AUSTIN, Texas — The Texas Reliability Entity has revised its self-certification process to make it more efficient for registered entities, staff said last week.
Self-certification is an attestation by registered entities on whether they are compliant or not with a reliability standard requirement. They can also declare that they do not own facilities subject to the requirement or that the requirement is otherwise not applicable.
Keith Smith, manager of operations and planning compliance monitoring, told attendees of Texas RE’s Spring Standards and Compliance Workshop on Thursday that registered entities will now be given more advance notice of the process and that Texas RE has worked to improve the quality of information it first receives.
In previous years, registered entities were given 30 days’ notice before the start of the self-certification process, with attestations due on the day the process begins. They will now be given 90 days, with submissions due 60 days before self-certification starts. That gives entities an extra 60 days of back-and-forth communication with Texas RE.
“We want you to provide us all the information up front, so we don’t have this continuous back and forth,” Smith said.
Texas RE’s self-certification worksheets will include questions crafted to obtain “appropriate and sufficient evidence” of compliance, he said. Registered entities will also be asked to provide narratives that support the attestation and identify internal controls, helping staff in understanding how the entity arrived at its attestation.
Smith hopes this will eliminate the constant clarification requests and responses during self-certification, which slows the entire process. Texas RE processed 12 self-certifications in 2018 and is already halfway to that number this year.
New Systems to Improve Efficiencies
COO Jim Albright advised entities to be on the lookout for a pair of new technology systems that will be coming online over the next two years.
The Centralized Organization Registration ERO System (CORES) is scheduled to go live June 17, replacing several other systems on NERC’s ERO Portal. A repository for collecting registered entity data and documentation, CORES will improve the processing of registration requests, Albright said.
Texas RE will host testing of the system at its office May 16.
Albright also discussed the new Align system, a common portal for use by NERC, regional entities and registered entities in performing their compliance monitoring and enforcement program activities. Align, which Albright called a “whole new tool for work,” will be released in three stages, beginning in September. Release 2 is scheduled for the first half of 2020, with Release 3 anticipated in the second half of 2020.
The first release will enable entities to create and submit self-reports and self-logs, view and track enforcement actions, and receive and respond to requests for information.
Albright said the system will use CORES’ information to align NERC and the REs’ business processes, improve documentation, sharing and analysis of compliance activities, and provide “deep and broad views” of reliability across the ERO enterprise.
“We’re banking on this creating efficiencies across the ERO and [allowing] us to work with other regions,” said Albright, chair of the project’s steering committee. “We can’t share information easily now. Align will take care of that.”
TRE CEO Welcomes Attendees
Texas RE CEO W. Lane Lanford made a brief appearance at the workshop to welcome attendees and remind them that ERCOT’s historically low 7.4% reserve margin does not mean the end times are here.
“I remember when I was at the legislature and it was a hot day. We would be hoping everything would work out alright,” said Lanford, who managed legislative issues during his 12 years as the Public Utility Commission’s executive director.
“The narrower reserve margins [Texas faces] doesn’t mean the sky is falling or you run out with your hair on fire,” he said. “It’s something we hope you are preparing for. If we can help you, call on us. We all have to get there somehow.”
FBI: Cyber Crime Growing from New Software Tools
FBI Senior Special Agent Duncan Edwards gave a “non-classified” presentation on cybersecurity issues, warning attendees of the latest developments in ransomware, botnets, spoofing and dark web marketplaces.
The availability of Wi-Fi “crackers” and other software applications are driving the surge in cybercrime, Edwards said. “You don’t have to be a super hacker. Like anything in life, if you can make a buck on it, why not do it?” he said.
Edwards pointed out that the weakest link in internal security measures is “human error.”
“Your training is only as good as the individual who follows the training and protocols in place,” he said.
NERC Collecting Data on Wind Resources
NERC’s Generation Availability Data System (GADS) is expanding its collection of wind data and is planning to add solar data, said Mark Henry, Texas RE’s director of reliability services.
GADS has long collected outage data and operating history on conventional generation. Filings are due 45 days after the end of each quarter.
GADS Wind is collecting similar data from wind resource owners, with a phased-in implementation though 2020. GADS began collecting data on 200-MVA resources in 2018, and those between 100 and 200 MVA started filing in 2019. All units greater than 75 MVA must begin filing in 2020, and smaller units may participate voluntarily.
GADS Solar is on the horizon, possibly in 2022, Henry said.
Texas RE Budget Up 5.7% for 2020
Texas RE’s Board of Directors reviewed its preliminary budget proposal for 2020 during a Wednesday conference call. The $13.8 million budget is a 5.7% increase over 2019’s final budget of $13.1 million.
Personnel costs, Texas RE’s largest expenses, are up 4.3%, though staff’s size will remain constant for 2020. Medical benefits are increasing 14%, with a possible future increase of 20 to 25% leading staff to consider changing providers.
Texas RE’s operating expenses are increasing 12% because of an increase in its office rent. The entity has $2.7 million in operating reserves.
The Member Representatives Committee will review the budget during a Friday conference call before it goes to the board for its final approval on May 15. The budget will be presented to FERC and NERC in late May.
— Tom Kleckner
