The Compliance Enforcement Authorities (CEA) perform an Inherent Risk Assessment of registered entities to identify areas of focus and the level of effort needed to monitor compliance with enforceable NERC and regional Reliability Standards. The IRA is a review of potential risks posed by an individual registered entity to the reliability of the bulk power system (BPS). An IRA considers risk factors such as assets, systems, geography, interconnectivity, prior compliance history, and overall unique entity composition when determining the compliance oversight plan for a registered entity.
Reliability Compliance Program Assessment
As part of the compliance oversight plan, a registered entity will undergo periodic compliance audits of the NERC and regional reliability standards including the cyber security standards outlined in the FERC Orders. Whether or not a registered entity is on the next-years audit schedule, it is considered best practice to routinely evaluate the standing of ones compliance program against each applicable NERC and regional reliability standard. CGM Consulting will assist the registered entity through the performance of a similar assessment to better prepare the entity for its compliance oversight plan. The process of the CGM Consulting assessment will being by obtaining a better understanding of the registered entity and its operations including footprint, prior compliance history and performance, and types of BPS assets. In addition, it is necessary to identify potential risk trends, identify the applicable NERC and regional reliability standards that may apply to an entity based on the BPS assets in which they own. And finally, outline the entity's internal compliance environment including the organizations compliance with the reliability standards.
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