provisions to
                                                                                                      available.              monitor two or more
                                                                                                                              IROLs when the main
                                                                                                                              monitoring system is
                                                                                                                              not available, or
                                                                                                                              4) it has provisions to
                                                                                                                              monitor SOLs and one
                                                                                                                              IROL when the main
                                                                                                                              monitoring system was
                                                                                                                              unavailable.

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Encompassing All Commission-Approved Reliability Standards
Standard     Requirement
                                       Text of Requirement                        Lower VSL             Moderate VSL                High VSL                   Severe VSL
Number         Number
IRO-002-1   R9.            Each Reliability Coordinator shall control its   Reliability               Reliability             Reliability Coordinator     Reliability
                           Reliability Coordinator analysis tools,          Coordinator has           Coordinator has         has approval rights for     Coordinator approval
                           including approvals for planned                  approval rights for       approval rights for     planned maintenance         is not required for
                           maintenance. Each Reliability Coordinator        planned maintenance       planned                 but does not have plans     planned maintenance.
                           shall have procedures in place to mitigate the   outages of analysis       maintenance but         to mitigate the effects
                           effects of analysis tool outages.                tools but does not have   does not have plans     of outages of the
                                                                            approval rights for       to mitigate the         analysis tools and does
                                                                            work on analysis tools    effects of outages of   not have approval rights
                                                                            that creates a greater    the analysis tools.     for work on analysis
                                                                            risk of an unplanned                              tools that creates a
                                                                            outage of the tools.                              greater risk of an
                                                                                                                              unplanned outage of the
                                                                                                                              tools.
IRO-003-2   R1.            Each Reliability Coordinator shall monitor       N/A                       N/A                     The Reliability             The Reliability
                           all Bulk Electric System facilities, which                                                         Coordinator failed to       Coordinator failed to
                           may include sub-transmission information,                                                          monitor all Bulk            monitor Bulk Electric
                           within its Reliability Coordinator Area and                                                        Electric System             System facilities,
                           adjacent Reliability Coordinator Areas, as                                                         facilities, which may       which may include
                           necessary to ensure that, at any time,                                                             include sub-                sub-transmission
                           regardless of prior planned or unplanned                                                           transmission                information, within
                           events, the Reliability Coordinator is able to                                                     information, within its     adjacent Reliability
                           determine any potential System Operating                                                           Reliability Coordinator     Coordinator Areas, as
                           Limit and Interconnection Reliability                                                              Area and adjacent           necessary to ensure
                           Operating Limit violations within its                                                              Reliability Coordinator     that, at any time,
                           Reliability Coordinator Area.                                                                      Areas, as necessary to      regardless of prior
                                                                                                                              ensure that, at any time,   planned or unplanned
                                                                                                                              regardless of prior         events, the Reliability
                                                                                                                              planned or unplanned        Coordinator is able to
                                                                                                                              events, the Reliability     determine any
                                                                                                                              Coordinator is able to      potential System
                                                                                                                              determine any potential     Operating Limit and
                                                                                                                              System Operating Limit      Interconnection
                                                                                                                              and Interconnection         Reliability Operating
                                                                                                                              Reliability Operating       Limit violations within
                                                                                                                              Limit violations within     its Reliability
                                                                                                                              its Reliability             Coordinator Area.
                                                                                                                              Coordinator Area.


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Encompassing All Commission-Approved Reliability Standards
Standard     Requirement
                                       Text of Requirement                          Lower VSL             Moderate VSL                High VSL                  Severe VSL
Number         Number
IRO-003-2   R2.            Each Reliability Coordinator shall know the        N/A                       N/A                    The Reliability             The Reliability
                           current status of all critical facilities whose                                                     Coordinator failed to       Coordinator failed to
                           failure, degradation or disconnection could                                                         know either the current     know the current
                           result in an SOL or IROL violation.                                                                 status of all critical      status of all critical
                           Reliability Coordinators shall also know the                                                        facilities whose failure,   facilities whose
                           status of any facilities that may be required                                                       degradation or              failure, degradation or
                           to assist area restoration objectives.                                                              disconnection could         disconnection could
                                                                                                                               result in an SOL or         result in an SOL or
                                                                                                                               IROL violation or the       IROL violation and
                                                                                                                               status of any facilities    the status of any
                                                                                                                               that may be required to     facilities that may be
                                                                                                                               assist area restoration     required to assist area
                                                                                                                               objectives.                 restoration objectives.
