A key factor in the success of compliance monitoring and enforcement of mandatory standards rests on a common understanding among industry and ERO Enterprise Compliance Monitoring and Enforcement Program (CMEP) staff of how compliance can be achieved and demonstrated. For many standards, this is straightforward. For others, a variety of approaches may achieve the same objective.
In November 2015, the NERC Board of Trustees approved the Compliance Guidance Policy, located under Key Resources. Compliance Guidance under the Compliance Guidance Policy includes two types:
- Implementation Guidance, which provides examples for implementing a standard; and
- CMEP Practice Guides, which provide direction to ERO Enterprise CMEP staff on approaches to carry out compliance monitoring and enforcement activities.
Implementation Guidance is developed by industry and vetted through pre-qualified organizations. In order for an organization to become pre-qualified, a member of that organization must submit an application to the Compliance and Certification Committee. Vetted examples can then be submitted to the ERO Enterprise for endorsement, and, if endorsed, the ERO Enterprise would give the example deference during CMEP activities with consideration of facts and circumstances. Implementation Guidance would not prescribe the only approach to implementing a standard and entities may choose alternative approaches that better fit their situation. Draft Implementation Guidance will be posted below while it is being considered for ERO Enterprise endorsement. Once the Implementation Guidance is endorsed, it will be moved to the ERO Enterprise-Endorsed Implementation Guidance section. Draft Implementation Guidance that does not receive ERO Enterprise endorsement will be removed.
CMEP Practice Guides are developed solely by the ERO Enterprise to reflect the independent, objective professional judgment of ERO Enterprise CMEP staff, and, at times, may be initiated following policy discussions with industry stakeholders. Following development, they are posted for transparency on the NERC website.