Periodic Data Submittal
About Periodic Data Submittals
Registered entities shall provide Periodic Data Submittals when requested by ReliabilityFirst in accordance with the North American Electric Reliability Corporation (NERC) published ERO Enterprise Periodic Data Submittal Monitoring Schedule. The schedule is published annually by NERC and is linked below. The schedule provides registered entities with a consistent approach to the Periodic Data Submittal schedule that is used throughout the ERO Enterprise and eliminates any regional schedule variations.
All scheduled requests for Periodic Data Submittals are created, transmitted and posted to applicable registered entities via the ERO Align system (Align). Entities must submit responses to their requests for data submittals for which they are applicable to ReliabilityFirst in Align. Entities must answer a set of qualifying questions for each data submittal and, based on the responses, additional data submittal form templates will be provided in the interface for the entities to complete before submitting the data to ReliabilityFirst. If a registered entity identifies the need to submit information or data related to a data submittal request, they must upload the applicable forms with data via Align and the ERO Secure Evidence Locker (SEL). Upon receiving notification from Align, ReliabilityFirst Compliance staff will follow-up with the registered entity concerning any questions related to the submission.
There are two types of Periodic Data Submittals that are to be completed in Align: Periodic Data Submittals and Event-Driven Periodic Data Submittals.
Periodic Data Submittals
Periodic Data Submittals are annual or quarterly requests for data or information for Reliability Standards that require them. They typically require specific data or information sets for a reporting period and include due dates as specified in a Reliability Standard and/or Requirement. Currently, there are two (2) Reliability Standards that fall into this category in Align: FAC-003 and PRC-023.
FAC-003-4 and PRC-023-4 Periodic Data Submittals
ReliabilityFirst requests Periodic Data Submittals from applicable entities for FAC-003-4 and PRC-023-4 in accordance with the ERO Periodic Data Submittal Schedule.
For applicable registered entities that do not own facilities applicable to Reliability Standards and Requirements subject to the Periodic Data Submittal requests, ReliabilityFirst accepts attestations. Align is utilized to provide attestations to ReliabilityFirst. Registered entities that provide attestations will not receive data submittal requests for these Reliability Standards and Requirements unless warranted by facts and circumstances. However, if conditions change that impact the registered entity’s applicability to a Reliability Standard and Requirement subject to a Periodic Data Submittal for which an attestation has been submitted, it is expected that the registered entity notify ReliabilityFirst Compliance of the change so the registered entity can begin meeting the reporting requirements for the applicable Reliability Standard and Requirement. Additionally, if an entity has provided an attestation to ReliabilityFirst and the attestation no longer applies (entity becomes applicable), the entity must notify ReliabilityFirst and rescind the attestation in Align.
To facilitate uniformity in the submission process, Align and the ERO SEL are designed to support the submission of FAC-003-4 and PRC-023-4 information. If a registered entity identifies a need to submit information, please submit via Align and the ERO SEL. Upon receiving notification from Align, ReliabilityFirst will work with the registered entity for questions regarding their submission.
The implementation of Align and the ERO SEL requires the new submission method and new forms. Please see the sample ERO Enterprise-wide Data Submittal Form – FAC-003-4 Final and PRC-023-4 Final document to gain a reasonable understanding of inputs required for Align entry. Attestation forms are managed in Align. If you have any questions pertaining to the use of Align or the ERO SEL please contact ReliabilityFirst Compliance.
– Data Submittal Form FAC-003-4
– Data Submittal Form PRC-023-4
Event-Driven Periodic Data Submittals
Event-Driven Periodic Data Submittals are less common data submittals that must be provided to the Region (ReliabilityFirst) that are specified in the Standard Requirements and are typically based on the date of occurrence of specific events. Event-driven data submittals are created by the entity in Align using the Event-Driven Periodic Data Submittal template in Align and submitted to the Region (ReliabilityFirst) that provide timely reporting of data required due to the occurrence of specific events. Currently, there are four (4) Event-Driven Data Submittal Forms in Align available to the entities for submission: PRC-002, R12, EOP-008, TPL-001, and TPL-007.
ReliabilityFirst publishes a monthly CMEP Update Letter that is sent to all ReliabilityFirst entities and includes a schedule for upcoming Periodic Data Submittals and their due dates for the current and following month of the compliance year.
If you have any questions regarding Periodic Data Submittals, please visit our Contact Us page and direct your question to the Compliance department through the dropdown menu.
PRC-002-2
PRC-002-2 R12 requires that Transmission Owners and Generator Owners shall, within 90 calendar days of the discovery of a failure of the recording capability for any Sequence Event Recording (SER), Fault Recording (FR), or Dynamic Disturbance Recording, (DDR) data either:
- Restore the recording capability, or
- Submit a Corrective Action Plan to the regional entity and implement it
To facilitate uniformity in the submission process, Align and the ERO SEL are designed to support the submission of Corrective Action Plans to ReliabilityFirst Compliance. The registered entity is required to maintain all relevant evidence, including the Corrective Action Plan, per Measure M12 of PRC-002-2. Please note that no Corrective Action Plan submission is necessary if recording capability is restored within 90 calendar days. If it is determined that the recording capability cannot be restored within the 90 calendar days, submission of a Corrective Action Plan must be made within 90 calendar days of discovery.
