By Abby Fellinger – Manager, Registration and Certification Program at Texas RE

The Electric Reliability Organization (ERO) Enterprise, which is comprised of the North American Electric Reliability Corporation (NERC) and the six Regional Entities, is dedicated to supporting and collaborating with industry to assure the reliability, resilience, and security of the North American bulk power system (BPS). The documents referenced below were created to assist newly registered entities with completing required and recommended action items, though existing entities may also find these resources to be useful.

The ERO Enterprise Entity Onboarding Checklist provides new Primary Compliance Contacts (PCCs), Primary Compliance 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 is intended to provide clarity on registration processes and improve efficiency for registered entities. To learn more about initial steps for new entities and new entity contacts, please review the ERO Enterprise 101 Informational Package and the ERO Enterprise Registration Procedure.

Additionally, Texas RE created a Generator Welcome Package to be a focused resource for brand new registered entities as they begin their compliance journey. It can be overwhelming for a new entity coming online to grasp everything that has to be accomplished when reviewing the various websites and many different documents containing information regarding new entity obligations. As a result, Texas RE developed this package to help registered entities plan the development and implementation of their compliance program to address key responsibilities and obligations.

The Generator Welcome Package includes:

General Planning Considerations – Contains information on what to think about, look at, and be aware of when bringing on a new generator.

Recommended Reading – Provides different resources like compliance guidance documentation, winter weather preparedness recommendations, and NERC lessons learned and event reports.

Internal Controls Overview – Describes preventative, detective, and corrective controls that can be put in place. Texas RE also encourages entities to test their controls once implemented.

There is a GO GOP Roadmap that lays out several Standards and provides timelines to help registered entities understand obligations that need to completed even before they come online, and what needs to be ready by day one of being registered. The Requirements mentioned within the roadmap are organized by categories:

• The Procedural category has the processes you need to have in place on day one, which include items like an Event Report Operating Plan (EOP-004 R1), documentation for determining Facility Ratings and Facility Ratings methodology (FAC-008 R1, R2) and a Protection System Maintenance Program (PRC-005 R1, R2).
• The Initial Performance category provides guidance on timing nuances within Requirements and when those Requirements become enforceable. One example is setting Governor parameters in accordance with BAL-001-TRE-2 R6.
• The Time-Based Performance category provides insights to Requirements that may need to be quickly addressed by new registered entities. For example, performing a Vegetation Inspection on 100 percent of its applicable transmission lines (FAC-003-4 R6) must be completed within the first calendar year following registration and is not to exceed 18 calendar months from registration.

The Internal Controls Considerations Table covers internal controls that are based on best practices. Registered entities should review and consider these best practices, but entities should develop and implement controls that best fit their business practices and processes. There are several examples for Requirements that are frequently included within Self-Certifications.

Example Self-Certification Questions are based on the Texas RE Common Questions document located on the Texas RE website on the Compliance page under Entity Resources. This gives registered entities a good idea of what to expect during an engagement. This is not a guarantee of the questions that could be received during an engagement, but it gives registered entities a general overview of the questions that are initially asked.

If you have any questions or suggestions on enhancing any of these documents, please E-mail information@texasre.org.