2025 Positive Observations and Best Practices

In 2025, several registered entities took steps that surpassed standard practices, prompting positive observations. For many Standards, registered entities have utilized governance, risk, and compliance (GRC) tools to support compliance objectives, ensure proper retention of evidence, assess internal controls, track regulatory requirements and deadlines, track revisions of procedures, and ensure current procedural process documents were communicated with relevant personnel immediately upon approval. Texas RE noted some entities adopted upcoming Reliability Standards prior to the effective date. Many entities also took initiative and reached out to Texas RE outside of audit engagements to gain clarification on standard requirements. Enhanced internal controls with escalations and notifications were utilized as a best practice across the standard requirements.

Extreme weather protection and compliance with EOP-012 was a focus throughout 2025. Entities illustrated best practices through detailed processes and procedures (R4). This included peer reviewed checklists (quality assurance (QA) and quality control (QC)), and clear roles and responsibilities located within plans. Integrating practical exercises with classroom learning for R5 helped personnel better master the checklists and equipment necessary to reduce cold weather response times.

Cybersecurity Standards were also emphasized in 2025, with modifications and new Standards focused on grid security. CIP-014-3 and CIP-006-6 include physical security/physical security of Bulk Electric System (BES) Cyber Systems. Examples of best practices included layered physical security controls, performing internal walkdowns to confirm controls were in place that comprised of fencing, locked doors, and security lighting. Taking additional steps such as erecting temporary fencing during construction was another observation. For Control Centers, best practices included having defense in depth with a guard on duty, signing in with a guard post, and then implementing a man trap before gaining access to the Physical Security Perimeter (PSP).

Texas RE appreciates the steps taken to improve processes and procedures as many of the best practices discussed help ensure the reliability and security of the electric grid.