Agenda 2014 Standards and Compliance Fall Workshop September 23–25, 2014 The Westin Buckhead Atlanta 3391 Peachtree Road NE Atlanta, GA 30326 Tuesday, Sept. 23 Presentation Speaker(s) 10:00 a.m.–Noon (optional) NERC Standards and Compliance 101: NERC’s history; standards development; compliance program; basic web tutorial Ryan Stewart, NERC Standards Developer; Adina Mineo, NERC Senior Auditor Noon–1:00 p.m. Lunch 1:00–1:15 p.m. Welcome and Introductions Jordan Mallory, NERC Standards Developer Specialist; Ryan Stewart, NERC Standards Developer 1:15–2:00 p.m. Keynote Remarks Mark Lauby, NERC Senior Vice President and Chief Reliability Officer 2:00–2:15 p.m. Break 2:15–2:30 p.m. Project Management and Oversight Subcommittee (PMOS) Update Jennifer Sterling, PMOS Chair 2:30–3:15 p.m. NERC Standards Update and the 2015– 2017 Reliability Standards Development Plan Valerie Agnew, NERC Director of Standards; Laura Hussey, NERC Director of Standards Development 3:15–4:15 p.m. Reliability Assurance Initiative Update Steven Noess, NERC Director of Compliance Assurance 4:15 – 4:45 p.m. Compliance Implementation Plan Overview Jim Armstrong, NERC Audit Manager; Adina Mineo, NERC Senior Auditor 4:45–5:00 p.m. General Q&A Jordan Mallory, NERC Standards Developer Specialist 5:00–6:30 p.m. Reception
Transcript
Agenda 2014 Standards and Compliance Fall Workshop September 23–25, 2014 The Westin Buckhead Atlanta 3391 Peachtree Road NE Atlanta, GA 30326
Developer Specialist 8:15–9:15 a.m. CIP Version 5 Standards Revisions Ryan Stewart, NERC Standards
Developer; Marisa Hecht, NERC Standards Developer
9:15–10:15 a.m. CIP Version 5 Transition Steven Noess, NERC Director of Compliance Assurance; Tobias Whitney, NERC CIP Compliance Manager
10:15–10:30 a.m. Break 10:30–11:30 a.m. CIP-014-1 – Physical Security Steven Noess, NERC Director of
Compliance Assurance; Stephen Crutchfield, NERC Standards Developer
11:30 a.m.–Noon Miscellaneous Q&A and Closing Remarks Valerie Agnew, NERC Director of Standards; Jordan Mallory, NERC Standards Developer Specialist; Ryan Stewart, NERC Standards Developer
Agenda – Standards and Compliance Fall Workshop – September 23–25, 2014 3
Speaker Bios NERC Standards and Compliance Workshop September 23–25, 2014 Valerie Agnew ([email protected]) Valerie Agnew is currently the director of standards for NERC. She joined NERC in early 2009, and has also held the positions of director of standards development, manager of interface and outreach in compliance operations, and manager of enforcement processing. She came to NERC from Honeywell International in Phoenix, where she negotiated and managed international aerospace contracts. Prior to Honeywell, she was the Director of Commercial Customer Care for UniSource Energy (Tucson Electric Power and UniSource Energy Services - Gas and Electric) in Tucson, Arizona. Ms. Agnew is a licensed attorney in the state of Arizona and has an M.B.A. from Colorado State University. Jim Armstrong ([email protected]) Jim Armstrong joined the NERC staff on April 16, 2012 in the Atlanta, Georgia office as the Audit Manager reporting to Jerry Hedrick. In his most recent role with Assurant Inc., Jim was an Audit Manager and was responsible for mitigating risk for three primary business units which compiled nearly 40 percent of the company's $8 billion in revenue. Prior, he was with MedQuest Associates as an Internal Controls Manager. He also served with MCI, Inc. as an Internal Audit Manager. Jim is a Certified Internal Auditor (CIA) with approximately 14 years of financial, operational, compliance, fraud and Sarbanes-Oxley audit experience. Jim also holds a Bachelor of Science degree from the University of South Florida. Terry Brinker ([email protected]) Terry Brinker currently serves as Manager of Registration Services. As part of his new duties Terry manages the regional entity registration oversight program, monitors the implementation of the regional registration programs for consistency with NERC requirements and provides management and guidance to improve registration and certification processes within NERC and the Regional Entities. Terry joined NERC on August 15, 2011 in the Atlanta, Georgia office as an Event Investigator where he was responsible for performing Compliance Inquiries of power system events and performing non-public Compliance Violation Investigations. Terry most recently worked as a Reliability Coordinator at Midwest ISO in Carmel, Indiana. He was involved in the startup of MISO's Energy and Ancillary Services Markets. Terry has over 17 years of experience in the electric industry ranging from power plant production, transmission installation and maintenance, and real time control room operations. Prior to working for MISO he was a Transmission System Supervisor for Northern Indiana Public Service Company. Terry is a NERC Certified System Operator and has a Bachelor’s of Organization Management from Calumet College and his MBA from Indiana University Northwest.
Thomas Burgess ([email protected]) Thomas Burgess joined NERC in January 2013 as the vice president and director of reliability assessment and performance analysis. Prior to NERC, Mr. Burgess most recently worked at FirstEnergy Corporation, serving as executive director of integrated system planning and development, where he was responsible for developing strategic plans that maximized value for the transmission and generation business segment, as well as developing integrated planning strategies that optimized transmission and generation. Prior to that, he worked for the Ohio Edison Company and the Pennsylvania Power Company, serving in numerous engineering, planning, regulatory, and transmission policy positions. Before he began working for NERC, Burgess participated in many NERC efforts, including serving on the Member Representatives Committee and as a former chair of the NERC Planning Committee. He holds a B.S. in electric power engineering from Rensselaer Polytechnic Institute, a M.S. in electrical engineering from University of Akron, and J.D. from the University of Akron Law School.
Sean Cavote ([email protected]) Sean Cavote joined NERC on January 28, 2013 as a standards developer. Prior to NERC, Mr. Cavote was with NiSource in Indianapolis, Indiana where he was a senior FERC attorney. His prior experience was with Van Ness Feldman in Washington, D.C. as an associate energy attorney, and with United Dynamics in Louisville, Kentucky as a power generation consultant. Mr. Cavote graduated from the University of Louisville with a BA in Political Science and later earned a Juris Doctor from the George Washington University Law School. Stephen Crutchfield ([email protected]) Steve Crutchfield joined NERC as a Standards Developer in May of 2007. His role is to facilitate and provide guidance to drafting teams in the development of technically excellent and timely reliability standards for the reliable operation and planning of the bulk power system.
Prior to joining NERC, Steve was a Project Manager with Shaw Energy Delivery Services, managing engineering and construction projects in the substation and transmission line fields. Steve’s background also includes experience with PJM as Manager of RTO Integration, working on the operations and markets integration of new members (AEP, ComEd, Dayton, Dominion and Duquesne) into PJM and southern seams operations issues with Progress Energy, Duke and TVA. Steve also helped lead the team that was developing GridSouth in the dual roles of Organization Architect and Manager of Customer Support. Prior to GridSouth, Steve was the Manager of Power System Operations Training at Progress Energy where he spent over 10 years training System Operators and Engineers. Overall, Steve was with Progress Energy for 16 years.
Steve received his Bachelor of Arts in Physics from the University of Virginia and Masters of Science in Electrical Engineering from North Carolina State University. Steve also holds a Master of Science in Management degree, also from North Carolina State.
Steve resides in Fort Mill, South Carolina with his wife, Lisa, who is a consultant to the Pharmaceutical industry. They have two sons, Connor and Colin. In their spare time, Steve and his family like to play golf and travel. Maris Hecht ([email protected]) Marisa Hecht is a Standards Developer at NERC in Atlanta. She currently is one of the co-developers on the CIP Version 5 Revisions standards development efforts. Prior to joining NERC, Marisa worked at Van Ness Feldman, LLP, where she was an Associate Attorney practicing energy regulatory law in Washington, D.C. Marisa graduated from Princeton University with a Bachelor's degree in History. She received her law degree from American University, Washington College of Law. Laura Hussey ([email protected]) Laura Hussey is one of NERC’s directors of standards development. Previously, she served as the director of standards processes, and she joined NERC in 2010 as the standards process manager. Prior to joining NERC her industry experience includes one year as director of cyber security policy at Schweitzer Engineering Laboratories and nine years at Edison Electric Institute, where she held various positions, most recently serving as manager of security, infrastructure and operations. In addition to her electric industry experience, Ms. Hussey has 15 years of experience as an IT trainer and consultant. In her consulting role, she worked with organizations from a variety of sectors, including healthcare, banking, manufacturing, legal services, and higher education, to select or develop and implement solutions to achieve business objectives. Ms. Hussey has a B.S. in information science from the University of Pittsburgh and has completed graduate coursework in Georgetown University’s communication, culture, and technology program, where she focused on public policy for network industries.
