SYSTEM RELIABILITY
The NERC auditors are coming
The persons responsible for reliability (responsible entities) at utilities and other participants in the U.S./Canadian bulk power industry are preparing to have their companies’ compliance with the North American Electric Reliability Corp.’s (NERC’s) mandatory reliability standards audited by teams from NERC Regional Entities (REs). The audit schedule for 2008-2010 should have been posted on NERC’s web site (
www.nerc.com) by the end of October.
Transmission operators, balancing authorities, generator owner/operators, and the other functional responsible-entity categories are gathering documentation and other evidence to demonstrate their compliance with the reliability standards to the audit teams. NERC REs will notify entities of the date of their audit and which standards it will address. NERC posted Reliability Standards Audit Worksheets for 40 different reliability-related activities on its web site this May, ahead of the June 1 effective date of the standards. The site visit will conclude with an exit presentation by the audit team and the passing out of an audit evaluation form to be filled out by audit team members and the audited entity.
New compliance challenges
As responsible entities vet the standards applicable to their category, they are finding that, in most cases, compliance is being achieved. Their next challenges are to ensure that all internal departments know which activities they must perform and document and that proof of compliance is readily accessible in a convenient format. For many participants, the challenge of compliance has become a question of “how” and “where,” rather than “if.”
Responsible entities are preparing for the audits in various ways, from insisting on electronic documentation, to planning to record or transcribe the audit itself, to arranging for their lawyers to be present. Some are making plans to have consultants on hand for pre-audit preparation, for the audit itself, and for post-audit activities such as evaluation, settlement of alleged violations, and contributing to records needed to support litigation, if needed.
Complicating these efforts is the fact that the structure, intent, and target of some standards remain unclear and questionable. Many of the mandatory standards were adapted from voluntary standards written when most utilities were vertically integrated and housed separate functions such as balancing authority, transmission owner, transmission operator, load-serving entity, and generator owner/operator under one roof. Because deregulation unbundled many of these functions, some reliability standards and their requirements now are difficult to apply to discrete responsible entities.
In some cases, the complications resulting from unbundling even extend to registration of functional entities. For example, in some instances competitive retail power providers are being cast in the role of load-serving entities, required to account for demand-side management programs and load forecasting. NERC says it is in the process of realigning the functional model that serves as the basis of registrations. But that is little comfort to the responsible entities at new participant categories that were not part of the old industry structure. They are being told that they must comply with the new standards even as their scope of applicability is being revised.
Email
Comments
Print
Reuse
