Welcome! NERC 2019 Compliance and Standards Workshop Embassy Suites - - PowerPoint PPT Presentation

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Welcome!

NERC 2019 Compliance and Standards Workshop Embassy Suites by Hilton Minneapolis July 24, 2019

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It is NERC’s policy and practice to obey the antitrust laws and to avoid all conduct that unreasonably restrains competition. This policy requires the avoidance of any conduct that violates, or that might appear to violate, the antitrust laws. Among other things, the antitrust laws forbid any agreement between or among competitors regarding prices, availability of service, product design, terms of sale, division of markets, allocation of customers, or any other activity that unreasonably restrains competition. NERC Antitrust Compliance Guidelines

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Participants are reminded that this meeting is public. Notice of the meeting was posted on the NERC website and widely

• distributed. The notice included the number for dial-in
• participation. Participants should keep in mind that the

audience may include members of the press and representatives of various governmental authorities. Public Announcement

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• 8:00 – 8:15 a.m.: Opening Announcements
• Chris Boyd-Witherspoon
• 8:15 – 9:00 a.m.: Compliance Certification Committee Update
• Jennifer Flandermeyer
• Steven Noess
• 9:00 – 10:00 a.m.: Compliance Oversight Program
• Jeff Hargis
• Jeff Norman
• Yvette Landin
• 10:00 – 10:15 a.m.: Updates on 2019 Technology
• David Calderon
• 10:00 – 10:30 a.m.: Break

Today’s Agenda

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• 10:30 – 11:00 a.m.: Updates on 2019 Technology
• Ryan Stewart
• 11:00 – 11:30 a.m.: Coordinated Oversight of Multi Region

Registered Entities (MMRE):

• Fahad Ansari
• 11:30 – 12:00 p.m.: Internal Controls Enforcement
• Ed Kichline
• 12:00 – 1:00p.m.: Lunch
• 1:00 – 1:45 p.m.: CMEP and Compliance Guidance Updates
• Kiel Lyons
• Ryan Mauldin

Today’s Agenda

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• 1:45 – 2:30 p.m.: CIP Update – Supply Chain and CIP Practice Guides
• Lonnie Ratliff
• 2:30 – 2:45 p.m.: Break
• 2:45 – 3:15 p.m.: Standards Under Development Updates
• Howard Gugel
• 3:15 – 3:45 p.m.: Standards Efficiency Review
• Chris Larson
• 3:45 – 4:15 p.m.: Registration and Certification Updates
• Ryan Stewart
• 4:15 – 4:35 p.m.: General Q&A
• Chris Boyd-Witherspoon
• 4:35 – 5:00 p.m.: Closing Announcements
• Steve Noess

Today’s Agenda

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Compliance Certification Committee Update

Jennifer Flandermeyer, Evergy, Director, Federal Regulatory Policy, Chair NERC CCC Steven Noess, NERC, Director, Regulatory Programs 2019 Compliance and Standards Workshop

July 24, 2019

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NERC Standing Committees

Compliance and Certification Committee Reliability Issues Steering Committee Critical Infrastructure Protection Committee Standards Committee Operating Committee Planning Committee

Advisory Committees Technical Committees Compliance and Certification Committee (CCC) Advises NERC Board of Trustees and Senior Staff

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CCC Background

NERC Board- appointed stakeholder committee Engages with, supports, and advises the NERC Board regarding the Compliance Monitoring and Enforcement Program (CMEP), Organization Registration and Certification program (ORCP) Monitors NERC’s compliance with the Rules of Procedure for these programs Monitors NERC’s compliance with the Rules of Procedure regarding the Reliability Standards development process

• Exception of

appeals

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Membership

• Investor-Owned Utility
• State/Municipal Utility
• Cooperative Utility
• Federal or Provincial Utility/

Federal Power Marketing Administration

• Transmission Dependent
• Merchant Electricity Generator
• Electricity Marketer
• Large End-use Electricity Customer
• Small End-use Electricity Customer
• Independent System Operator/

Regional Transmission Organization

• Regional Entity
• Government

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I ndustry Partnership

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• Provide advice and support for CMEP as well

as Registration and Certification processes

• Participate in development of ERO

Stakeholder Effectiveness Survey

• Partner with ERO Enterprise related to review

and comment of draft RSAWs

• Develop NERC criteria for Regional oversight
• Provide input on development of

Implementation Guidance process

• Provide Stakeholder input on the ERO

Enterprise Program Alignment Process

• Participate in discussions to identify

emerging risks to reliability

CCC Work Plan

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Feedback Loops

Members active involvement in compliance forums Barometer for NERC on compliance and enforcement initiatives Liaisons to trade

• rganizations,

membership forums, industry forums, regional compliance committees

RE

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Key Support Efforts

• Enterprise Wide Risk Committee participation
• Key partnership in Program Alignment
• Partnership with Standards Committee on Standards

Efficiency Review (SER) – SER Advisory Group member

• Stakeholder Survey (Program Focused)
• Collaboration with NERC on Technology Projects (Align, CORES)
• Stakeholder Feedback Loop on Guidance
• Feedback Loop for CMEP Implementation and Design Resources

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COLLABORATION IS KEY

Key Collaboration Initiatives Key Partners – Compliance Assurance, Enforcement and Internal Audit Industry Outreach Stakeholder Survey and Feedback Focus Discussion Topics ERO Program Alignment Compliance Guidance

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ERO Program Alignment Working Group

NERC Initial Review Resolution of Issue and Posting Results Issue Raised by Registered Entity Input from CCC and Program Alignment Working Group

• Aids in the screening of

information, as appropriate

• Supports further

investigation of a potential issue as requested by NERC

• Providing suggested

resolutions, as appropriate

• Works directly with

stakeholders to shape issue to be reviewed

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• Test
• Test
• Test

– Test

Program Alignment Process

• Program Oversight and Monitoring
• Survey Responses
• Stakeholder Reporting
• NERC Central Repository

Track

Identify & Capture Issues

• NERC Initial Screening
• Regional Input and CCC Alignment Working Group Engagement
• Materiality and Priority
• Responses and Recommendations

Triage

Classify, Analyze, & Prioritize

• Program Alignment – Issues and Recommendations Tracking
• Quarterly Reporting
• Regional Program Information

Transparent

Post & Report

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Resources

Regional Program Information Resources Consistency Reporting Tool Issues & Recommendations Tracking

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• Test
• Test
• Test

– Test

Program Alignment Page

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Regional Program I nformation Matrix

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I ssues and Recommendations/ Resolutions I ssues and Recommendations/ Resolutions