Tony Jankowski ([email protected]) Tony Jankowski is the Manager of Electric System Operations at Wisconsin Electric Power Company d/b/a/ We Energies. He is responsible for the safe, reliable Bulk Electric System operation of the transmission dependent utility’s Balancing Authority Area within the Midwest ISO. Mr. Jankowski has over 26 years of experience in the Electric Utility Industry through various assignments involving nuclear and fossil generation, wholesale merchant business and Bulk Electric System operations. He is a NERC Certified Reliability Operator and has been involved in regulatory and industry policy issues for over 16 years. Mr. Jankowski actively participates in MISO, RFC and NERC committees as: Chair of the MISO Reliability Subcommittee; a member of the RFC Reliability Committee, NERC Operating Reliability Subcommittee, NERC Functional Model Working Group, and MISO Balancing Authority Committee. Tony
served on the GOTO task force and FM-DRAT both of which align with the Dispersed Power Producing Resources project. He has also been a member of several past and present RFC and NERC Standard Drafting Teams, along with numerous past group or committee positions. Soo Jin Kim ([email protected]) Soo Jin Kim joined NERC in December 2012. She joined NERC as a Standard Developer, and she is the current Manager of Reliability. Prior to joining NERC, she was an associate in Troutman Sanders LLP’s Energy Practice Group. At Troutman Sanders, she worked on a variety of FERC compliance matters, and prior to her law career, she worked for consulting firms where she focused on energy and commodity training. She has a J.D. from American University and a B.A. in Economics and English from the University of Georgia.
Mark Lauby ([email protected]) Mark G. Lauby is the vice president and director of standards, responsible for leading a team that develops and enhances NERC’s Reliability Standards. Joining NERC in January 2007, Mr. Lauby previously was the vice president and director of reliability assessments and performance analysis.
Prior to joining NERC, Mr. Lauby worked since 1987 for the Electric Power Research Institute (EPRI) where he held a number of senior positions, including: director, Power Delivery & Markets; managing director, Asia, EPRI International; and Manager, Power System Engineering in the Power System Planning and Operations Program. Mr. Lauby started his career in the electric industry at the Mid-Continent Area Power Pool (MAPP), in Minneapolis, Minnesota in 1979. His responsibilities included transmission planning, power system reliability assessment, and probabilistic evaluation.
Mr. Lauby earned both his Bachelor of Electrical Engineering in 1980 and Master of Science in Electrical Engineering in 1989 from the University of Minnesota. In addition, Mr. Lauby attended the London Business School Accelerated Development Program.
He is the author of numerous papers on the subjects of power system reliability, expert systems, transmission system planning, and power system numerical analysis techniques. Mr. Lauby has served as Chair and is a life member of the International Electricity Research Exchange (IERE), and served as Chairman of a number of IEEE working groups. Mr. Lauby has been recognized for his technical achievements in many technical associations, including the 1992 IEEE Walter Fee Young Engineer of the Year Award. In November 2011, Mr. Lauby was named a Fellow by IEEE. He received the honor for "leadership in the development and application of techniques for bulk power system reliability."
Jordan Mallory ([email protected]) Jordan Mallory joined NERC in June 2011 as an administrative assistant for compliance operations. She was promoted in January 2013 to a standards developer specialist and has completed the development of PER-005-2 and is currently working on PRC-005-X. Before joining NERC in 2011, she worked at MEAG Power. Jordan holds a B.S. in managerial science from Georgia State University.
Al McMeekin ([email protected]) Al McMeekin joined NERC as a Standards Developer in October of 2009. His role is to facilitate and provide guidance to drafting teams in the development of technically excellent, timely, and unambiguous reliability standards that support the reliable operation and planning of the bulk power system. Al earned his Bachelor of Science Degree in Agricultural Engineering from Clemson University and is a registered Professional Engineer in the states of South Carolina and Georgia. Prior to joining NERC, Al worked for twenty-nine years with South Carolina Electric & Gas Company (SCE&G) holding a variety of professional and supervisory positions within the distribution and transmission organizations. Al has two children, Melissa lives in Seattle, WA, and Hayne lives in Jackson Hole, WY. Al resides in Atlanta, GA and enjoys golf and travel. Adina Mineo ([email protected]) Adina Mineo joined NERC as a senior compliance operations auditor in January 2013. In this capacity, she is responsible for managing multiple activities across the ERO that supports oversight of the Regional Entities, drives risk-based audit capabilities. Ms. Mineo also develops and delivers training on audit techniques as well as conduct and lead audit engagements. Prior to joining NERC, Ms. Mineo worked in FERC’s Division of Audits in the Office of Enforcement for seven years. She has led a variety of multi-scope FERC-mandated audits within the electric and gas industry. Most recently, Ms. Mineo worked on audits that evaluated Regional Entity compliance with the NERC Rules of Procedure, Regional Entity Bylaws, and Delegation Agreements. Additionally, she has conducted financial performance reviews of the Regional Entities and their business plan and budgets. Ms. Mineo has B.S. from Edinboro University of Pennsylvania and an M.B.A. from Upper Iowa University with a focus in accounting. She is a Certified Public Accountant in the state of Virginia.
Steven Noess ([email protected]) Steven Noess is the Director of Compliance Assurance. Steve joined the NERC staff on May 25, 2011, as a Standards Developer reporting to Valerie Agnew. Prior to joining NERC, Steven was an attorney at the Minnesota Legislature, where he advised legislative members, drafted and managed development of legislation, and coordinated rulemaking with executive branch agencies. Steven also worked as a law clerk for Thrivent Financial and Ameriprise Financial, both of Minneapolis, MN, with a focus on mutual fund law, tax law, and employment law. Before becoming an attorney, Steven served on active duty in the United States Army, serving in Germany-based communications and intelligence units. From 2003 to 2004, he deployed to Iraq and was awarded the Bronze Star Medal.
Steven has a bachelor’s of science degree in International Relations and Systems Engineering from the U.S. Military Academy, West Point, and his J.D. from the University of Minnesota Law School. Steven is a licensed attorney in the state of Minnesota. Mark Olson ([email protected]) Mark Olson joined the NERC staff on October 23, 2012 in the Atlanta, Georgia office as a Standards Developer reporting to Laura Hussey. Mark recently concluded a career as an officer in the U.S. Navy where he served in various positions related to the operations and management of surface ships and naval personnel. He has a master's degree in electrical engineering from the Naval Postgraduate School and a bachelor’s degree from the U.S. Naval Academy. Darrel Richardson ([email protected]) Darrel Richardson joined the NERC staff as a Standards Developer. In this role he facilitates and provides guidance to drafting teams in the development of technically excellent and timely reliability standards for the reliable operation and planning of the bulk power system. Darrel began his career with NERC in November 2007. Darrel has extensive experience in the utility industry having spent over 37 years with Illinois Power Company. In his tenure at Illinois Power he held several different positions in the Engineering, Planning and Operations groups. Among the position he has held are Transmission Coordinator, Generation Coordinator, Manager Wholesale Marketing, Manager Wholesale Marketing and Trading, Director Generation Control and Manager Compliance. Darrel lives in Decatur, Illinois with his wife, Teresa and three children, Jeremy, Heather and Melissa, all of whom are presently in college. He enjoys golf, music and reading. Jennifer T. Sterling ([email protected]) Jennifer T. Sterling is the Director, NERC Compliance Program for Exelon. In her current position, she is responsible for managing the Exelon NERC Reliability Standards Compliance Program. Her areas of oversight include administering the internal NERC Reliability Standard Compliance Program requirements across the applicable Exelon Business Units and managing the external contacts with NERC and the Regions. She also has responsibility for the business planning activities for Exelon’s Transmission Strategy and Compliance department. She has also held positions in ComEd’s System Planning, Bulk Power Operations, Transmission Policy and Regulatory & Strategic Services Departments. Jennifer is an active participant in industry working groups and forums including NERC Standards Drafting Teams and the EEI Reliability Executive Advisory Committee. She currently serves as a member of the NERC Standards Committee and is the current Chair of the NERC Project Management and Oversight Subcommittee.
She has a Bachelor of Science degree in Electrical Engineering as well as a Master of Science degree in Electrical Engineering both from the University of Illinois – Urbana-Champaign. She is a registered Professional Engineer in the State of Illinois. Prior to assuming her present position in January 2007, she served as Exelon’s Director of Transmission Planning. In that position, she was responsible for transmission system reinforcement, technical studies and transmission system interconnections for both the ComEd and PECO transmission systems. Ryan Stewart ([email protected]) Ryan Stewart joined NERC in July 2010. Currently, he is a standards developer for the Project 2014-02 CIP Version 5 Revisions Standard Drafting Team. He was the developer for the Project 2012-05 ATC Revisions (MOD A) team, which consolidated six FERC-approved standards into one encompassing the reliability components of Available Transmission Capability. Before joining the standards department, Mr. Stewart supported organization registration, certification, and compliance monitoring as an engineer in the compliance operations department. In that capacity, he assisted the Regional Entities in implementing their daily registration and certification functions, writing detailed reports on those standards that were most violated, and supporting the NERC Compliance & Certification Committee. Mr. Stewart has a B.S. in systems engineering from The George Washington University, with minors in computer science and economics.
