FERC

FERC Issues Final Rule Approving BAL-001-2 Standard - April 16 - FERC issued a final rule approving reliability standard BAL-001-2, which addresses Real Power Balancing Control Performance and four new definitions.  The new standard is designed ensure that applicable entities maintain system frequency within narrow bounds around a scheduled value.  The standard is intended to improve reliability by adding a frequency component to the measurement of a Balancing Authority's Area Control Error.  The approved standard becomes effective July 1, 2016.

FERC Accepts Two COM Standards - April 16 - FERC issued Order No. 808, accepting two proposed NERC communications standards.  Standard COM-001-2 establishes communications requirements which functional entities must have in place and maintain; FERC largely accepted this standard as proposed, but required an additional filing addressing internal communications.  Standard COM-002-4 requires applicable entities to develop communications protocols meeting certain requirements (including three-part communication when issuing operating instructions), sets out communications training requirements, and establishes a flexible enforcement approach for non-emergency violations and a mandatory enforcement system for violations of the standard during emergency conditions.  Standard COM-001-2 will be effective on October 1, 2015, and standard COM-002-4 will be effective on July 1, 2016.

FERC Proposes to Approve Reliability Standard PRC-002-2 - April 16 - FERC issued a Notice of Proposed Rulemaking (NOPR) proposing to approve Reliability Standard PRC-002-2 (Disturbance Monitoring and Reporting Requirements).  The proposed standard, which consolidates the requirements of unapproved Reliability Standard PRC-002-1 and currently-effective Reliability Standard PRC-018-1, would require the availability of adequate time-synchronized data for post-disturbance analysis.  Comments on the NOPR are due June 22.  

FERC Issues NOPR on PRC-005-4 Standard - April 16 - FERC proposed to approve Reliability Standard PRC-005-4 (Protection System, Automatic Reclosing and Sudden Pressure Relaying Maintenance), which would expand the applicability of Reliability Standard PRC-005-3 to include “those sudden pressure relays that NERC has identified as having a potential effect on the reliable operation of the Bulk-Power system.” Comments on the proposed rule are due by June 22.

FERC Announces Bulk Power System Technical Conference - April 9 - FERC announced that it will hold a technical conference on the reliability of the bulk power system in Washington, DC on June 4, 2015.  The agenda will be announced closer to the conference date, but registration is now open for in-person and web attendees.

NERC        

NERC Releases Report Identifying Reliability Impacts of Clean Power Plan - April 21 - NERC released its Phase 1 report assessing potential reliability impacts of EPA's proposed Clean Power Plan, which would regulate carbon dioxide emissions from existing fossil-fuel generators. The report includes a sensitivity analysis to evaluate resource adequacy and compliance timelines in light of a range of gas prices and potential single- or multi-state compliance plans, as well as an analysis of transmission and gas pipeline adequacy and a review of existing studies.  The report indicates that the infrastructure improvements necessary to support the Clean Power Plan will require longer compliance and implementation plans, and recommends that EPA include a reliability assurance mechanism in the final rule (anticipated in summer 2015).  Once the rule is finalized, NERC will conduct Phase II analysis, and anticipates a report in 2016.

NERC Issues Statement in Response to FERC Orders Approving Reliability Standards and Issuing NOPRs - April 16 - NERC posted on its website a statement of approval of FERC's orders adopting three reliability standards and issuing two Notices of Proposed Rulemaking (NOPR).  In its statement, NERC indicates that it supports FERC's decisions and emphasized the need for the Communications and Resource and Demand Balancing standards approved by FERC.

NERC Submits Motion for 60-Day Extension on ROP Revisions - April 13 - NERC requested a 60-day extension from FERC to comply with the Commission’s request for revisions to the NERC Rules of Procedure (ROP).  The revisions are intended to implement NERC’s Risk-Based Registration (RBR) initiative.  If the motion is granted, NERC would submit its compliance filing on or before July 17.

NERC Proposes Revisions to Rules of Procedure To Implement Risk-Based Registration and Reliability Assurance Initiatives - In response to FERC orders approving NERC's Risk-Based Registration (RBR) Initiative and Reliability Assurance Initiative (RAI), NERC has posted proposed revisions to its Rules of Procedure.  Comments on the proposed RBR changes are due May 28 and comments on the proposed RAI changes are due May 21.

Cybersecurity and Grid Security

ICS-CERT Releases 2014 Annual Report - The Department of Homeland Security's Industrial Control Systems Cyber Emergency Response Team (ICS-CERT) released its 2014 Year in Review report.  The report states that incidents reported at energy facilities were a higher proportion of overall incidents than any other critical infrastructure sector, totaling 32% of all identified cyber incidents.  The report also discusses on-site inspection programs and ongoing DHS efforts to improve cyber security at critical infrastructure facilities.

Congress

Cybersecurity Legislation Committee Report Filed - A report from the Senate Committee on Intelligence was filed for the Cybersecurity Information Sharing Act of 2015.  The legislation would create additional incentives to increase sharing of cybersecurity threat information and facilitate voluntary cooperation between private companies and the government in sharing cyber threat indicators.

Cybersecurity Protection Advancement Act Advances Through Committee - April 21 - The National Cybersecurity Protection Advancement Act of 2015 (H.R. 1731), introduced by Rep. Michael McCaul (R-TX), will be considered by the House Rules Committee.  The bill would amend the Homeland Security Act of 2002 to increase cooperative information sharing regarding cybersecurity risks while also attempting to address privacy concerns. 

Regional Developments

ReliabilityFirst Posts Annual Report - ReliabilityFirst posted its Annual Report for Fiscal Year 2014.  The report describes RFC’s implementation of the Reliability Assurance Initiative, implementation of an RFC Entity Risk Management Program; RFC’s corporate reorganization, including the creation of three new departments – Entity Development, Risk Analysis & Mitigation, and Standards and Services; the activities of each of the three new departments; and compliance and enforcement activities.

The Van Ness Feldman Electric Reliability Update is published by Andrew Art, Malcolm McLellan and Gabe Tabak, with assistance from Chris Zentz, Ilan Gutherz, and Van Smith. 

Van Ness Feldman counsels, 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.

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