Standards Updates

Global Audit-Ready Standards Updates

Global Audit-Ready Standards Updates

March 2019

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

  • Global Audit-Ready Enhancements

  • Upcoming Industry Events

  • Retiring Standards

  • New or Revised NERC Standards

  • NERC Standards Under Development

  • Standards That Recently Became Effective

  • New RSAWs

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Cooper Compliance News

NERCRequirements List Updated

Summary of changes (more details below0
Added: PER-003-2, TPL-007-3
Retiring: IRO-006-TRE-1, PER-004-2, PRC-004-WECC-2
Changed Effective Dates: PRC-002-2

Several revised standards have recently become effective. See Standards That Recently Became Effective below for more details.

 

Global Audit-Ready Application Enhancements

Global Audit-Ready Approval Tracking System: The Global Audit-Ready Approval Tracking System lets you track not only one-time data requests, but also cyclical required updates to documents such as policies and procedures. You can also use it to process Authorization Requests for access to BES Cyber Assets or Information, BES Cyber Asset software upgrades, or reviews of RSAWs.  A reminder based tracking system cycles documents through the updating, reviewing, finalizing, and approving stages of document update, while obtaining electronic signatures throughout the process. You have the ability to add notes at each stage and assign different stakeholders to various tasks relating to the update.

Global Audit-Ready Survey tool: The new Global Audit-Ready Survey tool is an automated internal control system. This interactive survey tool allows you to query your SMEs to determine if certain activities occurred.  A positive response generates a task prompting them to take action and provide evidence related to a Requirement. It can also be used to simply collect information needed for regulatory reporting. All survey questions are listed by the subject matter expert in one form with one email reminder whenever the survey period opens up. An escalation email reminder is sent if the survey and associated tasks have not been completed within the designated time period. This powerful automated tool can assist with many compliance-related activities including the reporting of number of accidents, endangered species or other activities. This month, we added additional information to the Survey Answer list. We also added the ability to assign Survey-initiated tasks to other people

Global Audit-Ready Compliance Status Report: The next due dates appear under the processes.

Global Audit-Ready Dashboard: There is now a button to open a one page summary.

Global Audit-Ready Operating Instruction Log:

  • Add logos to OIL emails

  • Add ability to search descriptions in Open Logs

  • Add ability to specify scheduled date in logs

Global Audit-Ready PSMP Application Release Notes:

  • Update of maintenance log interface

    • Change equipment selection to checkbox to make it easier to select multiple pieces of equipment

    • Selecting new equipment will not clear out data entered for previously selected equipment.

    • New document Note window; enter notes that will appear in the Compliance Status Report and the completed RSAW

    • Equipment Selection box is now resizable

    • Lets users add additional work order instructions if unresolved issue box is checked

  • Improved robustness and error checking

    • Fixed a problem where clients change the library name after it’s created)

    • Disallows attachments that have # in the title to maintain SharePoint compatibility.

    • Prevents a security error if the user takes more than 30 minutes to submit a log

    • If there are no checked instructions, gives a warning and does not update the equipment list dates

  • Updated how unresolved work orders are handled

    • Lets users close all open unresolved work orders for a piece of equipment if all the instructions for that instruction is checked

    • Adds support to create a unique unresolved work order for each equipment

    • No longer automatically creates a new unresolved work order if there is already an active unresolved work order.   There is now a confirmation window to let a user create a new work order if there is already an open one.

    • Lets the user update multiple unresolved work orders on the same equipment. 

    • Due dates for the unresolved work orders are displayed in unresolved work order selection window

  • Updated data fields

    • Added EquipmentType to EquipmentLog list

    • In EquipmentLog list, MaintenanceComplete is "Yes" only if there was no unresolved issue

Upcoming Industry Events

Here are a few upcoming industry events. See Erica and Mary Jo from Cooper Compliance TOMORROW at WECC. Drop by our booth to see a demo of our great new product enhancements.

  • Tomorrow! WECC Spring Workshop, April 9 - 11, Garden Grove CA (near Anaheim). More details.

  • NPCC Spring Compliance & Standards Workshop, May 22 - May 23, Groton CT. Get tickets.

