NERC/ERO Compliance Services

It is vitally important to electric consumers that the North American electric system is reliable, adequate, and secure. As a result of the August 2003 Northeast Blackout, more attention has been focused on reliability, adequacy, and security at the federal level. The Energy Policy Act of 2005 granted the Federal Energy Regulatory Commission (FERC) the authority to enforce a set of newly mandated Reliability Standards. These Reliability Standards, developed by the North American Electric Reliability Corporation (NERC) and established by Congress as part of the Energy Policy Act of 2005, will now be enforced by FERC through the Electric Reliability Organization (ERO). With the advent of the new mandatory Reliability Standards, it is extremely important that every user, owner, and operator of the Bulk Power System understand the requirements and be ready to comply. GDS Transmission Services is experienced in assisting Load Serving Entities, Distribution Providers, Transmission Operators, ownersTransmission Owners, Transmission Planners, Balancing Authorities, Generation Owners, Generation Operators, Purchase-Selling Entities and Resource Planners in meeting their respective NERC compliance requirements. GDS offers expertise in the compliance programs in many of the Regional Entities as well as NERC.

FERC and NERC Developments

The development of mandatory, enforceable reliability standards can have a substantial impact on load serving entities and generation and transmission owners and operators. It is important to understand how current and proposed reliability standards can affect operational practices, reporting requirements and ultimately, the bottom line. GDS staff has assisted several clients by developing compliance programs, following the new industry developments, and preparing them for upcoming mandatory standards.

Review FERC Orders and Rulemakings
Review and develop comments on Standards
Participate in Technical Conferences and other meetings
Participate in Industry Groups
Evaluate client use of the Bulk Power System and determine the impact of new legislation and policy

NERC and Regional Entity Compliance

NERC has developed over 100 Reliability Standards which contain over 3,000 individual requirements. These Reliability Standards and requirements have been submitted to FERC for review and will become mandatory for all users of the Bulk Electric System once approved. NERC is assisted by several Regional Entities in implementing and enforcing the mandatory Reliability Standards. GDS Transmission Services assists clients in complying with the present NERC and regional standards and will continue to provide assistance and guidance in complying with new standards as the develop.

Review Reliability Standards and requirements
Assess client's operation to determine which Standards and requirements apply
File quarterly and annual compliance reports with Regional Entities
Attend regional and NERC compliance seminars and meetings
Participate in NERC and regional Working Groups and Committees

Compliance Audits and Assessments

To monitor and enforce the mandatory Reliability Standards, NERC, through the Regional Entities, conducts Compliance Audits and Spot Checks. GDS assists its clients with preparation for these audits in order to support audit findings of compliance. In addition, GDS can assist clients with implementing any recommended changes that might be made during audits to achieve improved compliance with the Reliability Standards.

Develop documentation required for audits
Review audit questionnaires and responses
Conduct mock audits
Perform "post mortem" analysis on compliance audit recommendations
Identify areas for improvement and develop implementation plans
Develop training for personnel
Preparation for and support during audits

Critical Infrastructure Protection (CIP)

With FERC Order 706, new considerations for security of assets comprising Bulk Power System were made, with particular emphasis on cyber security. NERC has issued standards governing network security, cyber asset hardening, personnel risk considerations and training. The CIP standards remain the fastest evolving in the suite of NERC Reliability Standards and are making a quick rise to being the most commonly violated. GDS assists its clients with CIP program development, compliance assessments and audit support. GDS offers a wide range of services to assist in compliance with the CIP standards as they continue to develop.

Develop procedures for complying with the full suite of CIP standards
Construct Risk Based Assessment Methodology and conduct assessment including powerflow analysis
Perform CIP Vulnerability Assessments
Identify potential process improvements to reduce compliance workload and violation risks
Development of training for Cyber Security Awareness and Sabotage Awareness programs

Reliability Risk Management

FERC, through NERC, assesses financial penalties to entities that are not compliant with the mandatory Reliability Standards. These penalties will vary based on the level of non-compliance, the size of the entity, and the type of Reliability Standard and requirement which the utility was found to be not in compliance. FERC has the statutory authority to assess a fine of up to $1,000,000 per day for non-compliance. GDS is equipped to assist clients in understanding the risks associated with non-compliance and to make an informed business decision regarding compliance with the relevant Reliability Standards and requirements.