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Maintaining the reliability of the bulk power system (BPS) is necessary to protect the health, welfare, and safety of the public. Failure of registered entities to comply with federal and regional reliability standards could place end-use customers at risk and jeopardize the security of the interconnected Bulk Electric System (BES).

Compliance with NERC Reliability Standards will be assessed through various compliance monitoring tools.

Texas RE strongly encourages self-reporting of non-compliance and the development of responsive mitigation plans.

The goal of the Texas RE Risk Assessment group is to identify the individual risks that each entity poses to the BPS and develop a compliance oversight approach that focuses on those risks. Texas RE utilizes Inherent Risk Assessments (IRA) to develop a “right-sized” approach for compliance monitoring and enforcement. The risk based approach, based on the individual entities risk and internal controls, allows a proper allocation of resources and encourages registered entities to identify and enhance internal controls in an effort to improve system reliability and compliance with NERC Reliability Standards.

Texas RE performs IRAs of registered entities to identify areas of focus and the level of effort needed to monitor compliance with enforceable NERC Reliability Standards. The IRA is a review of potential risks posed by a registered entity to the reliability of the BPS. An assessment of BPS reliability impact due to inherent risk requires identification and analysis of risk factors related to each registered entity, and the consideration of BPS reliability impact significance for identified risks. An IRA considers risk factors such as assets, systems, geography, interconnectivity, and overall unique entity composition when determining the compliance oversight plan for a registered entity. Texas RE performs IRAs on a periodic basis, with the frequency based on a variety of factors including, but not limited to, changes to a registered entity, significant changes to reliability risks, or emergence of new reliability risks.

Texas RE also performs Internal Control Evaluations (ICE) of registered entities to further determine the focus and selection of appropriate tools to be used in identifying and more effectively considering existing registered entity risk mitigation practices in the development of Texas RE’s oversight plan for a registered entity.

Documents

Risk-Based CMEP Framework
IRA Risk Factors
Risk Assessment General Entity Information
ERO Risk Factors and Texas RE Deviations

A list of Reliability Standards is available on the NERC website. Texas RE recommends that you refer to the Appendix for Texas RE in the Electric Reliability Organization (ERO) Compliance Monitoring and Enforcement Program (CMEP) Implementation Plan for a description of how compliance monitoring engagements will be approached.

To assist Texas RE in determining how much risk an entity poses to reliability, the ERO Enterprise has identified a number of aspects that point to activities, behaviors, and qualities that will define the extent to which compliance monitoring is applied.

Compliance Audit and Spot Check

Auditing and spot checks are two tools used by Texas RE for compliance monitoring. Entities registered with NERC are subject to audit and/or spot check for compliance with the NERC Reliability Standards that apply to the functions for which the entity is registered.

Texas RE notifies entities of upcoming engagements within the appropriate timeframe. For information on what to expect, see the General Information Briefing and General Engagement Plan Briefing.

Texas RE uses Reliability Standards Audit Worksheets (RSAWs) as an audit tool. Below is a list of RSAWs by NERC functions.

Documents

Self-Certification

Texas RE uses self-certification by registered entities to affirm that those entities meet requirements of applicable NERC Reliability Standards as determined through a risk-based approach.

Self-certifications are conducted for areas in which risk has been identified. The results and information gathered during self-certifications will help provide Texas RE with reasonable assurance that compliance obligations are being met to support reliability.

The process requires a registered entity to perform and document specific tasks during the execution of the self-certification. The registered entity will certify its compliant status with the NERC Reliability Standard in question and is required to provide specific evidence to Texas RE to support conclusions. This process will help to establish reasonable assurance and may, in some cases, eliminate the need for the use of other traditional CMEP monitoring methods, such as an audit of a specific NERC Reliability Standard.

In some cases, Texas RE will re-perform some of the work in order to verify the accuracy of the self-certifications conclusions. If issues surface during this review, Texas RE staff may conduct further communication with the registered entity.

NERC self-certifications are conducted through webCDMS. NERC-registered entities are notified of each self-certification period at least 30 days before the due date for self-certification form submission.

If you have any questions or concerns, please contact Texas RE Self-Certification.   If you are responsible for a self-certification, and you do not know if you have access to webCDMS, contact your organization’s Primary Compliance Contact (PCC). If you do not know who your PCC is, contact Texas RE Information.  

Documents

The Annual Audit Plan includes a list of registered entities that are considered candidates for compliance engagements. In conformance with the NERC Rules of Procedure, the initial list includes Reliability Coordinators, Balancing Authorities, and Transmission Operators. Additionally, the Candidate List includes registered entities considered for compliance engagements that may include audits, self-certifications, or spot checks. The risk-based compliance monitoring framework allows Texas RE the flexibility to determine the type of CMEP engagement that will be used for each entity after Texas RE completes an IRA of the entity. Texas RE will provide adequate notice of the specific dates of any scheduled engagement prior to its commencement, in accordance with the NERC Rules of Procedure, Appendix 4C.

