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Electric Reliability Update - October 11, 2013

October 11, 2013


FERC Continues Operations During Shutdown September 30 – FERC has indicated that it has sufficient funding to remain open during the government shutdown, and continues with business as usual.  NERC has not been affected to date.  For more information, see VNF’s Shutdown Updates.

NERC Submits New Generator Relay Loadability Standard to FERC for Approval September 30 – NERC petitioned FERC for approval of a new “generator relay loadability” reliability standard, PRC-025-1, which was developed in response to a directive in FERC Order No. 733. According to NERC, the new standard is designed to reduce the risk of cascading outages by preventing generator tripping “when conditions do not pose a direct risk to the generator and associated equipment.”  NERC requests that FERC delay approving the new generator relay loadability standard until after NERC submits an updated version of NERC’s Transmission Relay Loadability Standard, PRC-023-3, in order to maintain consistency between the generator and transmission relay loadabilty standards.

Trade Associations File Comments Supporting Approval of Frequency Response StandardsSeptember 27 –  EEI, APPA, NRECA and EPSA and the  ISO/RTO Council filed comments generally supporting FERC’s rulemaking proposal to approve reliability standard BAL-003-1 (Frequency Response and Frequency Bias Setting), which was submitted for approval by NERC in March. NERCfiled comments supporting the proposal and offering certain clarifications.

NERC Annual Report on Use of Technical Feasibility Exceptions September 28 – NERC submitted its 2013 Annual Report on Wide-Area Analysis of Technical Feasibility Exceptions (TFEs), as required by FERC Order No. 706, which directed NERC to submit an annual analysis of the use of TFEs for certain critical infrastructure protection reliability standards, and their effects on BES reliability.

NERC Filings – Recent NERC filings at FERC include: (1) a status Report Informational Filing in Response to FERC's March 4, 2013 Order in EL13-22 (PacifiCorp complaint against WECC and LADWP); and (2) Sept. 30 and Oct. 1 Errata to Petition for Approval of CIP Version 5‚Äč.

NERC Penalties September 30 – NERC filed with FERC (1) five new Notices of Penalty (NOP) and (2) a spreadsheet NOP resolving 35 separate violations.


WECC Submits Governance Documents for New RC Company to FERC September 20 – As part of its plan to separate its compliance and enforcement functions from its Reliability Coordinator (RC) and Interchange Authority (IA) functions, WECC submitted the bylaws for Peak Reliability, the entity that will take over as RC for WECC; an Interchange Authority Agreement between WECC and Peak Reliability; and a Termination Agreement between NPCC and WECC concerning NPCC’s current compliance monitoring and enforcement responsibilities for WECC’s RC functions. On June 20, FERC conditionally granted WECC’s request to transfer its RC functions to Peak Reliabilty, subject to FERC’s review of the above documents. WECC’s request anticipates that Peak Reliability would assume RC functions for the Western Interconnection starting January 1, 2014.

WECC Interim Board Seeks Comment on Proposed Board Charter and Corporate Governance Guidelines for Peak Reliability Entity September 27 – The WECC Interim Board has posted drafts of the Board Charter and Corporate Governance Guidelines for the new RC company, Peak Reliability, which will take over RC responsibilities from WECC once approved by FERC (see story above). Comments on the documents are due by November 1.


DOE Funding for Pre-Commercial Synchrophasors  September 30 – The Department of Energy announced up to $9 million in funding for synchrophasor research and development.  The funds would support efforts to develop software allowing utilities to take full advantage of synchrophasors’ rapid response capabilities to improve grid reliability.  The application deadline is December 2, 2013. 

The Van Ness Feldman Electric Reliability Update is published by Andrew ArtMalcolm McLellan and Gabe Tabak, with assistance from Christopher ZentzThomas HuttonIlan Gutherz, and Van Smith.  Van Ness Feldman counsels, advises and trains a wide range of clients on reliability matters.  Please email us for additional information.

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