NERC Standards Under Development – Interesting Yes, Surprising No

NERC Standards Under Development – Interesting Yes, Surprising No

Although the pace of new NERC Reliability Standards rolling out of the development process is not as rapid as in recent years, they are still being drafted, argued about, and voted on. Many entities have asked our advice on how to prepare for and deal with these “standards NERC is forever creating.” A two-part response is in order.

First, NERC doesn’t actually create standards, and second, the process is completely transparent. The process is not quick, and Registered Entities typically have about two years to review the initial drafts of the standard, or revision, before final approval and publication of an effective date by FERC. Sometimes a little less, sometimes more.

Standards are created and/or revised by Drafting Teams made up of industry participants. You too can be on a drafting team if you prefer. NERC staff facilitates the standard development process, but they have no vote on the approval of the document.

While the standards development process has many decision points and balloting measures, focusing on the following information will help assure you’re not blindsided by something that can materially affect how you run your business. All the posting steps in the process afford ample opportunity for comment and even dissent from Registered Entities. No one must simply wait and deal with whatever is processed and ultimately approved by FERC. If some component of a proposed change does not conform to how you operate, potentially impose undue costs, or the applicability to your scope is questionable, your comments and concerns are not only permitted, they are encouraged.

Here are the steps you should be aware of:

Registered Entities subject to mandatory compliance with the NERC Reliability Standards can be perplexed, disgusted, or pleased by the ongoing changes to the requirements within a standard. What Registered Entities need not be is surprised by the changes. You can see them coming from a long way off.

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