Retired Standards

IRO-006-TRE-1: RC  (IROL and SOL Mitigation in the ERCOT Region)
For the Texas Reliability Entity region, per FERC order RD19-2-000, IRO-006-TRE-1 is retired on 1/29/2019. NERC contends "continent-wide Reliability Standards have been approved that cover the same reliability goals as the requirements in regional Reliability Standard IRO-006-TRE-1, rendering the regional Reliability Standard redundant."

PER-004-2:  RC  (Reliability Coordination — Staffing)
On November 21, 2018 in FERC order RD18-9-000 FERC approved retirement of PER-004-2. The order states,  "With respect to the proposed retirement of Reliability Standard PER-004-2, NERC states that Reliability Standard PER-004-2 contains two requirements that are redundant with other Commission‐approved Reliability Standards." It becomes retired the day before PER-003-2 becomes effective 6/30/2019.

PRC-004-WECC-2  TO, GO, TOP  (Protection System and Remedial Action Scheme Misoperation)  
This regional Reliability Standard is becoming redundant with other approved standards and no longer necessary for reliability. In particular, Reliability Standard PRC-012-2 (Remedial Action Schemes), approved by the Commission in Order No. 837, contains requirements for remedial action scheme analysis. Reliability Standard PRC-012-2 will become effective in the United States on January 1, 2021. According to NERC and WECC, PRC-004-WECC-2  may therefore be retired at that time with no adverse effect on reliability. According to FERC order RD18-3-000 on March 28,2019,  regional Reliability Standard PRC-004-WECC-2  has a retirement effective date of January 1, 2021
 

New or Revised Standards In the CCC Standards Database

PER-003-2 (Operating Personnel Credentials)
Will replace PER-003-1 as of 7/1/2019.  The only substantive change is that a clarifying footnote is added to ensure that stakeholders (now and in the future) understand (i) the connection between the Standard and the Program Manual; and (ii) that the certifications referenced under PER-003-2 are those under the NERC System Operator Certification Program.. Also, boilerplate text common to all standards has been updated to reflect NERC's current template.
Effective Date: 7/1/2019
Applies to: RC, TOP, BA.

TPL-007-3  (Transmission System Planned Performance for Geomagnetic Disturbance )
Was added to Cooper Compliance NERC database. It is the same as TPL-007-2 except -3 adds a Canadian Variance. Thus TPL-007-2 never becomes effective but is superceded by the revised TPL-007-3, with all phased-in compliance dates carried forward unchanged.
Effective Date: Earliest is 7/1/19, with varying effective dates for specific requirements thereafter.
Applies to: PC, TP, TO, GO

PRC-002-2: (Disturbance Monitoring and Reporting Requirements)
For R2, R3, R4, R6, R7, R8, R9, R10, R11 , changed Effective Date from 7/1/2022 to 7/1/2020. This is because according to the NERC Implementation Plan, 50% compliance is required at 7/1/2020 and 100% compliance is required at the stated NERC effective date of 7/1/2022.
Applies to: PC, RC, TO, GO
 

Standards Under Development

2018-03 Standards Efficiency Review Retirements Project Scope
The Standard Authorization Request (SAR) drafting team evaluated NERC Reliability Standards using a risk-based approach to identify potential efficiencies through retirement or modification of Reliability Standard Requirements. Many Reliability Standards have been mandatory and enforceable for 10+ years in North America. The SAR drafting team identified potential candidate requirements that are not essential for reliability, could be simplified or consolidated, and could thereby reduce regulatory obligations and/or compliance burden.Initial Ballots and Non-binding Pollsstart: 4/3/2019end: 4/12/2019 Comment Period                            start 2/27/2019end: 4/12/2019

2019-02 BES Cyber System Information Access Management

Background
This project enhances BES reliability by 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 (aka cloud), such as Microsoft 365.

Standard(s) Affected – CIP-004-6 - Cyber Security - Personnel & Training | CIP-011-2 - Cyber Security - Information Protection

Comment Period start: 3/28/20194/26/2019

Standards That Recently Became Effective

On 4/1/2019 (No Joke!), the following standards become effective, replacing their previous versions:
BAL-002-3 BA RSG Disturbance Control Standard – Contingency Reserve for Recovery from a Balancing Contingency Event
EOP-004-4 BA DP GO GOP RC TO TOP Event Reporting
EOP-005-3  DP TO TOP GOP System Restoration from Blackstart Resources
EOP-006-3  RC  System Restoration Coordination
EOP-008-2  BA RC TOP Loss of Control Center Functionality