IRO-004-1   R1.            Each Reliability Coordinator shall conduct         The Reliability           The Reliability        The Reliability             The Reliability
                           next-day reliability analyses for its              Coordinator failed to     Coordinator failed     Coordinator failed to       Coordinator failed to
                           Reliability Coordinator Area to ensure that        conduct next-day          to conduct next-day    conduct next-day            conduct next-day
                           the Bulk Electric System can be operated           reliability analyses or   reliability analyses   reliability analyses or     reliability analyses or
                           reliably in anticipated normal and                 contingency analysis      or contingency         contingency analysis        contingency analysis
                           Contingency event conditions. The                  for its Reliability       analysis for its       for its Reliability         for its Reliability
                           Reliability Coordinator shall conduct              Coordinator Area for      Reliability            Coordinator Area for        Coordinator Area for
                           Contingency analysis studies to identify           one (1) day during a      Coordinator Area       four (4) to five (5) days   more than five (5)
                           potential interface and other SOL and IROL         calendar month.           for two (2) to three   during a calendar           days during a calendar
                           violations, including overloaded transmission                                (3) days during a      month.                      month.
                           lines and transformers, voltage and stability                                calendar month.
                           limits, etc.
IRO-004-1   R2.            Each Reliability Coordinator shall pay             N/A                       N/A                    N/A                         The Reliability
                           particular attention to parallel flows to ensure                                                                                Coordinator failed to
                           one Reliability Coordinator Area does not                                                                                       monitor parallel flows
                           place an unacceptable or undue Burden on an                                                                                     to ensure one
                           adjacent Reliability Coordinator Area.                                                                                          Reliability
                                                                                                                                                           Coordinator Area does
                                                                                                                                                           not place an
                                                                                                                                                           unacceptable or undue
                                                                                                                                                           Burden on an adjacent
                                                                                                                                                           Reliability
                                                                                                                                                           Coordinator Area.
IRO-004-1   R3.            Each Reliability Coordinator shall, in             The Reliability           The Reliability        The Reliability             The Reliability
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Complete Violation Severity Level Matrix (IRO)
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Standard     Requirement
                                       Text of Requirement                          Lower VSL                Moderate VSL                 High VSL                   Severe VSL
Number         Number
                           conjunction with its Transmission Operators         Coordinator, in             Coordinator, in          Coordinator, in             Coordinator, in
                           and Balancing Authorities, develop action           conjunction with its        conjunction with its     conjunction with its        conjunction with its
                           plans that may be required, including               Transmission                Transmission             Transmission Operators      Transmission
                           reconfiguration of the transmission system,         Operators and               Operators and            and Balancing               Operators and
                           re-dispatching of generation, reduction or          Balancing Authorities,      Balancing                Authorities, failed to      Balancing Authorities,
                           curtailment of Interchange Transactions, or         failed to develop           Authorities, failed to   develop action plans        failed to develop
                           reducing load to return transmission loading        action plans that may       develop action plans     that may be required,       action plans that may
                           to within acceptable SOLs or IROLs.                 be required, including      that may be              including                   be required, including
                                                                               reconfiguration of the      required, including      reconfiguration of the      reconfiguration of the
                                                                               transmission system,        reconfiguration of       transmission system, re-    transmission system,
                                                                               re-dispatching of           the transmission         dispatching of              re-dispatching of
                                                                               generation, reduction       system, re-              generation, reduction or    generation, reduction
                                                                               or curtailment of           dispatching of           curtailment of              or curtailment of
                                                                               Interchange                 generation,              Interchange                 Interchange
                                                                               Transactions, or            reduction or             Transactions, or            Transactions, or
                                                                               reducing load to return     curtailment of           reducing load to return     reducing load to return
                                                                               transmission loading        Interchange              transmission loading to     transmission loading
                                                                               to within acceptable        Transactions, or         within acceptable SOLs      to within acceptable
                                                                               SOLs or IROLs for           reducing load to         or IROLs for four (4) to    SOLs or IROLs for
                                                                               one (1) day during a        return transmission      five (5) days during a      more than five (5)
                                                                               calendar month.             loading to within        calendar month.             days during a calendar
                                                                                                           acceptable SOLs or                                   month.
