Regulator-side compliance for the Bulk Electric System

The auditor's questions, answered before the auditor asks them.

Energy Compliance, Inc. is an independent advisory firm for organizations connected to the North American Bulk Electric System. Every engagement is led personally by a practitioner who has run control rooms, audited registered entities from inside the regulator's process, and supported the development of violation notifications and settlements in FERC-directed enforcement actions.

Rob Smith

Founder & Principal

Reliability Coordinator, Transmission Operator, and Power System Operator across RTO/ISO and utility control centers
Senior Compliance O&P Auditor, Western Electricity Coordinating Council — NERC Compliance Monitoring and Enforcement Program
Regulatory reliability audit of the Oman Electric Transmission Company, on behalf of the Authority for Electricity Regulation
Assistant Professor, Energy Degree Programs, Bismarck State College

EDUCATION

MBA, Energy Management — University of Mary
MSL, Compliance Law — Fordham Law University
BAS, Energy Management — Bismarck State College
BAS, Mechanical Engineering, Metallurgy minor — University of Florida
BAS, Criminology — St. Petersburg College
AAS, Power Plant Technology — Bismarck State College
AAS, Electrical Transmission System Technology — Bismarck State College

Where we engage

Compliance is a lifecycle, not an event. EC works across all of it — and the earlier the engagement, the smaller the eventual problem.

STAGE 01

Registration

Applicability analysis, function registration, and the IBR registration initiative. Knowing which standards actually apply to you.

STAGE 02

Program

Program design, governance assessment, and controls tied to standards, requirements, evidence, and responsible roles.

STAGE 03

Evidence

Monthly evidence production and RSAW narrative development — written to be read by an auditor, not filed in a binder.

STAGE 04

Audit

Audit preparation and regulator-perspective program review. The Region's judgment applied before the Region applies it.

STAGE 05

Enforcement

Self-Report and Self-Log development, mitigation planning, Notice of Penalty response and settlement posture.

Who we serve

Registered entities and the people who run their compliance programs — renewable developers, data centers, utilities, and large loads.

Generation

Generator Owners and Generator Operators, including inverter-based resources navigating registration and the technical record behind it.

GOGOPIBR

Transmission

Transmission Owners and Transmission Operators — facility ratings, protection system performance, and the operating record.

TOTOP

Coordination & Distribution

Reliability Coordinators, Balancing Authorities, and Distribution Providers operating under multi-region obligations.

RCBADP

How we work

One senior practitioner, regulator-side

The senior is in the room. Five-person consulting teams where the experienced name appears on the proposal and never on the work is not our model.

Outcomes, not billable hours

Deliverables built to be executed and defended — not structured to manufacture activity.

Automate what should be automated

Where automation can replace manual evidence work, we build it. Where senior judgment is required, we apply it.

Audit-defensible by default

Every deliverable is structured for the auditor's question rather than the consultant's binder. Every assertion ties to evidence.

Compliance Services

Program support, audit and enforcement defense, and the operational and engineering alignment that has to stand behind both.

NERC Compliance Program Support

The standing program work, built so it holds up when it's examined.

Reliability and compliance advisory
Program design and improvement
Governance and program assessments
Registration and applicability analysis
Monthly evidence production
RSAW narrative development

Audit & Enforcement Support

Regulator-side judgment applied to the program before the Region applies it to the entity. Support is non-advocacy.

Audit preparation
Regulator-perspective program reviews
Notice of Penalty response and settlement posture
Mitigation planning
Self-Report and Self-Log development

Operational & Engineering Alignment

Grounded in real control-room and engineering experience — the technical record that stands behind the narrative.

Facility ratings — FAC family
Protection and misoperations — PRC family
Model validation — MOD-025, MOD-026, MOD-027, MOD-032, MOD-033
IBR registration, model and dynamic-data submittal coordination
Ride-through and protection coordination review — PRC-019, PRC-024

Education & Executive Briefings

Training grounded in what auditors actually want to see, and where the common evidence gaps are.

The published EC-WP whitepaper library
Custom NERC and operations training
Executive briefings for boards, plant managers, and site operations personnel

Regulatory coverage

Scoped to the entity's role, function, and bulk system impact.

Domain	Coverage
NERC — Operations & Planning	PRC, MOD, VAR, FAC, COM, EOP, PER families, and the TPL planning standards
NERC — CIP	CIP-002 through CIP-014, scoped to BES Cyber System impact rating
IBR	Obligations arising under the NERC inverter-based resource registration initiative
Regional Entities	Texas RE, WECC, MRO, ReliabilityFirst, SERC, NPCC
RTOs / ISOs	ERCOT, CAISO, MISO, PJM, SPP, NYISO, ISO-NE — resource and market registration, protocol and tariff obligations
State	Texas PUCT 16 TAC Chapter 25 reporting and the SB3 weatherization regime, with equivalent requirements in each market

Legal Services

Coverage from regulatory compliance review through formal legal opinion, coordinated under one program rather than handed between firms.

Regulatory & contractual compliance review

Delivered by EC. Reading a standard, an order, and a contract the way each is actually enforced — where the obligation attaches, what satisfies it, and what the record has to show.

Formal legal opinions and privileged work

Delivered through EC's legal arm. Where a matter requires attorney-client privilege or a formal written opinion, it is handled inside the same engagement.

Enforcement representation

Support through Notice of Penalty proceedings, settlement discussions, and the record that accompanies them — informed by having worked the regulator's side of those files.

