NERC Issues

							NERC Issues
Prepared by
David Grubbs
City of Garland
     Transmission Operator
          (TOP) JRO
•   Six municipal utilities were brought into the NERC
    audit of ERCOT in October through December, 2009
•   As a result of the ERCOT TOP audit last fall, Austin,
    San Antonio, Brownsville, Bryan, College Station
    and Garland were registered by Texas Reliability
    Entity as a TOP.
•   Other cities are likely to also be registered as a TOP
•   Newly registered TOPs are undergoing certification
    audits this summer to determine compliance with
    the 415 requirements in the JRO.
•   The JRO allows compliance for each requirement to
    be split individually between registrants.
         NERC Planning
          Committee
ERCOT utilities are represented by
 Stuart Nelson of LCRA as one of two
  Municipal/State Utility Representatives
NERC Critical Infrastructure
  Protection Committee
          (CIPC)
Texas Municipal Systems are well represented
  on the NERC CIPC Committee

•   David Grubbs, (Garland) Representing
    ERCOT
•   David Godfrey, (TMPA) Representing
    Municipals
•   Nathan Mitchell (APPA) Representing
    Municipals
NERC Critical Infrastructure
  Protection Standards
   On December 31, 2009 version 1 of the
    NERC CIP Standards became mandatory to
    ERCOT Municipal Systems.
   On April 1, 2010 version 2 of the NERC CIP
    Standards replaced version 1.
   On October 1, 2010 version 3 of the CIP
    standards will replace version 2.
   NERC CAN on Remote Access effective
    October 1, 2010
       Future CIP Versions
There are currently three new versions of the CIP
  Standards under development.

•   NERC Staff is preparing a version to address remote
    access. To be effective in early 2011.

•   Version 4 is being developed by the CIP Standards
    drafting team to replace the current Risk Based
    Assessment Methodology. Expected to be effective
    in first half of 2011.

•   The CIP Standards drafting team is developing a
    complete rewrite of the CIP Standards. Probably
    effective in 2012.
ERCOT CIPWG

   ERCOT has a Critical Infrastructure
    Protection Working Group to assist
    member systems in understanding and
    coordinating issues on the CIP
    Standards and other security issues.
   Will host a Copper Theft Workshop on
    July 27.
Audits…Audits…Audits…
   Like many systems we are in a mode of almost
    continuous audits.
   Scheduled full audits average every three years.
    Some are one year, some three, some six years.
   Because Municipal Utilities remain integrated
    utilities we are registered for multiple functions
    (GPL is registered for 8). Larger utilities expect
    audits every year
   Any function not audited in a year is required to
    perform self audits once or twice per year on
    various Standards.
Be Prepared…

•   Be prepared to significantly increase
    your compliance budgets and staff
•   Be prepared to spend more time on
    documentation and procedures
•   Be prepared to be assessed penalties
    for NERC and ERCOT violations
Questions ?