Advancing Risk-Based Posture through Platform Alignment: NERC’s ERO Enterprise CMEP Technology Project

Stan Hoptroff, VP, CTO, and Director of Information Technology at the North American Electric Reliability Council, discusses the use of NERC’s ERO Enterprise CMEP technology to streamline compliance monitoring and reduce risk.

Maintaining reliability across the bulk power system is not an isolated endeavor—it is a multi-pronged effort that is supported by numerous programs, initiatives, and organizations across North America. NERC and the seven Regions—collectively the Electric Reliability Organization (ERO) Enterprise—work together to assure continued reliability of the bulk power system through the identification, prioritization, and effective and efficient mitigation of risks.

This is done in a variety of ways, one of which is the way the ERO Enterprise conducts its Compliance Monitoring and Enforcement Program (CMEP). Over time, each of the seven Regional Entities developed its own processes and systems for monitoring compliance in accordance with NERC’s Rules of Procedure. This resulted in varying practices and consistency issues across the ERO Enterprise. Additionally, the use of different tools and software platforms for data collection impeded information sharing across the ERO Enterprise. While the various products, tools, templates, and file transfers in use today are effective for ensuring reliability and verifying compliance, the amount of manual work required to maintain and share the information contained within them is intensive.

The mission of the new CMEP Technology Project is to solve these problems, while enhancing the ERO Enterprise’s ability to share and analyze data that is crucial to the security and reliability of the grid. A single platform to capture and share this data will better align the business processes of the ERO Enterprise, improve documentation, sharing, and analysis of compliance work activities, and make CMEP activities more efficient and effective across the ERO Enterprise. The CMEP Technology Project will radically improve consistency, cost management, productivity, and effectiveness.

• Consistency. Moving to a common platform with a single common way for registered entities to interact with the ERO Enterprise on compliance and enforcement activities addresses current gaps in consistency.

• Cost Management. By moving to a common platform, the annual recurring costs for CMEP software for the ERO Enterprise would be reduced by almost 50 percent. The technology footprint would be reduced from three systems to one. The platform is a commercial off-the-shelf software product specifically designed to support the governance, risk management, and compliance (GRC) function common in many other industries, moving away from the custom-built legacy applications in place today that are more expensive to enhance and maintain.
• Productivity. Because of the large number of staff both within the ERO Enterprise and at registered entities who are working to ensure reliability through verification of compliance with the Reliability Standards, there is a significant potential for improvements in productivity to provide great benefits to a large population of users. Manual efforts to track activities, exchange information, develop and maintain forms and templates, and verify data integrity will be eliminated through centralization and, where appropriate, automation. These increases in productivity (estimated at more than 15,000 person-hours per year across the ERO Enterprise following full implementation and adoption) will allow staff to spend less time documenting compliance and more time ensuring reliability.
• Effectiveness. In addition to the benefits provided by implementing consistent processes across the ERO Enterprise, moving to a commercial GRC tool ensures focus is kept on those things that matter most to reliability and less time is spent on the administrative aspects.

Initial discovery workshops were conducted in 2014 and 2015, leading to the development of a long-term roadmap and a vendor selection in early 2018. The project kicked off this year, with full implementation scheduled for 2020.

The ERO Enterprise fosters a culture of reliability excellence by adopting and promoting the use of risk-management approaches across ERO program areas and by supporting risk-informed and prioritized actions by industry. Now is the time take the next step, recognizing the need to evolve and further unify with a single platform to better serve the ERO Enterprise, its staff, and its mission of continued grid reliability.