Mastering the marathon

When the final report arrived in April, the tension that had quietly hummed through the hallways of Minnkota gave way to a deep breath of relief. Then came a well-earned celebration. The cooperative's employees achieved a successful North American Electric Reliability Corporation (NERC) review, earning zero compliance violations and two positive observations.

But this wasn’t just a victory in a single moment. It was the culmination of years of disciplined effort, a deeply rooted culture of compliance and a dedication to doing things the right way long before auditors ever step onsite.

“Audits are definitely more of a marathon than a sprint,” said Theresa Allard, Minnkota compliance manager. “The auditors are really looking for evidence of compliance throughout the audit period, which is about a three-year, backward-looking period. But in addition to that, they’re also looking for evidence that shows we will continue to be compliant and operate reliably and securely into the future.”

NERC, a not-for-profit regulatory authority, is charged with ensuring the reliability and security of the bulk power system across North America. Its audits, carried out through regional partners like the Midwest Reliability Organization (MRO), assess whether utilities are meeting more than 1,000 stringent federal reliability requirements.

Minnkota undergoes these rigorous reviews every three years. The comprehensive process is akin to a full-body scan of compliance health examining everything from cybersecurity and transmission planning to power plant operations. In addition to data requests and detailed documentation reviews, the audit is also a stage for Minnkota’s subject matter experts (SMEs) to demonstrate their knowledge and commitment.

“The compliance department is not solely responsible for meeting NERC compliance,” said Andy Fuhrman, compliance analyst III. “We have our team of 60-plus subject matter experts who put in a lot of time and effort to ensure that we remain compliant. On a day-to-day basis, it’s that crew that does the bulk of the compliance work. So, it really falls on a lot of other folks to be executing flawlessly all the time.”

Cold weather cred

Among the highlights of this year’s audit was a rarely given positive observation related to Minnkota’s efforts in cold weather preparedness – a focus since the 2021 Texas grid failure during Winter Storm Uri. Auditors specifically commended the cooperative’s methodology used to determine its Extreme Cold Weather Temperature (ECWT) calculation.

The task was perfect for Nikki Carson-Marquis, a compliance analyst with a background in atmospheric sciences, who wrote computer code to assess the large temperature data sets required under NERC’s standards.

“What made our ECWT calculation different is I prepared a Python script to objectively evaluate every single temperature based on logic,” said Carson-Marquis. “It was much faster and far less subjective than a manual review of over 53,000 data points in a spreadsheet.”

That technical expertise helped support the decades of cold-weather operational experience at the Milton R. Young Station, located in the heart of North Dakota’s challenging climate.

“The Young Station has half a century’s experience of successfully operating at a rural location and, arguably, in one of the most extreme climates in the continental U.S.,” said Carson-Marquis. “There aren’t many locations within the U.S. that often go from negative-30 degrees to 100-degree heat within six months.”

Minnkota also earned formal praise for the clarity and organization of its documentation, evidence, narratives and internal controls, which made it easier for auditors to navigate the complex and often technical material.

Always ready

Although the next NERC audit is not scheduled until 2028, Minnkota’s compliance team knows that reliability doesn’t rest. Standards evolve. The grid changes. Cyber threats grow more sophisticated. There’s no standing still.

Every action taken today will be scrutinized in the next audit.

“We know there are several areas where we have room for improvement,” Allard said. “And it’s not just about passing the audit. We want to continually encourage the compliance department and the SME teams to have strong processes and strong internal controls in place as we do our part to keep the lights on.”

MAIN IMAGE: (Left to right) Minnkota’s compliance team of Theresa Allard, Nikki Carson-Marquis and Andy Fuhrman played a pivotal role in the cooperative’s successful NERC audit in April. (Minnkota/Michael Hoeft)