NERC Audits for FERC Compliance: Lessons Learned

Meeting the Complex NERC Reliability Standards to Avoid Substantial Penalties

Recording of a 90-minute premium CLE webinar with Q&A

Conducted on Tuesday, February 23, 2010

Recorded event now available

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Course Materials

This CLE course will discuss complying with NERC's reliability standards, compiling evidence needed to demonstrate compliance, preparing for NERC audits, and responding to possible compliance violations.


Compliance with the NERC Reliability Standards is complex and challenging. Although primarily technical in nature, the Reliability Standards include significant legal and regulatory hurdles for companies.

Managing the risks associated with the audit requires first undertaking a pre-audit assessment, then addressing potential audit problems, and finally implementing a program and structure to ensure continued compliance.

With the threat of penalties up to $1 million per day per violation, companies and counsel must thoroughly understand the audit process and how to minimize the risk of non-compliance.

Listen as our authoritative panel of attorneys experienced with NERC audits examines the audit process from counsel's perspective and discusses internal compliance programs, pre-audit preparation, substantiation of compliance, and steps to take if auditors identify a potential violation.



  1. Internal compliance programs
    1. Assessment
    2. Remedial action plan
    3. Implementation
  2. Audit process
  3. Pre-audit preparation
    1. Identifying potential areas of risk
    2. Self-reporting?
    3. Mock audit
  4. Demonstrating compliance
  5. Responding to possible violations


The panel will review these and other key questions:

  • What strategies should companies and counsel employ to develop and implement effective compliance programs?
  • What are the key areas of potential risk and what steps should companies and counsel take to minimize those risks?
  • What actions should companies and counsel take if auditors identify possible violations?


Deborah A. Carpentier
Deborah A. Carpentier

Dickstein Shapiro

She focuses primarily on federal regulatory and transactional energy issues for electric utilities and natural gas...  |  Read More

J. Christopher Hajovsky
J. Christopher Hajovsky
Director of Regulatory Affairs and NERC Reliability Standards
RRI Energy

His responsibilities included development and oversight for RRI Energy’s NERC Corporate Compliance Program,...  |  Read More

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