This approach provides for consistent treatment of all registered entities regarding the engagement tool notification timeframe and allows for more flexibility to manage risk-based processes, both for registered entities and the Regional Entity.

Documents

​​Texas RE analyzes submitted complaints for compliance with NERC Reliability Standards. Complaint analysis may lead to an investigation.

Complaint Analysis

If a complaint is filed against an entity, Texas RE will notify the entity and NERC (if the complaint is regarding possible non-compliance with a NERC Reliability Standard). Texas RE will review the evidence produced by the complainant and by the entity to determine if any further action is necessary.

Submit a Complaint

Alleged violations of NERC Reliability Standards may be reported by emailing a complaint form to Texas RE Complaint or via the Ethics and Compliance Hotline site, which allows anonymous and confidential reporting.

Documents

Data Submittal

Through scheduled data submissions from registered entities, Texas RE monitors and reports the performance metrics for ERCOT region compliance with certain NERC Reliability Standards. The 2017 Consolidated ERO Enterprise Data Submittal Schedule is now posted on the NERC website to provide registered entities a consistent periodic data submittal schedule throughout the ERO Enterprise by eliminating the regional schedule variations.

Misoperations Reporting

​​The NERC ERO Reliability Assessment and Performance Analysis (ERO-RAPA) group reviews protection and control system misoperations that are associated with a significant percentage of BES disturbances. Reducing the risk to reliability from relay and control system misoperations requires consistent collection of misoperation information by Regional Entities along with systematic analysis and correction of the underlying causes of preventable misoperations.

NERC Reliability Standard PRC-004-4i requires Transmission Owners, Generator Owners, and Distribution Providers to analyze Protection System misoperations, and to develop and implement Corrective Action Plans.

With the implementation of PRC-004-4i, reporting of Protection System misoperations is covered by a Section 1600 data request. The NERC Misoperation Information Data Analysis System (MIDAS) is the portal for registered entities to upload Protection System misoperation data to NERC and the Regional Entities.

A reporting template is posted on the NERC website.

MIDAS submission schedule:

Reporting Quarter  MIDAS Report Submission Period   
Q1April 1 - May 30
Q2July 1 - August 29
Q3October 1 - November 29
Q4January 1 - March 1

Remedial Action Scheme (RAS) Misoperations Reporting

NERC Reliability Standard PRC-016-0.1(a) requires Transmission Owners, Generator Owners, and Distribution Providers that own a RAS to analyze RAS misoperations per the Regional Entity's procedures, and to provide documentation of the misoperation analysis and corrective action plans to the Regional Entity upon request.

RAS misoperation submission schedule:

Reporting Quarter  Report Due Date                               
Q1May 31
Q2August 31
Q3November 30
Q4February 28

The reporting procedure and reporting template are posted below. All reports are to be submitted via webCDMS. Please send questions to Texas RE Compliance.

Documents

Recording Capability Corrective Action Plan

FERC approved Reliability Standard PRC-002-2 (Disturbance Monitoring and Reporting Requirements) on September 17, 2015, in Order 814. The purpose of Reliability Standard PRC-002-2 is to have adequate data available to facilitate analysis of the BES disturbances. In the ERCOT Interconnection, this standard is applicable to all registered Generation Owners, Transmission Owners, along with the Planning Coordinator or Reliability Coordinator and has an initial effective date of July 1, 2016 with phased-in dates for various requirements. Below is a summary of the Implementation Plan.

Requirement% CompliantCompliant By
R1, R5100%7/1/2016
(6 months)
R12100%10/1/2016
(9 months)
R2-R4, R6-R1150%1/1/2020
(4 years)
R2-R4, R6-R11 (Entities owning only one BES bus, BES Element, or generating unit shall be fully compliant within 6 years)100%1/1/2022
(6 years)
R2-R4, R6-R11100%1/1/2026
(10 years)

PRC-002-2 R12, enforceable October 1, 2016, requires that Transmission Owners and Generator Owners shall, within 90 calendar days of the discovery of a failure of the recording capability for any Sequence Event Recording (SER), Fault Recording (FR), or Dynamic Disturbance Recording, (DDR) data either:

  • Restore the recording capability, or
  • Submit a Corrective Action Plan (CAP) to the Regional Entity and implement it.

To facilitate uniformity in the submission process, Texas RE has created a form for submission of Corrective Action Plans to Texas RE Compliance. This form will be kept on file at Texas RE, however the registered entity will still be required to maintain all relevant evidence, including the CAP, per M12. Other registered entity-developed forms will be accepted and reviewed with the registered entity as needed. Please note that no CAP submission is necessary if recording capability is restored within 90 calendar days. If it is determined that the recording capability cannot be restored within the 90 calendar days, submission of CAP must be made within 90 calendar days of discovery. General questions on this reporting requirement can also be made to Texas RE Compliance.

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