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I ssues and Recommendations/ Resolutions Tracking

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• Program Alignment enables stakeholders to raise perceived

alignment issues

• NERC is committed to providing transparency to the submitter

and stakeholders

• Industry alone, and through the CCC, participates in the process
• ERO Enterprise needs stakeholder input to improve alignment

Closing

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Compliance Oversight Plan Process Enhancements

Jeff Hargis, Texas RE, Manager of Risk Assessment Jeff Norman, MRO, Director of Compliance Monitoring Yvette Landin, NERC, Compliance Assurance Advisor 2019 Compliance and Standards Workshop July 24, 2019

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Overview

• Maturation of risk-based assessment processes
• Compliance Oversight Plan (COP) Process Highlights
• Inputs – Qualitative and Quantitative Data
• Targeted Oversight
• Risk Categories
• Oversight Strategies
• Performance Impact
• Contents of the COP Report
• Implementation Timeline
• Q&A

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Maturation of Risk-based Assessment Processes 2016 2018 2019 - 2020 I RA Process Harmonization COP Process Harmonization Transition Period

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Updated COP Process Highlights

Enhanced Analysis

Analysis of inherent and performance data provides an understanding of an entity’s overall inherent risk and performance profile

Targeted Oversight

Provides considerations for an entity’s continuous improvement and a focus to a Regional Entity for its compliance monitoring activities

Prioritized Monitoring

Identifies target interval for

• versight,

primary monitoring tools, and informs annual planning

Single Report

One report to provide both inherent risk assessment results and the compliance

• versight plan

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I nputs – Quantitative and Qualitative Data

Inherent risk assessment – quantitative entity data such as what you own or operate Performance assessment – qualitative entity data such as internal controls, culture of compliance, compliance history, event data

Enhanced Analysis

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Targeted Oversight

Provides considerations for an entity’s continuous improvement Provides focus for Regional Entity for its compliance monitoring activities COPs will communicate the Regional Entity’s current understanding of a Registered Entity’s inherent risk and performance profile COPs will include selected Risk Categories for monitoring

Targeted Oversight

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Risk Categories

Asset/System Identification Entity Coordination Identity Management and Access Control Emergency Operations Planning Operating During Emergencies/Backup & Recovery Asset/System Management and Maintenance Training Modeling Data Asset/System Physical Protection Long-term Studies/Assessments Operational Studies/Assessments System Protection Normal System Operations

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Prioritized Monitoring

Prioritized Monitoring

Identifies target interval for oversight, primary monitoring tools, and informs annual planning

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Prioritized Monitoring 1

1 – 3 Years Higher inherent risk without demonstrated positive performance

2

Higher inherent risk with demonstrated positive performance 2 – 4 Years

3

Moderate inherent risk without demonstrated positive performance 3 – 5 Years

4

Moderate inherent risk with demonstrated positive performance 4 – 6 Years

5

Lower inherent risk without demonstrated positive performance 5 – 7 Years

6

Lower inherent risk with demonstrated positive performance 6 + Years

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Performance I mpact

Category 1

The target monitoring interval for a higher risk entity without demonstrated positive performance is once every 1 – 3 years. A Regional Entity will use one or a combination of the following CMEP Tools:

• Audit (on or off-site)
• Self-Certifications
• Spot Check

Category 2

The target monitoring interval for a higher risk entity with demonstrated positive performance is once every 2 – 4 years. A Regional Entity will use one or a combination of the following CMEP Tools:

• Audit (on or off-site)
• Self-Certifications
• Spot Check

COPs establish target intervals for engagements based off of inherent risk and performance profile

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Contents of the COP Report

• 1. Purpose
• 2. Analysis and Results
• 3. Oversight Strategy
• App. A: IRA Results Summary
• App. B: Standards and

Requirements for Monitoring

Single Report

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COP Process I mplementation Timeline

• Throughout the second half of 2019, Regional Entities will begin

implementation of new COP summaries.

• Industry outreach will begin in July 2019 and continue through

2020.

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Align Project Update

David Calderon, NERC, Senior Engineer, Grid Planning & Operations Assurance 2019 Compliance and Standards Workshop July 24, 2019

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What is Align?

• Single, common portal for registered entities, enabling

consistency of experience.

• Real-time access to information, eliminating delays and manual

communications.

• Improved capability to support the Risk-Based Compliance

Oversight Framework.

• Enhanced quality assurance and oversight, enabling consistent

application of the CMEP.

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Align Release 1: What to expect as a registered entity? Stakeholder Group Release 1 Functionality

• Create and submit Self-Reports and Self-

Logs

• Create and manage mitigating activities

(informal) and Mitigation Plans (formal)

• View and track Open Enforcement Actions

“EAs” (resulting from all monitoring methods)

• Receive and respond to Requests for

Information “RFIs”

• Receive notifications and view dashboards
• n new/open action items
• Generate report of Standards and

Requirements applicable to your entity

• Manage user access for your specific entity

Reg egist st er ered ed Ent it ies es

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Update on Development

• Development and testing will require a 6-8 week extension.
• Revised deployment approach .
• Will provide a more manageable go live for NERC and the

Regions.

• NERC will go live with two Regions; MRO and Texas RE, by

September 30th.

• The remaining regions will onboard by November 1st.

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Update on Training

• The following roles need training for Release 1:
• Primary Compliance Contact (PCC), Alternate Compliance Contact (ACC),

Authorizing Officer (AO)

• Regional staff and registered entity trainings will be rescheduled

to after September 15 at the earliest; based on the schedule set up by NERC.

• Will be supported with training materials and process

documentation.

• Entities should coordinate with their Regional Align contacts for

additional training and timing related questions.

