What is a Certification Review?
Are you an actively registered Balancing Authority (BA), Reliability Coordinator (RC), or Transmission Operator (TOP)? Are you thinking about or have plans to remodel, build, or relocate a control center? Is next year the year you plan to upgrade your EMS or switch vendors? Maybe you are acquiring new Facilities (as defined by the NERC Rules of Procedure) or expanding boundaries. These types of changes have significant operational effects and may transform the way an organization would normally perform the functional operations of BA, RC, or TOP. An organization requires maintenance and thus conditions change. When conditions change an entity/organization should reach out to its Regional Entity, like MRO.
If you answered yes to one or more of these questions, a review of your organization’s conditions—a Certification review—is required. The performance of BA, RC, or TOP real-time actions impact the reliable operation of the bulk power system (BPS). The Organization Certification review process is outlined in NERC ROP Section 500 and Appendix 5A. The purpose of the review is to gain a level of assurance that the organization can meet the reliability obligations of its registration. The review activity will assess the processes, procedures, tools, and training that an applicable organization uses in the performance of its reliability functions. NERC and the applicable Region(s) must be confident through the assessment activity that an already certified registered entity will continue to support the reliable operations of the BPS after initiating a material change.
What is a material change?
NERC ROP Section 500 and Appendix 5A Section V addresses the Certification review process, including operational changes that are material and necessitate a Certification review. The objective of the review is to:
- Verify the functional entity has the tools, training, and security in place to reliably operate with new responsibilities due to a footprint change/gain. A registered entity’s footprint might be adjusted due to changes in ownership of Bulk Electric System (BES) Facilities, changes in the applicability of the BES Definition of a Facility, and newly installed BES Facilities.
- Confirm that the functionality impacts on system operation facilities (BES system awareness tools and applications, data exchange capabilities, interpersonal (and alternate) communications capabilities, power source(s), physical and cyber security) due to a relocation of Control Center (primary (PCC) or back-up (BUCC)) are understood and were addressed.
- Assure that the system operations functionality, machine interfaces, situational awareness tools and CIP security perimeters affected by a modification of an entity’s Energy Management System (EMS) were appropriately assessed and included in the execution of the entity’s EMS project. An EMS modification includes complete replacement of SCADA/EMS with a new or current vendor, same vendor significant changes to software that materially impact functionality, user interface or security (firewall capability or vendor, significant network architecture change (i.e., physical infrastructure to a virtualized infrastructure, etc.).
What should I do if my organization is planning or anticipates material condition changes?
A registered entity that is changing its organization’s operational or performance conditions from when it was initially certified and/or registered is required to be reviewed. To initiate a review, entities should complete and submit the Certification Request form and the Certification Preliminary Questionnaire. Informal questions related to Certification review are encouraged and should be directed to [email protected]. Each entity is unique, and its change in scope is individual, thus every submission is reviewed, and the applicable Region(s) and NERC collaboratively decide whether to conduct a review under the Certification review process or engage in a lesser activity.
What can I expect from MRO?
A Certification review is a forward-looking activity that seeks to confirm that the impacts of the material change have been considered and that appropriate controls have been implemented to ensure the registered entity will continue to effectively perform its reliability function(s). The Certification review process is broken down into four phases: Initiation, Planning, Fieldwork and Reporting. When the decision is made to initiate a Certification review or lesser activity, MRO will inform the registered entity.
During the planning phase, MRO coordinates the activity specifics (logistics, timeline/schedule, and check-in communications), and distributes the activity scope via a Certification Review Packet. The fieldwork phase kicks off with the regional review of the entity’s data response. Included in the fieldwork phase is an onsite visit, which involves facility walk-throughs, along with subject matter expert and system operator interviews. In the final phase (reporting), MRO will draft a summary report with any regional recommendations and submit it to NERC. If NERC approves the continued Certification, confirmation and a final report will be sent to the entity. Certification review activities should take place in advance of any conditional change. A best practice is to contact your Regional Entity a minimum of 180 days prior to the desired production or go-live date of the change. MRO will work with the entity throughout the process to support a successful material change of the registered entity(ies). Resources on Certification reviews can be found on the MRO website under the Registration & Certification Program Area and the NERC Organization Certification webpage.
– Michael Spangenberg, MRO Senior CIP RAM Engineer, and Summer Stephens, MRO Senior Reliability Specialist