July 16, 2024
In part 2 of this blog series, we discuss the importance and impact of regional audits, identify the different regional entities, and describe how they are structured.
Regional Audits
One of the critical functions of NERC’s regional entities is conducting audits to assess compliance with the NERC standards. These audits aim to proactively identify and address potential vulnerabilities or weaknesses in the system. Thereby reducing the risk of disruptions or cyber-attacks. Regional audits involve a comprehensive evaluation of utilities’ adherence to the standards, encompassing physical and cyber security measures, operational procedures, and emergency response capabilities.
All regional entities conduct compliance monitoring, enforcement, and auditing activities. It verifies the compliance of entities within the North American power grid with the NERC reliability standards (including NERC CIP!). Aiming to identify and address any potential risks or vulnerabilities to the power system.
In addition to compliance monitoring, the regional entities play a crucial role in promoting reliability through coordination and collaboration. It works closely with the Balancing Authorities (that’s another blog!), industry participants, regulatory authorities. As well as other stakeholders to facilitate information sharing, exchange best practices, and enhance the overall reliability of the grid.
Lastly, there is a relatively new NERC initiative and effort called Unify that has the goal of having all the regions sing off the same sheet of music on what they are focused on in their audits in an effort to standardize the process for every NERC registered entity. So, on to the specifics of the Regional Entities:
Let’s go from west to east!
WECC – From Rolling Blackouts to the Rockies
The Western Electricity Coordinating Council (WECC) is the largest regional entity geographically within the North American electric grid. Covering a vast geographic area that includes 14 western states, two Canadian provinces (Alberta and British Columbia), and a portion of Baja California in Mexico. WECC is responsible for ensuring the reliability and security of the power system in the Western Interconnection.
Headquartered in Salt Lake City, Utah, WECC’s reach covers 14 western states including California, Oregon, Washington, Arizona, Nevada, New Mexico, Utah, Idaho, Colorado, Wyoming and parts of Montana, Nebraska, South Dakota. It even includes the El Paso area of Texas.
WECC does a great job at the collaboration part with their Compliance Workshops. There is even a group called WICF (Western Interconnect Compliance Forum) that has collaboration sessions with other entities on their audit experiences, among other things, and without any auditors in the room. It is a unique way to hear about the current focus of the auditors.
MRO – Where the Mosquitos are Big Enough to Move Small Cars
The Midwest Reliability Organization (MRO) is one of the regional entities within the North American Electric Reliability Corporation (NERC) jurisdiction. It covers a significant portion of the central United States and is responsible for ensuring the reliability and security of the electric grid in this region.
Based in the Twin Cities of Minnesota, the MRO region spans 15 states, including Illinois, Indiana, Michigan, Minnesota, Kansas, most of South Dakota, North Dakota, Iowa, Nebraska, and parts of Missouri, Arkansas and Oklahoma. In Canada, it includes parts of Manitoba and Ontario. It encompasses diverse terrain and a mix of urban, suburban, and rural areas, presenting unique challenges for maintaining a reliable power system.
Texas RE – Everything’s Bigger in Texas
Austin-based, Texas Reliability Entity (Texas RE) is the regional entity responsible for ensuring the reliability and security of the electric grid in the state of Texas. It operates within the jurisdiction of the Electric Reliability Council of Texas (ERCOT) and collaborates closely with ERCOT in overseeing the power system’s operation and planning activities.
Given the unique characteristics of the Texas power system, Texas RE faces specific challenges and responsibilities. Texas has its own independent grid, separated from the rest of the United States, which allows ERCOT to operate and manage the electric system within the state’s boundaries. This autonomy necessitates specialized expertise and a focused approach to maintaining reliability and security.
You may remember ERCOT in the news in the winter of 2021 when they had massive power failures, leading to the resignation of most of their board members. The entire Texas grid was in danger of going down, which would have resulted in a black-start event. In layman’s terms, power could have been out for weeks.
Oddly enough, there are areas in Texas that are not in the jurisdiction of TRE, like El Paso, and there are entities outside of Texas that have assets regulated inside the TRE footprint.
RF – The Other Big Tourist Destination When in Cleveland
Similar to the excitement felt visiting the Rock and Roll Hall of Fame, The ReliabilityFirst office in Cleveland works hard to ensure reliability in parts of the mid-west and mid-Atlantic. The region spans parts of 13 US states, including Illinois, Ohio, Pennsylvania, New Jersey, Delaware, Maryland, and parts of Ontario, CA. Their footprint also includes our nation’s capital, Washington DC. Lots of large cities to provide power too but also very remote areas in the northern mid-Atlantic and eastern mid-west, southern north-east.
