North American Transmission Forum

NERC Audit and NATF Peer Review

North American Transmission Forum (NATF) Peer Review

Platte River is a member of the North American Transmission Forum (NATF). The NATF’s mission is to promote excellence in the reliable operation of the electric transmission system. NATF members advance industry performance by sharing detailed and timely information; this includes lessons learned and superior practices, providing constructive peer challenge to foster effective and efficient reliability improvement, and ensuring the focus and commitment of members’ senior leadership.

NATF peer reviews help members improve upon their own operations. Review teams are comprised of subject matter experts and staff from utility companies nationwide. The peer teams review selected practice areas and cross-functional topics. The teams’ final reports include noteworthy positives that are shared with other members, and improvement recommendations for the host utility to implement. In August 2015 Platte River had its first peer review; since then Platte River staff has spent several months reviewing the reports and finalizing plans to address any areas of improvement. A follow-up review by NATF will be performed in 2016 to evaluate progress to date and discuss future plans. As a member of NATF, entities are required to participate in a peer review every three years. Platte River staff will also be participating as members of review teams at other member utilities in 2016 to gain knowledge and experience of the best practices to implement here at Platte River. Platte River is dedicated to bettering not only ourselves, but our industry too.

The North American Electric Reliability Corporation (NERC) Audit

As an owner and operator of generation and transmission facilities, Platte River is required under the Federal Power Act to meet mandatory and enforceable standards for reliability and critical infrastructure protection. These NERC standards include over 1,000 requirements and sub-requirements. Platte River has a dedicated Compliance Department that provides oversight to all compliance related activities to ensure adherence to all reliability standards. Failure to comply with the standards can result in fines up to $1 million per violation per day.

In February 2015 the Western Electricity Coordinating Council (WECC), the designated compliance enforcement authority for NERC, performed an audit of Platte River’s compliance and found no violation of any standard or requirement that resulted in an enforcement action and no areas of concern.

These audits take place every three years and check for compliance during that period. It took over 30 employees six months to prepare and review of hundreds of documents for the audit. It is Platte River’s responsibility to demonstrate compliance with the Operations & Planning (O&P) and Critical Infrastructure Protection (CIP) standards. On the CIP side alone, 1,593 files totaling 1.4 GB of data were collected to demonstrate compliance. and 181 pages of narrative were supplied to help the auditors understand the evidence. The auditors examine compliance through statistical sampling, analysis of evidence files, and/or interviews. Throughout an audit the auditors make data requests for additional information to build a case for compliance. Fewer data requests indicate a positive demonstration of compliance. An audit with 100 data requests or fewer is considered a good audit. In 2015, Platte River received 34 data requests, and met compliance regulations with no enforcement actions.