Combining
two programs strengthens Western
Every moment of every
day, Western employees are responsible for complying with 115 North American
Electric Reliability Corporation Reliability Standards, which include more than 1,250
requirements and sub-requirements. These requirements mandate a host of
activities ranging from cyber and physical security measures to ensuring
appropriate officials have signed the proper forms within the right time
frames.
At the same time,
those two example requirements pose different risks to the utility and bulk
electric system, whose reliable operation is the goal of the NERC standards.
It takes a team
effort to put the right people in the right place at the right time to manage
all the NERC requirements, sustain grid operations and protect the utility.
On June 28, the
Enterprise Risk Management and Reliability Compliance programs combined into a
single office to help Western consistently and strategically approach
reliability compliance, while also following an industry trend.
“Centralizing an
independent team allows us to quickly adapt to regulatory standard changes,
supports continuous improvement of internal controls and aligns with NERC’s
direction of a risk-based compliance program,” said Executive Vice President
and Chief Operating Officer Tony Montoya. “This strategic decision is aligned
with the first two critical pathways of the Strategic Roadmap: Business,
Technology, and Organizational Excellence; and Mutually Beneficial Partnerships.”
VP of Risk and
Reliability Compliance Matt Miller oversees the new program, which includes the
enterprise risk manager, reliability compliance program manager and the four
regional compliance managers who will all remain at their current duty stations
and grade levels.
“I am really excited
about this change. The reliability compliance managers are a highly qualified
and dedicated group as is ERM Specialist Keith Gittlein,” said Miller.
“We want to build on what the reliability compliance managers have accomplished
to date and take it to the next level across the agency.”
Risk,
reliability compliance make compatible partnership
Before the
reorganization, regions conducted individual reliability compliance programs.
The regional compliance managers and program manager talked to one another in
weekly meetings through the Reliability Standards and Compliance Team, also
known as RSCT, to discuss the various efforts and how best practices in each
could be implemented Westernwide to save time and resources.
“Regions do things a
little differently. Everyone is compliant, but the regions would collect
evidence and show how they meet the requirements in different ways,” said
Desert Southwest Reliability Compliance Manager Matt Schmehl. “We want to do
things the same way to promote efficiency and be better able to establish
emphasis and priorities.”
The reorganization
gives the RSCT members more authority and presence in Western to create a
central, risk-based internal compliance program. “We will create efficiencies in
removing duplicating efforts and implementing common practices, training,
policies and procedures,” said Schmehl.
A second major
expected outcome of the reorganization is improving Western’s preparedness for
reliability audits. Utilities are audited by NERC-registered regional entities
every three years. But Western, who has separate NERC registrations for each
region, faces four audits every three years.
“This reorganization
demonstrates the commitment from the administrator and the Senior Executive
Team to build a culture of compliance within Western,” said Miller. “In the
past, we had to push to prepare for audits by gathering appropriate evidence
just before the audit, but the new approach is to maintain the appropriate
compliance evidence on a regular basis and monitor those efforts to demonstrate
our commitment to compliance to NERC and others.”
“Having a single
Westernwide program will continue to improve the compliance culture,” said
Schmehl. “We will develop consistent practices and procedures, and the training
to go with it. This will ideally streamline our compliance efforts and make us
more effective in backing each other up across the regional boundaries. A
single program will also strengthen our mock audit program, which has shown to
improve the audit experience for employees and result in fewer findings for
Western.”
Finally, the ERM
program will help focus the reliability compliance program on monitoring those
standards that will most affect the grid and Western’s objectives. It will also
continue working with the functional councils and working groups on mitigating
Western’s seven enterprise risks.
“Western
has a lot of highly capable people keeping the electrons flowing. These changes
to our reliability compliance program will help us document those efforts,
improve them and demonstrate them to NERC and our customers,” said Schmehl.