Implementation Guidance Development - NERC

Implementation Guidance Development Craig Struck, Senior Auditor Lonnie Ratliff, Senior CIP Assurance Advisor December 6, 2017

Overview • Compliance Guidance Policy Review • Pre-qualified Organizations • Endorsement Process • Common Issues with Guidance • Implementation Guidance Development Aid • Resources • Questions and Answers

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Compliance Guidance Policy Review • Purpose of policy  Approaches to comply with Reliability Standards  Electric Reliability Organization (ERO) Compliance Monitoring and Enforcement Program (CMEP) staff execute duties

• Compliance Guidance team  Reviewed role, purpose, development, use, and maintenance  Recommended use of examples

• NERC Board of Trustees approved Compliance Guidance Policy • Additional Considerations     3

Have finite and limited set of tools Collect related guidance in one location Consider revising standard Apply professional judgment RELIABILITY | ACCOUNTABILITY

Compliance Guidance Policy Review

Compliance Guidance Implementation Guidance

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CMEP Practice Guides

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Compliance Guidance Policy Review • Implementation Guidance  Developed by industry, for industry  Examples or approaches  Developed by o Standard Drafting Team (SDT) o Pre-qualified Organization

• CMEP Practice Guides  Developed by ERO Enterprise, for ERO Enterprise o Guides on how ERO CMEP staff perform their duties

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Compliance Guidance Policy Review • Standard Drafting Teams  Composed of industry and NERC personnel  Develop Reliability Standards

• Pre-qualified Organizations  Approved by Compliance and Certification Committee (CCC)  The organization must o Be actively involved in NERC operations o Have methods to assure technical rigor o Possess ability to vet content

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Compliance Guidance Policy Review • Industry Vetting  Required by Compliance Guidance Policy  Standard Drafting Teams o During standards Ballot process

 Pre-qualified Organizations o After standard approved at ballot

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Pre-qualified Organizations

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American Public Power Association (APPA) Canadian Electricity Association (CEA) Edison Electric Institute (EEI) Electricity Consumers Resource Council (ELCON) Electric Power Supply Association (EPSA) ISO/RTO Council Large Public Power Council (LPPC) National Association of Regulatory Utility Commissioners (NARUC) National Rural Electric Cooperative Association (NRECA) North American Generator Forum (NAGF) North American Transmission Forum (NATF) Northwest Public Power Association (NWPPA) Nuclear Energy Institute (NEI) Transmission Access Policy Study Group (TAPS) Western Interconnection Compliance Forum (WICF) NERC Planning Committee (PC) NERC Operating Committee (OC) NERC Critical Infrastructure Protection Committee (CIPC) Regional Entity Stakeholder Committees RELIABILITY | ACCOUNTABILITY

Endorsement Process Endorsement of Implementation Guidance • Pre-qualified Organization or Standard Drafting Team submits proposed guidance  Emails to [email protected]  Includes Implementation Guidance Submittal Form

• NERC  Acknowledges receipt  Posts proposed guidance  Distributes to ERO Enterprise Subject Matter Expert (SME)

• ERO Enterprise endorses or declines to endorse • Publicly posted  Non-endorsed noted in spreadsheet 9

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Common Issues with Endorsement • Consider spelling out, or defining, acronyms during their initial use.  DER acronym is used but never defined.

• Ensure guidance capitalizes terms defined in the NERC Glossary of Terms.  Entire Document: review NERC Glossary to ensure defined terms are capitalized throughout document—examples are “interchange”, “transmission service”, and “load”.  Transmission Owner not capitalized on page 15.

• Ensure guidance does not conflict with, or change, the meaning or intent of the Requirement and Measure.  Reference #3 states the topics are for normal and emergency operations training per R1 and R3. R1 does not reference normal or emergency operations.

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Common Issues with Endorsement • Ensure guidance addresses the subject Reliability Standard and Requirement in sufficient detail and does not skip steps or stop short of complying.  Document does not state testing is required following re-calibration after an initial failed test.  On page 15, the guidance lists the elements to be included in the Facility Ratings methodology. The generator interconnection and Transmission sections do not include shunt compensation devices, which are listed in Part 2.4.1 and Part 3.4.1 of the Standard.  Many other sections that list “acceptable documentation” fail to mention the need for dated records, adequate component identification, test results, etc.