Acronyms and Initialisms NERC Standards and Compliance Workshop April 1-3, 2014 Acronym Stands for: AC Alternating Current ACE Area Control Error ADI ACE Diversity Interchange AFC Available Flowgate Capability AFN Abnormal Frequency Notification ATC Available Transfer Capability ATF After the Fact AGC Automatic Generation Control AIE Area Interchange Error ALM Active Load Management ALR Adequate Level of Reliability AML Actively Monitored List AMR Automatic Meter Reading ANSI American National Standards Institute APX Automatic Power Exchange ARS Automatic Reserve Sharing ATC Available Transmission Capacity ATEC Automatic Time Error Correction AVR Automatic Voltage Regulator BA Balancing Authority BAL Resource and Demand Balancing (Standards Family) BAAL Balancing Authority ACE Limit BES Bulk Electric System BOT Board of Trustees BOTCC Board of Trustees Compliance Committee BPS Bulk Power System CA Control Area or Critical Asset CAN Compliance Application Notice CAP Corrective Action Process CB Circuit Breaker CBM Capacity Benefits Margin CCA Critical Cyber Asset CCC Compliance and Certification Committee CCP Critical Constrained Path
CCVT Capacitor-coupled voltage transducer CEAP Cost Effective Analysis Process CEH Continuing Education Hour CEI Compliance Enforcement Initiative CETL Capacity Emergency Transfer Limit CF Coordinated Flowgates CIP Critical Infrastructure Protection (Standards Family) CIPC Critical Infrastructure Protection Committee CM Congestion Management CMEP Compliance Monitoring and Enforcement Program COM Communications (Standards Family) COO Continuity of Operations CPS Control Performance Standard CT Current Transformer CUG Compliance User(s’) Group CVI Compliance Violation Investigation CVT Capacitive Voltage Transformer DADS Future Demand Availability Data System DAM Day Ahead Market DB Data Base DCA Designated Congestion Areas DCLM Direct Control Load Management DCS Disturbance Control Standard DF Distribution Factor DFR Digital Fault Recorder DHS Department of Homeland Security DME Disturbance Monitoring Equipment DP Distribution Provider DSM Demand Side Management DTS Dispatcher Training Simulator EA Event Analysis EAIE Event Analysis and Information Exchange EDT Eastern Daylight Time EEI Edison Electric Institute EHV Extra High Voltage EMP Electromagnetic Pulse EMS Energy Management System EOP Emergency Preparedness and Operations (Standards Family) EPRI Electric Power Research Institute ERO Electric Reliability Organization
Acronyms and Initialisms: 2014 Standards and Compliance Spring Workshop 2
ES-ISAC Electricity Sector Information Sharing and Analysis Center ESP Electronic Security Perimeter ETC Existing Transmission Commitments ETIN Electronic Transmission Information Network FAC Facilities Design, Connections, and Maintenance (Standards Family) FAT Factory Acceptance Test FBA Flow-Based Analysis FCITC First Contingency Incremental Transfer Capability FCL Fault Current Limiter FCTTC First Contingency Total Transfer Capability FDR Frequency Data Recorder FEMA Federal Emergency Management Administration FERC Federal Energy Regulatory Commission FFT Find, Fix and Track (sometimes FFTR for Find, Fix, Track and Report) FM Functional Model FOH Forced Outage Hours FOIA Freedom of Information Act FPA Federal Power Act FRCC Florida Reliability Coordinating Council (Regional Entity) GADS Generation Availability Data System GCIR Generation Capability Import Requirement GLDF Generator-to-Load Distribution Factor GMD Geomagnetic Disturbance GMD Geometric Mean Distance GO Generator Owner GOL Generator Operator Limit GOP Generator Operator GSF Generator Shift Factor GSU Generator Step-up Transformer GTDF Generation Transfer Distribution Factor GUI Graphical User Interface GWh Gigawatt Hours HCA Host Control Area HEMP High-Altitude Electromagnetic Pulse HI Hourly Interruptible HILF High-Impact, Low-Frequency HVDC High Voltage Direct Current Hz Hertz
Acronyms and Initialisms: 2014 Standards and Compliance Spring Workshop 3
IA Interchange Authority IAIP Information Analysis and Infrastructure Protection IBM International Business Machines ICCP Inter-Control Center Protocol ICP Internal Compliance Program IDC Interchange Distribution Calculator IDF Interchange Distribution Factor IEEE Institute of Electrical and Electronics Engineers IESO Independent Electricity System Operator IMM Independent Market Monitor INPO Institute of Nuclear Power Operations INT Interchange Scheduling and Coordination (Standards Family) IOS Interconnection Operations Services IOU Investor Owned Utility IP Internet Protocol IPP Independent Power Producer IPX Independent Power Exchange IRL Interconnection Reliability Limit IRO Interconnection Reliability Operations and Coordination (Standards Family) IROL Interconnection Reliability Operating Limit IRP Integrated Resource Plan ISAC Information Sharing and Advisory Center ISC Independent Security Center ISO Independent System Operator JOA Joint Operating Agreement JTSIN Joint Transmission System Information Network KRSSC Key Reliability Standards Spot Check kV kilovolts LCO Limited Condition of Operation LDC Local Distribution Company LIFO Last In – First Out LMP Local Marginal Pricing LOOP Loss of Off-site Power LOP Loss of Potential LSE Load-Serving Entity LSF Load Shift Factor LTC Load Tap Changer LTRA Long Term Reliability Assessment
Acronyms and Initialisms: 2014 Standards and Compliance Spring Workshop 4
MM Market Monitor MOD Modeling, Data, and Analysis (Standards Family) MP Market Participants MRC Member Representatives Committee MRO Midwest Reliability Organization (Regional Entity) MTU Master Terminal Unit MUST Maximizing Utility System Transfer MVA MegaVoltAmperes MVAR Megavar MW Megawatts MWh Megawatt hours NAESB North American Energy Standards Board NCF Net Capacity Factor NCR NERC Compliance Registry NCSD National Cyber Security Division NDA Non-Disclosure Agreement NEAT NERC Event Analysis Tool NEB National Energy Board (Canada) NEM National Electricity Market NEPA National Energy Policy Act of 1992 NERC North American Electric Reliability Corporation NESC National Electric Safety Code NHC National Hurricane Center NIAC National Infrastructure Advisory Council NIPC National Infrastructure Protection Center NIPP National Infrastructure Protection Plan NNL Native and Network Load NOP Notice of Penalty NOPR Notice of Proposed Rulemaking Nox Nitrous Oxides NPCC Northeast Power Coordinating Council (Regional Entity) NPIR Nuclear Plant Interface Requirements NRC Nuclear Regulatory Commission NRECA National Rural Electric Cooperative Association NREL National Renewable Energy Laboratory NUC Nuclear (Standards Family) NUG Non-Utility Generator OAG Open Access Gateway OASIS Open Access Same Time Information System OATT Open Access Transmission Tariff
Acronyms and Initialisms: 2014 Standards and Compliance Spring Workshop 5
OC Operating Committee OL Operating Limit OP Operating Procedures OPF Optimal Power Flow OSL Operating Security Limit OTC Operating Transfer Capability OTDF Outage Transfer Distribution Factor PA Planning Authority PC Planning Committee or Planning Coordinator PCB Power Circuit Breaker PER Personnel Performance, Training, and Qualifications (Standards Family) PLC Programmable Logic Controller POD Point of Delivery POR Point of Receipt POTT Permissive Overreach Transfer Trip PRC Protection and Control (Standards Family) PSC Public Service Commission PSDR Power System Data Recorder PSE Purchasing-Selling Entity PSM Power System Measurements PSP Physical Security Perimeter PSS Power System Stabilizer PSS/E Power System Simulator/Electric PT Potential Transformer PTDF Power Transfer Distribution Factor PTP Point to Point Transmission Service PU Per Unit PUC Public Utilities Commission PUHCA Public Utilities Holding Company Act PURPA Public Utilities Regulator Policy Act PV Potential Violation PX Power Exchange QF Qualified Facility RA Reliability Authority RAI Reliability Assurance Initiative RAPA Reliability Assessment and Performance Analysis RAS Remedial Action Scheme RBAM Risk-Based Assessment Methodology RBB Registered Ballot Body
Acronyms and Initialisms: 2014 Standards and Compliance Spring Workshop 6
RBS Results-Based Standards RC Reliability Coordinator RCIS Reliability Coordinator Information System RE Regional Entity RFC ReliabilityFirst Organization (Regional Entity) RFI Request for Interchange RFP Request for Proposal RISC Reliability Issues Steering Committee RMS Root Mean Square ROP Rules of Procedure ROW Right-of-Way RP Resource Planner RPM Revolutions per Minute RSAW Reliability Standards Audit Worksheets RSDP Reliability Standards Development Plan RSG Reserve Sharing Group RTCA Real-Time Contingency Analysis RTU Remote Terminal Unit SAFFNR Situational Awareness for FERC, NERC, and the Regions SAR Standard Authorization Request SC Standards Committee SCADA Supervisory Control and Data Acquisition SDT Standard Drafting Team SDX System Data Exchange SE State Estimator SERC SERC Reliability Corporation (Regional Entity) SMD Solar Magnetic Disturbance SME Subject Matter Expert SOL System Operating Limits SOTC Standards Oversight and Technology Committee SPIG Standards Process Input Group SPM Standard Processes Manual SPOC Single Point of Contact SPP Southwest Power Pool RE (Regional Entity) SPS Special Protection Systems / Schemes SRI System Risk Index SSVT Station Services voltage transformer STDB Spare Transformer Database SVC Static Var Compensator TA Transmission Administrator
Acronyms and Initialisms: 2014 Standards and Compliance Spring Workshop 7
TADS Transmission Availability Data System TFC Total Flowgate Capability TDF Transfer Distribution Factor TFE Technical Feasibility Exception TLR Transmission Loading Relief TO Transmission Owner TOP Transmission Operator or Transmission Operations (Standards Family) TP Transmission Planner or Transmission Provider TPF Transaction Participation Factor TPL Transmission Planning (Standards Family) TRE Texas Reliability Entity (Regional Entity) TRM Transmission Reliability Margin TSIN Transmission System Information Network TSP Transmission Service Provider TSR Transmission Service Reservation TTC Total Transfer Capability TWh Terawatt hour (trillion watts hours) UFLS Under-Frequency Load Shedding URC Utilities Regulatory Commission UVLS Under Voltage Load Shedding VAR Voltage and Reactive (Standards Family) VPN Virtual Private Network VRF Violation Risk Factor VSA Voltage and Stability Analysis VSL Violation Severity Level WACS Wide-Area Control System WECC Western Electricity Coordinating Council (Regional Entity)
*If you think of an acronym or initialism that should be added to this list, email [email protected]*
Acronyms and Initialisms: 2014 Standards and Compliance Spring Workshop 8
IC- Initial CommentIB- Initial BallotAB - Additional BallotPB- Presented to BOTF-Projected filing with FYRP- Five-year Review Posting
Project Status
Project NumberActivity/Project (Project Names
Hyperlinked to Project Page) Deliverable Deadline, if any
Priority in 2014-2016 RSDP, if applicable (see
Note 1, below)2013 P81
Reqs Number
of Directives
# of Guidances
(see Note 2)Directionally consistent
with IERP findings Comments PMOS Liaison NERC ContactStatus: Green, Yellow,
Red
Milestones: Planned vs. Actual/Projected (See Notes 3 and 4)
Plan
Yes
Project extended to address an additional issue
by FERC Actual/ProjectedPlan
Yes Actual/ProjectedPlan
Yes Actual/ProjectedPlan
Yes
Delayed to coordinate with the development of
the SPS definition Actual/Projected FPlan
TBD Actual/ProjectedPlan
Yes Actual/Projected FPlan
Yes Actual/ProjectedPlan
Yes Actual/ProjectedPlan
Yes Actual/ProjectedPlan
Yes Actual/ProjectedPlan
n/a Actual/ProjectedPlan
Yes Actual/Projected
Plan
TBD Actual/ProjectedOn hold pending PlanTOP/IRO project Actual/Projected
PlanYes Actual/Projected
Plan
n/a Actual/ProjectedPlan
Yes Actual/Projected Plan
n/a Actual/Projected
Plan
n/a Actual/ProjectedPlan
TBD Actual/ProjectedPlan IB AB PB F
n/a Actual/Projected IB PB FPlan
n/a Actual/Projected
2010-04 Demand Data (MOD C)
CIP Version 5 Revisions
TOP/IRO
CIP
Various
Implementation of NUC Review Recommendations NUC-001
Geomagnetic Disturbance Mitigation Stage II
Medium (prioritized by SC January 2014)
2
14
Low
High
TPL-001
F
PB F
Project extended to address an additional issue
raised by FERC
Goal is to complete directives and file in time for FERC action prior to implementing TPL-001-4 Matt Morais Ed Dobrowolski
Gary Kruempel Sean Cavote
FERC filing deadline of January 21, 2015
PMOS Oversight
Deadline of January 31, 2015
Many FYRT recommendations being addressed in Project 2014-03
Passed final ballot.