If a registered entity identifies a need to submit a Corrective Action Plan to ReliabilityFirst, please submit via Align. Upon receiving notification from Align, ReliabilityFirst will work with the registered entity for questions regarding the submission.
The implementation of Align and the ERO SEL requires a new submission method referred to as an “Event-Driven Periodic Data Submittal.” Please see the sample ERO Enterprise-wide Event-Driven Data Submittal Form – PRC-002-2 Final document below to gain a reasonable understanding of inputs required for Align entry. If you have any questions pertaining to the use of Align or the ERO SEL, please contact ReliabilityFirst Compliance.
EOP-008-2
EOP-008-2 R8 requires Reliability Coordinators, Balancing Authorities, and Transmission Operators that have experienced a loss of their primary or backup functionality and that anticipate that the loss of primary or backup functionality will last for more than six calendar months to provide a plan to their Regional Entity within six calendar months of the date when the functionality is lost, showing how they will re-establish primary or backup functionality.
To facilitate uniformity in the submission process, Align and the ERO SEL are designed to support the submission of plans to ReliabilityFirst Compliance. If a registered entity identifies a need to submit a plan to ReliabilityFirst, please submit via Align. Upon receiving notification from Align, ReliabilityFirst will work with the registered entity for questions regarding the submission.
The implementation of Align and the ERO SEL requires a new submission method referred to as an “Event-Driven Periodic Data Submittal.” Please see the sample ERO Enterprise-wide Event-Driven Data Submittal Form – EOP-008-2 Final document below to gain a reasonable understanding of inputs required for Align entry. If you have any questions pertaining to the use of Align or the ERO SEL please contact ReliabilityFirst Compliance.
TPL-001-4
The ERO Enterprise has developed the Electric Reliability Organization (ERO) Enterprise TPL-001-4: Use of Footnote 12 for Non-Consequential Load Loss Review Process document, which addresses how ERO Enterprise staff will jointly review requests to utilize footnote 12 for Non-Consequential Load Loss under TPL-001-4 in determining the possibility of any Adverse Reliability Impact in a timely, structured, and consistent manner. For your reference, the document is attached to the ERO Enterprise Periodic Data Submittals Schedule.
To facilitate uniformity in the submission process, Align and the ERO SEL are designed to support submission of TPL-001 Footnote 12 requests to ReliabilityFirst Compliance. If a registered entity identifies a need to submit a request to ReliabilityFirst, please submit via Align. Upon receiving notification from Align, ReliabilityFirst will work with the registered entity for questions regarding the submission.
The implementation of Align and the ERO SEL requires a new submission method referred to as an “Event-Driven Periodic Data Submittal.” Please see the sample ERO Enterprise-wide Event Driven Data Submittal Form – TPL-001-4 Final document below to gain a reasonable understanding of inputs required for Align entry. If you have any questions pertaining to the use of Align or the ERO SEL please contact ReliabilityFirst Compliance.
TPL-007-4
TPL-007-4 Part 7.4 and Part 11.4, enforceable Oct. 1, 2020, require that “responsible entities” (Planning Coordinator or Transmission Planner as determined in TPL-007-4 Requirement R1) submit a request for extension of time to the Compliance Enforcement Authority if the “responsible entity” is unable to implement the Corrective Action Plan within the timetables identified in the initial Corrective Action Plan developed under Part 7.3 or Part 11.3.
The ERO Enterprise has developed the TPL-007-4 CAP Extension Request Review Process to ensure a timely, structured, and consistent approach to extension request submittals and processing. The process is included in Appendix B of the ERO Enterprise Periodic Data Submittals Schedule.
To facilitate uniformity in the submission process, Align and the ERO SEL are designed to support submission of Corrective Action Plans to ReliabilityFirst. If a registered entity identifies a need to submit a Corrective Action Plan to ReliabilityFirst, please submit via Align. Upon receiving notification from Align, ReliabilityFirst will work with the registered entity for questions regarding the submission.
The implementation of Align and the ERO SEL requires a new submission method referred to as an “Event-Driven Periodic Data Submittal.” Please see the sample ERO Enterprise-wide Event-Driven Data Submittal Form – TPL-007-4 Final document below to gain a reasonable understanding of inputs required for Align entry. If you have any questions pertaining to the use of Align or the ERO SEL please contact ReliabilityFirst Compliance.
– Event-Driven Data Submittal Form – EOP-008-2
– Event-Driven Data Submittal Form – PRC-002-2