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ReliabilityFirst Granted Additional Discretion for Standards Impacted by COVID-19

The ERO Enterprise (i.e., North American Electric Reliability Corporation (NERC) and the Regional Entities) announced an expansion of regulatory discretion related to coronavirus impacts. More specifically, the ERO Enterprise is implementing a temporary expansion of Self-Logging to allow all registered entities to self-log instances of potential noncompliance related to coronavirus impacts. (See Full Announcement.) This is limited to noncompliance posing only minimal and moderate risk and excludes noncompliance posing serious risk.

Under this temporary expansion of the Self-Logging Program, potential noncompliance related to coronavirus impacts and logged in accordance with the guidance is expected to be resolved without further action. All registered entities are encouraged to review NERC's comprehensive guidance document for the additional discretion. This expansion does not constitute an admission to the Self-Logging Program and expires on September 30, 2020.

The announcement is an expansion of the regulatory discretion provided on March 18, 2020, relating to personnel certification and periodic requirements, which can be viewed here. NERC is maintaining an FAQ document addressing industry questions on the guidance on the CMEP One-Stop Shop. FERC also approved NERC's motion to defer the implementation of seven Reliability Standards with effective dates or phased-in implementation dates in the second half of 2020 to help assure grid reliability amid the impacts posed by the coronavirus outbreak. Finally, the ERO Enterprise postponed on-site audits and other on-site activities through September 7, 2020.

Entity Instructions

In a case of a noncompliance relating to entities' COVID-19 response, the entity should reach out to their enforcement case manager at ReliabilityFirst (RF) to discuss how to securely submit Self-Logged noncompliance(s). If an entity is not aware of who their case manager is, please contact RF using the Contact Us Page, and your case manager will reach out to you.

After you have connected with your case manager, please submit your entity's COVID-19 Self-Log by downloading a copy of the spreadsheet log template posted on the NERC website. This should be accomplished in accordance with the guidance below.

  • Include the following required information in the log template submission:
    • Entity name, NCR, and entity contact information;
    • Applicable Region;
    • Affected functions;
    • Date the potential noncompliance was submitted to the Regional Entity;
    • Specific Standard and Requirement at issue;
    • Description of the potential noncompliance, including the circumstances relating to the impact of the Coronavirus response the entity employed, that will (has) prevent(ed) maintaining or achieving compliance;
    • Date the potential noncompliance was discovered;
    • Date the potential noncompliance began or will begin;
    • Anticipated date the potential noncompliance will be resolved and compliance will be achieved;
    • Description of the potential harm not being compliant could cause to the bulk power system;
    • Actions taken, or to be taken, to get back into compliance; and
    • Actions taken to mitigate any risk associated with the potential noncompliance until compliance can be achieved and the anticipated completion dates for such actions.  

Thank you for your dedication to ensuring the health and safety of your employees, your communities, and the continued reliability and security of the RF 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. Choose “COVID-19" as the Area and “Updates - COVID-19" as the Topic.