NEWS

On March 19, 2015, FERC issued an order that approves in part, and denies in part, NERC's petition for approval of proposed revisions to the NERC Rules of Procedure that would implement NERC's risk-based registration initiative.  The initiative is intended to ensure that entities are subject to an appropriate set of applicable Reliability Standards by using a consistent approach to risk assessment and registration.  The Order approves NERC's proposal except for the proposed elimination of the load-serving entity function from the registry process, which it denies, without prejudice, and directs NERC to submit a compliance filing to address the Commission's concerns.  Click HERE to read the FERC order.

Proven Compliance Solutions Inc. (PCS) is continuing its legacy of excellence in NERC Reliability Standards compliance support into its fifth year. Since forming in July of 2010, PCS has provided expert NERC compliance program development and implementation, gap analyses, mock audits, NERC/Regional audit support, including audit preparation, SME support, and post-audit support, as well as procedure writing, RSAW development, and on-site/off-site training for its clients. PCS’ record of supporting clients in successful audits is unsurpassed. Regional audit teams across the country recognize PCS’ approach to data organization when reviewing audit packages and provide positive feedback to PCS clients regarding this work. PCS-supported audits and pre-audit work has resulted in no unidentified potential violations for the documentation reviewed by the PCS team. PCS often identifies areas where improvements can be made, as well as areas of concern. Identified issues are resolved, mitigated, or self-reported, leaving no surprises when an audit team’s findings are received.

The challenges faced by registered entities experiencing compliance audits in 2014 have increased significantly. Audits are more in-depth and the experience of the regional audit team members has grown significantly since 2007. Beyond establishing and portraying a “Culture of Compliance,” the ability to show reliable operations through well written operating policies, procedures and the collection of appropriate evidence has been a key factor in the successful audits for PCS clients.

PCS President and Managing Partner, Crystal Musselman, emphasized, “PCS’ audit success story is entirely attributable to its excellent staff. The PCS team is a remarkable group of highly skilled individuals who continue to make our clients’ compliance experience uncomplicated, efficient and organized in a fashion that provides auditors confidence in the completeness and thoroughness of their program.” PCS consultants have decades of experience in generation, transmission, marketing, control systems, physical/cyber security, compliance management, industry committee participation and leadership that sets them apart in the industry.

The Reliability Assurance Initiative (RAI) brings many unknowns to 2015 and the outlook of compliance audits. PCS is prepared to assist entities with identifying and developing internal controls (most of which are already in place) and provide support that will enhance an entity’s next audit, self certification or spot check.

For information regarding how Proven Compliance Solutions can assist with your NERC or Regional Compliance needs, call (262) 436-4116.

Interested in reviewing FERC Enforcement Orders regardng reliability compliance investigations or information regarding Commission Staff Reliability Audits?  FERC recently created a page on its website to easily access this information.  If you'd like to access this page, go to http://ferc.gov/industries/electric/indus-act/reliability/enforce-orders.asp.

The Federal Energy Regulatory Commission (FERC) will meet this Thursday, November 20, 2014 and is expected to take further action on NERC Reliability Standard CIP-014-1 which addresses physical security of the Bulk Electric System.

Proven Compliance Solutions Inc. (PCS) has been positioning itself to meet the needs of both its current and future clients with respect to CIP-014-1 since FERC issued its original NOPR.

Some of the activities PCS has undertaken include:

  • The enhancement of internal capabilities associated with Physical and Cyber Security.
  • The affirmation and strengthening of agreements with its current partner firms.
  • Building new relationships with Physical Security and Power Engineering partners that support a quality joint physical security review coinciding with Power Flow analysis, as required in CIP-014-1.

PCS President and Managing Partner, Crystal Musselman, stated, “What PCS envisions is a process of evaluation that encompasses proper Physical Security Assessments and Network Power Engineering Analysis that leads to consistent results for CIP-014 initial electrical defense assessments and affirmations.”

Francis Esselman, PCS Vice President and Managing Partner, Operations, goes on to say, “The key to success beyond simply meeting the CIP-014 requirements is for Physical Security science and Power System Engineering Analysis to come together to render an accurate picture of the overall risk, rank those in order, and then to focus on the protection of those that, in fact, have a viable impact on the reliability of the Bulk Electric System.”

PCS is monitoring this field of expertise with great interest and believes its in-house personnel and that of its partners bring the right attributes for all aspects associated with CIP-014 to meet or exceed the expectations for readiness. PCS continues to closely follow the CIP-014-1 approval activities and will share more on its vision and activities as its process develops. For more information contact Francis Esselman at This email address is being protected from spambots. You need JavaScript enabled to view it. or (262) 510-2446. To read more about PCS and its NERC reliability standard compliance services, visit the PCS website at www.provencompliance.com.

Ryan Carlson will be attending the NERC Critical Infrastructure Protection Committee (CIPC) meetings June 10-11, 2014 at the Hyatt Regency Orlando International Airport, in Orlando, Florida.  Ryan attends all CIPC and a variety of other industry meetings focusing on NERC CIP.  As the lead Senior CIP Consultant for PCS, he stays current on all CIP matters.  If you're at the meetings, please stop by and say hello to Ryan.  For more information on how PCS can assist you with your NERC Reliability Standards compliance activities, contact Ryan at This email address is being protected from spambots. You need JavaScript enabled to view it..

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