Many of us have been there: you have discovered an instance of possible noncompliance with a NERC Reliability Standard requirement and you need to submit a Self-Report or Self-Log. You dig out the Registered Entity Self-Report and Mitigation Plan User Guide to review what needs to be included in your submission. You cover every chapter there: Description of the Noncompliance, Risk Assessment, Mitigation of the Noncompliance, and all the details within each chapter. Although Self-Reports are never fun, you are feeling pretty good about how thoroughly you have prepared your filing.
Pretty soon you get a Request For Information (RFI) from Midwest Reliability Organization (MRO). You send your entity’s response. Shortly after, you get another RFI. You respond. Perhaps another RFI follows. The RFIs are asking for more detail related to the standard requirement that may have been violated. The back-and-forth of the requests and responses takes additional time for you and your SMEs to complete, and MRO staff are spending significant time trying to gather the information they need to evaluate your submission.
If only there were some kind of tool that covered the specific requirement to help make your initial Self-Report/Log so complete that you (and MRO) could avoid all these RFIs.
Such a tool is now available for at least two of the more frequently violated NERC Reliability Standard requirements!
MRO Risk Assessment and Mitigation (RAM) staff, members of the Compliance Monitoring and Enforcement Program Advisory Council (CMEPAC), and volunteers from entities in the region formed a group to talk about how to address types of information routinely missing from noncompliance submittals. To develop the concept, the group selected two NERC Reliability Standard requirements as the initial requirement-specific RFI subjects: CIP-007-6 R2 and FAC-008-5 R6. The group then split into two subgroups, with each focusing on one of these two requirements.
The initial plan was to develop forms that entities would fill out and return in response to an RFI from MRO. However, the diversity of thought and depth of expertise of the individuals working on this project resulted in a much more responsive end product! This CMEPAC subgroup produced a precise set of guidance targeted at specific requirements that, because it can be read and understood up front, will enable the registered entity to submit a very robust Self-Report/Log right out of the gate, even before MRO staff sees it. The benefits of this tool include:
- More detailed and comprehensive submissions from registered entities
- Fewer RFIs from RAM staff for further information
- Time saved for both the submitting entities and RAM staff, and
- More streamlined process resulting in a shorter time between submission and closure
MRO conducted a webinar in early December to introduce everyone to requirement-specific RFIs. The recording is available here.
The two requirement-specific RFI templates are available on MRO’s website under Program Areas/Compliance Monitoring and Enforcement Program//Requirement Specific Request For Information Library. These documents can be included in the initial Self-Report/Log submission in Align.
The CMEPAC plans to develop more requirement-specific RFIs for standards that are frequently violated. You can help shape the future of this initiative by providing feedback, either positive or constructive, on the existing RFI templates and/or by suggesting other requirements that might benefit from this process.
This project is an excellent example of what we can accomplish together as a region to forward our shared vision of a highly reliable and secure bulk power system. The collaborative efforts of registered entities, CMEPAC members, and MRO staff has resulted in a streamlined and efficient process that benefits us all. If you would like to participate in the development of future requirement-specific RFIs, volunteer to serve on the CMEPAC, or simply have questions on the process, please reach out to [email protected].
– Kevin Lyons, Regulatory Compliance Administrator, Central Iowa Power Cooperative and MRO CMEPAC member
ABOUT THE AUTHOR
Kevin Lyons, Regulatory Compliance Administrator, Central Iowa Power Cooperative
Kevin Lyons has 24 years of electric utility experience, serving the last 14 as Regulatory Compliance Administrator at Central Iowa Power Cooperative. His education includes a BA in Marketing and an MBA in Finance, both from the University of Iowa. Kevin currently serves on the CMEP Advisory Council and has served on the Mid-Continent Compliance Forum Board of Directors. He and his wife Jennifer have three children and two grandchildren. In his free time, Kevin enjoys golfing, fishing, shooting pool, biking, and playing cards.
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.