Maintaining the reliability of the bulk power system (BPS) is necessary to protect the health, welfare, and safety of the public. Texas RE’s staff works collaboratively with industry professionals to help ensure the security of the interconnected Bulk Electric System (BES) through effective and efficient compliance monitoring and enforcement.

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

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

The goal of the Texas RE Risk Assessment group is to identify the risk that each entity poses to the bulk power system and develop a compliance oversight approach that focuses on that risk. Texas RE utilizes Inherent Risk Assessments (IRA) to develop a “right-sized” approach for compliance monitoring and enforcement. This risk-based approach allows Texas RE to focus its compliance oversight efforts on those issues that present more serious reliability risk.

Texas RE performs IRAs of registered entities to identify areas of significant risk, as well as the level of effort needed to monitor compliance with NERC Reliability Standards. An IRA considers risk factors such as generation and transmission assets, geography, interconnectivity, and unique entity composition when determining an entity’s compliance oversight plan. Texas RE performs IRAs on a periodic basis, with the frequency based on a variety of factors including changes to a registered entity, significant changes to reliability risk, or emergence of new risk.

Texas RE also performs Internal Controls Evaluations (ICE) to help registered entities understand and develop their controls. The ICE is a voluntary process; Texas RE encourages entities to participate so that they can reduce their reliability risk, enhance the effectiveness of their compliance operations, and ultimately reduce their regulatory burden.


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

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

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

Compliance Auditing and Spot Checks are two tools used by Texas RE for compliance monitoring. Entities registered with NERC are subject to Compliance 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 by no later than the appropriate time frame called for in the Rules of Procedure. For information on what to expect, see the General Information Briefing and General Engagement Plan Briefing. Cyber Security Data Submittal Guidance is available to assist in engagements containing CIP requirements.

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



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 a Compliance Audit of a specific NERC Reliability Standard.

In most 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 submit information associated with the Self-Certification, contact your organization’s Primary Compliance Contact (PCC). If you do not know who your PCC is, contact Texas RE Information.  

The Annual Audit Plan includes a list of registered entities scheduled for a Compliance Audit. In conformance with the NERC Rules of Procedure, the initial list includes Reliability Coordinators, Balancing Authorities, and Transmission Operators. Additionally, the Annual Audit Plan includes registered entities in the Coordinated Oversight Program that are scheduled for a Compliance Audit for which Texas RE has been the Lead Regional Entity. Although an entity may not be listed on the Annual Audit Plan, the risk-based compliance monitoring framework allows Texas RE the flexibility to determine if entities may go through any type of compliance engagement (e.g. Spot Check, Compliance Audit). The scope and type of engagement are direct results of Inherent Risk Assessments (IRAs) completed for each registered 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 time frame and allows for more flexibility to manage risk-based processes, both for registered entities and the Regional Entity.


​​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 noncompliance 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.


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 2019 ERO Enterprise Periodic Data Submittals Schedule and the 2018 Consolidated ERO Enterprise Periodic Data Submittals Schedule are 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-004-5i 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-004-5i, 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


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. 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.

If a registered entity identifies a need to submit a Corrective Action Plan to Texas RE, please send notification to Texas RE at Texas RE Compliance. Upon receiving notification from the registered entity, Texas RE will work with the registered entity to accommodate submission of the Corrective Action Plan through Texas RE’s Extranet site.



EOP-008-2 R8 requires Reliability Coordinators, Balancing Authorities, and Transmission Operators that have experienced a loss of its primary or backup functionality and that anticipate that the loss of primary or backup functionality will last for more than six calendar months to provide a plan to its Regional Entity within six calendar months of the date when the functionality is lost, showing how it will re-establish primary or backup functionality.

To facilitate uniformity in the submission process, Texas RE has created the form posted below for submission of plans to Texas RE Compliance. This form will be kept on file at Texas RE.

If a registered entity identifies a need to submit a plan to Texas RE, please send notification to Texas RE at Texas RE Compliance. Upon receiving notification from the registered entity, Texas RE will work with the registered entity to accommodate submission of the plan through Texas RE’s Extranet site.


FAC-003-4, PRC-016-1, and PRC-023-4 Periodic Data Submittals

Texas RE requests Period Data Submittals from applicable entities for FAC-003-4, PRC-016-1, and PRC-023-4 in accordance with the ERO Periodic Data Submittal Schedule. The data submittal forms utilized by Texas RE for these Periodic Data Submittals are included below.

For applicable registered entities that do not own Facilities applicable to the Reliability Standards and Requirements subject to the Periodic Data Submittal requests, Texas RE accepts one-time attestations. Registered entities that provide one-time attestations will not receive data submittal requests for these Reliability Standards and Requirements unless warranted by facts and circumstances. However, if conditions change that impact the registered entity’s applicability to a Reliability Standard and Requirement subject to a Periodic Data Submittal for which a one-time attestation has been submitted, it is expected that the registered entity notify Texas RE Compliance of the change so the registered entity can begin meeting the reporting requirements for the applicable Reliability Standard and Requirement. The one-time attestation forms for these Reliability Standards and Requirements are included below.


​​Many of the CIP V5 Standards and Requirements became effective on July 1, 2016. Full details on the CIP V5 transition can be found on the NERC CIP V5 Transition Program page, or on Texas RE's CIP Transition page.

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