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Regional Contacts

Region Contact Name Contact Email MRO Desiree Sawyer Marissa Falco Desiree.Sawyer@mro.net Marissa.Falco@mro.net NPCC Jason Wang jwang@npcc.org RF Ray Sefchick ray.sefchik@rfirst.org SERC Todd Curl TCurl@serc1.org Texas RE Rochelle Brown Rochelle.Brown@TEXASRE.org WECC Michael Dalebout mdalebout@wecc.org

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Break

Webinar participants: We will return at 10:30 a.m. Central

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Centralized Organization Registration ERO System (CORES) Update

Ryan Stewart, NERC, Senior Manager of Registration and Certification 2019 Compliance and Standards Workshop July 24, 2019

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• CORES Concept Video Demonstration
• https://vimeopro.com/nerclearning/cores-video-library/video/337820719
• Overview of CORES
• Registered Entity Pilot Sessions and Outreach Engagements
• Training and Outreach Events
• Rollout Strategy

Agenda

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• The objective of the Centralized Organization Registration ERO

System (CORES) project is to create a centralized registration system for the Electric Reliability Organization (ERO). This project will address:

• Processing of registration requests
• Granting of a NERC Compliance Registry (NCR) identification number
• The information collected in CORES will be based upon the existing

Common Registration Form that each Regional Entity currently uses for processing registration requests

• Link to CORES project page – FAQs, timeline, opportunities for engagement

(https://www.nerc.com/pa/comp/Pages/CORESTechnologyProject.aspx)

CORES Overview

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• The CORES application is hosted on the ERO Portal
• Each entity user that will register or modify registration with NERC will

need an ERO Portal account

• https://eroportal.nerc.net/
• Registered entities will not need to register again
• The process for collecting data is different – the data is virtually

the same

• Initial training videos developed – more in the works

Key Points About CORES Transition

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ERO Portal Access

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• CORES will expand current functionality, align regional

registration processes, and provide an improved system-based approach to processing registration requests.

• Central repository for collecting registered entity data
• New functionality for entities in multiple regions
• Coordinated Oversight now captured
• Easily update information in a central location

Benefits

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• CORES is not currently planned to be used for:
• Compliance Monitoring and Enforcement Functions – see the Align project.
• https://www.nerc.com/ResourceCenter/Pages/CMEPTechnologyProject.aspx
• Certification or Certification Reviews
• No system in place for Certification or Certification reviews at this time
• BES Exceptions
• BES Exceptions will continue to utilize the BESnet application for processing

Key Points About CORES Transition

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• Focus Group
• AWG
• ORCS
• CCC
• Bulletins
• Regional Workshops
• Registered Entity Pilots – Testing
• Training

Outreach and Engagements

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• Registered Entity Pilot Sessions
• May 14 | RF Hosted Reg. Entity Pilot Roadshow
• May 16 | Texas RE Hosted Reg. Entity Pilot Roadshow
• May 21 | NPCC Hosted Reg. Entity Pilot Roadshow
• May 23 | NERC/Slalom Hosted Reg. Entity Pilot Roadshow

Registered Entity Pilot Sessions

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• Planned Training Dates (subject to change)
• June 6/7 | Begin to Post Training Materials
• July 10| NERC hosted ERO WebEx (pre-release)*
• July 15-19 | Expected CORES System Release*
• End of July| NERC hosted ATL ERO In-person & WebEx, open Q&A, (post-

release)*

• End of July| NERC hosted ERO WebEx (*in-person), open Q&A, (post-

release)*

*Expected based on when this material was developed

Training and Outreach Events

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• ERO is currently developing the rollout strategy
• Initial group will include pilot session and focus group

participants

• Each Regional Entity will work with their unique registered

entities on certain milestones

• ERO Portal accounts created
• Contact information verified
• Data validation from the migration of existing data
• Entering of other information
• NERC will work with all Regional Entities for those registered in

multiple Regions Rollout Strategy

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Website

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Multi-Region Registered Entity Coordinated Oversight Program

Fahad Ansari, NERC, Senior Compliance Auditor 2019 Compliance and Standard Workshop July 24, 2019

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Terminology

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• Streamline ERO Enterprise activities for the registered entities

by eliminating unnecessary duplication of administrative tasks

• Focus on risk to reliability, while improving efficiency and

consistency of Compliance Monitoring and Enforcement Program (CMEP) Activities

• Coordinate Lead Regional Entity (LRE) and Affected Regional

Entity (ARE) oversight responsibilities to work collectively and collaboratively to support risk-based compliance monitoring and effective implementation of the Program Program Objectives

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• Self-Reports
• Compliance Audits and Spot Checks
• Self-Certifications
• Periodic Data Submittals
• Complaints
• Technical Feasibility Exceptions (TFEs)
• Mitigation Plan Review and Verification
• Enforcement Coordination
• System Events
• Organization Registration
• NERC Alerts

Activities Under Coordinated Oversight

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Current MRRE Program Breakdown

• 50 MRRE Groups in

Coordinated Oversight (210 registered entities)

Distribution of 47 MRRE Groups by LRE

MRO, 17 NPCC, 1 RF, 11 SERC, 6 Texas RE, 9 WECC, 6

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• Registered Entity Inclusion Criteria
• Operates in or owns assets in two or more Regional Entity jurisdictions
• Verifies its Primary Compliance Contact (PCC), Authorizing Officer (AO) or

Primary Compliance Officer (PCO) contact information is accurate prior to submitting request for inclusion

• Designates a PCC
• Common (integrated) Compliance Program across all NCRs and programs

Program Criteria

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• LRE Selection Criteria
• Bulk power supply (BPS)/Bulk Electric System (BES) reliability

considerations

• Registered entity operational characteristics
• Resource considerations

Program Criteria

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• Focus on Key Program Initiatives
• Clearly defined roles/responsibilities
• Timing of conducting Inherent Risk Assessment (IRA) and Compliance

Oversight Plan (COP)

• CMEP Technology Project
• Onboarding meeting for new participants
• Post-audit feedback survey
• Publicly posted FAQs and MRRE Coordinated Oversight guide

Stakeholder Communication

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• Am I an MRRE?
• I am registered in multiple regions under different NCRIDs, can I

participate in the Coordinated Oversight Program?

• Upstream owner is not a registered entity, what now?
• After participating in the Program, does the number of Regional

Entities reduce to one?

• Do I have to respond to NERC Alerts for all NCRIDs in my MRRE

Group?

• Why do I have to submit MiDAS reporting in ARE footprint?

Other Questions

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I nternal Controls in Enforcement

Ed Kichline, NERC, Senior Counsel and Director of Enforcement Oversight 2019 Compliance and Standards Workshop July 24, 2019

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• Enforcement’s role in the risk-based Compliance Monitoring and

Enforcement Program

• Identification and reporting of noncompliance
• Risk assessment of noncompliance
• Mitigation of noncompliance

Overview

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• Outcomes for noncompliance are based on risk
• Risk is based on specific facts and circumstances
• Mitigation required for all noncompliance
• Continuous evaluation and communication of risks
• Analysis and lessons learned shared publicly
• Input to risk identification

