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Hard Truths and Lessons Learned - Building a Competent NERC Compliance Department

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JC Culberson's picture
Manager of Operations Certrec Corporation

A proven industry leader in energy system operations, planning, compliance, and wholesale energy market structure, I have developed NERC compliance programs for entities ranging from ISO/RTO...

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  • Dec 8, 2020
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What you are about to read may not be as complimentary as you would expect, but it is a very real look at the relationship between operations and planning groups and their counterparts in the compliance departments. This is a very real look at the issues that have existed in the past between these departments, why they existed, and how to make a lean, intelligent cross departmental approach work to perfection. The departments that perform the operations, planning, and compliance duties at an energy company are, in the best of cases, able to work together to achieve goals, while understanding what the others do and how those activities play into the greater goal of maintaining a reliable Bulk Electric System.

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That Symbiotic relationship between NERC compliance and system planning and system operations can be a tough one to navigate. When done correctly, that relationship will yield efficiencies of scale and afford an energy company a seamless approach to carrying out its essential operations and planning functions while maintaining a high degree of confidence in achieving compliance with the applicable NERC Reliability Standards. Many times, an energy company will try and separate these functions, leaving only a small amount of coordination between the business units, however, this rarely leads to success in the regulatory arena. It’s my experience that the dreaded compliance staff member showing up for audit preparation was less a product of additional work for the business unit staff, which should be minimal, but more the anxiety over having to explain “what and how things are done” to an outsider, albeit an employee at the same company. This, unfortunately, is a very real worry and is often not approached in the way that makes the most business sense. For example, in the past, there was a disconnect between the way a long-term system planning department developed System Operating Limits, or IROLs and the way these limits are determined in the Operations Horizon. ISOs, when carrying out Planning Coordinator and Reliability Coordinator functions saw this as a clear risk and developed plans to have a feedback function address the deltas in calculating the limits, thus providing the type of coordination that leads to a more robust and realistic planning model, as these discussions often addressed operating idiosyncrasies and anomalies that may not have been otherwise contemplated in the Planning Horizon. This type of coordination required a certain kind of synergy that broke down siloed approaches to work and created a greater sense of accomplishment for those engineers and operators involved. This approach can and should be applied when addressing NERC compliance and the O&P responsibilities. Convincing Executive level management of this needed relationship can prove to be rife with its own challenges, but it is worth the effort in the long run. The challenge must start with the compliance staff and their knowledge of both the regulatory requirements and the existing O&P processes. This means the compliance staff must be better than they have been viewed to be in the past, whether correctly or incorrectly. There are too many requirements that will necessitate a deep understanding of how work gets done to simply provide a high-level narrative with minimal examples and evidence and hope it satisfies the auditor and the business units that are represented. At many companies for which I have consulted, compliance was an ugly word, because the staff was not competent enough to understand what actually got done and how, and they required far too much time in explanation and coaching than would seem reasonable. This led to inevitable resource drains in business units that are often already stretched thin. The converse to this example is that intelligent and competent compliance personnel can provide helpful feedback to business units to ensure duplication of work is not being done, which sometimes happens in rigidly structured engineering roles, due to the lack of overall understanding of how the piece one individual is working on fits into the greater puzzle. Another advantage is that a competent compliance staff can often reduce the workload of individuals who are performing duties just to prove compliance with a particular requirement. In most cases, the detail that appears to be missing is actually covered in a different process and makes sense to the overall work product, whether it be a five-year transmission plan, SOL methodology, or emergency operations. Having this broader level of understanding helps to gain efficiencies among the business unit staff, while being savvy enough to use existing processes and procedures to prove they comply with the standards. Having a feedback loop, similar to the one that exists between ops and planning will allow for a sharing of lessons learned and will provide a means to establish reliable operations, and best practices on both the compliance side, and the business units. As with any successful department, success begins with proper staffing and continues with the training needed to hone existing aptitudes and skills. As our industry continues to grow and change, it is important that our people can rise to meet those challenges. Just as the need for smart, workable planning and operations processes will continue into the future, so will the need to have a great compliance group, focused on the successes of their represented business units. I hope you can learn from some of the growing pains that I have had to endure, to ensure the greatest level of success for your energy company.

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