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Regulatory Discretion for COVID-19 Impacts
3/24/2020

The Federal Energy Regulatory Commission (FERC) and the North American Electric Reliability Corporation (NERC) announced that they are taking steps to ensure that operators of the bulk electric system can focus their resources on keeping people safe and the lights on during this unprecedented public health emergency. (See Full Announcement here.)

To that end, FERC and NERC are using regulatory discretion to consider the impact of the coronavirus outbreak in complying with Reliability Standards as follows:

  • Personnel Certification: The effects of the coronavirus will be considered an acceptable basis for non-compliance with obtaining and maintaining personnel certification, as required by PER-003-2, for the period of March 1, 2020 to December 31, 2020. 
     
  • Standards involving Periodic Actions: The effects of the coronavirus will be considered an acceptable reason for case-by-case non-compliance with Reliability Standard requirements involving periodic actions that would have been taken between March 1, 2020 and July 31, 2020. Examples include timing requirements under PRC-005-6 and CIP-007-6 R2.

Entity Instructions

In a case of delay in compliance activities under either of the two scenarios above (PER-003-2 or Standards involving periodic actions), entities must:

  • Notify ReliabilityFirst of their exception request using ReliabilityFirst's Exception Request Form, available here.    Follow the submittal instructions contained within the form. Your Enforcement Case Manager will work with you in processing the request.
  • Be prepared to communicate and document the following information.
    • What specific Standard/Requirement is at issue?
    • What circumstances exist at your entity relating to COVID-19 that will prevent the compliance activity from being completed on-time?
    • Are there interim mitigating activities you are putting in place?
    • What actions will you need to take to get back into compliance, and when do you anticipate that these will be complete?

Thank you for your dedication to ensuring the health and safety of your employees, your communities, and the continued reliability and security of the ReliabilityFirst Region.

If you have other questions or concerns regarding the coronavirus outbreak that are not related to this regulatory discretion, please use the Contact Us page located here. Choose “COVID-19" as the Area and “Updates - COVID-19" as the Topic.