BAL-002-3  Disturbance Control Standard – Contingency Reserve for Recovery from a Balancing Contingency Event
R1.3.1  expanded and clarified under what situations the Responsible Entity experiencing a Reportable Balancing Contingency Event shall deploy Contingency Reserve. It now includes Responsible Entities that have, during communications with its Reliability Coordinator in accordance with the Energy Emergency Alert procedures, (i) notified the Reliability Coordinator of the conditions described in the preceding two bullet points preventing the Responsible Entity from complying with Requirement R1 part 1.1, and (ii) provided the Reliability Coordinator with an ACE recovery plan, including target recovery time.
Applies to: BA RSG


EOP-004-4  Event Reporting
For R2, entities shall report events by the later of 24 hours of recognition of meeting an event type threshold for reporting or by the end of the Responsible Entity’s next business day (4 p.m. local time will be considered the end of the business day). Previously, events had to be reported within 24 hours of recognition or by end of next business day if event occurred on a weekend.
Also, R3, which existed in EOP-004-3, no longer exists in EOP-004-4. R3 was this: "Each Responsible Entity shall validate all contact information contained in the Operating Plan pursuant to Requirement R1 each calendar year." Cooper Compliance feels this exercise is a good one to continue.  For our clients we simply move the validation process to R1, as an internal control.
Applies to: BA DP GO GOP RC TO TOP

EOP-005-3   System Restoration from Blackstart Resources
EOP-005-3 has extensive revisions, including updated restoration plan guidelines, testing requirements, documentation requirements, and training requirement for restoration.
Applies to: TOP, GOP, TO, DP

EOP-006-3    System Restoration Coordination
Clarifies re-establishing interconnections during restoration.
In the new standard, if conflicts between restoration plans are found, the RC must notify neighboring RCs of such conflicts in 60 days. The new standard mandates System restoration drills/simulations per year. The requirement for the RC to coordinate resynchronizing islanded areas has been dropped.
Applies to: RC

EOP-008-2   Loss of Control Center Functionality
Data Communications has been changed to Data exchange capabilities for R1.2.2.
Voice communciation has been changed to Interpersonal Communications for R1.2.3
Applies to: BA RC TOP
 

New RSAWs

No new RSAWs have been released recently.

For more information, and for early access to this newsletter, consider subscribing:

NERC Update Summary February 2019

Global Audit-Ready Standards Updates

February 2019
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

  • Upcoming Industry Events

  • New or Revised NERC Standards

  • NERC Standards Under Development

  • Standards Becoming Effective

  • New RSAWs


Cooper Compliance News

NERCRequirements List Updated

In January, BAL-002-3 and VAR-001-5 RSAWs were added to the Cooper Compliance database. See the New RSAWs section.
The future enforceable standard PER-003-2 has been added,and retirement dates have been entered for PER-003-1 and PER-004-2 (which is being retired with no new version to replace it).

Global Audit-Ready Application Enhancements

Development at Cooper Compliance continues at a steady pace to give you more control and automation for managing your compliance program.
Approval Tracking System:Last month, as you may remember, we announced our new Global Audit-Ready app, the Approval Tracking System. This lets you track not only one-time data requests, but also cyclical required updates to documents such as policies and procedures. You can also use it to process reviews of RSAWs.  A reminder based tracking system cycles documents through the updating, reviewing, finalizing, and approving stages of document update, while obtaining electronic signatures throughout the process. You have the ability to add notes at each stage and assign different stakeholders to various tasks relating to the update.

Global Audit-Ready Survey tool:Feeling overwhelmed? Short of resources? Not enough time to keep up with all the activity going on around you and maintain compliance with the ever-growing regulations?

Cooper Compliance has you covered through automation!

This month, we are very excited to announce the new Global Audit-Ready Survey tool, which is an automated internal control system. This interactive survey tool allows you to query your SMEs to determine if certain activities occurred.  A positive response generates a task prompting them to take action and provide evidence related to a Requirement. It can also be used to simply collect information needed for regulatory reporting. All survey questions are listed by the subject matter expert in one form with one email reminder whenever the survey period opens up. A second email reminder is sent if the survey and associated tasks have not been completed within the designated time period.  Features include:

  • Drill down survey capability

  • Task creation to upload documents

  • Task creation to report a value or text

This powerful automated tool can assist with many compliance-related activities including the reporting of number of accidents, endangered species or other activities.

