NERC is set to begin training registered entities on its new Align software project and Secure Evidence Locker (SEL) by the end of the year. Training will follow a staggered schedule, with the Midwest Reliability Organization and Texas Reliability Entity going first.

Align — formerly known as the CMEP (Compliance Monitoring and Enforcement Program) Technology Project — is intended to improve and standardize compliance monitoring and reporting processes across the ERO Enterprise. The SEL was conceived as a way to provide secure storage where potentially sensitive information collected as evidence can be kept separate from work papers managed through the Align tool itself.

NERC Planning 3-phase Rollout

In a joint webinar Tuesday, representatives from MRO and ReliabilityFirst provided more details about the timeline for Align’s rollout, currently scheduled to begin in the first quarter of 2021. The tool is to be released in three stages covering escalating levels of functionality:

• Release 1 — Q1 2021. To be introduced as a pilot in MRO and Texas RE before expanding to other regions. Functionality includes allowing registered entities to create and submit self-reports and self-logs, create and manage mitigating activities and mitigation plans, and respond to requests for information.
• Release 2 — Q2 2021. Includes technical feasibility exceptions, periodic data submittals, self-certifications and additional needed enhancements identified in Release 1.
• Release 3 — Q4 2021. Includes compliance planning and audits, spot checks and compliance investigations.

NERC is finalizing training materials for RE representatives, who will train registered entity staff from their regions in turn. Training for Release 1 will cover functionality for the initial release and features of the SEL supporting that functionality, along with regional changes in business procedures and transition plans for legacy systems. All training sessions will be conducted remotely.

“During the short time frame between Release 1 and Release 2, the information listed under Release 2 will be maintained in the current platforms, such as WebCDMS or any other platforms that [your regional entities] are having you work in now,” said Ray Sefchik, director of reliability assurance and monitoring at RF. “So there’ll be a couple of months’ gap where you may have to maintain [these platforms] for TFEs, periodic data submittals [and self-certifications] until rollout for Release 2 happens in Q2.”

Entities Free to Develop Private Lockers

The SEL is still under development, with plans to introduce it alongside Release 1 and expand it to store data for the functionalities covered under each subsequent release. NERC had initially planned to include this feature — which for security reasons is not part of the main Align tool — in an update, but the organization added it to the initial release because of concerns from registered entities over the software provider’s ties to a Hong Kong-based private equity firm. (See NERC Investigating Chinese Tie to Software Vendor.)

While all entities will be required to use a secure evidence locker to store relevant data, participants in the webinar stressed that they are free to deploy their own lockers if they prefer to keep potentially sensitive information in their own systems. This is already done by many entities for evidence associated with NERC’s Critical Infrastructure Protection rstandards, though Sefchik and MRO’s Desiree Sawyer said no entities have indicated definite plans to do so for CMEP information. (See FERC Approves NERC’s Align Spending Request.)

However, Matthew Thomas, RF’s director of compliance monitoring, emphasized that entity-developed lockers must be “authorized for use by CMEP activities” by NERC and the REs to ensure their reliability and security according to the specifications provided by NERC in April. A webinar is scheduled for Oct. 29 to answer entities’ questions about developing their own tools.