Global Audit Ready Standards Updates - August 2018

Global Audit-Ready Standards Updates
August 2018

This newsletter contains information of interest to compliance professionals in the electric utility industry. Cooper Compliance clients and non-clients alike will find useful, timely information, including the following:
  • Cooper Compliance News
  • Industry Events
  • Industry News
  • New or Revised NERC Standards
  • NERC Standards Under Development
  • Recently Added RSAWs

Cooper Compliance News

NERCRequirements List Updated

You might notice a couple of new standards in the lists of standards for Global Audit-Ready applications. We recently updated all clients’ standard databases to keep pace with the released standards on the NERC website. These reside in your Cooper Compliance SharePoint website in the NERCRequirements list.
Here are the highlights:
  • Added BAL-002-2i
  • Added BAL-004-WECC-03
  • Added CIP-003-7
  • Added EOP-006-3
  • Added EOP-008-2

Global Audit-Ready Application Enhancements

  • Global Audit-Ready Operator Instructor Log – Added the ability to automatically send logs such as outages as SMS text messages instead of email.
  • All apps – Improved product robustness to load faster and manage SharePoint requests from multiple users. 
  • Global Audit-Ready Reporter – New interface elements for Internal Auditors allow for audit ratings, attaching audit work papers, and preserving audit results for different audit periods.
  • Global Audit-Ready Editor – Just became even faster to setup new Standards with inherent existing process feature.

Come See Us and View our Products...

Please come to the Cooper Compliance booth to view our latest products.

The WECC Reliability and Security Workshop (formerly "Compliance Workshop") is in San Diego from October 23 to 25.  
Sign up for the conference here.

The Northeast Power Coordinating Council 2018 Fall Compliance & Standards Workshop is in Providence, RI from November 7 to 8.
Sign up for the conference here. 

The North American Generator Forum (NAGF) annual member meeting is at the NERC headquarters in Atlanta from October 2 to 3.  
Sign up for the conference here.

We will post our notes at

Industry News

Peak Reliability announced that it will cease operations at the end of 2019. The CAISO will be offering Reliability Coordinator services for the independent system operator footprint and will also offer those services to others in the West. Press release is here.
WECC will begin collecting functional relationship information between Generator Owners (GO) mapping to Transmission Planners (TP), and Generator Operators (GOP) mapping to Transmission Operators (TOP), and Transmission Operators (TOP) mapping to Balancing Authorities (BA). Deadline for submission of this data via webCDMS is September 28, 2018. FAQ is here

New or Revised Standards

There have been no new or revised standards released since the last newsletter.

Standards Under Development

2018 Bulk Electric System Definition Reference

The BES Definition Reference Document is being revised.
Comment Period: 8/7/2018 to 9/10/2018

This document explains how the revised Bulk Electric System (BES) definition should be applied. 
Cooper Compliance plans to submit the following comments on the new reference document:
  • In general, for all proposed modifications, clarity should be made to Figure I2.1, which attempts to define what is considered a “single point of interconnection”. Further clarification is attempted under the heading Common Point of Connection (p 22 of clean copy linked above). Neither provide full clarity and need to be improved.
    • Does the configuration represent the breaker scheme, a substation, or a line?
    • Does breaker configuration matter? If breaker configuration prevents a cascade outage on both generators, should they be added together?
    • Do the boxes in figure E3.3 represent a breaker configuration or a substation configuration?

Functional Model Advisory Group (Reliability Functional Model and Functional Model Technical Document)

Comment Period: 8/3/2018 to 9/17/2018
The Reliability Functional Model (FM), Function Definitions and Function Entities, and Reliability Functional Model Technical Document (FMTD), have come up for review again. Cooper Compliance, on behalf of several of our clients, had proposed significant changes to provide clarification during the last round of edits. No changes were accepted based on the fact that the drafting team explained that the functional model is not tied to the registration process and is only used as guidance for the development of Standards.We feel this complete disconnect should not be accepted given the functional model explains the activities of a registered entity. If the registration process is flawed and includes entities that don't perform the activities listed in the functional model, then the document has very little value and NERC should consider retiring it.

2018-02 Modifications to CIP-008 Cyber Security Incident Reporting (SAR)

Comment Period: 8/10/2018 to  9/10/2018

In Order No. 848 FERC has directed NERC to revise the Standard to require the reporting of Cyber Security Incidents that compromise, or attempt to compromise, a responsible entity’s Electronic Security Perimeter (ESP) or associated Electronic Access Control or Monitoring Systems (EACMs). Cooper Compliance agrees that reporting should be made as directed by NERC. However, it seems that this Standard should be merged with EOP-004, which requires redundant reporting.

2015-10 Single Points of Failure | TPL-001-5 and Implementation Plan

Comment Period: 7/30/2018 to 9/14/2018
Balloting dates: 9/5/18 to 9/14/18
The proposed standard project will benefit reliability by providing clear, unambiguous and results-based reliability standard requirements to address the assessment’s recommendations for modifying NERC Reliability Standard TPL-001-4 (Transmission System Planning Performance Requirements)

2016-02 Modifications to CIP Standards | CIP-002-6 and CIP-003-8

Join Ballot Pool: 8/23/18 to 9/21/18
Balloting dates: 9/28/18 to 10/9/18
Comment Period: 8/23/2018 to 10/9/2018
This will modify the CIP family of standards (or develop an equally efficient and effective alternative) to address issues identified by the CIP V5 TAG, address FERC directives contained in Order 822; and address requests for interpretations as directed by the NERC Standards.

2015-09 Establish and Communicate System Operating Limits

Balloting dates: 10/1/2018 to 10/10/2018
Comment Period: 8/24/2018 to 10/10/2018
The project will revise the requirements for determining and communicating SOLs and IROLs to address the issues identified in Project 2015-03 Periodic Review of System Operating Limit Standards.


Click the Microsoft Word icon below to be taken to the RSAW on NERC’s website.
d8756b7a-f702-4bc9-a2fa-863f50bd2f32.jpg  BAL-002-2(i) Disturbance Control Performance - Contingency Reserve for Recovery from a Balancing Contingency Event 8/22/2018
d8756b7a-f702-4bc9-a2fa-863f50bd2f32.jpg  BAL-005-1 Balancing Authority Control 8/22/2018
d8756b7a-f702-4bc9-a2fa-863f50bd2f32.jpg  FAC-001-3 Facility Interconnection Requirements 8/21/2018
d8756b7a-f702-4bc9-a2fa-863f50bd2f32.jpg  PRC-025-2 Generator Relay Loadability 8/21/2018

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Cooper Compliance - Keeping you Audit Ready

Cooper Compliance strives to simplify compliance by integrating compliance into our clients’ daily work.  The Global Audit-Ready system records and stores evidence as you perform your normal activities, freeing-up time so you can focus on adding value to your organization. Let us know if we can help, or if you would like a demo of our transformative Global Audit-Ready compliance applications.

Cooper Compliance has been providing NERC Compliance services since 2007.  The Global Audit-Ready Software suite by Cooper Compliance are SharePoint applications designed to provide automatic RSAW Development as well as controls to ensure accuracy when demonstrating compliance.
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