Risk-Based Enforcement

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• Overarching goal of sustainable compliance
• Focus on robust mitigation to reduce risks and likelihood of recurrence
• Establishing cultures of continuous learning
• Meaningful engagements and interactions between Regional Entities and

registered entities throughout resolution of noncompliance

• Value of internal controls to foster lasting solutions

Goals and Principles of Enforcement Activities

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• Describe the internal control that led to discovery of the

noncompliance

• Effect on extent of condition review
• Determine whether a preventive control did not work as

designed

• Opportunity for mitigation

I nternal Controls in I dentifying and Reporting Noncompliance

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• Preventive controls that reduce incident probability
• Reduce the likelihood of something occurring
• Detective internal controls
• Periodic reviews to identify possible issues
• Corrective internal controls that reduce the length of the

noncompliance I nternal Controls in Risk Assessment

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• Redundancy in processes that have been drilled and practiced
• Walkdowns for additional visibility of facilities and equipment
• Automated tools
• CIP-004-6 R3
• CIP-007-6 R5
• Alarms
• Checks to ensure the controls are functioning as designed

Controlling risks

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• Strengthen the preventive controls that may have failed
• Opportunities for improved detective controls
• Value of details on your internal controls
• What will be done
• Who will do it
• How often will it be done

I nternal Controls in Mitigation

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• Report the results of your completed mitigation
• Any adjustments to ratings or settings?
• Any applicable patches missed?
• Any events in unreviewed logs?

Results of Mitigation

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• Tasks with checklists
• Requirements to be kept on hand during performance of tasks
• Checkbox to confirm use of checklists
• Administrative barriers that cannot be avoided in completion of

activities

• CIP-010
• Physical barriers vs. Written policies and warning signs
• Requiring sign-off on results of testing, inspection, or

maintenance activity

• Revise procedures to include explicit process steps addressing

the missed activity Effectiveness of internal controls

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• Training
• Recurring mandatory training
• For new employees soon after onboarding
• Demonstrating comprehension of training
• Change management
• Mergers and restructuring
• Additions of assets and facilities

Effectiveness of internal controls

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• PRC and MOD
• Biannual review of new facilities to identify new equipment to add to the

Protective System Maintenance Program

• GRC tracking tool with notifications to internal personnel and outside

consultant

• Preventive Maintenance work orders to ensure completion of periodic

activities

• FAC-008-3 R6
• Require two planners to enter and verify data for new facilities and

equipment

• Tracking new or revised Standards to ensure more effective

implementation Examples of internal controls in mitigation

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• Greater reliance on what you report
• Protection against harm from the noncompliance
• Reduced likelihood of recurrence of the noncompliance
• Sustainable compliance
• Enhanced reliability and security

The Benefits of I nternal Controls

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Lunch

Webinar participants: We will return at 1:00 p.m. Central

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Compliance Guidance

Kiel Lyons, NERC, Senior Manager, Grid Planning and Operations Assurance 2019 Compliance & Standards Workshop July 24, 2019

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• Background
• Compliance Guidance Policy
• Types of Guidance
• Prequalified Organizations
• Endorsement Process
• Implementation Guidance Development Aid
• Current Guidance
• Compliance Guidance Web Page
• Resources
• Key Take-Aways
• Questions and Answers

Overview

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Transformation of Guidance Documents

• FERC Interpretations
• Implementation Guidance
• CMEP Practice Guides
• Compliance Process Bulletins (being retired)
• Directives and Bulletins for Regional Entities (being retired)
• Compliance Application Notices (CAN) (being retired)
• Compliance Analysis Report (CAR) (being retired)

Background

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• Purpose of policy
• Industry implement Reliability Standards
• ERO CMEP staff execute duties
• Compliance Guidance team
• Reviewed role, purpose, development, use, and maintenance
• Recommended use of examples
• NERC Board or Trustees approved Compliance Guidance Policy

Compliance Guidance Policy

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Principles

• Cannot change scope of Reliability Standard
• May be developed concurrently with Reliability Standard,
• Should not conflict
• Should be developed collaboratively
• Not only way to comply
• Additional Considerations:
• Finite and limited set
• Related guidance in one location
• Consider revising standard
• Apply professional judgment
• Feedback loops

Compliance Guidance Policy

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Compliance Guidance Implementation Guidance CMEP Practice Guides

Types of Guidance

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• Developed by industry, for industry
• Endorsed by the ERO Enterprise
• Given deference during monitoring by the ERO Enterprise
• Examples or approaches
• One of several possible approaches
• Developed by:
• Standard Drafting Team (SDT)
• Pre-Qualified Organization

I mplementation Guidance

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• Developed by ERO Enterprise, for ERO Enterprise
• May be initiated through industry discussions
• Publically posted
• ERO Enterprise CMEP staff approach
• Fosters consistency
• All guidance reviewed by NERC Vice President, Deputy General

Counsel, and Director of Enforcement CMEP Practice Guides

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Approved by Compliance and Certification Committee (CCC)

• The organization must:
• Be actively involved in NERC operations
• Have methods to assure technical rigor
• Possess ability to vet content

Pre-Qualified Organizations

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Applicant applies with the CCC CCC Reviews Application CCC notifies the applicant

• f approval

Applicant is added to Pre- Qualified Organization List

Pre-Qualified Organizations

Pre-Qualified Organization Application Process

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• Standard Drafting Teams (SDTs)
• Identifies examples
• Reviews existing guidance
• Examples vetted by industry through comment/ballot process
• Decision to submit for ERO Enterprise endorsement made by
• Project Management and Oversight Subcommittee (PMOS) liaison
• NERC standards developer
• May not submit guidance after standard is approved
• Must be submitted by Pre-Qualified Organization

Standard Drafting Teams

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Endorsement of Implementation Guidance

• Pre-Qualified Organization or SDT submit proposed guidance
• Email to ComplianceGuidance@nerc.net
• Include Implementation Guidance Submittal Form
• NERC:
• Acknowledges receipt
• Posts proposed guidance
• Distributes to ERO Enterprise SMEs
• ERO Enterprise endorses or declines to endorse
• Publicly posted
• Non-endorsed noted in spreadsheet

Endorsement Process

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Development Aid

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• Ensure guidance provides specific examples or approaches to

compliance.

• Ensure guidance provides specific examples or approaches to

compliance.

• Ensure guidance does not conflict with, or contradict, previously

approved documents

• Ensure guidance capitalizes terms defined in the NERC Glossary of

Terms when the term is intended to have the same meaning as defined in the Glossary.

• Ensure guidance does not add compliance obligations to an entity that

is not specifically required by the subject Reliability Standard and Requirement.

Development Aid

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• Ensure guidance does not make the subject Reliability Standard and

Requirement less restrictive.

• Ensure guidance does not include language that attempts to describe

an audit approach.

• Ensure guidance does not introduce new terminology, attempt to

define a term, interpret a term, or clarify an ambiguity in the subject Reliability Standard and Requirement.

• Ensure guidance correctly references footnotes, citations, active links,

illustrations, table numbers, attachments, addendums, appendices, etc.

