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Risk to the Grid from non-NERC Registered Control Centers

The shifting landscape of the North American Bulk Electric System (BES) towards renewable resources has provided ample opportunities to redefine how power is generated and how that generation is managed. In the traditional model, a power plant was operated by a staff of trained professionals on site. Full automation was not economically feasible. It is too challenging to automate every valve, switch and breaker, and install enough monitoring to allow remote operations. All that changes when talking about wind and PV facilities. Many are routinely unmanned and operated remotely, with technicians assigned for troubleshooting, maintenance, and the rare times when local operations are required. The cost savings achieved by centralizing the control of renewables to a control center is significant. Large entities can monitor and control gigawatts of power from thousands of wind turbines / PV panels at multiple generation facilities spanning the continent with a handful of personnel. With renewables, the ratio of operators per MW drops significantly when compared to conventional generation. These massive control centers are subject to the NERC CIP standards for cyber-security and are routinely monitored and audited by NERC’s Regional Entities (REs).


Some power generation companies utilize their Original Equipment Manufacturer (OEM) to monitor and control their turbines and PV facilities. In some instances, this control is turned over to the OEM outside of normal business hours, and in other cases the owner uses only OEM monitoring and control. Unfortunately, these OEM manufacturers and their Remote Operations Control Centers are not NERC registered, and thus, NERC and the REs have no ability to monitor or audit the OEM’s cyber security stance. Having some entities that are operating portions of the BES with no monitoring or auditing from NERC and the REs poses an unknown level of risk to the reliable operation of the BES. As an example, one OEM’s website states that they have four of these control centers worldwide associated with more than 15,000 global renewable assets. How many are part of the North American BES? Operating even a single BES asset is cause for NERC registration.

Clearly, these OEMs are operators of the BES. They should be registered as such.

Do you agree or disagree?

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