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One of the key features of the Energy Policy Act of 2005 was to empower the U.S. Federal Energy Regulatory Commission (FERC) to enforce mandatory reliability standards. These standards apply to all users of the bulk electric system and are scheduled to be enforced via monetary penalties and mitigation measures by the summer of 2007.
All users of the bulk electric system, including transmission owners, load serving entities, generator owners, and operators, will be responsible for complying with the compliance elements and measures of the standards developed by North American Electric Reliability Corporation (NERC). In many cases, entity registration and self-certifications have already begun across the country.
ICF brings a full spectrum of preparedness and compliance tools:
- Standards Education and Training
- Readiness and Risk Assessments
- Critical Infrastructure Identification
- Standards Development Support
- Development of Self-Certification Process
- Reporting and Response Support
- Violation Settlement and Support
Our Approach
ICF believes an integrated and ongoing compliance effort will best serve the responsible entities that will be in the spotlight of these new measures. We are equipped with experience in the history of the reliability standards, their development, scope, and intent.
Compliance entails a broad spectrum of activities on the part of the responsible entities, and ICF has designed a similarly broad approach to compliance activities. From risk analysis, readiness assessments, and reporting tools, to applicability evaluations, training, and advice on issues of concern inherent in developing standards, ICF brings a full spectrum of preparedness and compliance tools to manage and avoid the risks, and capitalize on the benefits of an excellent record of compliance.
Our Capabilities
Risk-Based Assessments
As part of the cyber security set of standards, each responsible entity must use a risk-based assessment to determine if its assets are critical under the standard. ICF, with its well-documented ability and experience in assessing the characteristics of the interconnected transmission systems, is uniquely positioned to provide such assessments on a timely and efficient basis.
Training
ICF has extensive experience in developing, delivering, and administering on-line, Web-based training solutions. Responsible entities have a broad range of resources involved in the compliance efforts, including operations, legal, regulatory, and senior staff personnel. We provide customized approaches where various disciplines can access the most vital and relevant data they need to fill their roles in the compliance activities.
Compliance
ICF provides ongoing advice on the content and applicability of the self-certification forms and other requirements for the regional entities (RE), what they mean, and what levels of risks are embedded in the standards. Each RE has distinct needs and expectations of responsible entities, with unique sets of actively monitored standards, self-certification schedules, and verification of procedures. ICF assists in the timely submission of the self-certification forms and tracks the schedules of the expected submittals in each region.
ICF can build and maintain an on-line repository, the necessary procedures and methods of documentation for each standard requiring these items. This database of documents is template-based for consistency, contains explanatory comments as required, and is constantly updated as needed by changing requirements and newly developed standards.
Development
The NERC standards development process is very open and inclusive to anyone who wants to comment on or participate in the process, which suits companies that have sufficient resources to devote to the processes, drafting teams, ballot bodies, and evaluations of developing standards. ICF is substantially engaged in the standards development and compliance issues at NERC. We also monitor and evaluate risk points inherent in the standards under development, as well as the FERC process of approving the standards for enforcement. We provide updates and assessments of the developmental issues.
Featured Solutions
NERC Standards Development and Compliance Forums
ICF staff have played and continue to play significant roles in the NERC Standards Development and Compliance forums. Staff has coordinated the registration of responsible entities in all eight regional reliability regions and developed relevancy matrices for responsible entities to track and complete compliance reporting requirements. Ongoing work includes advice and guidance on applicability, reporting content and changing requirements of standards already approved, being developed, and undergoing revision.
Energy Market Compliance Support
As other energy regulations and legislation has been instituted, like the Clean Air Act, NOx SIP Call, and various other multi-pollutant policies, ICF has assisted companies in assessing costs and market impacts of the regulations and in developing an effective compliance strategy geared to minimize costs and preserve value.
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