2017 NPCC Regional CMEP Implementation Plan posted

This Appendix contains the CMEP Implementation Plan (IP) for the NPCC as required by the North American Electric Reliability Corporation (NERC) Rules of Procedure (ROP).

Compliance Monitoring and Enforcement

CMEP IP Highlights and Material Changes

NPCC will continue to support all Electric Reliability Organization (ERO) Enterprise committees, subcommittees, working groups, task forces, and other teams to improve risk assessment and controls evaluations that support compliance monitoring and enforcement activities within the ERO Enterprise.

NPCC has developed various regional specific tools to ensure that audits, spot checks, guided self-certifications, Inherent Risk Assessments (IRA), and Internal Control Evaluations (ICE) are performed in consistent fashion.

• Evidence tracking sheet (audits, spot checks)

• Guided Self-Certification worksheet

• Function specific IRA templates

• Matrix of NERC/NPCC Risk Elements that map to NERC Risk Factors

• Documented procedure and process flow diagrams for performing IRA and determining monitoring scope

• IRA Summary report

• ICE worksheet

• ICE summary report

A separate implementation plan will apply to entities registered in New Brunswick with the New Brunswick Energy and Utilities Board.

A separate implementation plan will apply to entities registered in Québec with the Régie de l’énergie.

Other Regional Key Initiatives and Activities

NPCC has instituted a program to perform CIP-014 gap analysis to assist the entities in fine-tuning their CIP-014 process. Results will be shared with the ERO.

NPCC has instituted a program to perform CIP V5 outreach for entities that have only Low impact facilities.

Regional Risk Assessment Process

NPCC coordinated with the other Regional Entities to develop the following 2017 ERO Risk Factors:

1. UFLS Equipment

2. UFLS Development and Coordination

3. UVLS

4. Load

5. Transmission Portfolio

6. Voltage Control

7. Largest Generator Facility

8. Variable Generation

9. Total Generation Capacity

10. Planned Facilities

11. CIP – Technical

12. ICCP - Connectivity

13. Critical Transmission

14. Balancing Authority Coordination

15. Remedial Action Schemes/Special Protection Systems

16. Workforce Capability

17. Situational Awareness and Monitoring Tools

18. System Restoration

In the development of the standards and requirements that appear in this regional plan, NPCC considered the 2017 ERO Risk Factors and other tangible Bulk Electric System (BES) attributes such as entity functional registration, transmission assets, Remedial Action Schemes, Blackstart plans and facilities, generation assets, role of Underfrequency Load Shedding (UFLS), and historical events.

As a result, NPCC believes that the application of the Revised BES Definition may offer reliability exposure due to the over 1,000 newly captured BES elements within NPCC. The transmission portfolio of many entities has increased and several entities have increased operational responsibility associated with the newly captured elements. In 2016, the lone NPCC Regional Risk Element was termed “Revised BES Definition”. Moving into 2017, it is more accurate to describe the Regional Risk Element as the “Registration and Compliance Obligation Changes Associated with the BES Definition”. As a result, NPCC will place regional focus on standards and requirements associated with operations, maintenance, and planning for the following types of functional entities:

1. New TOPs, TOs, and TPs.

2. Existing TOs with an expanded pool of BES elements under their ownership umbrella.

3. Existing TPs with an expanded pool of BES elements under their planning umbrella.

Entities already registered as Reliability Coordinators (RCs), Balancing Authorities (BAs), or Transmission Operators (TOPs) do not fall under this Regional Risk Element.

In addition, NPCC recognizes the vital role that UFLS development and coordination play in minimizing and defending against a total system blackout. Due to this, NPCC has also added second Regional Risk Element called “Coordination of UFLS Schemes”.

NPCC also expanded the requirements, with explanation, under several of the ERO Risk Elements.

NPCC has determined that none of the requirements included in the ERO Compliance Monitoring Enforcement Program (CMEP) Implementation Plan (IP) should be removed from the NPCC regional IP.

See the attachment for more details.

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