PSMP App:The PSMP app has been updated with some interface changes to make it easier to select multipl pieces of equipment. A new Notes window, for notes that will appear in Compliance Status Report and the finished RSAW, has been added. You can now add additional work order instructions for unresolved issues. Due dates for unresolved work orders are now displayed. The new PSMP app also includes other changes that allow for a smoother and more efficient user experience.

Industry News

It turns out that NERC penalties are real and can cost you a bundle:https://www.eenews.net/stories/1060119265

The California PUC recently implemented Cyber Security regulations, applicable to DPs in the state: http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M260/K335/260335905.PDF

Upcoming Industry Events

Here are a few industry events where you might see Cooper Compliance. Drop by our booth to see a demo of our great new product enhancements.

  • Solar Asset Management, March 26 - 27, San Francisco CA. More details.

  • WECC Spring Workshop, April 9 - 11, Garden Grove CA (near Anaheim). More details.

  • NPCC Spring Compliance & Standards Workshop, May 22 - May 23, Groton CT. Get tickets.

Retired Standards

No standards are being retired at this time.
PER-004-2 is scheduled to retire 6/30/2019 due to its requirements being redundant with other enforceable standards.

New or Revised Standards In the CCC Standards Database

PER-003-2, titled Operating Personnel Credentials, will replace PER-003-1 as of 7/1/2019.  The only substantive change is that a clarifying footnote is added to ensure that stakeholders (now and in the future) understand (i) the connection between the Standard and the Program Manual; and (ii) that the certifications referenced under PER-003-2 are those under the NERC System Operator Certification Program.. Also, boilerplate text common to all standards has been updated to reflect NERC's current template.
Effective Date: 7/1/2019
Applies to: RC, TOP, BA.

Standards Under Development

At this time, there are no upcoming Ballots, no ballot pools open for joining, and no standard changes posted for comment.

Standards Becoming Effective Soon

On 4/1/2019, the following standards become effective:
BAL-002-3
EOP-004-4
EOP-005-3
EOP-006-3
EOP-008-2
See future newsletters for what these changes mean for you.

New RSAWs

These RSAWs have been added to the NERC website and have also been added to the Global Audit-Ready software for Cooper Compliance clients.

BAL-002-3

VAR-001-5


Global Audit-Ready users will be provided these RSAWs to upload to your RSAW Documents library in a separate email.

December 2018 - Standards Updates

Happy New Year! 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

  • Upcoming Industry Events

  • Retired Standards

  • New or Revised NERC Standards

  • NERC Standards Under Development

  • Standards Becoming Effective

  • New RSAWs


Cooper Compliance News

NERCRequirements List Updated

The Cooper Compliance is excited to welcome aboard all our new clients with a strong 2018 finish. We are looking forward to 2019 and can’t wait to tell you about our plans which will be announced upon completion. We are super excited for what will be released in next months newsletter.

Reflecting back to 2018, Global Audit-Ready just keeps getting better and better. Here are all the new features added:

  • Heat Map to view compliance for all your facilities at once.

  • Enhanced workflows, including document review and approval discussed below.

  • RSAW creator to generate your compliance documentation with a click of a button.

  • Enhancements to our PSMP tool, now used to track many other activities such as generator testing and model validations.

  • Key indicator graphics.

  • Enhanced Auditor module for your internal auditors to track their audit-results.

  • Many other minor enhancements such as filters by subject matter experts, click link from email or task list to upload documents to close out tasks, enhancements to document review (also discussed below), and many more.

In December, the Global Audit-Ready database of NERC and regional standards has been updated to reflect changes NERC took during the previous month. It was a quiet month at NERC (maybe the holiday cheer?) and only one new standard, VAR-001-5, was added.

Global Audit-Ready Application Enhancements

Cooper Compliance has developed a new Global Audit-Ready app, the Approval Tracking System. This lets you track not only one-time data requests, but also cyclical required updates to documents such as policies and procedures. You can also use it to process reviews of RSAWs. A reminder based tracking system cycles documents through the updating, reviewing, finalizing, and approving stages of document update, while obtaining electronic signatures throughout the process. You have the ability to add notes at each stage and assign different stakeholders to various tasks relating to the update.

