On February 21, 2012, the North American Electric Reliability Corporation (“NERC”) released a draft of its assumptions used for preparing the organization’s draft Strategic Plan and projected budget for 2013. According to the draft Strategic Plan, NERC will focus on three areas:
- Standards and Compliance;
- Risks to Reliability; and
- Coordination and Collaboration.
The released budget assumptions were categorized by program areas, and NERC listed the following areas as functions that would see an increase in activity or resources:
- For the Reliability Standards Program, NERC expects to allocate additional resources to improve the quality of standards development and guidance, and the number of projects in the Reliability Standards Development Plan is expected to increase;
- For Compliance and Enforcement, spot checks will become more frequent as risk-based monitoring is rolled out, but this should not affect the number of resources needed;
- Organization Registration and Certification may require additional resources with the implementation of the new definition for the Bulk Electric System (“BES”), but that cannot be determined until the requests for exceptions to the definition are received;
- The Reliability Assessment and Analysis Program may also need additional resources to handle exceptions to the BES definition, increase data collection and analysis systems, and implementation of an “outcome based approach to achieve measurable improvements in reliability;”
- The Training, Education, and Operator Certification Program may need additional resources particularly for auditor credentialing and more frequent training opportunities, but it is uncertain how that will affect resources at this time;
- The Critical Infrastructure Protection (“CIP”) Program will now manage the Event Analysis program that used to be part of Compliance and Enforcement, and CIP will likely need to invest in retaining outside experts to train/credential NERC and regional staff; and
- Information Technology will require ongoing investments in order to support NERC business needs and enhance the NERC and regional websites.
NERC was unable to address the resources for the Find, Fix, and Track process because the process is still in its early stages. NERC also stated it is considering modifying the current three and six year audit cycles to focus more on reliability risks, not a predetermined schedule. Further, it is uncertain at this time what impact new technologies or environmental regulations will have on the budget.
Comments on the draft Strategic Plan and assumptions are due on March 9, 2012, and NERC expects to submit a final version of the Strategic Plan and budget to FERC in August 2012.
A copy of the draft Strategic Plan and budget are available here.