REGULATORY RISK MANAGEMENT AND COMPLIANCE SUPPORT
We partnered with BC Hydro to affirm its understanding of the risks posed by the applicable entities and oversee the effective implementation of a risk‑based compliance monitoring and enforcement program. While NERC has provided general guidance on the various risk factors that are commonly understood for the North American grid, we assessed BC Hydro’s current processes and understanding of specific risks identified by the Western Electricity Coordinating Council (WECC). This included the following:
- Discussion with BC Hydro system operations, planning, and compliance teams.
- Review of compliance narratives and evidence to verify sufficient quality and provide adequate interview training to enable BC Hydro to pass its audit.
- Assist with coordination in response to WECC data requests leading up to and during the 2017, 2019 and 2021 audits related to compliance evidence, as well as assisting with audit interviews, mitigation plans and liaising between BC Hydro SMEs and WECC auditors.
- Review of compliance narratives and evidence to verify sufficient quality for its 2018 and 2020 self-certification cycles.
- Review several years’ annual British Columbia Utility Commission’s Mandatory Reliability Standards (MRS) assessment report for sufficient quality to verify new and revised MRS and NERC glossary of terms under assessment for potential adoption in British Columbia.
- Full staff augmentation assistance with root cause analysis, extent of condition evaluations, program improvement, milestone tracking and implementation efforts.
- Technology road map for all compliance-related technology systems (both information technology and operational technology), which focuses on asset management to include each NERC CIP asset’s system of record, future integration, workflow and automation within the asset life cycle. This includes identifying future and intermediate states, assessing BC Hydro’s existing tools, defining short-term opportunities for improvement as well as mid-term and long‑term approaches to systems implementation to support desired compliance outcomes and strategic initiatives.
- Implementation of governance compliance tool SigmaFlow to allow clear and consistent documentation of activities related to change management and patch management across all BC Hydro business units in relation to the British Columbia Utilities Commission’s approved CIP reliability standards.