“The NERC Times – They Are A’Changin – Constantly”

 

Just over eleven years ago, FERC issued Order 693 approving 83 mandatory Reliability Standards, and the North American electric grid regulatory landscape changed dramatically.  FERC also directed NERC to modify several Standards, bringing about dozens of Standard Drafting Teams.  The initial Standards changes were fast and furious, but NERC had a goal of achieving a “Steady State” in regards to the Standards.  With only nine currently active Standards Development Projects, has NERC achieved a Steady State?  Just as importantly, can your Compliance Program operate at a Steady State? Is your Compliance Program up-to-date with the latest Standards changes?

Steady State is a relative assessment, so consider this.  Of the 101 currently effective National and Regional Reliability Standards, sixty have an effective date of January 1, 2016 or later.  Almost 60% of the current Reliability Standards have changed in some manner in the last 2.5 years.  That does not include the 10 approved standards awaiting implementation, or the standards approved by NERC awaiting approval from FERC, or the new Compliance Guidance documents being routinely posted, or the multiple changes to the NERC Rules of Procedure.  Some of the changes were minor, and some were significant. 

So, can your Compliance Program operate at a Steady State?  Only if you routinely incorporate Change Management into your overall Compliance Program management (not talking about CIP required Change Management here).

What are the right components of managing changes to NERC compliance requirements?

  • Identification – Monitor FERC, NERC and Regional filings, postings, workshops, webinars, committees and forums to identify changes in standards, compliance guidance documents, and auditing approaches.

  • Implementation – Review posted Implementation Schedules carefully and communicate with NERC and Regional Entities to clearly understand the implementation schedule.   Plan your implementation to allow time to meet compliance well ahead of the deadlines.

  • Modifications – Review and update any applicable Policies and Procedures to promote compliance with the new requirements.

  • Training – Make sure Operating Personnel are effectively trained on meeting any new compliance obligations.

  • Communication – Clearly communicate compliance expectations to impacted personnel.

  • Control – Establish controls or review activities to ensure new compliance obligations are being met.

We, as the industry, and NERC have an obligation to support grid reliability by continually reviewing and improving the mandatory Reliability Standards.  Changes to the Standards and Requirements will be ongoing.  That can include adding or modifying Requirements, or retiring low value/low risk Requirements.  If your Compliance Program is not up-to-date with the latest Standards, your company could be at risk for missing compliance obligations, or alternately, your company could be wasting resources on retired Requirement activities.  Either way, to minimize the risk and maximize the effectiveness of your Compliance Program, Change Management should be integral to your processes.

If you have questions about how to more effectively manage the continually changing NERC compliance obligations, do not hesitate to contact PCS.  We currently monitor and communicate Standards and Compliance change activities for a number of clients on an ongoing basis with our Standards Compliance Intelligence Portal (SCIP). 

Contact Proven Compliance Solutions for a SCIP demo today at This email address is being protected from spambots. You need JavaScript enabled to view it. or call 262-436-4116.

 

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