The importance of periodic data requests and submittals should not be underestimated. This invaluable source of registered entity information provides NERC and your Compliance Enforcement Authority (or Regional Entity: MRO, WECC, SERC, Texas RE, RF, NPCC) insight into risks and trends across the grid, which in turn helps to monitor risks to reliability and support the safety and security of the bulk power system. This article serves as a guide for periodic data requests, including types of requests, what is required to be reported, timing of the submittals, controls for the management of requests, and who to contact at NERC or MRO (Reginal Entity of focus for this article) when you have questions.

Periodic Data Requests: What Are They?

Simply stated, they are requests from NERC or MRO to a registered entity for documents, data, or information. There are two types of data requests that a registered entity can receive from NERC or MRO: Periodic Data Submittals (PDS) and Event-Driven Periodic Data Submittals (Event-Driven PDS).

Periodic Data Submittals are collected by the Regional Entities on a periodic or as-needed basis. They can be models, studies, analyses, documents, procedures, methodologies, operating data, processes, or other information to demonstrate compliance with Reliability Standards. MRO collects data submittals on a quarterly and annual basis. Registered entities will receive guidance and instruction from MRO concerning periodic data submittal schedules and the data collection process.[1]​ Some PDS are initiated by the Compliance Enforcement Authority (CEA) as a data request in accordance with the schedule stated in the applicable Reliability Standards or as needed, in accordance with the NERC Rules of Procedure (ROP), Appendix 4C Section 4.6.

A list of current PDS submitted to NERC or the Regional Entity is available in the ERO Periodic Data Submittal Schedule document: 2024 ERO Enterprise Periodic Data Submittal Schedule (nerc.com). This schedule is published annually and can be accessed on the NERC website by going to the One-Stop Shop (Compliance Monitoring & Enforcement Program) webpage and clicking on Compliance-Compliance.

Of the data submittals listed within the ERO Enterprise Periodic Data Submittals Schedule, there are two PDS for Reliability Standards (FAC-003[2] and PRC-023) that are currently collected in Align[3] according to the schedule below:

Q1: FAC-003-4 Vegetation Outage Reporting

Q2: FAC-003-4 Vegetation Outage Reporting

Q3: FAC-003-4 Vegetation Outage Reporting & PRC-023-4 Updated List of Circuits

Q4: FAC-003-4 Vegetation Outage Reporting

NERC and the Regional Entities may also request additional data or information under Sections 800 or 1600 of the NERC ROP; these data requests are not included in the schedule above. Under NERC ROP Section 1600, NERC may request data or information that is necessary to meet its obligations under Section 215 of the Federal Power Act as authorized by Section 39.2(d) of the FERC regulations. Under the Performance Analysis program, NERC currently collects data from registered entities that meet reporting requirements for demand response, generation, transmission, protection system operations, and geomagnetic disturbances. Each Section 1600 application has associated data reporting instructions that are available through the Performance Analysis section of NERC’s website.[4] See the chart below a listing of these data requests.

Section 1600 Reporting Requirements Listed by Function
Reporting Type	Description	Required Reporting For	Access Needed	Contact E-mail
Demand Response Availability Data System (DADS)	DADS reporting has been temporarily suspended. Data collection is still required. See DADS suspension notice.	BA, DP	Application TBD	[email protected]
Generation Availability Data System (GADS)	Mandatory quarterly reporting of generator performance and outage data for conventional generating units that are 20 MW and larger, including smaller units that are aggregated.	GO	OATI NERC web Portal	[email protected]
Generation Availability Data System Wind (GADS Wind)	Mandatory quarterly reporting of generator performance data for wind plants that are 75 MW and larger.	GO	OATI Digital Certificate	[email protected]
Generation Availability Data System Solar (GADS Solar)	Mandatory quarterly reporting of generator performance data for solar plants that are 20 MW and larger.	GO	OATI Digital Certificate	[email protected]
Geomagnetic Disturbance Data (GMD)	Mandatory annual reporting of GMD device information and GMD event data, or indicating that the entity does not have GMD equipment.	GO, TO	ERO Portal, GMD permission(s)	[email protected]
Misoperations Information Data Analysis System (MIDAS)	Mandatory quarterly reporting of protection system operation and misoperation data for BES elements or indicating that the entity does not have MIDAS equipment.	DP, GO, TO	ERO Portal, MIDAS permission(s)	[email protected]
Transmission Availability Data System (TADS)	Mandatory quarterly reporting of transmission line and transformer outage data for BES elements 100 kV or greater.	TO	OATI NERC webPortal	[email protected]

Event-Driven Periodic Data Submittals are submitted by the registered entity on an ad hoc basis as required by the NERC Reliability Standards. These submissions are typically based on the date of occurrence of specific events. Currently, NERC Reliability Standards EOP-004 Event Reporting and CIP-008 Cyber Security — Incident Reporting and Response Planning require reporting of system events and incidents under this category. These standards are aligned with NERC ROP Section 800, specifically sections 807 and 808 regarding the analysis of events and disturbances.

