Today’s LiveWire Spotlight describes our analysis of NERC’s Notices of Penalty in 4Q2019.  During the quarter, the ERO posted five filings using the unabridged Notice of Penalty (NOP) Process – a time-consuming process reserved for only the most severe violations.  The most substantial penalty was $2,300,000 for four non-CIP infractions that led to a 11-minute frequency event in WECC after planned maintenance.

Violations that compromise BES cyber security continue to result in the highest penalties.  However, expect those that contribute to system events or indicate malfeasance on the part of the Registered Entity will treated harshly if they should occur.