Standards-Efficiency-Review

 

Related Files

Status of SER Phase 2
Based on industry feedback of six efficiency concepts, the SER Phase 2 Working Team prioritized four concepts to pursue. The top 4 priorities were all addressed by the SER group.

1.   Evidence Retention Overhaul

• SER Evidence Retention Recommendations (Endorsed by SC December 18, 2019, agenda item 9)
• SER Evidence Retention White Paper
  

2.   Consolidate Information/Data Exchange Requirements

• Operation Data Exchange Simplification SAR (Pending SC endorsement January 20, 2021, agenda item 7)

3.   Move Requirements to Guidance (incorporated into NERC policy; Risk Mitigation Framework) 

• Framework to Address Known and Emerging Reliability and Security Risks (Endorsed by RSTC December 16, 2020, agenda item 4)

4.   Prototype Standard (reframed)

• ​SER Recommendation for Standards Template and Drafting Team Training Review​; (Endorsed by SC December 9, 2020, agenda item 6) 

Overall Project Scope

Evaluate NERC Reliability Standards using a risk-based approach to identify potential efficiencies through retirement or modification of Reliability Standard Requirements. Considering that many Reliability Standards have been mandatory and enforceable for 10+ years in North America, this project seeks to identify potential candidate requirements that are not essential for reliability, could be simplified or consolidated, and could thereby reduce regulatory obligations and/or compliance burden.

SER Phase 1
On June 7, 2019, NERC staff submitted a petition, FERC Docket Number RM19-17-000, for the approval of Reliability Standards Requirement retirements in the INT, FAC, PRC, and MOD Reliability Standards families, as developed by Project 2018-03 SER Retirements project. The petition proposed the retirement of approximately 84 Requirements.

CIP SER
The CIP Standards Efficiency Review project began in July 2019.

SER Phase 2 Scope and Approach
Evaluate NERC Reliability Standards (O&P and CIP), as informed by implementation experiences and compliance practices, to develop and recommend standards-based solutions intended to reduce inefficiencies and unnecessary regulatory burdens for the purpose of supporting continued safe, secure and reliable operations.

The Phase 2 Team will focus on the following activities:

• Identify areas of inefficiency in the current framework of Reliability Standards.
• Collaborate and communicate with industry to ensure all areas of inefficiency and potential solutions are considered.
• Potential solutions may include, but are not limited to:
• SARs to remove inefficiencies in the Reliability Standards.
• Policy recommendations to appropriate ERO staff or committee.
• A sub-team, consisting of a few members from SER Phase 1 and Phase 2, are reviewing information from the SER Matrix input from the early stages of Phase 1, in order to identify efficiency opportunities not covered by Project 2018-03 SER Retirements or SER Phase 2. This sub-team is tasked with developing a SAR to summarize a consolidated list modification recommendations.