Who are you? Who, who, who, who? (I really wanna know)
The song Pete Townshend penned 40 years ago (that’s right, I said it, 40 years) asks a question that is relevant to NERC CIP compliance today. The first step to determining if your organization is required to comply with the CIP standards is to determine if your organization is one of the functional entities listed section 4.1 of each of the Version 5 standards. This seems pretty straight forward. But not so fast. “Functional entity” is not defined in the Glossary of Terms Used in NERC Reliability Standards. And, while the standards refer to functional entities collectively as “responsible entities”, responsible entity is also not defined in the glossary. In fact, only two of the eight responsible entities listed in the standards are labeled as responsibly entities in the glossary (Balancing Authority and Interchange Authority) and there are entities labeled in the glossary as responsible entities that are not included in the in the list of responsible entities in section 4.1 of the standards (Planning Authority or Planning Coordinator and Load Serving Entity).
So we can use the glossary to define the functional entities, but we must rely on the standards themselves to tell us which functional entities are included in the list of responsible entities to which the standards apply. What follows is a list of functional entities found in sections 4.1.1 through 4.1.8 of each of the version 5 CIP standards (the list is the same in all of the cyber security standards, CIP-002-5.1, CIP-003-5, CIP-004-5.1, CIP-005-5, CIP-006-5, CIP-007-5, CIP-008-5, CIP-009-5 and CIP-010-1), and the definition for each entity from the Glossary of Terms Used in NERC Reliability Standards.
| Section | Functional Entity | Definition |
| 4.1.1 | Balancing Authority | The responsible entity that integrates resource plans ahead of time, maintains load-interchange-generation balance within a Balancing Authority Area, and supports Interconnection frequency in real time. |
| 4.1.2 | Distribution Provider | Provides and operates the “wires” between the transmission system and the end-use customer. For those end-use customers who are served at transmission voltages, the Transmission Owner also serves as the Distribution Provider. Thus, the Distribution Provider is not defined by a specific voltage, but rather as performing the Distribution function at any voltage. |
| 4.1.3 | Generator Operator | The entity that operates generating unit(s) and performs the functions of supplying energy and Interconnected Operations Services. |
| 4.1.4 | Generator Owner | Entity that owns and maintains generating units. |
| 4.1.5 | Interchange Coordinator or Interchange Authority | The responsible entity that authorizes implementation of valid and balanced Interchange Schedules between Balancing Authority Areas, and ensures communication of Interchange information for reliability assessment purposes. |
| 4.1.6 | Reliability Coordinator | The entity that is the highest level of authority who is responsible for the reliable operation of the Bulk Electric System, has the Wide Area view of the Bulk Electric System, and has the operating tools, processes and procedures, including the authority to prevent or mitigate emergency operating situations in both next-day analysis and real-time operations. The Reliability Coordinator has the purview that is broad enough to enable the calculation of Interconnection Reliability Operating Limits, which may be based on the operating parameters of transmission systems beyond any Transmission Operator’s vision. |
| 4.1.7 | Transmission Operator | The collection of Transmission assets over which the Transmission Operator is responsible for operating. |
| 4.1.8 | Transmission Owner | The entity that owns and maintains transmission facilities. |
The post Who Are You appeared first on Encari LLC.