Comment and ballot period being conducted until September 19.
Comment and ballot period being conducted until August 25.
Medium
This worksheet displays estimates of anticipated standards development milestones for projects in 2014, and it is intended to be a project management tool for use in tracking the status of projects under development compared to their anticipated milestones. Detailed information for each project is available from their respective project pages on the NERC website. Projects that remained from 2013's Project Tracking Spreadsheet that were not prioritized in the RSDP, but that are continuing beyond the first quarter of 2014, are also represented here. Projects not anticipated to continue beyond the first quarter of 2014 are not included (information for those projects remains available under the "Standards Under Development" page on the NERC website). Note that projects listed here represent known projects for 2014. As facts and circumstances warrant, it may be necessary to update this tool, and additional projects may be added in response to regulatory directives, input from RISC, or to meet goals of the NERC strategic plan.
2014 2015
PB
F
F
Ron Parsons Soo Jin Kim3
N t 1 Th i iti ti h fl t th i iti ti i d t f th 2014 2016 R li bilit St d d D l t Pl (RSDP) I it h t i iti i R li bilit St d d j t th RSDP
1
2014-01Standards Applicability for Dispersed Generation Resources
Goal is to complete (including regulatory approval) prior to BES Phase 2 implementation 7/1/2016
Medium (prioritized by SC March 2014)TBD TPL Directive
2014-02
May not move forward.
FERC filing deadline for certain directives of February 3, 2015.
High (prioritized by SC March 2014) 8
Milestone Keys:
Projected Posting ScheduleThe above is a link to the schedule of upcoming postings, which is updated weekly. It includes near term posting projections.
11
10 10
2
1
BAL-001, BAL-002, BAL-013 4
p concluded on July 25 but definition did not pass. Additional BOT milestone added. First is for definition of SPS; the second is for the standards.
Ballot concluded on June 9 but did not achieve approval.
Passed final ballot.
Scott BarfieldJennifer Sterling
Passed final ballot.
PB
Phase 2 ballot concluded on July 30 but did not achieve approval.
Al McMeekin
Brian Murphy2
Project posted for initial ballot on June 2. Six standards and the definitions passed ballot. CIP-003-6 and CIP-010-2 did not pass ballot.
Passed final ballot.
Ron Parsons Darrel Richardson
Ken Goldsmith Sean Cavote
Scott Miller Darrel Richardson
Matt Morais
Brian Murphy Mark Olson
FYRR
Soo Jin Kim
PB
PB
PB (FAC-001 and -
002)
FPB
ABIB
FYRR
PB
PBAB
IB (UFLS)IB
IB
AB
AB
F
AB
IB
2 Passed final ballot.
AB
PB
PB
PB
PB
PB
PB (affirmed stds only)
IB
PB
AB
IB
IC
F
AB
IC
PB
IB AB
PB
IB PB F
FIB PBAB
IBIB
PB
PB
PB
IB
PB
F
F
F
FYRP
PB
IB
IC
IB AB
AB
PB F
PB F
AB PB F
PB F
IB
IB
ABIB
AB
F
PB F
PB F
IB PB F
IB AB
IB
OCT NOV DEC
Second Quater Third Quarter Fourth Quarter First Quarter
F
JAN FEB MAR APR MAY JUN JUL AUG SEP
F
F
F
F
F
F
PB
2007-11
F
F
IB
IB
F
F
IB (UVLS)
FPB
F
IB
IB
AB
AB
PB
IB
PB
PB
IBIBStephen Eldridge2012-13
2013-03 TPL-007
BARC Directives and Issues-Project 2010-14.1 Balancing Authority Reliability-based Controls
Undervoltage Load Shedding and Underfrequency Load Shedding PRC-010, PRC-022, PRC-006
Mallory Huggins
PRC-005 posted for comment and ballot until September 12.
August 14. Periodic review project delayed for completion of Project 2014-01.1 due to limited subject matter experts in BAL standards
1
Charles Long Scott Barfield3
Connecting new facilities to the grid/Five-year Review of FAC standards FAC-001, FAC-002
Jordan Mallory
2010-05.1
2008-02
2010-13.3
2007-17.3
1
Medium
Relay Loadability Stable Power Swings PRC
Medium (prioritized by SC March 2014)
Protection System Maintenance: Sudden Pressure Relays PRC-005
Self-imposed deadline for definition of SPS is February 2015 for coordination with other PRC projects.
N/A
Special Protection Systems: Phase 2 of Protection Systems PRC
Medium (prioritized by SC March 2014)
December 31, 2014 deadline to address phase 3 directives covered by this project
N/A
BAL-004, BAL-005-0.1b, BAL-006-2
High
Low
Phase 1 of Protection Systems: Misoperations
Al McMeekin
PB
Jennifer SterlingKatherine Street (UVLS) and Lacey Ourso (UFLS)
Charles Yeung
PB
PRC-002, PRC-018 Medium
1
PRC-010-1 passed ballot and will be posted for final ballot first week of September. PRC-006-1 will be posted for ballot in late August.
AB
Guy Zito Steve Crutchfield
Jennifer Sterling AB
PBAB
2010-05.2
DECJUN JULMAR APR MAYJAN FEB AUG SEP
14
2
January 31, 2015 deadline to address concerns in NOPR proposing to remand TOP/IRO standards; the directives associated with this project are being addressed in Project 2014-03; consider consolidating the two projects on this spreadsheet.EOP-011-1 did not pass initial ballot and will be posted for additional ballot.3
Third Quarter
NOV
Fourth Quarter Second QuarterFirst Quarter
1
FYRR - Five-year Review Recommendation to SC
2014-03 TOP/IRO Revisions
F
IB
PBPB
High
High (prioritized by SC March 2014)
1Additional ballot concluded on June 25 but did not achieve approval.
System Protection Coordination PRC-001, PRC-027
VAR Directives VAR-002 6 5
OCT
Phase 2 of Balancing Authority Reliability-based Control; Time Error, AGC, and Inadvertent
N/A2013-04
Laura Anderson
Jennifer Sterling Ed Dobrowolski
Ken Goldsmith
1
N/A
Emergency Operations
Real-time Reliability Monitoring and Analysis Capabilities
New Standards or revisions to TOP and IRO standrds
Weekly Standards & Compliance Bulletin September 15–21, 2014
SPOTLIGHT ON THE RELIABILITY ASSURANCE INITIATIVE
2015 CMEP Implementation Plan, Risk Elements Guide, and Webinar Resources Now Available On September 8, NERC posted the 2015 ERO Compliance Monitoring and Enforcement Implementation Plan (CMEP IP), the annual operating plan carried out by Compliance Enforcement Authorities. Historically, the CMEP IP has specified the NERC Reliability Standards and Requirements to be actively monitored and audited by the Regional Entities during the implementation year. For the 2015 CMEP IP and beyond, NERC replaced the approach used to develop the CMEP IP and the Actively Monitored List. Instead of the one-size-fits-all list of Reliability Standards in the Actively Monitored List, the Risk Elements Guide posted on September 8 outlines the process by which NERC will identify continent-wide risks to reliability, as well as the Reliability Standards and registration functional categories related to those risks. This information informed the 2015 ERO CMEP IP, which in turn provides guidance to Regional Entities in the identification of regional risks for their Regional Entity Implementation Plans (which will be posted by the end of the month).
The new approach involves further tailoring through the Inherent Risk Assessment and the (voluntary) Internal Controls Evaluation – for which program guides are being finalized – and ultimately allows for a more individualized, risk-based compliance oversight plan for registered entities.
