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Electric Reliability Update - August 14, 2015

August 14, 2015


FERC Issues Order on Grid Assurance Spare Equipment Service - August 7 – FERC issued an order approving a June 9 Grid Assurance LLC petition for declaratory order requesting certain declarations relating to a spare transmission equipment service that Grid Assurance intends to offer to transmission owners to support grid resiliency.  Specifically, FERC issued declarations that (1) contracting with Grid Assurance for access to spare critical transmission equipment is a permissible resiliency element of a physical security plan under Requirement 5 of Reliability Standard CIP-014-1, and (2) prior authorization under the Federal Power Act is not required for sales or purchases from Grid Assurance of spare transmission equipment that is not in service at the time it is transferred.

FERC Accepts NERC Supplemental Filing - August 6 - In a letter order, FERC accepted NERC’s report of comparisons of budgeted to actual costs for 2014 for NERC and its Regional Entities.

Coordination on Implementation of the Clean Power Plan - August 3 - FERC, EPA, and DOE issued a document describing the efforts being made between the three agencies to ensure continued electric reliability during the implementation of the Clean Power Plan (CPP), regulating carbon dioxide emissions from existing power plants.  The agencies will make reasonable efforts to monitor the development and implementation of state CPP compliance plans and ensure coordination where reliability issues arise.   See Van Ness Feldman’s alert on the final Clean Power Plan rule for more information.


NERC Answers Protests and Comments on Proposed  Revised Regional Delegation Agreements - August 10 – NERC filed an answer to a protest of the American Public Power Association and comments of several transmission owners and operators on NERC’s request for approval of revisions to the pro forma Regional Delegation Agreement (RDA) as well as the eight individual RDAs with the Regional Entities.  NERC requested that FERC deny the protest and approve the proposed revised pro forma RDA and the revised individual RDAs, to be effective January 1, 2016.

NERC Posts Revised Rules of Procedure – August 7 - NERC posted a revised version of its Rules of Procedure, which cover all NERC operations as the FERC-certified electric reliability organization (“ERO”).  NERC revised Section 317 of the Rules of Procedure relating to review of Reliability Standards, moving from reviews every five years to a “periodic” review.

NERC Issues Statement on Clean Power Plan Finalization - August 3 - NERC issued a statement on the Environmental Protection Agency’s Clean Power Plan rule (CPP), noting that the final rule reflected changes identified in two NERC special reliability assessments of the CPP. NERC is planning a third CPP assessment, expected by the second quarter of 2016.  

NERC Penalty Activity - July 30 - NERC filed with FERC a spreadsheet notice of penalty resolving 26 violations of 6 Reliability Standards.

NERC Submits Comments on Proposed TPL Reliability Standards - July 27 - NERC submitted comments supporting FERC’s proposal to approve Reliability Standard TPL-007-1 ((Transmission System Planned Performance for Geomagnetic Disturbance Events).  NERC’ s comments cover issues including the benchmark GMD event definition, transformer thermal impact assessment, installation of GMD monitoring devices, corrective action plan deadlines, minimization of load loss and curtailment, and the implementation plan.

Regional Developments

Peak Reliability Completes Key Funding Agreement - August 7 - Peak Reliability reached a major funding milestone under the Reliability Coordinator Funding Agreement by securing executed Agreements representing 90% of net energy for load in the US portion of the Western Interconnection.  Peak will now be funded under the Funding Agreement, and will notify FERC that it will not seek Section 215 funding for 2016.  

WECC Releases 2015 Operational Practices Survey Report - July 17 - The Western Electricity Coordinating Council (WECC) released a report detailing the survey responses from its 2015 Operational Practices Survey, in which it questioned registered entities regarding Next-Day Studies, Seasonal Studies, Situational Awareness, Protection System, and Other Questions.  WECC uses the Report to facilitate industry discussion and share operational best practices.


The Van Ness Feldman Electric Reliability Update is published by Andrew ArtMalcolm McLellan and Gabe Tabak, with assistance from 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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