                                                                                                           IROLs for two (2) to
                                                                                                           three (3) days during
                                                                                                           a calendar month.
IRO-004-1   R4.            Each Transmission Operator, Balancing               The responsible entity      The responsible          The responsible entity      The responsible entity
                           Authority, Transmission Owner, Generator            in the Reliability          entity in the            in the Reliability          in the Reliability
                           Owner, Generator Operator, and Load-                Coordinator Area            Reliability              Coordinator Area            Coordinator Area
                           Serving Entity in the Reliability Coordinator       provided the                Coordinator Area         provided the                provided the
                           Area shall provide information required for         information required        provided the             information required for    information required
                           system studies, such as critical facility status,   for system studies,         information required     system studies, such as     for system studies,
                           Load, generation, operating reserve                 such as critical facility   for system studies,      critical facility status,   such as critical facility
                           projections, and known Interchange                  status, Load,               such as critical         Load, generation,           status, Load,
                           Transactions. This information shall be             generation, operating       facility status, Load,   operating reserve           generation, operating
                           available by 1200 Central Standard Time for         reserve projections,        generation,              projections, and known      reserve projections,
                           the Eastern Interconnection and 1200 Pacific        and known                   operating reserve        Interchange                 and known
                           Standard Time for the Western                       Interchange                 projections, and         Transactions, but said      Interchange
                           Interconnection.                                    Transactions, but said      known Interchange        information was             Transactions, but said
                                                                               information was             Transactions, but        provided after the          information was
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Complete Violation Severity Level Matrix (IRO)
Encompassing All Commission-Approved Reliability Standards
Standard     Requirement
                                      Text of Requirement                        Lower VSL               Moderate VSL                  High VSL                  Severe VSL
Number         Number
                                                                            provided after the         said information         required time as stated     provided after the
                                                                            required time as stated    was provided after       in IRO-004-1 R4 for         required time as stated
                                                                            in IRO-004-1 R4 for        the required time as     four (4) to five (5) days   in IRO-004-1 R4 for
                                                                            one (1) day during a       stated in IRO-004-1      during a calendar           more than five (5)
                                                                            calendar month.            R4 for two (2) to        month.                      days during a calendar
                                                                                                       three (3) days during                                month.
                                                                                                       a calendar month.
IRO-004-1   R5.            Each Reliability Coordinator shall share the     The Reliability            The Reliability          The Reliability             The Reliability
                           results of its system studies, when conditions   Coordinator failed to      Coordinator failed       Coordinator failed to       Coordinator failed to
                           warrant or upon request, with other              share the results of its   to share the results     share the results of its    share the results of its
                           Reliability Coordinators and with                system studies, when       of its system studies,   system studies, when        system studies, when
                           Transmission Operators, Balancing                conditions warranted       when conditions          conditions warranted or     conditions warranted
                           Authorities, and Transmission Service            or was requested, with     warranted or was         was requested, with         or was requested, with
                           Providers within its Reliability Coordinator     other Reliability          requested, with          other Reliability           other Reliability
                           Area. The Reliability Coordinator shall          Coordinators and with      other Reliability        Coordinators and with       Coordinators and with
                           make study results available no later than       Transmission               Coordinators and         Transmission                Transmission
                           1500 Central Standard Time for the Eastern       Operators, Balancing       with Transmission        Operators, Balancing        Operators, Balancing
                           Interconnection and 1500 Pacific Standard        Authorities, and           Operators,               Authorities, and            Authorities, and
                           Time for the Western Interconnection, unless     Transmission Service       Balancing                Transmission Service        Transmission Service
                           circumstances warrant otherwise.                 Providers within its       Authorities, and         Providers within its        Providers within its
                                                                            Reliability                Transmission             Reliability Coordinator     Reliability
                                                                            Coordinator Area for       Service Providers        Area for four (4) to five   Coordinator Area for
                                                                            one (1) day during a       within its Reliability   (5) days during a           more than five (5)
                                                                            calendar month.            Coordinator Area         calendar month.             days during a calendar
                                                                                                       for two (2) to three                                 month.
