USV UpdatesI am beyond grateful for the employees that we have at Utility Services. All our staff continue to grow and we encourage their development in all areas of the industry, with some taking on additional certification trainings and others going back to school for their master’s degree. I trust that you, our clients, are recognizing the value that our dedicated analysts bring to you in every interaction. We greatly encourage any feedback as this is one of the most important ways that our employees can grow and improve the support they offer. In Q1 and Q2, USV has continued to increase our staffing in both the CIP and O&P teams, in addition to a few other changes. More below:
Additionally, we are about to roll out our new website with significantly improved functionality, more descriptive services pages (with new services added!), and a repository for any Reliability Ramblings posts that we share. Last, we are including a “Member Resources” section of the website that only Routine Services clients can access which will include downloadable resources such as training slides and recordings, reporting templates, and access to the monthly TO/DP call slides. We will send out another notice once the website goes live and will provide you with a login to access the Member Resources page if you are subscribed.
NERC is currently taking a look at the CIP low/medium/high impact levels to understand if they are adequately mitigating risks. This process is just beginning within some of the subcommittees of the Reliability and Security Technical Committee (RSTC), starting with survey questions sometime this month. NERC has not committed to making changes to the impact level categorization, but there is the potential that we will see changes to how registered entities’ CIP programs are categorized. We will continue to monitor this process.
NERC is continuing to register a new subset of generators in the ERO program. As a reminder, these are single or aggregate facilities at 20 MVA or higher and connected above 60kV. The Generator Owner and Generator Operator glossary definitions have been revised in May 2025 which will automatically apply to a set of eight standards in 2026 that did not require modifications to apply to Category 2 GO/GOPs. Additionally, NERC has developed PRC-028, PRC-029, and PRC-030, though the last two are still pending FERC approval. There are many other standards that are still being developed, some of which need to be completed by November 2025, and the rest by November 2026. USV has been participating in the balloting process of these projects to flag our concerns, which we will continue to do until this effort is completed.
NERC has kicked off the Modernization of Standards Processes and Procedures (MSPP) Task Force, which is going to take a holistic review of the entire standards development process. The purpose is to more effectively and efficiently meet the speed at which risks to the bulk power system are emerging from the point of risk identification and prioritization to implementation. The MSPP TF started with a survey to industry stakeholders which sought suggestions of specific aspects of the standards development process, such as how Standard Authorization Requests (SAR) are handled and the information provided in a SAR. Utility Services responded to the survey with suggestions, the focus of which are to ensure that stakeholder participation in standards development is not reduced in any capacity. We will continue to share updates from this effort as they become available.
The Regional Entities continue to make FAC-008 a focus of their audits. We have heard through other entities, especially those in NPCC, that high-risk standards that are typically expected on an audit scope are being left off, but FAC-008 continues to be included and under high scrutiny, especially with large Transmission Owners where audit staff will visit on-site to verify the equipment in the field to compare to the inventory included in your FAC-008 methodology. Fortunately, Utility Services is now offering FAC-008 walkdowns as a standalone service where we will send two analysts to your facility to create a virtual walkthrough package using photos of equipment and rating documentation. Please reach out to your lead contacts if you are interested.
Thank you,
Devon Tremont
USV President
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