On June 17, 2020, NERC published a Compliance Monitoring and Enforcement Program (CMEP) Practice Guide addressing the evaluation of Facility Ratings and System Operating Limits. As most registered entities are aware, NERC has been publishing compliance guidance documents following the approval of its Compliance Guidance Policy in November of 2015.
NERC’s Policy includes two types of guidance: 1) Implementation Guidance, which provides guidance and examples to registered entities regarding possible methods for implementing standards to achieve and demonstrate compliance; and 2) CMEP Practice Guides, which provide direction to NERC and Regional Auditors on approaches to carry out compliance monitoring and enforcement activities and evaluate a registered entity’s compliance with a Standard. In other words, CMEP Practice Guides provide a road map of what auditors will review to determine a registered entity’s compliance with a particular Reliability Standard or set of Standards.
The June 17 CMEP Practice Guide is titled “ERO Enterprise CMEP Practice Guide Evaluation of Facility Ratings and System Operating Limits” and focuses on multiple Reliability Standards related to Facility Ratings and System Operating Limits, including FAC-008, FAC-011, FAC-014, TOP-001 and TOP-002. Key areas of emphasis in this document include the following:
Consistency of Ratings across Databases and across Planning/Operating Systems
Dynamic Facility Ratings
Applicability (and limits) of Design Ratings
Field Verification of Equipment
Impact of Controls (with an emphasis on Change Management)
Proven Compliance Solutions Inc. (PCS) strongly encourages registered entities to closely review this CMEP Practice Guide, both to improve their current program and in advance of audit preparation. NERC is telling us how they will be auditing related requirements, and we should put that information to good use. This document is located on NERC’s website at https://www.nerc.com/pa/comp/guidance/Pages/default.aspx under the CMEP Practice Guides heading.
If you have questions about this CMEP Practice Guide, how to improve your Facilities Ratings and SOL compliance, or the development and implementation of Internal Controls, PCS can help. Please contact Dale Zahn at dzahn@provencompliance.com or (262) 436-4116 for further information.