Filings and regulatory correspondence

Regulatory filings, responses to data requests, and correspondence with Regional Entities and state commissions.

Why it sits with the compliance work

A legal opinion that doesn't understand the evidence record is an opinion about a document. A compliance program that hasn't been read by someone who knows how enforcement actually proceeds is a program that has never been tested. EC runs both under one engagement so neither is guessing about the other.

Whitepapers

The EC-WP library — more than sixty professional references written for practitioners, covering the standards families, evidence expectations, and the gaps that turn up most often in audit.

Request the library index

The full EC-WP catalog is available on request, along with any individual title. Tell us the standard family or the problem you're working on and we'll point you to what's relevant.

Representative topics

PRC

Protection system performance and misoperation analysis

What the record has to show after an operation, and where misoperation reporting most often falls short.

MOD

Model validation and the dynamic-data record

MOD-025 through MOD-033 — verification, submittal, and the evidence that supports each.

FAC

Facility ratings and the methodology behind them

Rating methodology documentation, the most-limiting-element record, and field verification.

CIP

BES Cyber System categorization and scoping

Impact rating, the asset list, and why scoping errors propagate through every downstream CIP requirement.

IBR

Inverter-based resource registration

The registration initiative, what it obligates, and the technical record a new registrant needs to assemble.

CMEP

Self-Reports, mitigation, and settlement posture

When to self-report, what a credible mitigation plan contains, and how the Region reads both.

About

Energy Compliance, Inc. was built to deliver senior regulator-side compliance authority without the layered staffing and billable-hour overhead of larger firms.

Thirty years, every side of the system

The first major chapter was control-room operations — Reliability Coordinator, Transmission Operator, and Power System Operator across RTO/ISO and utility control-center environments. That experience is why a Reliability Standard reads two ways at once here: what the requirement says, and what the asset is actually doing.

The second was regulator-side compliance. Senior compliance auditor and subject matter expert for NERC Reliability Standards. Audited grid facilities. Evaluated mitigation adequacy. Participated in risk-based oversight of utility mitigation activities, and supported the development of violation notifications and settlements as part of FERC-directed enforcement actions — from inside the regulator's process.

Overseas, a regulatory audit in the Sultanate of Oman conducted against the Sultanate's Sector Law and Grid Code. That engagement is where verify-before-voice became the operating habit that governs every EC deliverable today.

Credentials

MBA, specializing in Energy Management — University of Mary
Master of Studies in Law (MSL), Compliance Law — Fordham Law University
Bachelor of Applied Science, Energy Management — Bismarck State College
Bachelor of Applied Science, Mechanical Engineering, minor in Metallurgy — University of Florida
Bachelor of Applied Science, Criminology — St. Petersburg College (State Law Enforcement Certification)
Associate of Applied Science, Power Plant Technology — Bismarck State College
Associate of Applied Science, Electrical Transmission System Technology — Bismarck State College

Engineering reads the asset. Energy Management reads the market and the program. Law reads the standard, the order, and the record. Certifications: NERC Lead Auditor training; previously NERC-certified at the Reliability Coordinator level; 1st Class A Boiler Engineer License, Minnesota.

Frequently asked

Do you work with entities that aren't registered yet?

Yes, and that's often the best time to engage. Applicability and registration analysis determines which standards attach to you at all. Getting that wrong in either direction — registering for functions you don't perform, or missing ones you do — creates years of avoidable work.

What does "regulator-side" actually mean here?

It means the work is informed by having audited registered entities from inside the regulator's process, evaluated mitigation adequacy, and supported the development of violation notifications and settlements in FERC-directed enforcement actions. The practical difference is knowing what an auditor does with a document after you hand it over.

Will I be working with senior people or a delivery team?

You work with the principal. That's the model, not a sales promise — engagements are scoped so the senior practitioner is the one doing the work rather than reviewing someone else's.

Can you support us during an active audit or enforcement matter?

Yes. Audit preparation, regulator-perspective program review, mitigation planning, Self-Report and Self-Log development, and Notice of Penalty response and settlement posture are all core work. Support is non-advocacy.

Do you handle the engineering, or just the paperwork?

Both, and they aren't separable. Facility ratings, protection and misoperation analysis, and model validation produce the technical record that a narrative has to be consistent with. A narrative that isn't grounded in the engineering doesn't survive contact with an auditor.

Which regions and markets do you cover?

Texas RE, WECC, MRO, ReliabilityFirst, SERC, and NPCC on the Regional Entity side; ERCOT, CAISO, MISO, PJM, SPP, NYISO, and ISO-NE on the market side; plus Texas PUCT requirements under 16 TAC Chapter 25 and the SB3 weatherization regime, with equivalent state requirements in other markets.

How do engagements typically start?

Usually with a scoping conversation and a program baseline — establishing what applies, what evidence exists today, and where the gaps are. That baseline determines whether the right engagement is ongoing program support, a defined project, or a single deliverable.

Contact

Tell us the entity, the function, and what's in front of you. If there's a deadline attached, say so — it changes the sequencing.

Direct

Rob Smith — Founder & Principal
763.438.4427
rsmith@complianceforenergy.com
info@complianceforenergy.com
Bloomington, Minnesota

What's useful in a first message

Your registered functions — GO, GOP, TO, TOP, RC, BA, DP
Region and market
The standard families in question, if you know them
Whether there's an active audit, Self-Report, or enforcement matter
Any date that's already fixed