                                                                                                       (3) days during a
                                                                                                       calendar month.
IRO-004-1   R6.            If the results of these studies indicate         The Reliability            The Reliability          The reliability             The Reliability
                           potential SOL or IROL violations, the            Coordinator failed to      Coordinator failed       Coordinator failed to       Coordinator failed to
                           Reliability Coordinator shall direct its         direct action to address   to direct action to      direct action to address    direct action to address
                           Transmission Operators, Balancing                a potential SOL or         address a potential      a potential SOL or          a potential SOL or
                           Authorities and Transmission Service             IROL violation on one      SOL or IROL              IROL violation on four      IROL violation on
                           Providers to take any necessary action the       (1) occasion during a      violation on two (2)     (4) to five (5) occasions   more than five (5)
                           Reliability Coordinator deems appropriate to     calendar month.            to three (3)             during a calendar           occasions during a
                           address the potential SOL or IROL violation.                                occasions during a       month.                      calendar month.
                                                                                                       calendar month.
IRO-004-1   R7.            Each Transmission Operator, Balancing            The responsible entity     The responsible          The responsible entity      The responsible entity

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Complete Violation Severity Level Matrix (IRO)
Encompassing All Commission-Approved Reliability Standards
Standard     Requirement
                                       Text of Requirement                         Lower VSL            Moderate VSL               High VSL                  Severe VSL
Number         Number
                           Authority, and Transmission Service               failed to comply with    entity failed to       failed to comply with      failed to comply with
                           Provider shall comply with the directives of      the directives of its    comply with the        the directives of its      the directives of its
                           its Reliability Coordinator based on the next     Reliability              directives of its      Reliability Coordinator    Reliability
                           day assessments in the same manner in             Coordinator based on     Reliability            based on the next day      Coordinator based on
                           which it would comply during real time            the next day             Coordinator based      assessments in the same    the next day
                           operating events.                                 assessments in the       on the next day        manner in which it         assessments in the
                                                                             same manner in which     assessments in the     would comply during        same manner in which
                                                                             it would comply          same manner in         real time operating        it would comply
                                                                             during real time         which it would         events on four (4) to      during real time
                                                                             operating events on      comply during real     five (5) occasions         operating events on
                                                                             one (1) occasion         time operating         during a calendar          more than five (5)
                                                                             during a calendar        events on two (2) to   month.                     occasions during a
                                                                             month.                   three (3) occasions                               calendar month.
                                                                                                      during a calendar
                                                                                                      month.
IRO-005-2   R1.            Each Reliability Coordinator shall monitor        The Reliability          The Reliability        The Reliability            The Reliability
                           its Reliability Coordinator Area parameters,      Coordinator failed to    Coordinator failed     Coordinator failed to      Coordinator failed to
                           including but not limited to the following:       monitor one (1) of the   to monitor two (2)     monitor three (3) of the   monitor more than
                                                                             elements listed in       of the elements        elements listed in IRO-    three (3) of the
                                                                             IRO-005-2 R1.1           listed in IRO-005-2    005-2 R1.1 through         elements listed in
                                                                             through R1.10.           R1.1 through R1.10.    R1.10.                     IRO-005-2 R1.1
                                                                                                                                                        through R1.10.
IRO-005-2   R1.1.          Current status of Bulk Electric System            N/A                      N/A                    N/A                        The Reliability
                           elements (transmission or generation                                                                                         Coordinator failed to
                           including critical auxiliaries such as                                                                                       monitor the current
                           Automatic Voltage Regulators and Special                                                                                     status of Bulk Electric
                           Protection Systems) and system loading.                                                                                      System elements
                                                                                                                                                        (transmission or
                                                                                                                                                        generation including
                                                                                                                                                        critical auxiliaries
                                                                                                                                                        such as Automatic
                                                                                                                                                        Voltage Regulators
                                                                                                                                                        and Special Protection
                                                                                                                                                        Systems) and system