• Ensure guidance does not skip steps or stop short of complying with

the subject Reliability Standard and Requirement by addressing the entire Requirement in sufficient detail.

Development Aid

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• Consider using the specific language of the subject Reliability Standard

and Requirement when possible.

• Consider avoiding terms that were used in previous versions of a

Reliability Standard, but are no longer in use in the current version of the subject Reliability Standard and Requirement.

• Consider using illustrations such as diagrams, sample records,

flowcharts, templates, etc.

• Consider using softer words such as “should consider”, “may want to”,

“recommended”, etc. when the processes, procedures, or approaches described are examples and are not prescriptive and mandatory.

Development Aid

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Website

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Website

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Website

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Website

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• Compliance Guidance web page
• http://www.nerc.com/pa/comp/guidance/Pages/default.aspx
• Compliance Guidance Policy
• http://www.nerc.com/pa/comp/Resources/ResourcesDL/Compliance_Guidance_Policy_FINAL_Board_Accepted_Nov_5_201

5.pdf

• Implementation Guidance Under Consideration
• http://www.nerc.com/pa/comp/guidance/Pending%20Implementation%20Guidance/Implementation%20Guidance%20Und

er%20Consideration%20or%20Development.pdf

• Pre-Qualified Organization list
• http://www.nerc.com/pa/comp/guidance/Documents/Pre-qualified%20organizations.pdf
• Procedure to Become a Pre-qualified Organization
• http://www.nerc.com/comm/CCC/Related%20Files%202013/Final%20CCCPP-011_May_BOTCC_updated.pdf
• Pre-Qualified Organization Application
• http://www.nerc.com/pa/comp/guidance/Documents/Application_Pre-Qualified_Organization.pdf
• How to Submit Proposed Guidance
• http://www.nerc.com/pa/comp/guidance/Documents/Pre-qualified_org_submittal_with_form.pdf
• U.S. Standards One-Stop Shop
• http://www.nerc.com/pa/Stand/Standard%20Purpose%20Statement%20DL/US_Standard_One-Stop-Shop.xls

Resources

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• Implementation Guidance
• Developed by industry for industry, and vetted by industry
• Endorsed by the ERO Enterprise
• CMEP Practices Guides
• Developed by ERO Enterprise for ERO Enterprise
• During development of guidance reference the Implementation

Guidance Development Aid

• Review the Compliance Guidance Policy document for more

details

• Check Compliance Guidance webpage regularly for changes

Key Takeaways

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ERO Enterprise CMEP I P

Updates

Ryan Mauldin, NERC, Compliance Assurance Advisor 2019 Compliance and Standards Workshop July 24, 2019

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• Purpose of the Compliance Monitoring and Enforcement

Program (CMEP) Implementation Plan (IP)

• Annual CMEP-related operating plan for NERC and Regional Entities
• Implementation of risk-based approach for CMEP activities
• Timeline
• NERC posts on or about September 1 of preceding year
• Regional Entities submit Regional IPs on or about October 1
• NERC reviews and posts combined IP in November
• Updates may occur throughout year

I mplementation Plan Background

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• Roles
• Highlight risks that merit increased focus for CMEP activities
• Used in prioritizing and evaluating monitoring scopes
• Not exclusive list of all risks to reliability of the bulk power system (BPS)
• Enhancements
• Reflects maturing risk-based program
• Better articulated as discrete issues
• Clearer focus in the plan on specific Reliability Standard requirements
• Enables feedback mechanism for future plans
• Evaluates how risks are being prevented or mitigated
• Results used to shape and impact future monitoring focus

Risk Element Overview

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• Several inputs
• Compliance findings and Enforcement data
• Event Analysis experience
• Prioritized or emerging risks
• Critical Infrastructure Protection themes
• Reliability Issues Steering Committee’s ERO Reliability Risk Priorities
• Risk elements written to consider potential impact or emerging

risk

• Does not mean all risks
• Provides actionable information to shape areas of focus
• Risk Elements and areas of focus inform entity-specific COPs and

monitoring activities

• When needed, Regional Risk Elements are used to identify region wide

risks

Establishing Risk Elements

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2019 Risk Elements Comparison

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• Improper Management of Employee and Insider Access
• This risk element focuses on the human element of security, one of the

descriptors of cybersecurity vulnerabilities identified in the 2018 Reliability Issues Steering Committee (RISC) report. Regardless of the sophistication

• f a security system, there is potential for human error.

2019 Risk Elements

Standard Requirements CIP-004-6 R1, R2, R3, R4 CIP-005-5 R2 CIP-006-6 R1, R2, R3 CIP-007-6 R2, R3, R5 CIP-010-2 R1, R2, R3, R4 CIP-011-2 R1, R2

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• Insufficient Long-Term Planning Due to Inadequate Models
• Adequately modeled planning cases become increasingly critical as a

changing resource mix, deployment of new technologies, etc., affect the risk to BPS reliability.

2019 Risk Elements

Standard Requirements FAC-002-2 R1, R2, R3, R4, R5 MOD-032-1 R2 MOD-033-1 R1, R2 TPL-001-4 R1, R2, R3, R4

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• Insufficient Operational Planning Due to Inadequate Models
• More comprehensive dynamic load models will be needed to sufficiently

incorporate behind-the-meter generation and distributed load resources such as demand-side management programs. Also, with the recent and expected increases of both utility-scale solar resources and distributed generation, the causes of a sudden reduction in power output from utility- scale power inverters need to be widely communicated and addressed by the industry.

2019 Risk Elements

Standards Requirements MOD-032-1 R2 MOD-033-1 R1, R2 TOP-003-3 R1, R2 TPL-001-4 R1, R2, R3, R4

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• Spare Equipment with Extended Lead Time
• Spare equipment strategy is an important aspect of restoration and
• recovery. The RISC report identifies that the failure to maintain equipment

is a reliability risk exacerbated when an entity either does not have replacement components available or cannot procure needed parts in a timely fashion. The failure to properly commission, operate, maintain, prudently replace, and upgrade BPS assets generally could result in more frequent and wider-spread outages, and these could be initiated or exacerbated by equipment failures.

2019 Risk Elements

Standards Requirements CIP-014-2 R1, R5 TPL-001-4 R2.1.5

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• Inadequate Real-time Analysis During Tool and Data Outages
• Entities are to be encouraged to have realistic plans to continue real-time

analysis during outages of tools, loss of data, or both. This risk element is made more important in situations where planning models may not keep pace with increasing BPS complexity and accurately reflect area specific dependencies on inverters, natural gas, or other items.