• Ensure guidance does not lead the entity to believe there are additional compliance obligations not specifically required by the subject Reliability Standard and Requirement.  Page 4 states “Transmission Planners need to explain their outage planning process for this R1.1.2.” Would suggest changing language to state “Transmission Planners should explain….”  Comments: This document should clearly state that the various testing procedures described are examples of testing and are not prescriptive and mandatory. 11

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Common Issues with Endorsement • Ensure guidance does not introduce new terminology, attempt to define a term, or interpret a term in the subject Reliability Standard and Requirement.  The definition for RTA that the paper gives does not match the definition of RTA in the NERC Glossary of Terms.

• Ensure specialized terminology, such as used by technical committees, is defined in the guidance document and that the definition does not conflict with related terminology defined in the NERC Glossary of terms.  Page 13: “Topic 3: Cascading Criteria and Methodology”, Recommendations Section - Bullet 2.a, the term “initiating event” should be clarified to assist the industry.  Disagreement with the definition of "Time Horizons" on page 10, which could have far-reaching impacts on other Standards.  Page 17: (SE) defined as acronym for “State Estimator”, while “state estimator” is used on previous pages. 12

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Common Issues with Endorsement • Ensure guidance is not a whitepaper, position paper, concept paper, FAQ, or technical reference document.  Document viewed as a whitepaper, position paper, etc. o Provides a chart of “Very good” to “Very poor” Controls. Entity’s individual facts/circumstances determine control effectiveness. o Broad topics and not focused on specific subject material. CIP-003 document very broad, should be broken out into numerous guides. o Guidance references cost effectiveness. Compliance guidance focus on Compliance.

• Ensure guidance does not include language that attempts to describe an audit approach.  On Page 18, Recommendations Section – Bullet 2 states “Individual utilities should be given broad leeway to determine transient voltage criteria for load buses and for buses with no load and no generators.”

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Common Issues with Endorsement • Ensure guidance correctly references footnotes, citations, table numbers, illustrations, Attachments, Addendums, Appendices, etc.  The document references Appendices instead of the Attachments that are included in PRC-024. There is inconsistency in the use of PRC-024 “Attachment” and “Appendix” throughout the document.  The Rationale for R1 references R1.2.4 for software integrity, but the correct reference for software integrity is R1.2.5.

• Ensure the latest version of the external source, including web site links, is being referenced.  This document has a few issues as noted: links are broken (first link on page 27); the standard version is not specified.  Page 19: If updates to IEEE 1547 are expected to be published in late 2016, it is recommended the guidance be updated with this information prior to publication. This document was received in late 2016: it should have included information from the updated IEEE 1547 standard; otherwise, this document may be obsolete in short order.

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Common Issues with Endorsement • Consider developing guidance that addresses Reliability Standards and Requirements that are subject to near future retirement.  Considering this Standard will be inactive soon, we do not feel anything needs to be addressed, and the guidance may not be needed. However, it is not aligned with the measures of the new Standard and could cause confusion.  This will soon be old guidance for a previous version of a standard.  Newer version of Requirement has expanded scope. CIP-003 R2 – Version 6 does not include TCAs, but Version 7 does.

• Ensure the guidance does not reference inactive Reliability Standards, or use terminology used in previous versions of a Reliability Standard and no longer in use in the current version of the subject Reliability Standard.

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 There are multiple places throughout the document that reference older PRC standards such as PRC-005-1.1b, PRC-005-2, etc.  The document specifies guidance for CIP-014-1. Version 1 of CIP-014 was only enforceable for one day. It would be beneficial to update the document to include CIP014-2.

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Implementation Guidance Development Aid

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Implementation Guidance Development Aid

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Resources – NERC Website

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Resources – NERC Website

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Resources – NERC Website

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Resources – NERC Website

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Additional Resources • Compliance Guidance web page  http://www.nerc.com/pa/comp/guidance/Pages/default.aspx

• Compliance Guidance Policy  http://www.nerc.com/pa/comp/Resources/ResourcesDL/Compliance_Guidance_Policy_FINAL_Board_Acce pted_Nov_5_2015.pdf

• Pre-qualified Organization list  http://www.nerc.com/pa/comp/guidance/Documents/Pre-qualified%20organizations.pdf

• Procedure to become a Pre-qualified Organization  http://www.nerc.com/comm/CCC/Related%20Files%202013/Final%20CCCPP011_May_BOTCC_updated.pdf

• Pre-qualified Organization Application  http://www.nerc.com/pa/comp/guidance/Documents/Application_Pre-Qualified_Organization.pdf

• How to submit Proposed Guidance  http://www.nerc.com/pa/comp/guidance/Documents/Pre-qualified_org_submittal_with_form.pdf

• U.S. Standards One-Stop Shop  http://www.nerc.com/pa/Stand/Standard%20Purpose%20Statement%20DL/US_Standard_One-StopShop.xls

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