Author: Leland McMillan, NERC Supervisor
The North American Electric Reliability Corporation (NERC) has issued new training and onboarding tools aimed to assist industry participants ensure that their personnel are up to date with software applications and communications essential for maintaining compliance.
The ERO Enterprise Entity Onboarding Checklist provides new Primary Compliance Contacts (PCCs), PrimaryCompliance Officers (PCOs) and Alternate Compliance Contacts (ACCs) with an easy guide for signing up for essential, ERO Enterprise reliability-focused applications and communications. The checklist includes ERO Portal, CORES (registration), Section 1600 reporting, NERCAlerts, news/information, regional applications, and many more items.
The ERO Enterprise 101 Informational Package provides a general overview of new registrations, rules of procedure, resources, and guidance for various ERO functions
The ERO Enterprise Registration Procedure serves as a directional document for all aspects of registration, including new registrations, registration options, changes, deactivations, and the NERC-led registration review panel. A sale or transfer of assets is addressed in Appendix A:
Registered entities must be aware of registration and compliance responsibilities when engaging in existing BES asset transactions that involve the transfer of BES assets from one entity (seller) to another entity (buyer). These entities must know which transactions must be reported to applicable REs. The change of ownership or control of such BES assets must be identified due to the possible impact to a registered entity’s compliance responsibilities with NERC Reliability Standards or the entity’s registration on the NERC Compliance Registry (NCR).
General Guidance for Sellers and Buyers of Existing Assets
When a sale or transfer of BES assets occurs such that the previous owner no longer performs any registered functions, the seller’s registration may be deactivated for the applicable function(s) following the deactivation procedure. The new owner’s registration is added or modified on the NCR following the registration procedure, including a new NCR ID if needed.
A seller is encouraged to coordinate with the buyer so that the buyer is properly registered as of the intended date of the transfer. The seller will remain responsible for compliance with relevant standards that may relate to the particular asset until it is deactivated from the NCR for the applicable function(s) and the buyer is subject to compliance responsibility. The seller will remain on the NCR until any outstanding settlement and enforcement issues associated with the asset in question are resolved.
When a transfer of asset(s) occurs and the buyer is registered for a function related to that asset, the buyer becomes responsible for compliance with all applicable standards relevant to the asset on the date of the asset transfer. The buyer may use its existing NCR ID and add the newly acquired assets to the scope of its existing registration. In this case, a change to the NCR is not required, but changes to the entity profile may be required in CORES, such as compliance contacts and upstream holding company, as appropriate. Contact your RE regarding what is the appropriate NCR ID for the newly acquired assets.
Buyers and sellers must make the applicable and necessary changes to any existing JRO or CFR agreements or enter into a new JRO or CFR that incorporates the transferred asset.
For more information relative to compliance implications of outstanding OEAs related to the assets being purchased or consolidated, contact your RE.