NERC Proposes To Reduce Burden Through Risk-Based Registration Initiative

On December 11, 2014, the North American Electric Reliability Corporation ("NERC") submitted proposed revisions to its Rules of Procedure in order to implement the Risk-Based Registration ("RBR") Initiative.  If approved, the revisions would significantly modify how NERC assigns responsibility to entities for compliance with mandatory Reliability Standards.  Among the proposed changes, NERC would eliminate some functional registration categories entirely, and adopt a risk-based approach that would permit some entities to limit the number of Reliability Standards that apply to them within a particular functional registration category.  In its filing, NERC estimated that that proposed revisions would, if approved by the Commission, "reduce the regulatory burden of approximately 700 organizations, and allow such organizations to focus on issues that impact reliability."