USV UpdatesIn 2025, USV continued to grow our staffing in both the CIP and O&P teams, in addition to a few other changes. Since my last update, the following staffing changes have occurred:
We are also going to be adding several new services to what is included in your Routine Services contract, such as training your new hires, maintaining an attestation internal control document, submitting ERPQs in Align, and a few other services depending on your registration type.
Additionally, we just rolled out our new website with greatly improved functionality, more descriptive services pages (with new services added!), and a repository for any Reliability Ramblings posts that we share. Last, we will be 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 alert you when this functionality goes live and provide you with your login credentials.
Last, we are offering a link to a short satisfaction survey here that you are welcome to submit at any time. We want to ensure that you are receiving the best service possible and we welcome any feedback that you have, such as your thoughts on how your programs and projects are currently being managed or if there are any additional services that you might be seeking.
There are two efforts that are focused on the CIP impact criteria. The first is the NERC CIP Roadmap, which is reviewing cybersecurity risks potentially impactful to the bulk power system, identifying any gaps that may currently exist in the CIP standards to mitigate those risks, and then recommend solutions – possibly standard revisions – to close those gaps. More recently, FERC issued a Notice of Proposed Rulemaking (NOPR) in their approval of CIP-003-11 seeking industry comments on the potential risks of a coordinated attack on Low Impact CIP entities, with the proposed recommendation to have NERC perform a study on evolving threats as they relate to low impact BES Cyber Systems. These two efforts have not been working together yet, but they may align at some point. USV will monitor both efforts and providing feedback if we believe it to be necessary.
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 Milestone 3 ballots have recently passed and are on their way to being sent to the NERC board and filed at FERC by November 4th. Milestone 4 is just kicking off with two Standard Authorization Requests (SARs) focused on operational visibility and real time assessments. Please see the new page on our website here to learn more!
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. There are many other standards that are still being developed, some of which needed 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 Task Force (MSPPTF), which is going to take a holistic review of the entire standards development process. The task force broke this up into three phases: initiation, development, and balloting, and produced several improvement opportunities for each phase in a July whitepaper, which has since been commented on by industry. We believe that the task force had developed some thoughtful solutions for process improvements in both the initiation and development phases, such as front-loading technical information in the initiation phase, having a biannual prioritization process, and leveraging artificial intelligence to increase efficiencies in certain areas. The final recommendations just came out with the comment period open until November 10th and are focused on ensuring that stakeholder engagement is preserved. There is also a webinar recording available on the NERC site, and two in-person meetings scheduled for November.
NERC continues to investigate and understand the reliability impacts to the Bulk Power System of emerging large loads such as Data Centers. These loads have unique operational characteristics which NERC is still studying. The efforts are increasing, such as a NERC Alert that recently came out, and a letter from the FERC Chairman asking ISO/RTOs how they plan for these loads and incorporate them into their forecasts. This effort will likely accelerate over the next few years, and NERC is beginning to make it clear that these types of loads will eventually have to be registered with NERC, though they have not yet committed to the criteria to be used for this registration.
As always, we are grateful for you, our clients, and the trust that you place in US. We also thank you for the relationships that we have built together over the years. We are committed to continuing to provide value in the services that you receive, and we are open to all suggestions. If there is anything you need, please feel free to reach out to your lead USV contacts or you can reach out to me directly.
Thank you,
Devon Tremont
USV President
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