Event Reporting Requirements
Reporting Type	Description	Required Reporting For
EOP-004	EOP-004 is an 0perations and Planning Reliability Standard that requires an entity to have an operating plan in accordance with Attachment 1 of EOP-004. Attachment 1 specifies event types and criteria by registration, which must be reported to NERC and other organizations (e.g., the applicable RE(s)). Upon recognition of a triggering event, the report (Attachment 2 of EOP-004) must be submitted by the later of 24 hours or by the end of the responsible entity’s next business day. It is important to train and educate staff on this requirement to ensure timely reporting.   Events, whether they meet the EOP-004 criteria or not, are generally addressed through the Event Analysis Program (EA Program). The goals of the EA Program are undertaking appropriate levels of analysis to determine the causes of the events, promptly assuring tracking of corrective actions to prevent recurrence, and providing lessons learned to the industry. The EA Program also provides valuable input for training and education, reliability trend analysis efforts, and, possibly, Reliability Standards development. For more information on the ERO Events Analysis Program, including process documents, cause-coding, categorization of events, and lessons learned, see the Event Analysis Program47 on the NERC website. Keep in mind that the Department of Energy (DOE) has similar reporting requirements as the EOP-004 process. Because of this alignment, NERC and the Regional Entities will accept a DOE-417 form in lieu of an EOP-004 form if the entity prefers to use that form for reporting. A copy of the DOE-417 can be submitted in the same manner as an EOP-004 form (Attachment 2) with the same directions as indicated in the EOP-004 standard (e.g., email [email protected] plus additional applicable organizations).	BA, DP, GO, GOP, RC, TO, TOP
CIP-008	Effective January 1, 2021, applicable NERC registered entities must comply with the expanded incident reporting requirements in revised Reliability Standard CIP-008-6. Reports must be submitted to the E-ISAC and, for those entities subject to the jurisdiction of the United States, the U.S. Department of Homeland Security Cybersecurity, and Infrastructure Agency (DHS CISA). Staff should work with their compliance departments on their entity’s specific requirements and obligations.   The E-ISAC is providing this information for situational awareness. If you have specific questions about the revised CIP-008-6 Reliability Standard applicability, or guidance, contact NERC’s Compliance Assurance or your respective RE compliance or enforcement Staff.	BA, DP, GO, GOP, RC, TO, TOP

Additionally, there are Event-Driven Periodic Data Submittal templates in Align which are submitted to the Regional Entity. Only standards and requirements applicable to your entity will be visible in Align. Some of these templates may include PRC-002 R12, EOP-008 R8, TPL-001, and TPL-007.

Are Periodic Data Requests and Submittals Mandatory or Voluntary?

Data requests are mandatory for US entities if they relate to compliance with NERC standards, fall under NERC ROP Section 1600 Requests For Data Or Information, or if they fall under NERC ROP Section 800 Reliability Assessment And Performance Analysis.

For Canadian entities, data requests are mandatory if they relate to compliance with adopted NERC standards or if they fall under NERC ROP Section 800 only. However, Canadians participate in these voluntary requests whenever possible. Requests are assessed on an individual basis considering confidentiality, risk to reliability and security of the bulk power system and industry participation.

Preventative Controls for Management of Requests

Let us be real, with so many requests and various due dates, it is all too easy to miss a submittal deadline. With this in mind, ensuring your organization has controls in place to meet these reporting obligations is vital. One possible control could include clearly designating individuals/departments in an Accountability Matrix for each standard requirement so that you know where your expertise lies when it comes to individual standards and requirements and who is best to action requests when they come in from NERC or MRO. Another control could include setting up automatic reminders for those consistent and predictable monthly, quarterly, annual, etc., data submittals that you are expecting along with NERC or MRO staff contact information if there are questions.

In addition, accountability for completing these data related tasks could be assigned to at least two individuals so that nothing is missed. Building on this idea of ensuring requests are not missed, entities should consider creating shared mailboxes for requests that may involve a larger group or various departments for awareness, to provide input and action data requests.

HELP!!! Who Do I Contact?

• MRO Periodic Data Submittals: If you have questions regarding periodic data submittals, you can contact: [email protected]
• MRO Data Requests: Questions regarding data collection at MRO should be directed to [email protected]
• NERC Periodic Data Submittals: For questions or to suggest potential enhancements contact: [email protected]
• Align, SEL IT Support or help accessing NERC’s portal: Submit a help desk ticket: https://support.nerc.net/​
• Additional assistance with Align training: Contact [email protected]

– Nazra Gladu, Manitoba Hydro

REFERENCES

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[1] Midwest Reliability Organization, Home/Program Areas/Compliance Monitoring & Enforcement/Periodic Data Submittals (https://www.mro.net/program-areas/compliance-monitoring-enforcement/periodic-data-submittals/)

[2] FAC-003-4 Vegetation Outage Reporting Process

[3] Align is a tool used to facilitate the secure submission, tracking, and synchronization of compliance and enforcement information. Use the Secure Evidence Locker (SEL) as needed. See this webpage for links to training videos Align – Midwest Reliability Organization (mro.net)

[4] ERO Enterprise Informational Package New Registered Entities: 101, January 26, 2024; https://www.nerc.com/pa/comp/RegistrationReferenceDocsDL/ERO%20Enterprise%20101%20Informational%20Package.pdf

ABOUT THE AUTHOR

DISCLAIMER

MRO is committed to providing non-binding guidance to industry stakeholders on important industry topics. Subject matter experts from MRO’s organizational groups have authored some of the articles in this publication, and the opinion and views expressed in these articles are those of the author(s) and do not necessarily represent the opinions and views of MRO.