This month, NERC released the first draft of its 2019 Compliance Monitoring and Enforcement Plan (CMEP) which identifies power delivery system risks and outlines compliance audit requirements for next year.
The risk elements outlined in the plan include significant differences from previous years, as shown in the table below. Each NERC region must consider these risks as they develop their monitoring and audit scopes for utilities. Utilities should be prepared to be audited and implement any necessary compliance initiatives in these areas.
These high-level risks will be translated into detailed areas of focus involving many NERC standards, which are listed in the NERC CMEP draft.
The NERC CMEP now uses a streamlined format that eliminates redundant information, improves transparency of compliance related activities, and promotes consistency among the regional implementation plans. Uniformity across North America wide guidance and implementation information is presented while preserving regional differences through the region-specific plans that take into account the region-specific reliability risks (e.g. the greater likelihood of hurricanes in the southeast US).
Your company, depending on its location, will also need to focus on the regionally specific supplement plans that will come in out in November. TRC will stay abreast of these regional plans to aid clients in their compliance programs for 2019 and beyond.
Once NERC approves the regional implementation plans, it will revise the 2019 CMEP by attaching the regional plans. TRC clients are advised to review the documents in the resources section below and contact us regarding your support needs in preparation for audits scheduled for 2019. Independent review of your compliance initiatives should now be undertaken in light of these reports.