By Stefano Schnitger, NERC Reliability Specialist
In its most basic sense, Periodic Data Submittals are requests from NERC for information. This information may be operational data, models, studies, analyses, procedures, documents, or other forms of information. The purpose of these mandatory requests is for the registered entity (bulk power system owners, operators, and users) to prove compliance with the NERC Reliability Standards.
NERC typically relies on the Regional Entities to enforce the NERC Reliability Standards with registered entities. The Regional Entities are responsible for monitoring compliance of the registered entities within their regional boundaries, assuring mitigation of all violations of approved Reliability Standards and assessing penalties and sanctions for failure to comply.
Regional Entities Map
The Periodic Data Submittals are collected by the Regional Entities on a periodic or as-needed basis. When requested, registered entities shall provide Periodic Data Submittals in accordance with the NERC published ERO Enterprise Periodic Data Submittal Monitoring Schedule. This schedule is published by NERC annually and is linked here: 2025 ERO Enterprise Periodic Data Submittal Schedule. The schedule provides registered entities with a consistent approach that eliminates any regional schedule variations and is used throughout the ERO Enterprise (NERC and the six Regional Entities). As the need arises, the Regional Entities will work with each registered entity to extend any reporting deadlines while ensuring reporting as close to the schedule as possible.
With few exceptions, most all scheduled requests for Periodic Data Submittals are created, transmitted, and posted via the ERO Align system. Registered entities must also submit responses to their requests in Align. Registered entities will answer a set of qualifying questions for each data submittal. Based on the responses, additional data submittal forms may be provided for the entities to complete. If a registered entity identifies the need to upload information or documents related to a data request, they must upload the applicable documents through the ERO Secure Evidence Locker (SEL). Training and instructional videos for using the Periodic Data Submittal module in Align can be found in the Align PDS User Guide.
There are two types of Periodic Data Submittals that a registered entity can receive: Periodic Data Submittals and Event-Driven Periodic Data Submittals.
Periodic Data Submittals
Periodic Data Submittals are annual or quarterly requests for data or information for Reliability Standards that require them. They typically require specific data or information sets for a reporting period and include due dates as specified in a Reliability Standard and/or Requirement. Two Reliability Standards that commonly fall into this category for registered entities are FAC-003 and PRC-023 R5. Registered entities applicable to the FAC-003 Reliability Standard must provide data submittals quarterly. Registered entities applicable to the PRC-023 R5 Reliability Standard must provide data submittals annually.
For registered entities who do not own facilities that are applicable to the Reliability Standard of the Periodic Data Submittal request, an attestation may need to be provided. Align is commonly utilized to provide these attestations. Registered entities that provide attestations will not receive data submittal requests for these Reliability Standards and Requirements. However, if conditions change that impact the registered entity’s applicability, it is expectedthat the registered entity will notify the Regional Entity of the change.
Event-Driven Periodic Data Submittals
Event-Driven Periodic Data Submittals are also data submittals that must be provided to the Regional Entity. However, Event-Driven Periodic Data Submittals are less common than Periodic Data Submittals. Event-Driven Periodic Data Submittals are specified in the Standard Requirements and are typically based on the date of occurrence of specific events. Most event-driven data submittals are created by the registered entity in Align using an Event-Driven Periodic Data Submittal template. The submission of these in Align to the Regional Entities provides timely reporting of data required due to the occurrence of specific events. Three common Event-Driven Data Submittal Forms in Align available to the registered entities for submission are PRC-002 R12, PRC-023 R6, and TPL-007. The EOP-004 Reliability Standard is another standard that commonly falls into the Event-Driven Periodic Data Submittal category. This standard is reported to the NERC System Awareness team via the protocols described in attachment 1 of EOP-004.