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Do you have your Sabotage Response
guidelines in place? Is your Critical Cyber Asset information in order?
Maybe you need to get busy…….or maybe not.
It all depends on when the reliability standards become effective for
cooperatives and the entity classification of your cooperative. But, one thing
is for sure; NERC’s compliance authority will apply to all bulk power system
owners, operators, and users.
And, NERC now has the authority to assess
penalties for failure to comply with its reliability standards. While it must
consider an entities’ “financial ability to pay” (e.g. entity size, structure,
financial position), FERC mandates that no penalty is to be inconsequential when
it is assessed.
The standards approved by FERC are
scheduled to become enforceable effective June 2007. There still is a question
whether this will be the actual date on which enforcement commences, and whether
NERC penalties will be real or simulated for a period of time. In any case,
enforcement and penalties will soon become a reality.
In the interim, it would be prudent to
determine which standards would apply to your cooperative. The majority of
distribution cooperatives would likely fall into one of three categories: 1)
distribution provider (DP); 2) load-serving entity (LSE); or 3)
purchasing-selling entity (PSE).
A distribution provider (DP) is an entity
that provides and operates the “wires” between the transmission system and the
end-use customer. The distribution provider is not defined by a specific
voltage but rather as performing the distribution function at any voltage.
A load-serving entity (LSE) is an entity
that secures energy and transmission service (and related Interconnected
Operations Services) to serve the electrical demand and energy requirements of
its end-use customers.
A purchasing-selling entity (PSE) is an
entity that purchases or sells, and takes title to, energy, capacity and
Interconnected Operations Services.
EnerVision can help your cooperative
determine which of the NERC Reliability Standards apply to you and to what
extent. “We have followed the actions of NERC and FERC since the Energy Policy
Act (EPAct) of 2005 was enacted. The standards that apply to cooperatives are
still evolving and compliance issues will be upon us in the near future,” cites
Tom Siegrist, Vice President of EnerVision.
It will be very important to develop your
compliance plan and to get the guidelines and procedures in place which
implement that plan.
EnerVision can assist your cooperative with
all of these endeavors. In addition, we can conduct an audit of your compliance
procedures and records, and provide a “report card” on your level of compliance
with the NERC standards.
If you would like to know more about how
EnerVision can help you with NERC Reliability Standards compliance, please
contact Tom Siegrist at (888) 999-8840 or e-mail at tom.siegrist @enervision-inc.com. |