We've used Approval Tracking System's features to enhance the compliance management team's ability to review documents prior to a task being marked as complete. When this feature is turned on, the escalation team will receive an email to review new documents added to the system to ensure they are relevant and loaded to the appropriate task. Once approved by at least one person from the escalation group, the task will be marked complete.

Upcoming Industry Events

Here are a few industry events where you might see Cooper Compliance. Drop by our booth to see a demo of our great new product enhancements.

  • Solar Asset Management, March 26-27, San Francisco CA

  • WECC Spring Workshop, April 9-11, Anaheim CA

  • NPCC Spring Compliance & Standards Workshop, May 1, Groton CT

Retired Standards

None.

New or Revised Standards In the CCC Standards Database

VAR-001-5

Titled Voltage and Reactive Control, will replace VAR-001-4.2 as of 1/1/2019. The only substantive change is that E.A.15, a regional variance for WECC, was eliminated. It read “Each Generator Operator shall convert each voltage schedule specified in Requirement E.A.13 into the voltage set point for the generator excitation system.”

Effective Date: 1/1/2019

Applies to: TOs. Also to GOs within WECC for the WECC variance.

Standards Under Development

Project 2017-01 Modifications to BAL-003-1.1

Initial Ballots: 1/8/2019 to 1/17/2019

Comment Period: 12/4/2018 to 1/17/2019

Join Ballot Pools: 12/4/2018 to 1/2/2019

The Phase I portion of the project proposes to revise the BAL-003-1 standard and process documents to address: (1) the inconsistencies in calculation of IFROs (2) the Eastern Interconnection Resource Contingency Protection Criteria; (3) the frequency of nadir point limitations (4) clarification of language in Attachment A; and (5) the BAL-003-1 FRS Forms need enhancements.

Project 2018-04 Modifications to PRC-024-2

| Standard Authorization Request

Comment Period: 12/19/2018 to 1/18/2019

This update includes potential modifications to PRC-024-2 to help ensure that inverter-based generator owners, operators, developers, and equipment manufacturers understand the intent of the standard in order for their plants respond to grid disturbances in a manner that contributes to the reliable operation of the BPS. This change stems in part from the analysis of the Blue Cut Fire and Canyon 2 Fire disturbances in southern California

Standards Effective on 1/1/2019

Besides VAR-001-5, discussed above, BAL-005-1 and FAC-001-3 are becoming enforceable on 1/1/2019. Take a look:

BAL-005-1

Balancing Authority Control. Version 1 of this standard retires Version 0.2b as well as BAL-006-2. The Standard now only applies to the Balancing Authority and no longer applies to the Generator Operators (GOP) or Transmission Operators (TOP). The requirements for a GOP or TOP to be within the metered boundaries is met with the revised FAC-001 standard discussed below. The purpose of the Standard is to establishes requirements for acquiring data necessary to calculate Reporting Area Control Error (Reporting ACE). The standard also specifies a minimum periodicity, accuracy, and availability requirement for acquisition of the data and for providing the information to the System Operator. Complete re-write of standard.

FAC-001-3

Facility Interconnection. R4. of this Standard was revised to require those GO’s have a third party Facility interconnecting to their existing Facility to ensure their Interconnection Agreement includes provisions for the third party to be within the metered boundaries of a BA. The purpose of the Standard is Tto avoid adverse impacts on the reliability of the Bulk Electric System, Transmission Owners and applicable Generator Owners must document and make Facility interconnection requirements available so that entities seeking to interconnect will have the necessary information. Major change? TOs and GOs must address the following in Facility interconnection requirements: procedures for confirming with those responsible for the reliability of affected systems of new or materially modified transmission Facilities are within a Balancing Authority (BA) Area’s metered boundaries. This requirement retires the responsibility within BAL-005-1 to provide evidence that the TO or GO is within the

metered boundaries of the BA Area.

New RSAWs

These RSAWs have been added to the NERC website and have also been added to the Global Audit-Ready software for Cooper Compliance clients. Click the Microsoft Word icon below to be taken to the RSAW on NERC’s website.

BAL-002-3 System Restoration from Blackstart Resources 11/2/2018

VAR-001-5 Loss of Control Center Functionality 11/2/2018

Global Audit-Ready users will be provided these RSAWs to upload to your RSAW Documents library in a separate email.

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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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