Compliance Monitoring Methods

COMPLAINT

A Complaint is an allegation that a registered entity has violated a Reliability Standard. A Complaint can be submitted directly to SERC or NERC. If a Complaint is made, SERC is notified and must determine whether there is sufficient basis for a Compliance Investigation.

To submit a Complaint, the complainant logs into the  Compliance Portal, selects Complaints, and clicks Add Complaint from the left navigation menu. If the complainant does not have access to the Portal and does not wish to remain anonymous, the SERC Complaint Form can be submitted to SERC. Complaints may also be made by calling the SERC Complaint Hotline (1-877-644-SERC).

A complaint may be submitted directly to NERC for these reasons:

  • The complainant wishes to remain anonymous.
  • The complainant specifically requests NERC to conduct the review of the Complaint.
  • The complaint is against SERC Reliability Corporation or its affiliates, committees, or subordinate structures.

In these cases, the complainant can complete the NERC Complaint form call the NERC Hotline (609-524-7029), or send an e-mail to hotline@nerc.net

COMPLIANCE AUDIT

A Compliance Audit is a systematic, objective review and examination of records and activities to determine whether a registered entity meets the requirements of applicable Reliability Standards.

According to the NERC Rules of Procedure, registered entities that are subject to a Compliance Audit, on-site or off-site, will receive notice at least 90 days in advance of the audit. The notice explains the compliance monitoring period for the audit, provide a list of the requirements that will be included in scope, and list any initial Requests for Information (RFIs) that must be submitted to SERC in advance of the audit.

COMPLIANCE INVESTIGATION

A Compliance Investigation is a comprehensive investigation to determine if a violation of a Reliability Standard has occurred. The investigation may include an on-site visit and interviews of the appropriate personnel. A Compliance Investigation is usually initiated by a system disturbance, Bulk Electric System Event, Complaint, or a registered entity’s Periodic Reporting. However, a Compliance Investigation may be initiated at any time and at the discretion of the Compliance Enforcement Authority. The scope of a Compliance Investigation is generally limited to Reliability Standards that are reasonably associated with the issue. Compliance Investigations are usually led by the SERC Compliance staff; however, FERC and NERC have the right to assume the leadership of a Compliance Investigation. 

PERIODIC DATA SUBMITTAL

Periodic Data Submittals are models, studies, analyses, documents, procedures, methodologies, operating data, process information, or other information to demonstrate compliance with Reliability Standards. Registered entities provide these submittals to the Compliance Enforcement Authority within a time frame required by a Reliability Standard or on an ad-hoc basis. SERC collects Periodic Data Submittals through the Compliance Portal and Reliability Assessment Portals. The schedule of the Periodic Data Submittals is provided in the SERC Filing Due Dates document, located in the corresponding Compliance Program year.

SELF-CERTIFICATION

A Self-Certification is an attestation from a registered entity that states any of the following:

  • The registered entity is compliant or noncompliant with a Reliability Standard Requirement that is the subject of the Self-Certification.
  • The registered entity does not own facilities that are subject to the Reliability Standard Requirement.
  • The Reliability Standard Requirement is not applicable to the registered entity.

Registered entities submit Self-Certifications to SERC using the Compliance Portal Self-Certification Form. SERC requires registered entities to self-certify to Reliability Standards and Requirements that SERC and NERC identify as “Risk Areas.” The Self-Certification schedule can be found in the SERC Filing Due Dates document, located in the corresponding Compliance Program year.

A Guided Self-Certification is a compliance monitoring method that focuses on certain low-risk requirements in their monitoring scope. Guided Self-Certifications follow a similar process as the annual Self-Certifications; however, evidence is required to be submitted via the Compliance Portal Self-Certification Form.


SELF-REPORT

A Self-Report is a report by a registered entity stating that it believes it has violated, or may have violated, a Reliability Standard. Additional information related to Self-Reports is provided on the Self-Report and Mitigation page.

SPOT CHECK

A Spot Check is a process in which the Compliance Enforcement Authority requests a registered entity to provide information for these reasons:

  • To support the registered entity’s Self-Certification, Self-Report, or Periodic Data Submittal and to assess whether the registered entity complies with Reliability Standards
  • As a random check
  • In response to operating problems or system events