2019 Risk Elements

Standards Requirements IRO-008-2 R4 TOP-001-4 R13

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• Improper Determination of Misoperations
• The 2018 RISC report includes a key point that the ERO Enterprise, the

impacted organizations, and the respective forums and trade organizations should perform post-event reviews to capture lessons learned and how to reduce the impact of future events. These reviews will be incomplete if not every event is noticed because the relay operations were not reviewed by qualified personnel. The report also identifies the risk posed by the increasing complexity in protection and control systems, further emphasizing the importance of a skilled workforce analyzing events and relay operations.

2019 Risk Elements

Standards Requirements PRC-004-5(i) R1, R3

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• Inhibited Ability to Ride Through Events
• Generating plant protection schemes and their settings should be

coordinated with transmission protection, control systems, and system conditions to minimize unnecessary trips of generation during system

• disturbances. Increased implementation of inverter-based resources has

brought a focus on this issue.

2019 Risk Elements

Standards Requirements PRC-019-2 R1 PRC-023-4 R1, R2, R6 PRC-024-2 R1, R2 PRC-025-2 R1

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• Gaps in Program Execution
• Where records are not kept up to date, inaccurate models and damaged

equipment can result. Failing to keep accurate inventories of responsibilities and equipment following asset transfers, addition of new equipment, or mergers and acquisitions, is causing incomplete entity programs in Facility Ratings and vegetation management.

2019 Risk Elements

Standards Requirements FAC-003-4 R1, R2, R3, R5, R6, R7 FAC-008-3 R6 PRC-005-6 R3

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Looking Ahead to 2019

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• 2019 ERO Enterprise CMEP IP V2

https://www.nerc.com/pa/comp/Reliability%20Assurance%20Initiativ e/2019_ERO_CMEP_Implementation%20Plan_V2%20November%202 018.pdf

Resources

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BCSI / Cloud Update

Lonnie Ratliff, NERC, Senior Manager Cyber and Physical Assurance 2019 Industry Compliance and Standards Workshop July 23, 2019

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• Awareness / Meetings
• ERO Enterprise / FedRAMP
• CIWG Tabletops
• Microsoft Azure
• TBD
• Moving Forward
• BCSI Practice Guide
• Project 2019-02

Overview

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• The Federal Risk and Authorization Management Program

(FedRAMP)

• Government-wide program
• Standardized approach to security assessment, authorization,

and continuous monitoring for cloud products and services

• Enables Agencies to rapidly adapt from old, insecure legacy IT to

mission-enabling, secure, and cost effective cloud-based IT

• Established a mature marketplace to increase utilization and

familiarity with cloud services

• Facilitating collaboration across government through open

exchanges of lessons learned, use cases, and tactical solutions. FedRAMP

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• FedRAMP Project Management Office onsite
• Evidence Review
• Third party assessment organization (3PAO) reports
• Coalfire (3PAO)
• Microsoft (Cloud Service Provider)
• Azure Implementation Guide

April ERO Enterprise Meeting

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• Examine existing Azure FedRAMP Moderate / High evidence.
• Assist the ERO Enterprise in determining the suitability of

FedRAMP evidence to demonstrate compliance to the NERC CIP standards Microsoft Azure Visit Objectives

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• ERO Enterprise
• All Regions and NERC represented
• CIWG Representation
• Reviewing Evidence
• Offsite review of Security Analysis

Report

• Detailed review of evidence provided
• Reviewing Microsoft created RSAWs
• Azure Cloud Options
• Azure Moderate / High
• Azure Government

Microsoft Azure Visit

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• Objectives
• Consistent application of controls
• Consistent evidentiary requirements
• Reasonable assurance across multiple CSP’s
• Who / What / How
• Possible same ERO Enterprise Team
• Different Cloud Service Provider
• Different 3PAO
• Similar type of review

Additional Tabletop(s)

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• Purpose
• Provide direction to ERO Enterprise CMEP staff around BCSI
• Released – April 26, 2019
• Focus
• Access and Authorization (the ability to both obtain and use)
• Securely handling in storage, transit, and use
• Considerations
• Encryption, with key management
• Data could be on premise or off premise
• Possibly retire when Project 2019-02 is complete

ERO BCSI Practice Guide

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• Background

Creating increased choice, greater flexibility, higher availability, and reduced- cost options for entities to manage their BES Cyber System Information, by providing a secure path towards utilization of modern third-party data storage and analysis systems. In addition, the proposed project would clarify the protections expected when utilizing third-party solutions.

• History
• Submitted by Tri-State Generation
• Discussed through CIWG
• Standards Authorization Request Drafting Team
• June 18 – 19, 2019 face-to-face meeting
• Standards / Requirements need clarification or modification

Project 2019-02 BCSI Access Mgt

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Break

Webinar participants: We will return at 2:45 p.m. Central

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Standards Update

Howard Gugel, NERC, Vice President of Engineering and Standards Compliance and Standards Workshop July 24, 2019

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• Revisions to FAC-011
• Working to clarify System Operating Limit(SOL) Exceedances (Requirement

R6)

• Conducting a data analysis to understand the impact of proposed revisions

to industry

• Revisions to FAC-015
• Working to make revisions based on industry comment regarding

Coordination of Planning Assessments with the Reliability Coordinator’s SOL Methodology

• Next 45-day formal comment period and additional ballot

scheduled for late August 2019. Project 2015-09 Establish and Communicate SOLs

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• Phase I:
• Proposed Standard BAL-003-2 modifies the currently-effective standard

and process documents to address:

• The inconsistencies in calculation of Interconnection Frequency Response

Obligation(IFRO)s due to Interconnection Frequency Response performance changes of Point C and/or Value B;

• The Eastern Interconnection Resource Loss Protection Criteria (RLPC);
• The frequency of nadir point limitations (currently limited to t0 to t+12);
• Clarification of language in Attachment A, i.e. related to Frequency Response

Reserve Sharing Groups (FRSG) and the timeline for Frequency Response and Frequency Bias Setting activities; and

• The BAL-003-1.1 FRS Forms enhancements that include the ability to collect and

submit FRSG performance data.

• Initial Posting - 45-day comment and ballot period December 4, 2018-

January 17, 2019, with 96.41% approval and 92.02% quorum.

