By Jack Jackson, NERC Senior Reliability Specialist
While the big season of implementation and phased implementation plans is past the idea of the implementation plan is here to stay. And while there aren’t as many active implementation plans as there were several years ago, some are still going on from the first wave and new ones are coming in. It’s important to make sure that you’ve got some tools in your back pocket to make sure you stay on track.
Implementation plans are sometimes simple and sometimes quite complicated. The anatomy is generally consistent in defining the affected standard(s), definition changes, applicable entities, timelines, key dates and phases (if applicable). Taken individually, these elements are easy to mange but together they can make for a tracking or logistical nightmare. And not because they are difficult to do but because they are not typical of how compliance is managed in the bigger picture.
It’s worthwhile to take a moment to look back at those standards that are or were on implementation plans to make sure that you are either on track for a fully successful implementation or that you were able to meet all the milestones along the way. Here are some areas to make sure that you keep your eye on along the way.
Check your dates. Make sure that you know when the start of the implementation is and what the intervals or milestones are for implementation. The language concerning dates can be quite confusing. If there is any confusion on the dates or milestones, reach out to your regional entity or NERC for clarification.
Make those milestones. Milestones can vary from wholesale implementation of a requirement or standard to percentages to age including new versus existing elements. Make sure that you are clear on how the milestones impact your equipment and what your goals are.
It’s not a competition but you are competing. There are no awards for getting across the implementation line first, but it’s important to remember that you aren’t the only one that needs the resources that suddenly everyone needs (engineers, equipment, contractors and so on). It’s to your advantage to secure your resources early and as far into the future as is practicable.
Beat the clock. While one shouldn’t plan for failure, there is always the potential that something will go wrong. Make sure that your internal implementation goals are scheduled well in advance of the implementation deadline to make sure you have time for a do over should you need it.
Check your work. You planned, you met your milestones and now things can go back to normal, right? Not yet. Meeting the deadline for the standard doesn’t mean that all the milestones along the way were met. Double check your counts and percentages by date or phase to make sure you met and can clearly demonstrate all the stages of the implementation plan were met.
Implementation plans are intended to get facilities, equipment and processes into a reliable configuration within a defined time frame. But like so many things in NERC it is up to the registered entities to make that happen. Its important to read the standard and the implementation plan fully to make sure that you are informed on all the moving parts as well as what you are on the hook for. In short, if NERC has an implementation plan, you should have an implementation plan.