FERC

FERC Approves Revisions to EOP and PRC Reliability Standards - November 19 - FERC approved Reliability Standards EOP-011-1 (Emergency Operations) and PRC-010-1 (Undervoltage Load Shedding), and approved NERC’s revised definition of the term “Remedial Action Scheme”.  The proposed Reliability Standards consolidate the requirements of currently effective EOP and PRC standards.

FERC Approves Revisions to TOP and IRO Reliability Standards - November 19 - FERC published a final rule approving revisions to the Transmission Operations (TOP) and Interconnection Reliability Operations and Coordination (ERO) Reliability Standards.  According the ruling, the revised standards eliminate ambiguities and duplication in currently-effective TOP requirements by incorporating requirements from those eight TOP standards in three comprehensive Reliability Standards.

FERC Issues Letter Order on FFT Program - November 13 - FERC issued a letter order to accept NERC’s September 18, 2015 annual report on the Find, Fix, Track and Report (FFT) program.  NERC’s uncontested filing of the FFT report is hereby accepted pursuant to the authority delegated to the Director, Office of Electric Reliability, and is effective as of the date of this Order.

FERC Issues Letter Order Approving Errata to Reliability Standards - November 13 - FERC released a letter order approving NERC’s uncontested filing seeking approval of errata to Reliability Standards BAL-003-1 (Frequency Response Bias Setting), COM-001-2 (Communications) and VAR-001-4 (Voltage and Reactive Control), in addition to the implementation plan of Reliability Standard PRC-004-4 (Protection System Misoperation Identification and Correction).  The erratas correct inadvertent numbering errors and adds additional words.  The implementation plan for Reliability Standard PRC-004-4 is modified to retire a previous version of the standard upon implementation.

NERC

NERC Requests Expedited Action on Reliability Standard - November 13 - NERC requested that FERC defer implementation of Reliability Standards PRC-005-3, PRC-005-3(i) and PRC-005-4 until it issues a final order on proposed Reliability Standard PRC-005-6, for which it requested expedited action.  The new Reliability Standard “provides for the development of comprehensive Protection System Maintenance programs” that would apply to all previously approved versions of the PRC-005 Reliability Standards and would remove uncertainty for owners of dispersed generation resources. NERC requested that FERC issue an order on its motion by December 14.

NERC Petition of Approval of Proposed Reliability Standard MOD-031-2 - November 13 - NERC petitioned FERC for approval of Reliability Standard MOD-031-2 Demand Energy Data.  The proposed Reliability Standard makes modifications to Reliability Standard MOD-031-1, which provides authority for Bulk System planners and operators to collect data to support reliability assessments.  MOD-031-2 improves upon MOD-031-1 by clarifying the compliance obligations related to providing data to Regional Entities, and responding to a request for data subject to confidentiality restrictions.  NERC also requests approval of the associated Implementation Plan and the retirement of MOD-031-1.

NERC Submits Budgetary Compliance Filing - November 13 - NERC, pursuant to a January 16, 2013 FERC Order, submitted a compliance filing containing an unaudited report of its budget-to-actual variance information for the third quarter of 2015.  Through the end of the third quarter, NERC was $3.9 million under budget, but projects to be approximately $590,000 over budget at the end of the year due to the authorized use of reserves for various expenditures.

NERC Petition of Approval of Proposed Reliability Standard PRC-005-6 - November 13 - NERC petitioned FERC for the approval of Reliability Standard PRC-005-6 (Protection System, Automatic Reclosing, and Sudden Pressure Relaying Maintenance).  PRC-005-6 incorporates modifications made in PRC-005-5 that clarify the applicability of dispersed power producing resources.  The proposed standard also addresses FERC’s directive to “develop modifications to Reliability Standard PRC-005-3 to include supervisory devices associated with autoreclosing relay schemes to which the Reliability Standard applies.”

NERC Board Approves ERO Strategic Plan - November 5 - The NERC Board of Trustees approved the ERO Enterprise Strategic Plan 2016-2019 and 2016 ERO Enterprise and Corporate Metrics during their final meeting for 2015.  The Board also adopted four standard revisions, one new standard, and approved the new Standards Development Plan.

Cybersecurity and Grid Security

DOE Releases Audit Report on Cybersecurity Risk Management Framework - November 4 - DOE published an Audit Report on the nation’s transition to a continuous risk-based cybersecurity management.  The audit findings led to the recommendations that (1) DOE should develop and maintain cybersecurity procedures that are consistent with current Federal requirements and best practices and (2) develop effective oversight practices by ensuring that authorization processes are effective, ensuring that POA&M processes are effective, and establishing and communication risk tolerance levels for Department elements.   

The Van Ness Feldman Electric Reliability Update is published by Andrew Art, Malcolm McLellan with assistance from Ilan Gutherz, Van Smith, Gabe Tabak, Tyler Elliott, and Michael Weiner.  Van Ness Feldmancounsels, advises and trains a wide range of clients on reliability matters.  Please email us or call us at 202.298.1817 or 206.829.1814 for additional information.  Click here to sign up for the Reliability Update.  

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