Don’t make fun of Cleveland though as this regional entity was the lead auditor in what turned out to be the largest finding and fine in NERC regulatory history.
SERC – Region Needs Power to Watch SEC Football
The Southeastern Electric Reliability Council (SERC) is one of the regional entities within the North American Electric Reliability Corporation (NERC) jurisdiction. It encompasses a significant portion of the southeastern United States and is responsible for ensuring the reliability and security of the electric grid in this region. It is actually relatively unique as there are 4 of the largest power utilities that consume a vast majority of the region. With Southern Company in Atlanta, Duke Energy in Charlotte, Tennessee Valley Authority in Knoxville, and NextEra in Juno. Beach, Florida; there are some big fish to fry during audit season. SERC’s offices are about 15 minutes from the Duke Energy Center building in Charlotte, North Carolina.
The SERC region spans 16 states, including Alabama, Florida, Georgia, Louisiana, Mississippi, North Carolina, South Carolina, and Tennessee, as well as parts of Arkansas, Kentucky, Missouri, Texas, and Virginia. Its geographical diversity, which ranges from coastal areas to inland regions, presents unique challenges for maintaining a reliable power system.
NPCC – You’re Either a Yankees Fan or a Red Sox Fan
The Northeast Power Coordinating Council (NPCC) is responsible for ensuring the reliability and security of the electric grid in the northeastern part of North America. The region essentially consists of the New England states (New York, Vermont, New Hampshire, Massachusetts, Maine, Rhode Island, Connecticut) as well as the provinces in eastern Canada.
The NPCC region is known for its high population density, complex power systems, and significant energy demand and lots of entities packed into the geography. It faces unique challenges, including extreme weather events such as hurricanes and blizzards, as well as the integration of renewable energy resources. NPCC does a pretty good job working to address these challenges by fostering cooperation and information sharing among its members. NPCC’s Compliance Workshops are very well attended and it is a chance to hear from the regulators as well as collaborate with your peers.
The reason NERC exists came out of a 2003 blackout in New York City (and 45 million other people in the US and Canada). This spurred FERC to create NERC, which in turn created the Regional Entities.
How is NERC Compliance Different in Canada?
NERC compliance in Canada and the United States follows a similar framework, but there are some key differences due to the distinct regulatory structures and jurisdictions in each country. Here are some ways in which NERC compliance differs between Canada and the United States:
In the United States, NERC compliance is overseen by the Federal Energy Regulatory Commission (FERC), which has jurisdiction over interstate electricity transmission. FERC approves and enforces the NERC reliability standards for the U.S. In Canada, NERC compliance falls under the purview of the Canadian provincial and territorial regulators, such as the Alberta Utilities Commission or the Ontario Energy Board, depending on the jurisdiction.
NERC compliance in the United States is primarily focused on the North American bulk power system, which encompasses the interconnected grid spanning across the country. In Canada, NERC compliance applies to the interconnected grids within each province and their interties with neighboring jurisdictions, such as the United States.
While many of the NERC reliability standards are adopted and implemented in both countries, there may be variations and additional requirements specific to each jurisdiction. Provincial regulators in Canada have the authority to establish their own reliability standards or modify existing NERC standards to suit regional needs.
In the United States, FERC has the authority to enforce NERC compliance and impose penalties for non-compliance. In Canada, provincial regulators have the responsibility for ensuring compliance and may have their own enforcement mechanisms.
It’s important to note that while there are differences in the regulatory frameworks and compliance oversight. The overall goal of NERC compliance in both countries remains the same – to ensure the reliability, security, and resilience of the electric grid. Collaboration and information sharing between NERC and the relevant regulatory bodies in each country are crucial for maintaining a coordinated approach to reliability standards. As well as ensuring the smooth operation of the interconnected North American grid.
Well Now What?
Guess who gets left out in all of this fun? Hawaii and Alaska. Perhaps your new role and experience garnered from your new IT gig will lead you to the power company in Maui where you won’t have to worry about all this stuff and you can work with a drink in your hand with a straw coming out of a coconut. For the rest of us still living the NERC Compliance dream, having a grasp on the regional model for collaboration and enforcement is crucial to understanding the big picture.
Carpe diem! Go seize the day and always keep learning.
View our recent webinar, where we dive deeper into practical solutions to streamline CIP-004 compliance in your organization.
About the Author
Scott Crow is the Senior Business Systems Strategist – Energy & Utilities at AssurX. Scott has a proven track record of delivering successful IT/OT solutions that solve the challenges of cyber security for Critical Infrastructure. Passionate about bringing better ways of solving business problems through innovation to the marketplace and specializing in the intersection of people, technology and process.