On September 9, NERC held a webinar focused on the CMEP IP and Risk Elements Guide. The slide presentation and webinar recording have been posted on the RAI web page.
Register Now for the RAI 101 Webinar From 2:00 to 4:00 p.m. Eastern on October 3, 2014, NERC will host an RAI 101 Webinar to provide detailed information on the ERO Enterprise’s Risk-Based CMEP. Webinar topics will include program details specific to both compliance monitoring and enforcement activities, information on newly released guidance and current documents, program status update and next steps, and available resources. Register today.
Join Ballot Pools (ballot pool windows close at 8:00 a.m. Eastern)
Project Action Start Date End Date Project 2008-02 - Undervoltage Load Shedding & Underfrequency Load Shedding - PRC-006-2
Join Ballot Pool 08/21/14 09/19/14
Posted for Comment (comment periods close at 8:00 p.m. Eastern)
Project Action Start Date End Date Project 2014-03 - Revisions to TOP/IRO Reliability Standards Draft RSAWs have been posted for feedback through September 19, 2014. Please submit comments to [email protected].
Order 754 New Users Returning Users 06/27/14 09/30/14
Project 2010-14.1 - Phase 1 of Balancing Authority Reliability-based Controls: Reserves - BAL-002-2 NEW A draft RSAW has been posted for feedback through October 2, 2014. Please submit comments to [email protected].
Comment Form 08/19/14 10/02/14
Project 2010-13.3 - Phase 3 of Relay Loadability: Stable Power Swings - PRC-026-1 NEW A draft RSAW has been posted for feedback through October 6, 2014. Please submit comments to [email protected].
Comment Form 08/22/14 10/06/14
Project 2008-02 - Undervoltage Load Shedding & Underfrequency Load Shedding - PRC-006-2 NEW A draft RSAW has been posted for feedback through October 8, 2014. Please submit comments to [email protected].
Comment Form 08/21/14 10/08/14
Weekly Standards & Compliance Bulletin | September 15–21, 2014 3
Project 2013-03 - Geomagnetic Disturbance Mitigation - TPL-007-1 NEW A draft RSAW has been posted for feedback through October 10, 2014. Please submit comments to [email protected].
Comment Form 08/27/14 10/10/14
Project 2010-05.2 - Special Protection Systems (Phase 2 of Protection Systems) - Revised Definition of Remedial Action Scheme
Comment Form 08/29/14 10/14/14
Project 2014-01 - Standards Applicability for Dispersed Generation Resources – Two Versions of VAR-002
Comment Form 08/27/14 10/16/14
Project 2014-02 - Critical Infrastructure Protection Standards Version 5 Revisions An explanation of the Version X Posting Strategy is available on the project page.
Project 2014-01 - Standards Applicability for Dispersed Generation Resources – Two Versions of PRC-004
Comment Form 09/05/14 10/22/14
OTHER ACTIVE COMMENT PERIODS
Posted for Comment
Posting Action Start Date End Date Draft RSAW for PRC-005-2: A draft Reliability Standard Audit Worksheet (RSAW) for PRC-005-2—Protection System Maintenance has been posted for a 30-day stakeholder comment period. The draft RSAW is posted on the RSAW home page under “Draft RSAWs for Comment.”
Proposed Revisions to NERC Rules of Procedure: NERC is proposing changes to its Rules of Procedure Section 300, Section 500, Appendix 2, Appendix 3D, Appendix 5A and Appendix 5B, as part of the Risk-Based
Registration Initiative. A redlined version of Sections 302.1 and 501.1.6 and Appendices 2, 3D, 5A and 5B showing the proposed additions, deletions and revisions, is now available at: NERC Rules of Procedure. In addition, the posting includes a separate document that provides a detailed summary of the proposed revisions. Comments on the Risk-Based Registration – Phase 1 - Enhanced Draft Design Framework and Implementation Plan also are welcome and are due on October 10, 2014. In addition to the design framework, the technical review findings are posted in the document entitled, Risk-Based Registration Technical Justification. This document will be updated as additional technical studies are completed. Additional information will be available on the Risk-Based Registration Initiative project page. NERC intends to submit these materials to the Board of Trustees at its November 13, 2014 meeting.
the comment period does not close until October 10, 2014, commenters are respectfully requested to submit their comments sooner than October
10, 2014, if possible, in order to provide additional time for NERC staff and the Regional Entities to consider
them.
GENERAL STANDARDS NEWS
NEW Reliability Standards Webpage Update In order to provide clarity to the NERC Reliability Standards page to reflect standards with retired requirements, an additional column titled “Retired Requirements” has been added under the main header. Each standard that has a retired requirement is designated with a “Yes” in the new column. NEW Resources Posted The following slide decks and streaming webinars have been posted to the Standards Webinars page:
• Project 2014-03 - Revisions to TOP/IRO Reliability Standards: Second Posting and RSAW Overview – September 9, 2014 (Slide Presentation) (Streaming Webinar)
New Balloting and Commenting Software System Since launching the new Standards Balloting System (SBS) on April 1, 2014, NERC has been accepting new registrations for both commenting and participating in ballots in the SBS. NERC appreciates the stakeholders who have registered and participated in the practice ballots. Thanks to this early participation, NERC staff has noted additional items to address and improve in the SBS software. Staff has been working closely with the vendor to address all issues and will not post projects in the SBS until it can ensure a smooth implementation. For now, NERC will continue to post in the original balloting system. Before any projects are posted in the SBS, NERC staff will provide notice with an announcement and an update in the Standards Bulletin. In the meantime, stakeholders should continue to register in the SBS, and can expedite the vetting process by sending justifications for segment qualifications to [email protected] using the segment criteria from Appendix 3D. A significant number of currently registered ballot body members from the original system have not yet registered and therefore would not be able to vote or submit comments in the SBS if it contained new projects. Please refer to the following helpful tools for guidance on registration and participation in the SBS: Standards Balloting and Commenting System (SBS) Login, Registration, Validation and Permissions Standards Balloting and Commenting System (SBS) Webinar Frequently Asked Questions Register for the NEW Registered Ballot Body
GENERAL COMPLIANCE AND ENFORCEMENT NEWS Cyber Security Transition Guidance News The final Cyber Security Reliability Standards: CIP V5 Transition Guidance and V3-V5 Compatibility Tables remain available on the CIP V5 Transition Program web page.
QUICK LINKS Reliability Assurance Initiative CIP V5 Transition Program Reliability Standard Audit Worksheets Risk-Based Registration Initiative
Weekly Standards & Compliance Bulletin | September 15–21, 2014 6
To further ensure registered entity confidence in the transition to CIP Version 5, NERC is working with the Regional Entities and stakeholder participants from the transition pilot programs to develop lessons learned on specific issues. Guidance documents on Impact Rating of Relays (Far-end Relay), Virtualization, Interactive Remote Access, and Impact Rating of Generation Resources (Generation Segmentation) are being finalized and will be posted to the CIP V5 Transition Program web page in coming weeks. Additional lessons learned are under development, and they will be disseminated widely as soon as they are finalized. A CIP V5 Implementation Study Report will also be posted by the end of September 2014.
BOARD OF TRUSTEES AND FERC ACTION NEW NERC Files Comments on Physical Security Standard NOPR On September 8, NERC filed comments in response to FERC’s Notice of Proposed Rulemaking (NOPR) to approve CIP-014-1—Physical Security. The purpose of proposed Reliability Standard CIP-014-1 is to enhance physical security measures for the most critical Bulk-Power System facilities and thereby lessen the overall vulnerability of the Bulk-Power System to physical attacks. 2014 NERC Filings to FERC are posted here. NEW FERC Issues September 18 Meeting Agenda On September 11, FERC issued the agenda for its open meeting on September 18.
UPCOMING EVENTS For information about other NERC events, such as meetings and conference calls for standard drafting teams, other standing committees, subcommittees, task forces, and working groups, please refer to the NERC calendar. Workshops and Conferences
• Critical Infrastructure Protection Committee Cyber Incident Response Planning Workshop – 8:00 a.m.–noon Pacific, September 16, 2014, Vancouver, BC (Register)
• Monitoring and Situational Awareness Conference – September 23–24, 2014, Audobon, PA (Register) (Details) • 2014 Fall Standards and Compliance Workshop – September 23–25, 2014, Atlanta, GA (Draft Agenda) (Workshop Registration)
(Additional Meeting Details)
Weekly Standards & Compliance Bulletin | September 15–21, 2014 7
• Risk-Based Registration Workshop for Transmission Owners and Transmission Operators – October 2, 2014, Folsom, CA (Register) (Details) (CAISO Information)
• Grid Security Conference (GridSecCon) – October 14–17, 2014, San Antonio, TX (Draft Agenda) (Register) (Hotel Information) • Risk-Based Registration Workshop for Transmission Owners and Transmission Operators – October 15, 2014, Atlanta, GA (Register)
(Details) (Atlanta Information) • Human Performance Workgroup Conference (sponsored by WECC) – October 28–30, 2014, Portland, OR (Register)
Webinars
• Project 2010-13.3 - Phase 3 of Relay Loadability: Stable Power Swings – 2:00–4:00 p.m. Eastern, September 18, 2014 (Register) • NEW Project 2014-02 - Critical Infrastructure Protection Standards Version 5 Revisions – 11:30 a.m.–1:00 p.m. Eastern, September 19,
2014 (Register) • NEW Project 2010-05.2 - Special Protection Systems (Phase 2 of Protection Systems) – 1:00–2:00 p.m. Eastern, September 23, 2014
(Register) • Polar Vortex Webinar – 1:00–3:00 p.m. Eastern, September 30, 2014 (Registration to Come) • Winter Preparation for Severe Cold Weather Webinar – 2:00–3:00 p.m. Eastern, October 2, 2014 (Register) (Southwest Cold Weather
• NEW Reliability Assurance Initiative 101 Webinar – 2:00–4:00 p.m. Eastern, October 3, 2014 (Register) Standing Committee Meetings and Conference Calls
• Compliance & Certification Committee Meeting – September 17–18, 2014, Vancouver, BC (Register) (Details) • Standards Committee In-Person Meeting – September 30–October 1, 2014, Portland, OR (Register to Attend in Person) (Register to
Attend via Webinar on September 30 or October 1) (Details) •
ABOUT THE WEEKLY STANDARDS & COMPLIANCE BULLETIN This weekly bulletin compiles a list of standards and compliance projects with actionable deadlines, as well as upcoming events, recently posted resources, other NERC documents posted for comment, and other relevant news and information. Please email Mallory Huggins with
Weekly Standards & Compliance Bulletin | September 15–21, 2014 8
feedback on this bulletin. The current bulletin and old bulletins are available under “Program News” on both the Standards home page and the Compliance & Enforcement home page. If you would like to receive this bulletin or be added to the distribution list for a particular standards project, please email Arielle Cunningham. For questions or more information about any of the compliance news listed in the bulletin, please contact Brooke Thornton.