• NERC Board Adoption November 2019

Project 2017-01 Phase I Modifications to BAL-003

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• Phase II will consider:
• Revisions to the Reliability Standard to address the Real-time aspects of

Frequency Response necessary to maintain reliability;

• Ensuring comparability of and applicability to the appropriate responsible

entities;

• Developing measurements to incorporate Real-time and resource and load

characteristics; and

• Ensuring equitability of performance.
• Informal comment period August 2019
• NERC Board Adoption May 2020

Project 2017-01 Phase I I Modifications to BAL-003

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Project Scope:

• Update the PRC-024 ride-through curves to clarify that the area
• utside the “No Trip” zone is not a “Must Trip” zone
• Clarify inconsistencies to ensure that instantaneously calculated

frequency is not permissible to define the trip parameters

• Clarify the Curve Details section of the “Voltage Ride-Through

Curve Clarifications”

• Consider whether the to reinforce that the requirements pertain

to the point of interconnection Project 2018-04 Modifications to PRC-024

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• Clarify if the voltage and frequency protective functions within

an inverter control system that trip the inverter are subject to of PRC-024

• Clarify that plant auxiliary equipment protection systems are not

subject to the requirements of PRC-024.

• Clarify whether the use of momentary cessation within the “No

Trip” zone of PRC-024 does not comply with the standard.

• Consider whether Interconnection-specific modification(s) or

Regional Variance(s) are necessary for the voltage ride-through time duration curve(s) in Attachment 2. Project Scope

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• The Supplemental Standards Authorization Request (SAR)

expands the scope of the project to eliminate identified reliability issues by:

• Requiring all voltage and frequency protection up to the point of

interconnection (the high voltage side of the generator step-up (GSU) or collector transformer) to adhere to PRC-024;

• Requiring those Transmission Owners that own the GSU or collector

transformers and the associated voltage and frequency protective relays to be compliant with the standard.

Project Scope – Supplemental SAR

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• The SDT is still considering comment from the initial posting that

closed on May 31, 2019

• Supplemental SAR comment period closes – July 26, 2019
• SDT Meeting to review SAR comments and modify SAR, if

necessary – July 31, 2019

• Updated SAR submitted to SC – August 21, 2019
• Next in-person SDT meeting – September 4–6, 2019
• ERCOT offices (Austin, TX)
• 45-day additional ballot scheduled – September 13 – October

28, 2019

• SDT Meeting (in-person or remotely) – November 5–6, 2019

Project Timeline

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• FERC Order No. 851 directs NERC to develop and submit

modifications to Reliability Standard TPL-007-2:

• to require the development and implementation of corrective action plans

to mitigate assessed supplemental Geomagnetic Disturbance (GMD) event vulnerabilities; and

• to authorize extensions of time to implement corrective action plans on a

case-by-case basis.

• Initial Ballot and Comment Period scheduled July 26, 2019

through September 8, 2019

• NERC Board Adoption May 2020
• Regulatory Filing deadline July 2020

Project 2019-01 Modifications to TPL-007-3

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• Bulk Electric System (BES) Cyber System Information Access

Management

• To clarify the CIP requirements and measures related to both managing

access and securing BES Cyber System Information.

• SAR Drafting Team (DT) met on June 18-19, 2019 to make

revisions to the SAR and respond to industry comments.

• SAR will be presented to the Standards Committee for

Authorization on July 24, 2019 NERC

• Standard Drafting Team’s first meeting is tentatively scheduled

for August 6-7, 2019. Project 2019-02 BCSI Access Management

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• FERC Order No. 850 directs NERC modify the Supply Chain

Standards to address EACMSs, specifically those systems that provide electronic access control to high and medium impact BES Cyber Systems.

• NERC Supply chain report also recommends addressing Physical

Access Control Systems (PACS) that provide physical access control (excluding alarming and logging) to high and medium impact BES Cyber Systems.

• SAR Comment Period July 2, 2019 – August 1, 2019
• NERC Board Adoption November 2020
• Regulatory Filing deadline December 2020

Project 2019-03 Cyber Security Supply Chain Risks

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• CIP-002-6 Ballot
• Passed with 87.39% approval
• Virtualization Updates
• What we heard…
• Definitions
• CIP-005-7

Project 2016-02 Modifications to CI P

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• Initial Ballot September 14 – October 30, 2017 TO Control

Center (TOCC)

• Additional Ballot March 16 – April 30, 2018 (TOCC)
• Additional Ballot – Added IROL SAR | August 23 – October 9,

2018

• Additional Ballot CIP-002-6 w/TOCC & Planned / Unplanned

Change & Removed IROL Modifications | July 17, 2019 CI P-002-6 Timeline

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• What we heard
• Virtualization Case for Change White Paper
• Overwhelmingly positive response (85%+)
• Discussion of current configurations…

Virtualization Updates

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• Cyber Asset (CA)
• Electronic Security Perimeter (ESP)
• BES Cyber System (BCS)
• External Routable Connectivity (ERC)

Definitions - Unchanged

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• Virtual Cyber Asset (VCA):

A logical instance of an operating system, firmware, or self- contained application hosted on SCI.

• Shared Cyber Infrastructure (SCI):

Programmable electronic devices whose compute, storage, or network resources are shared with one or more Virtual Cyber Assets or that perform logical isolation for an ESZ. This includes its management systems.

• Electronic Security Zone (ESZ):

A security zone is a segmented section of a network that contains systems and components to create logical isolation. New Definitions

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• BES Cyber Asset (BCA) – to include Virtual Cyber Asset and

exclude Shared Cyber Infrastructure.

• Transient Cyber Asset (TCA) - to include Virtual Cyber Asset &

SCI connectivity

• EACMS -> EACS + EAMS - to include Virtual Cyber Asset
• PACS -> PACS + PAMS - to include Virtual Cyber Asset
• Protected Cyber Asset (PCA) - to include Virtual Cyber Asset &

those VCAs that share memory and CPU with a BCS

• Removable Media (RM) – to include SCI connectivity

Updated Definitions

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• Allow old style to remain:
• ESP, BCS, ERC scoping, etc.
• Create virtualization specific controls alongside for:
• ESZ, SCI, Virtualized BCAs, EACMS, PACS, PCAs etc.
• Test with many samples (Pinecone Power)

Requirements Approach

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• Move toward technology agnostic requirements.
• New terms to help describe the virtual environment.
• Clarify new requirements for the virtual environment.
• Preserve Cyber Asset term for backwards compatibility.

