SERC Update - June 2, 2020 - NERC Guidance on Expansion to Self-Logging Program

by Banna Underland | Jun 02, 2020
SERC staff provide a summary of what SERC entities need to know about the new guidance

The North American Electric Reliability Corporation (NERC) as the Electric Reliability Organization (ERO) announced they have released new guidance providing additional regulatory relief to registered entities’ coronavirus response.

This guidance addresses the handling of potential noncompliance related to the effects of the coronavirus. Specifically, it introduces a temporary expansion of the program in order to assist entities and the ERO Enterprise with the efficient reporting of potential noncompliance with minimal or moderate risk related to the ongoing coronavirus crisis. During this challenging time, health and safety of personnel and the continued reliability and security of the bulk power system are of crucial importance. This temporary expansion is not authorization to log potential noncompliance unrelated to the impacts of the coronavirus, nor is it admission to the Self-Logging Program. Rather, this expansion is to allow registered entities to focus on the reliable and secure operation of the bulk power system during this public health emergency by allowing them to log potential noncompliance resulting from the impacts of the coronavirus. Moreover, for such self-logged potential noncompliance, the ERO Enterprise will exercise appropriate regulatory discretion.

This guidance is intended to apply only during this public health emergency and will terminate on September 30, 2020.

What SERC Registered Entities Need to Know

  • Your SERC single-point-of-contact (SPOC) remains your main interface for compliance issues.
  • Registered entities do not need to resubmit coronavirus-related potential noncompliance impact notices already provided to SERC.    
  • Registered entities must report this information as soon as reasonably possible, but no later than two weeks after discovery. Registered entities should coordinate with their SERC SPOC within this time period if additional time is needed to obtain pertinent information for the log,
  • All registered entities should provide the following information about these minimal or moderate risk issues related to the ongoing coronavirus crisis, regardless of whether the activities are periodic, by downloading and using a copy of the spreadsheet log template posted on NERC’s website located here (examples have been provided in the spreadsheet.

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Do not use the prior SERC COVID-19 Impact Notice Form as this has been replaced with the new spreadsheet.

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  • Be prepared to document the following.
    • The name of the entity, NCR, and entity contact information;
    • The applicable Region;
    • The affected functions;
    • The date the potential noncompliance was submitted to the Regional Entity;
    • The specific Standard and Requirement at issue;
    • A description of the potential noncompliance, including the circumstances relating to the impact of the coronavirus response the entity employed, that will (has) prevent(ed) maintaining or achieving compliance;
    • The date the potential noncompliance was discovered;
    • The date the potential noncompliance began or will begin;
    • The anticipated date the potential noncompliance will be resolved and compliance will be achieved;
    • A description of the potential harm not being compliant could cause to the bulk power system;
    • The actions taken, or to be taken, to get back into compliance; and
    • The actions taken to mitigate any risk associated with the potential noncompliance until compliance can be achieved and the anticipated completion dates for such actions.
  • Send completed logged spreadsheets of issues pertaining to delay in completing compliance activities due to COVID-19 to serccomply@serc1.org with a copy to your SPOC. Be sure to retain copies of the notifications and file them accordingly to have available if a subsequent Monitoring activity dictates the need.

We will continue to maintain situational awareness about the spread of COVID-19 and its future impacts. The most current information will be featured on the SERC homepage news feed, and will be communicated via social media and email to keep stakeholders informed.

Thank you for your dedication to ensure the health and safety of your employees, your communities, and the continued reliability and security of the SERC Region.