Weekly Standards & Compliance Bulletin | September 15–21, 2014 9
Overview, Resources for Reliability Assurance Initiative
Compliance Exceptions
Aggregation/Logging
Assessing the Risk Posed by Noncompliance
RAI Web Page and Links
Headlines
New Initiatives Tab Added to Website
Expanded Weekly Standards and Compliance Bulletin
Board Authorizes Expansion of ES-ISAC Role to Improve Information Sharing; Adopts Four Standards
Fred Gorbet Appointed Officer of the Order of Canada
Compliance
Imperial Irrigation District, FERC and NERC Reach Settlement Agreement
Personnel Certification and Continuing Education
Personnel Certification Governance Committee Open Positions
Standards
CIP Version 5 Revisions to be Posted for Comment and Ballot
Looking Ahead: Upcoming Standards Postings
Upcoming Events
NERC Filings
Documents Filed with FERC and/or Canada during the Month
Careers
NERC Seeks Talented Professionals
NERC News August 2014
erwinj
Stamp
NERC News | August 2014 2
Spotlight on RAI Overview, Resources for Reliability Assurance Initiative The Reliability Assurance Initiative (RAI) program is the ERO Enterprise's strategic initiative to transform the current compliance and enforcement program into one that is forward-looking, focuses on high reliability risk areas and reduces the administrative burden on registered entities. A number of specific compliance and enforcement activities, all of which will be fully implemented beginning in January 2015, are supporting this transformation. Additional information is found below on several enforcement activities – compliance exceptions, aggregation/logging and assessing the risk posed by noncompliance – that support the overall RAI effort, as well as information about web changes related to RAI. Look for more information in announcements, the Weekly Standards & Compliance Bulletin, monthly NERC News “Spotlight on RAI” items and the RAI web page as NERC continues to release resources that support the transformation of its compliance and enforcement program under RAI. Compliance Exceptions Beginning in November 2013, the ERO Enterprise implemented a program under RAI to expand the exercise of enforcement discretion by identifying minimal risk noncompliance, which would be recorded and mitigated without triggering an enforcement action. Noncompliance that is not pursued through an enforcement action by the ERO Enterprise is referred to as a “compliance exception.” The expansion of enforcement discretion will allow both the Regional Entities and registered entities to focus their efforts on issues posing a greater risk to reliability. Compliance exceptions will not go through the enforcement process, although they must be mitigated within 12 months. A compliance exception is part of an entity's compliance history only to the extent that it serves to inform the ERO Enterprise of potential risk. Compliance exceptions are not,
however, part of an entity's violation history for purposes of aggravation of penalties. All minimal risk noncompliance is eligible for processing as a compliance exception regardless of the discovery method (including issues found at audit). The exercise of discretion is informed by the facts and circumstances of the noncompliance, the risk posed by the noncompliance to the reliability of the bulk power system and the deterrent effect of an enforcement action or penalty, among other things. These considerations are very similar to the considerations that have been used since 2011 to determine whether noncompliance should be processed through the Find, Fix, Track and Report disposition method. Although all minimal risk noncompliance is eligible for treatment as compliance exceptions, the determination that a minimal risk should be disposed of as a compliance exception is made on a case-by-case basis (in contrast to those issues logged pursuant to the aggregation program described below, which are presumed to be resolved as compliance exceptions absent additional risk factors). NERC currently reviews all compliance exceptions to maintain visibility and oversight into the application of the compliance exception process and to inform a filing to FERC. In addition, a reduced record of compliance exceptions is provided to FERC on a monthly basis. Aggregation/Logging The aggregation of minimal risk issues program (also known as the logging program) is one of the key enforcement process enhancements implemented under RAI. Beginning in October 2013, a small number of registered entities with demonstrated effective management practices have been permitted to aggregate/log minimal risk issues that would otherwise be individually self-reported. Since May 2014, the number of entities participating in this voluntary program has gradually expanded to allow the ERO Enterprise to further evaluate the benefits and to adjust related processes.
NERC News | August 2014 3
Registered entities that are permitted to aggregate minimal risk noncompliance do not have to submit individual self-reports for each instance of noncompliance that they identify. Instead, they determine the full scope of the issue and develop appropriate mitigating activities, subject to oversight by the Regional Entities. Participating entities submit their aggregation logs to their Regional Entities for review at least every three months. There is a presumption that absent any compelling factors indicating otherwise, minimal risk issues identified through the program will not be subject to an enforcement action. Rather, logged items will be processed as compliance exceptions (as detailed above). In determining eligibility for the aggregation program, NERC and the Regional Entities consider whether a registered entity is capable of self-identifying and mitigating minimal risk noncompliance on its own. A number of factors inform this determination and a detailed description of the eligibility criteria is being prepared, based on the experience with the program to this date. A detailed description of the program, including the eligibility criteria, is scheduled to be available prior to the November Board meeting. Importantly, an entity may be permitted to log noncompliance with all standards or only a subset of standards that reflects the strength and maturity of its practices in a given area. NERC continues to maintain oversight and visibility into minimal risk issues identified through the aggregation program. Assessing the Risk Posed by Noncompliance The new enforcement processes developed under RAI establish different disposition tracks according to the risk posed to the reliability of the bulk power system. Compliance exceptions are available for minimal risk noncompliance. The aggregation/logging program similarly is limited to minimal risk noncompliance. However, the Find, Fix, Track and Report program is available for minimal and moderate risk noncompliance.
The long-term success of these programs depends, in part, on a common understanding by registered entities and the ERO Enterprise as to the level of risk posed by a particular instance of noncompliance. To assist all registered entities in performing a thorough, consistent assessment of risk, NERC posted the Self-Report User Guide in May 2014. The Self-Report User Guide describes the guidelines and principles registered entities should use when assessing the risk associated with a particular instance of noncompliance. As described in the document, the first step in the risk assessment is to evaluate the potential impact of the noncompliance, considering risk sources and risk threats. The next step in the risk assessment is to determine the likelihood of the potential impact, based on factors such as statistical information, best educated guesses or the results of an internal controls analysis. To illustrate the risk assessment process, Appendix B to the Self-Report User Guide contains examples of risk assessments for specific reliability standards. The Self-Report User Guide also provides helpful information to registered entities regarding the information considered by Regional Entities in determining the nature, scope and duration of noncompliance, as well as the effectiveness of any mitigating activities. It was the result of a collaborative process involving staff from NERC and the Regional Entities, as well as industry reviewers and commenters. The Self-Report User Guide is posted on the RAI web page in the Resources section under “User Guides.” RAI Web Page NERC maintains and regularly updates the (RAI) web page. The web page has recently been reorganized to make essential stakeholder resources – especially Current Documents – easier to find. RAI Link Added to NERC Home Page NERC has added a direct link to the RAI web page to the NERC home page. The RAI link is in the Compliance and Enforcement section of the home page for easy access:
The spotlights on these specific RAI activities also were included in NERC’s Weekly Standards and Compliance Bulletin over the past month. They are posted in the “Program News” section of the RAI web page. If you would like to be added to the distribution list for the Weekly Standards & Compliance Bulletin, contact Arielle Cunningham. ■■■
Headlines New “Initiatives” Tab Added to NERC Home Page NERC has added an “Initiatives” tab to the NERC home page to provide stakeholders with easy access to the web pages for major initiatives like the Bulk Electric System definition, the CIP V5 Transition Program, the Reliability Assurance Initiative and Risk-Based Registration. The tab is shown below:
Expanded Weekly Standards and Compliance Bulletin NERC Communications began issuing an expanded version of what was previously the Weekly Standards
Bulletin on July 21. Now called the Weekly Standards and Compliance Bulletin, the document compiles a list of standards and compliance projects with actionable deadlines, as well as upcoming events, recently posted resources and other relevant news and information. The bulletin for the upcoming week is sent out each Monday by noon Eastern, and are then posted under “Program News” on both the Standards home page and the Compliance & Enforcement home page. Note: The bulletin is sent from the NERC Communications announcements email address. Contact Mallory Huggins with any feedback or questions about the bulletin. Contact Arielle Cunningham to be added to the bulletin distribution list.
