Complying with RUS Emergency Restoration Plan (ERP) Requirements:  What Does it Mean?

Here's what it means to you: 

• By July 12, 2005, affected co-ops (all RUS borrowers) will have to complete an initial Vulnerability and Risk Assessment (VRA) of critical facilities and assets.
   

• By January 12, 2006, co-ops will have to draft an Emergency Restoration Plan (ERP) that details the processes by which they will restore critical facilities and assets in the event of a disaster.
   

• By January 12, 2007, co-ops must conduct an initial ERP exercise.

This latest RUS regulation represents another important step in helping protect our nation in response to the events of 9/11; however, fulfilling it could divert precious time and manpower resources from your core business of serving your members.

The RUS is merely requiring each of its borrowers to certify that they have completed an Emergency Restoration Plan (ERP) based on an analysis of risks, and that the borrower be adequately prepared to implement the plan in the event of a major system outage or disaster.  While the RUS has not dictated specific methods to employ, compliance will require a thorough review of all critical assets, including people.  The final rule sets important milestone dates and outlines the following expectations: 

This clearly means each borrower will have to utilize some form of an objective process to answer some tough questions.  For example, what is a critical asset?  Why is one asset critical, and another similar asset, not critical?  What amount of risk is acceptable?  At what point are we obligated to invest?  In what technologies?

Fortunately, risk assessment is not a new science and there are multiple models available.  The RUS suggests at least partial use of the NERC Guide, “Vulnerability and Risk Assessment” and the “FEMA Emergency Management Guide for Business and Industry.”  The NRECA and RUS are currently teaming to offer workshops on managing physical and cyber security.  In addition, the DOE provides risk management guidance through the Office of Energy Assurance, and even more guidelines are available from the NFPA (National Fire Protection Association).  If you think all of this sounds confusing, it can be.

One of the key steps in developing the VRA is selecting a methodology for prioritizing and assessing risks.  Successful methodologies have already been developed and utilized to assist cooperatives with the VRA development and Business Continuity Planning (a specific requirement of the ERP).  EnerVision is currently working with clients in developing their emergency restoration plans.  Since the VRA is on the immediate horizon, many readers may find the following high-level diagram outlining the core of our VRA methodology helpful:
 

EnerVision is familiar with risk management, the RUS requirements, and cooperatives.  We have blended the best available risk management guidelines/checklists/resources and developed structured methodologies that are easily adaptable to the specific needs of individual cooperatives.   

For more information please contact Charles Nash or Robert Duval at (888) 999-8840, or e-mail them at charles.nash@enervision-inc.com or robert.duval@enervision-inc.com.