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.