Board Authorizes Expansion of ES-ISAC Role to Improve Information Sharing; Adopts Four Standards The North American Electric Reliability Corporation Board of Trustees adopted four standards at its August 14 quarterly meeting in Vancouver. Opening remarks were made by Ken Quesnelle, chair of Canadian Association of Members of Public Utility Tribunals (CAMPUT); Len Kelsey, chair of British Columbia Utilities Commission; and David Erickson, chief executive officer of Alberta Electric System Operator. Gerry Cauley, president and chief executive officer of NERC, opened the meeting with remarks on the success of collaboration with U.S. and Canadian stakeholders and noting significant initiatives of the ERO. “Our work on developing relationships with industry, both in the United States and in Canada, has been helpful and fruitful. To continue this progress, we must have adequate and thorough input from stakeholders and ensure our efforts stay transparent,” Cauley said. “NERC has had significant success on many initiatives this year, including physical and cybersecurity, Today we take an important step on expanding the role of the ES-ISAC. This is of strategic
importance to NERC and is a fundamental element of reliability.” The Board authorized a resolution to expand the Electricity Sector Information Sharing and Analysis Center (ES-ISAC) duties to include the operation of the Cyber Risk Information Sharing Program (CRISP). The program, which is a natural maturation of NERC’s cybersecurity initiatives, will improve the ES-ISAC’s ability to detect threats and the reliability of the bulk power system. The addition of this program is consistent with NERC’s philosophy that bulk power system operators are best able to protect the system when they are provided information to better understand a threat to reliability. The Board also adopted four standards and approved one data request:
Connecting New Facilities to the Grid – FAC-001-2 and FAC-002-2. These standards focus on adding clarity, removing redundancy and retiring requirements that have little impact on the reliable operations of the bulk power system when interconnecting new or modified facilities.
Nuclear Plant Interface Coordination – NUC-001-3. This standard requires coordination for safe operations and shutdowns.
Protection System Misoperations - PRC-004-3. This standard replaces PRC-004-2.1a and PRC-003- 1 and identifies and corrects causes of misoperations of protection systems, which was identified in the State of Reliability report as a significant contributor to disturbance events and automatic transmission outage severity.
Section 1600 Misoperations Data Request. This data request continues the consistent reporting of misoperations data to NERC through a standard template for use in performance analysis.
Discussion took place addressing the Environmental Protection Agency’s proposed rule to reduce carbon dioxide emissions from existing power plants by 30 percent below
2005 levels. The Board provided guidance to NERC on next steps. Recognizing NERC’s statutory responsibility to assess the reliability and adequacy of the bulk power system in North America under Section 215 of the Federal Power Act, the Board directed NERC to review the assumptions in this proposed rule and to assess the proposed rule’s potential impacts on the reliability of the bulk power system. In the coming weeks, NERC will provide a framework for review of the proposed CO2 rule, including any reliability impacts, to help inform the process.
“NERC’s statutory role is to remain independent, but vigilant,” Cauley said. “We stand for reliability. It is our statutory role to assess any impacts to reliability, while also ensuring our analysis and recommendations are backed by sound engineering data. Adhering to these principles will ensure that we stay on the path of what NERC stands for – the reliability of the North American grid.” The Board also approved the selection of Stan Hoptroff as NERC’s new vice president and chief technology officer. Hoptroff will lead NERC’s enterprise technology efforts to ensure the seamless integration of data systems and the integrity of the data within those systems. Previously, Hoptroff served as the director of Infrastructure Services at Southern Company, where he was employed in various roles for 33 years. He was named one of Computerworld magazine’s “Premier 100 IT Leaders” in 2013. Board presentations may be found by clicking here. The next Board meeting is scheduled for November 13 in Atlanta.
Fred Gorbet Appointed Officer of the Order of Canada Fred Gorbet, chair of NERC’s Board of Trustees, was recently appointed an Officer of the Order of Canada by the Governor General of Canada. Gorbet was appointed as a member of the Order in 2000. The Order is one of Canada’s highest civilian honors. Gorbet was elected to the Board in February 2006 and
was elected chair in February 2013. Gorbet previously served as vice-chair and chair-elect.
Gorbet has extensive experience in public policy advice and formulation, particularly with regard to financial institutions and energy policy. During a 25-year career in the Canadian public service, he served as senior policy adviser to the Department of Energy, Director of Policy for the International Energy Agency in Paris, Associate Secretary to the Cabinet for Strategic Policy and Deputy Minister of Finance.
Gorbet has a bachelor’s degree from York University and a Ph.D. degree in economics from Duke University. He is a member of the Advisory Council to the Dean of the Schulich School of Business and an Honorary Governor of York University. Official Announcement ■■■
Compliance Imperial Irrigation District, FERC and NERC Reach Settlement Agreement A settlement agreement was issued between the Imperial Irrigation District, the Federal Energy Regulatory Commission and the North American Electric Reliability Corporation on August 7 in the amount of $12 million for violations of NERC Reliability Standards by Imperial Irrigation District related to a September 8, 2011 system event. The civil penalty of $12 million will be split as follows: $3 million between the U.S. Treasury and NERC, and $9 million in investments for Imperial Irrigation District reliability enhancement measures that go beyond the mitigation of the violations resolved in the settlement agreement. The agreement is the second settlement related to the FERC-NERC joint investigation into the outage that left more than five million people in Southern California, Arizona and Baja California, Mexico, without power for up to 12 hours. Imperial Irrigation District stipulated to the facts in the agreement. Additional non-public, preliminary investigations related to other entities involved in the
September 2011 event are ongoing. Announcement |Settlement Agreement ■■■
Personnel Certification and Continuing Education Personnel Certification Governance Committee Open Positions NERC is accepting nominations to fill two positions on the Personnel Certification Governance Committee (PCGC). The term for both open positions are for two years -- from January 1, 2015 through December 31, 2016. Nominations will be accepted through 5 p. m. Eastern September 15. Interested candidates must have a valid NERC system operator credential; must be either a Canadian, American or Mexican national; and must have experience in interconnected system operations. Nominations are open to all interested parties and self-nominations are encouraged. The selected members will be in a pending position until appointed by the NERC Board of Trustees during the November meeting. The PCGC provides oversight to the policies and processes used to implement and maintain the integrity and independence of the NERC System operator certification program. The members are appointed by the NERC Board and report directly to the NERC Board regarding governance and administration of the system operator certification program. PCGC Nomination Letter | PCGC Nomination forms | PCGC Charter. Qualified candidates are encouraged to submit a nomination application to [email protected]. ■■■
Standards CIP Version 5 Revisions to be Posted for Comment and Ballot A 45-day comment period for Project 2014-02—Critical Infrastructure Protection (CIP) Standards Version 5 Revisions began on September 3. Ballot pools will be formed in the first 30 days of the
comment period, and ballots for the standards, definitions, implementation plan and non-binding polls of the associated violation risk factors and violation severity levels will be conducted during the last 10 days of the comment period, which will end on October 17. The most recent revisions in CIP-003-6 and CIP-010-2 focus on two directives from FERC Order No. 791: 1) develop modifications to the CIP standards to address security controls for Low Impact assets and 2) develop requirements that protect assets from vulnerabilities introduced by transient electronic devices. However, in order to meet the February 3, 2015 filing deadline for two other directives applicable to Project 2014-02, the standard drafting team has separated the revisions to some of the standards into a separate ballot. These standards are labeled version X – CIP-003-X, CIP-004-X, CIP-007-X, CIP-10-X and CIP-011-X – and will be combined with the version 6 standards once approved. The version X standards include only revisions addressing the following directives from FERC Order No. 791: 1) modify or remove the “identify, assess, and correct” language found in 17 of the 32 CIP Version 5 requirements and 2) create a definition of “communication networks” and develop new or modified reliability standards that address the protection of communication networks. Entities will vote on one ballot for the version X suite of standards and implementation plan. An explanatory document that provides additional information on the version X ballot will be posted to the project page alongside the standards. Contact standards developers Marisa Hecht or Ryan Stewart with any questions.
Looking Ahead: Upcoming Standards Postings As NERC continues to work toward a steady-state for transforming the body of NERC Reliability Standards to clear, concise, high quality and technically sound results-based and reliability-focused standards, there will be a number of standards posted for comment and/or ballot between August 27 and September 5:
Project 2007-11—Disturbance Monitoring (PRC-002-2 for a 45-day comment and additional ballot)
Project 2009-03—Emergency Operations (EOP-011-1 for a 45-day comment period and additional ballot)
Project 2008-02—Undervoltage Load Shedding & Underfrequency Load Shedding (PRC-010-1 for a 10-day final ballot)
Project 2010-05.2—Special Protection Systems Phase 2 of Protection Systems (definition of Remedial Action Scheme for a 45-day comment period and additional ballot)
Project 2013-03—Geomagnetic Disturbance Mitigation (TPL-007-1 for a 45-day comment period and additional ballot)
Project 2014-01—Applicability for Dispersed Generation Resources (VAR-002-4 for 45-day comment period and additional ballot and two final ballots on PRC-005-(X) versions; possibly another posting for additional ballot if needed for PRC-004)
Project 2014-02—Critical Infrastructure Protection Standards Version 5 Revisions (45-day comment period and additional ballot.
NERC has staggered the closing dates, to the extent possible, no two projects close on the same date. However, as there will be multiple projects closing in close proximity, advance notice will enable advance resource planning for stakeholders participating in the comment periods and ballots. Stakeholders also are reminded that NERC regularly updates the Projected Posting Schedule and the Project Tracking Spreadsheet, both of which are available in the left navigation of the NERC Standards web page.
Upcoming Events
Project 2014-03 Revisions to TOP/IRO Standards Webinar – 1-3 p.m. Eastern, September 9 | Register
RAI Webinar on Risk Elements Guide and 2015 ERO Compliance Monitoring and Enforcement Plan – 2-4 p.m. Eastern, September 9 | Registration to come
2014 Reliability Leadership Summit September 11 | Washington, DC Agenda | Register | Details. In the third year of the Reliability Leadership Summit, moderated panels of industry leaders will discuss the threats, challenges and opportunities facing bulk power system reliability.