How We Can Move Forward

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• Continue Virtualization Standard Drafting Efforts:
• Thursday Conference Calls (noon – 2:00 p.m. Eastern)
• July 16-19, 2019 in-person CIP SDT Meeting – NERC, D.C.
• August 27-29, 2019 in-person CIP SDT Meeting – NERC, Atlanta
• September 24-26, 2019 in-person CIP SDT Meeting – NPCC NYNY
• Upcoming postings
• Informal posting of CIP-005-7, July 23, 2019*
• Informal posting of CIP-007 & CIP-010, November

Next Steps

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Standards Efficiency Review

Chris Larson, NERC, Manager of Standards Information 2019 Compliance & Standards Workshop July 24, 2019

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Overall: Evaluate NERC Reliability Standards using a risk-based approach to identify potential efficiencies through retirement or modification of Reliability Standard Requirements. This project seeks to identify potential candidate requirements that are not essential for reliability, could be simplified or consolidated, and could thereby reduce regulatory obligations and/or compliance burden. SER Project Scopes Phase 2: Evaluate NERC Reliability Standards (O&P and CIP), as informed by implementation experiences and compliance practices, to develop and recommend standards-based solutions intended to reduce inefficiencies and unnecessary regulatory burdens for the purpose of supporting continued safe, secure and reliable operations.

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Phase 1 SER Working Teams & Timeline RT OP LT

2018-03 SDT

P2 1 2 3 4

2018-03 SDT

P2

CIP SER

2017 2018 2019 2020

CIP SDT New scope Phase 2 Concepts Modifications

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Multi-phase Approach Project 2018-03 SER Retirements (Phase 1)

• Focused primarily on retirements
• Three working teams consisted of 50+ industry participants
• Initial SAR proposed 107 Requirements, list trimmed to ~84 after

further discussions with NERC and FERC

• Final ballot: April 23-May 2

Phase 2:

• Six efficiency concepts presented in February 2019 webinar
• Industry survey 75 participants of ended March 22
• Evaluate & prioritize concepts
• Modifications of and dependencies with requirement(s)
• Sub-team of Phase 1 and Phase 2 members

CIP SER: define scope, approach, and timeline; form working team

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Phase 1 Deliverables

• Focused primarily on retirements
• Revised SAR submitted to Standards Committee (Summer 2018)
• Appointed Project 2018-03 SER Drafting Team (October 2018)
• Initial comment and ballot period closed (April 2019)
• Ballot pools of 300+ voters with ~97% approval average
• Final ballot ended (May 2019)
• Presented to NERC Board of Trustees (May 2019)
• NERC staff submitted two petitions to FERC (June 2019)

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Phase 2 Deliverables

• Form SER Phase 2 team by supplementing with new CCC & SC

members (complete)

• Clarify and adjust scope of work for Phase 2 (complete)
• Identify key issues to address with Advisory Group (complete)
• Review alternatives and concepts proposed by Phase 1

(complete)

• Develop new efficiency concepts (complete)
• Evaluate and identify best efficiency concepts (complete)
• Draft recommendations for prioritized concepts (2019 Q4 - 2020)

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Phase 2 I ndustry Survey

• Gauged level of support (1-10) of each concept from 75

participants, equally weighted

• Concept 1: Evidence Retention (8.12)
• Concept 5: Consolidate Information/Data Exchange Requirements (8.11)
• Concept 3: Move Requirements to Guidance (7.85)
• Concept 2: Prototype Standard (7.78) .
• Concept 6: Relocate Competency-based Requirements to the Certification

Program/Controls Review process (6.85)

• Concept 4: Consolidate & Simplify Training Requirements (6.19)
• Reviewed industry survey responses, comments, and concerns
• Evaluated and prioritized concepts based on potential benefit,

feasibility and effort of implementation

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CI P SER

• CIP SER: using a risk-based approach, evaluate NERC CIP Reliability

Standards in order to identify potential efficiencies through retirement or modification of Reliability Standard Requirements

• Approach is very similar to SER Phase 1
• Key considerations:
• Focus first on retirements, then on modifications
• Relationship & communications with active drafting teams
• Industry input in parallel with working team formation
• CIP has less history of mandatory and enforceable
• Working team nominations ends August 16
• Industry input using SER Matrix ends August 26
• Analysis of industry feedback (August - September)

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Resources

• Project 2018-03 SER Retirements
• Standards Efficiency Review Phase 2
• CIP Standards Efficiency Review

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NERC Registration and Certification Updates

Ryan Stewart, NERC Sr. Mgr. of Registration and Certification 2019 Compliance and Standards Workshop July 24, 2019

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• Overview of Certification and Registration Programs
• The Organization Registration and Certification Subcommittee

(ORCS) and Organization Registration and Certification Group (ORCG)

• Project and Focus Areas

Agenda

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NERC ORCP Team

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• Overview of Registration Program
• NERC Rules of Procedure (ROP) Section 500 and Appendices 5A and 5B
• Program put in place to clearly identify those entities that are responsible

for compliance with the FERC approved Reliability Standards

• NERC established and maintains a NERC Compliance Registry (NCR)
• Various registration options
• Daily Registration Processing
• Common Registration Form
• Information Technology (IT) System Work Flows
• Regional Entity Oversight
• NERC-led Review Panels

Overview of Certification and Registration Programs

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• Overview of Certification Program
• NERC Rules of Procedure (ROP) Section 500 and Appendix 5A
• Program put in place to certify a new Reliability Coordinator (RC),

Balancing Authority (BA), and/or Transmission Operator (TOP) has the tools, processes, procedures, and capabilities to reliably operate for that function

• Program includes process for entities to maintain Certification
• Regional Entity Oversight

Overview of Certification and Registration Programs

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• Electric Reliability Organization (ERO) group for managers,

engineers, analysts, etc.

• Work pertaining to Registration, Certification, BES Exceptions, IT efforts,

NERC-led Review Panels, etc.

• NERC co-chairs the ORCG with a Regional member
• Group has an annual Work Plan
• ORCG conducts bi-weekly calls and meets on a periodic basis in-

person Organization Registration and Certification Group (ORCG)

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• Industry group, reporting to the Compliance and Certification

Committee (CCC)

• NERC acts as secretary
• Purpose:
• Advise and provide support to NERC and the Regional Entities with

development and implementation of organization registration and certification processes (i.e., ROP 500 & Appendix 5), and

• Advise and provide ongoing support to NERC and the Regional Entities

relating to approved organization registration and certification processes.

Organization Registration and Certification Subcommittee (ORCS)

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• NERC Registration team managed the SPP RE transition process
• Supported FRCC RE transition
• Western Interconnection RC transition
• IT applications
• CFR Tool
• CORES
• Possible NERC Rules of Procedure changes
• Certification review “trigger” language
• Coordinated Functional Registration (CFR) and Joint Registration

Organization (JRO) language clarity

• RBR implementation

Projects and Focus Areas

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Closing Announcements

Steven Noess, NERC, Director of Regulatory Programs 2019 Compliance and Standards Workshop July 24, 2019