Forward Deployed Compliance Support

Pre-COD Plants

• Documentation Gathering, Coordination, and Technical Reviews: Provide coordination and technical review activities for new generation projects to gather and review all required data, models, studies, and other information to support the compliance requirements of all applicable NERC Standards. You provide access to all systems containing available and applicable documentation for the generation facility, and the FDL performs deep technical reviews of the documentation to identify gaps as part of the I&RP drafting.
• Completion of Assigned Deliverables: The I&RP specifies deliverables and an associated timeline, allocating deliverables to available resources, including your internal staff and the FDL. The FDL takes the lead on completing all assigned deliverables with you. Any deliverable that involves technical execution of compliance procedures for specific technical requirements requires your written authorization, and the FDL supervises an assigned engineer to complete it.
• Strategic Advising and Technical Leadership: Provide technical leadership and guidance for the overall strategy and technical work required for accurate NERC documentation necessary for new generation projects.
• NERC GO/GOP Registration Support: Support you during the Generator Owner and Generator Operator (GO/GOP) registration process with the applicable Regional Entity and NERC. This support can include documentation compilation, completing Regional Entity forms and documentation, and attending meetings and calls with Regional Entity and NERC representatives.
• Anticipating Effective Date of New Standards: By anticipating the effective date of new standards, we achieve better long-term cost savings by allocating resources optimally, which is included in the I&RP. As new standards become effective, we evaluate with you the optimal approach to execution of compliance procedures with respect to each. This typically entails a combination of internal and third-party resources.

Operating Plants

• Compliance Program Management: Provide support to maintain and enhance your NERC compliance program documentation and develop a compliance schedule that includes standard deadlines, evidence collection activities, and reporting tasks. We perform a comprehensive review of all existing compliance documentation against all applicable NERC Reliability Standard requirements and highlight any deficiencies and areas of concern in the I&RP. We work to address the identified deficiencies and areas of concern with your teams, subject to resource allocation and prioritization. As new or revised applicable standards are introduced, we evaluate their impact and help develop implementation plans for you as needed.
• Initial Internal Control Evaluation and Periodic Self-Assessments: Perform an initial internal controls evaluation and periodic self-assessments to ensure that key compliance areas are functioning effectively. Any potential non-conformities are documented and areas of concern are brought to the attention of your leadership team.
• Compliance Documentation & Evidence Retention: Review, update, and maintain compliance documentation such as policies, procedures, logs, and records. We coordinate the collection and organization of evidence with your teams to demonstrate compliance with applicable standards. All documentation is maintained using effective document control practices to ensure audit readiness in the GridStrong Dashboard.
• Staff Training (as needed and as required): Provide training annually for facility staff whose roles involve NERC compliance responsibilities, with refresher training delivered as needed to address program updates or regulatory changes. Training completion is documented and retained.
• Identify Potential or Actual Compliance Violations: Inform you of any potential or actual compliance violations and provide available documentation we have compiled and identified.
• Regulatory Developments and Updates: Actively track regulatory developments, alerts, and bulletins from NERC and the Regional Entity. Relevant information is summarized and communicated to your leadership team and the facility staff as needed. We also support any required compliance-related communications or formal reporting.
• Subject Matter Expertise: Provide general subject matter expertise on compliance impacts of the facility as equipment, controls, and personnel changes occur.