NERC

NERC Requests FERC Approval of Proposed Dispersed Generation Resources Reliability Standards -February 6 - NERC submitted a petition for approval of modifications to multiple versions of Reliability Standards PRC-004 and PRC-005, along with Reliability Standard VAR-002-4, to improve reliability of dispersed power producing resources such as wind and solar.  The proposed revisions tailor the existing Reliability Standard requirements to apply at the aggregate facility level rather than at the individual generating unit in cases where the “unavailability or failure of any one individual generating resource may have a negligible impact on the aggregated capability of the facility, and individual resources have limited effect on the reliability of the Bulk-Power System.”  

NERC Submits Petition for Approval of PRC-010-1 for Undervoltage Load Shedding - Febuary 6 - NERC filed a petition for approval with FERC for PRC-010-1, which deals with undervoltage load shedding.  As part of the filing, NERC also requests retirement of several, existing reliability standards dealing with undervoltage load shedding, including PRC-010-0, PRC-020-1, PRC-021-1, and PRC-022-1.  The proposed PRC-010-1 standard is a single, comprehensive standard aimed at addressing the same principles contained in the four standards proposed for retirement.  Also included in NERC's filing is a summary of the final 2003 Blackout Report and NERC's actions taken in response to the recommendations contained in that report.

NERC Proposes to Revise "Remedial Action Scheme" Definition - February 3 - NERC submitted to FERC a petition for approval of revisions to the definition of "Remedial Action Scheme" in the NERC glossary.  The petition also seeks to replace usage of the term "Special Protection System" in certain reliability standards with "Remedial Action Scheme."  The two terms are currently used interchangeably.

NERC Submits BES Cyber Asset Survey Results - February 3 - NERC filed with FERC the results of a survey regarding the scope of assets subject to the term "Bulk Electric System (BES) Cyber Asset."  The survey results highlight the approaches used by registered entities to evaluate systems potentially subject to the definition, indicate the areas of the definition which need further clarification, and include feedback from regional entities.

NERC Submits Errata to Petition for Approval of Proposed Geomagnetic Disturbance Standard -February 2 - NERC submitted an errata to address an omission of information in its petition for approval of proposed Reliability Standard TPL-007-1. 

January Penalty Activity - January 30 - NERC filed with FERC a spreadsheet notice of penalty resolving 17 violations of 9 reliability standards.

NERC Files Answer Regarding Risk-Based Registration - January - 26 NERC filed with FERC a limited answer to comments and regarding proposed changes to the NERC Rules of Procedure to implement the Risk-Based Registration Initiative, which if adopted would apply different standards to different entities based upon the potential risk to the bulk electric system.  In its answer, NERC argues that it is appropriate to apply the proposed changes via resource registration, rather than through standards development; that specific amendments particular to obligations of underfrequency load shedding distribution providers are appropriate; and emphasizes that factors used to determine the materiality of an impact to the bulk electrical system.

NERC Submits Comments in Response to FERC NOPR Proposing to Approve Proposed BAL-001-2 Standard - January 26 - In response to concerns raised by FERC in its Notice of Proposed Rulemaking to approve proposed reliability standard BAL-001-2, NERC submitted comments.  Specifically, FERC noted potential concerns raised by commenters regarding the possibility of significant amounts of unscheduled flows, which could cause large ACE swings, and the potential for significant increases in inadvertent interchange.  FERC directed NERC to submit an information filing following the implementation of the proposed reliability standard to address these issues, which in its comments, NERC opposes.

Cybersecurity and Grid Security

DOE IG Report Finds Severe Deficiencies in FERC Information Security - January 30 - The Inspector General (IG) of the Department of Energy (DOE) issued a report entitled "Review of Controls for Protecting Nonpublic Information at the Federal Energy Regulatory Commission,"  which found that FERC's "controls, processes and procedures for protecting nonpublic information were severely lacking."  The report, which focused on the release of certain nonpublic information about critical substations in the nation's grid, found that such information was shared with industry and Federal officials without FERC first subjecting the information to a formal classification review.

ISO-NE Reports Hacking Threat to DOE - January - ISO-NE reported a December 30, 2014 verbal threat of a potential cyber attack to DOE's Office of Electricity Delivery and Energy Reliability.  The FBI is investigating the event, which did not involve an actual cyberattack.

Regional Developments

Peak Reliability Approves 5-Year Strategic Plan - January 28 - Peak Reliability's Board of Directors approved its 5-Year Strategic Plan.  The strategic plan includes four pillars through which Peak Reliability seeks to implement its vision, mission, and purpose.  These pillars include: 1) achieving interconnection-wide operational excellence, 2) providing stakeholder value, 3) engaging with employees, and 4) maintaining financial stability.  The strategic plan will guide Peak Reliability over the next five years, with a specific focus on 2015-2017. 

SPP Releases 2014 Year-End Report - January 26 - Southwest Power Pool released its year-end report for 2014, which includes an examination of its compliance monitoring and enforcement, an overview of its 2014 goals and achieved performance, and a discussion of 2015 goals.  According to the report, SPP RE met or exceeded 15 of its 16 performance goals in 2014.  

Other Developments

DOE Issues FY 2016 Budget Justification - February 2 - DOE issued its FY 2016 Department of Energy's Budget Request to Congress.  The justification calls for a 9% increase over DOE's FY 2015 enacted budget, including $270 million for the Office of Electricity Delivery and Energy Reliability (an 84% increase over FY 2015 enacted levels), with increases requested for smart grid research, grid security and resiliency, and reliability.

Van Ness Feldman counsels, advises and trains a wide range of clients on reliability matters.  Please email usor call us at 202.298.1817 or 206.829.1814 for additional information.