Cyber Incident Response Planning Workshop Critical Infrastructure Protection Committee 8 a.m.-noon Pacific, September 16 | Vancouver, BC | Register. This course is intended for incident response managers, cybersecurity professionals and non-technical staff members responsible for building, planning and setting processes around incident detection response and threat intelligence. The workshop will cover practical and real-world lessons in cyber incident response planning, examine how the electricity sector at large is organized from a cybersecurity perspective, and explore how to successfully engage state and federal partners during or after a cyber compromise.
Monitoring and Situational Awareness Conference – September 23-24 | Audubon, Penn. Register | Details
2014 Fall Standards and Compliance Workshop – September 23-25 | Atlanta | Draft Agenda | Workshop Registration | Additional Meeting Details The 2014 Fall Standards and Compliance Workshop will present stakeholders with information about standards development, compliance monitoring and operations, and other initiatives. The in-person fee will be $300 for general registration and $100 to attend via webinar. An optional NERC Standards and Compliance 101 presentation will be offered in-person and via webinar from 10 a.m. – noon Eastern on September 23.
2014 Cold Weather Webinar 2-3 p.m. Eastern, October 2 | Registration to Come
Risk-Based Registration Workshop for Transmission Owners and Transmission
Operators – October 2 | Folsom, Calif. Register | Details | CAISO Information
Grid Security Conference | GridSecCon | October 14-17 | San Antonio Draft Agenda | |Register | Hotel Information
Risk-Based Registration Workshop for Transmission Owners and Transmission Operators – October 15 | Atlanta | Register | Details | Atlanta Information ■■■
Filings NERC Filings to FERC (click on the link for full filing) August 14, 2014 Compliance Filling in Response to January 16 Order NERC submits an unaudited report of NERC’s budget-to-actual variance information for the second quarter of 2014. This compliance filing is in accordance with the January 16, 2013 Order, which approved a Settlement Agreement between the FERC Office of Enforcement and NERC, related to findings and recommendations arising out of its 2012 performance audit of NERC. August 22, 2014 Petition of NERC for Approval of Errata to Interchange Scheduling and Coordination Reliability Standards NERC submits a petition for approval of errata to four Reliability Standards, INT-004-3 (Dynamic Transfers), INT-009-2 (Implementation of Interchange), INT-010-2 (Interchange Initiation and Modification for Reliability, and INT-011-1 (Intra Balancing Authority Transaction Identification). August 25, 2014 Comments of NERC in Response to Notice of Proposed Rulemaking MOD-001-2 (Available Transmission System Capability) NERC submits comments in response to the Notice of Proposed Rulemaking (NOPR) proposing to approve Reliability Standard MOD-001-2 (Available Transmission System Capability). Request for Change in Official Service List NERC submits a request to change the official service list in Docket No. RR14-5-000. Petition of NERC for Approval of Proposed Reliability Standards for Facility Connection Requirements FAC-001-2 and FAC-002-2 NERC submits a petition for approval of proposed Reliability Standards FAC-001-2 and FAC-002-2.
Request for Acceptance of NERC's 2015 Business Plan and Budget Filing and the 2015 Business Plans and Budgets of the Regional Entities NERC submits its request for acceptance of NERC's 2015 Business Plan and Budget Filing and the 2015 Business Plans and Budgets of the Regional Entities and for the approval of proposed assessments to fund budgets. August 27, 2014 NERC Reply Comments in Five-Year Assessment NERC submits reply comments in Docket No. RR14-5-000.
NERC Filings in Canada, click here (click on the link above for full filing)
August 1, 2014 Supplemental Information to the Notice of NERC of Proposed Reliability Standard PRC-025-1 (Generator Relay Loadabaility) (Alberta) Revisions to the Violation Risk Factors and Violation Severity Levels Assigned to Certain Critical Infrastructure Protection Reliability Standards (Alberta) August 5, 2014 Informational Filing Regarding Proposed Reliability Standards for Interchange Scheduling and Coordination (Alberta) August 14, 2014 Five-Year Electric Reliability Organization Performance Assessment Report (Alberta) Attachments to Five-Year Assessment August 22, 2014 Notice of Filing of NERC of a Supplemental Assessment to Fund the 2014 Budget of Peak Reliability, Inc. (Alberta) August 27, 2014 Petition of NERC for Approval of Proposed Reliability Standards for Facility Connection Requirements FAC-001-2 and FAC-002-2 |
Attachments for Filing ■■■
Careers at NERC CIP Physical Security Manager Location: Washington, DC Details ES-ISAC Administrative Assistant Location: Washington, DC Details
Associate Counsel-Enforcement Location: Washington, DC Details Compliance Enforcement Regulatory Assistant Location: Washington, DC Details Administrative Assistant-Legal Location: Washington, DC Details Senior Business Analyst\Adviser-PMO Location: Atlanta Details Compliance Auditor Location: Atlanta Details Event Investigator Location: Atlanta Details Senior Engineer of Registration and Certification Location: Atlanta Details Senior Reliability Engineer Location: Atlanta Details Reliability Engineer Location: Atlanta Details Training Technical Specialist Location: Atlanta Details Training and Education Coordinator Location: Atlanta Details
Reliability Assurance Initiative Summary September 2014
Summary The Reliability Assurance Initiative (RAI) is a collaborative, multi-year effort among NERC, the Regional Entities and the industry to identify and implement changes to enhance the effectiveness of the Compliance Monitoring and Enforcement Program (CMEP). The goal of RAI is to implement a more robust risk-based program for compliance monitoring and enforcement of Reliability Standards. Under this program, focused compliance monitoring, appropriate deterrence through enforcement and a feedback loop to improve Reliability Standards will result in a reasonable assurance of reliability. It is not practical, effective or sustainable to monitor all compliance issues to the same degree or treat all noncompliance in the same manner. Compliance monitoring and enforcement must be “right-sized” based on a number of considerations, including risk factors and registered entity management practices related to the detection, assessment, mitigation and reporting of noncompliance. A risk-based approach is necessary for a proper allocation of resources. It also encourages registered entities to enhance internal controls, including those focused on the self-identification of noncompliance. Over the course of 2013–2014, the ERO Enterprise tested a number of concepts, processes and programs for implementation in 2015. By the end of September 2014, NERC will have published guides and program documents related to all of the new and expanded processes and programs to allow for implementation in 2015. Implementation will be accompanied by training and outreach efforts directed at ERO Enterprise staff and industry stakeholders. Compliance Monitoring and Oversight The RAI’s transformation for compliance monitoring involves the use of the oversight plan framework (Framework), which is available on the RAI web page. Visual depictions of the compliance and enforcement components of the Framework are provided below. The Framework focuses on identifying, prioritizing and addressing risks to the bulk power system (BPS), which enables each Compliance Enforcement Authority (CEA) to focus resources where they are most needed and likely to be the most effective. Regional Entities are responsible for tailoring their approach to compliance monitoring (i.e., monitoring tools and the frequency and depth of monitoring engagements) in accordance with the processes described herein. The first step of the Framework is identification and prioritization of continent-wide risks based on the potential impact to reliability and the likelihood that such an impact might be realized. This analysis results in an annual compilation of Risk Elements. These Risk Elements are reflected in the ERO CMEP Implementation Plan (CMEP IP), which serves as guidance to Regional Entities in the preparation of their Regional Entity Implementation Plans.
Additional Resources This document provides a very high-level overview of RAI. The RAI web page (www.nerc.com > Initiatives > RAI) provides a detailed Framework document, as well as in-depth guides and program documents (for the bolded programs below) and a schedule of upcoming events and postings.
After risk elements are identified and prioritized, the Inherent Risk Assessment (IRA) enables the CEAs to determine areas of focus by scoping oversight of specific registered entities. As a result, the IRA identifies the Reliability Standards and Requirements that should be monitored. When developing more specific monitoring plans for registered entities in their footprints, the Regional Entities also take into account any information obtained through the processes outlined in the Internal Control Evaluation (ICE) Guide. The guide describes the process for identifying key controls, testing their effectiveness and documenting the conclusions of the internal controls evaluation. The ICE allows a further refinement of the compliance oversight plan and participation in the ICE is voluntary for registered entities. Ultimately, the Regional Entity will determine the type and frequency of the compliance monitoring tools (e.g., off-site or on-site audits, spot checks or self-certifications) that are warranted for a particular registered entity based on reliability risks. The determination of the appropriate CMEP tools will be adjusted, as needed, within a given implementation year. Enforcement Over the past several years, the ERO Enterprise has been migrating to a risk-based strategy of assessing and
processing noncompliance, beginning with the Find, Fix, Track and Report process, which has been successfully used to resolve instances of noncompliance posing minimal or moderate risks to the BPS. Based on this experience with a streamlined process and reduced record, since 2013, NERC and the Regional Entities have exercised discretion when deciding whether to initiate an enforcement action for certain noncompliance posing a minimal reliability risk to
the BPS. Issues resolved outside of an enforcement action are referred to as compliance exceptions. In addition, beginning in October 2013, NERC and the Regional Entities began to allow select registered entities with demonstrated effective management practices to self-identify, assess and mitigate instances of noncompliance to self-log minimal risk noncompliance that would otherwise be individually self-reported. Properly logged items are entitled to the presumption of being resolved as compliance exceptions unless additional risk factors are involved. The ERO Enterprise is now transitioning to the implementation of risk-based reliability assurance methods with the goal of full implementation of a mature compliance monitoring and enforcement program.
