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Electric Reliability Update - June 25, 2015

June 25, 2015


FERC Proposes to Approve TOP/IRO Standards – June 24 – FERC issued a Notice of Proposed Rulemaking (NOPR) in which the Commission proposes to approve revisions to Transmission Operations (TOP) and Interconnection Reliability Operations and Coordination (IRO) Reliability Standards.  According to FERC, the revised standards will eliminate ambiguities in current TOP/IRO standards and clarify the responsibilities of all applicable entities.  The NOPR also states FERC’s view that NERC has adequately addressed all of the issues identified in FERC’s November 2013 NOPR remanding the previous standards, and seeks additional clarifying comments on several issues.  Comments on the NOPR are due by August 24, 2015.

FERC Proposes to Approve Revisions to EOP and PRC Standards – June 18 – FERC issued a Notice of Proposed Rulemaking proposing to approve Reliability Standards EOP-011-1 (Emergency Operations) and PRC-010-1 (Undervoltage Load Shedding).  The proposed Reliability Standards would consolidate, streamline and clarify the existing requirements of certain currently-effective Emergency Preparedness and Operations (EOP) and Protection and Control (PRC) standards. In the NOPR, FERC also proposes to approve NERC’s revised definition of the term “Remedial Action Scheme.” Comments on the NOPR are due August 24, 2015.

FERC Accepts Revisions to NERC Financial Reserve Policy – June 18 – FERC issued an order conditionally accepting proposed revisions to NERC's working capital and operating reserves policy.  The revised policy includes reserves for (1) future obligations, (2) system operator certification, (3) the Cybersecurity Risk Information Sharing Program (CRISP), and (4) operating contingencies.  A compliance filing is due 60 days after the order specifically limiting the extraordinary use of assessment stabilization reserve funds.


Two Standards to Become Effective July 1 – July 1 – On July 1, two new NERC standards will become effective.

  • MOD-32-1, Data for Power System Modeling and Analysis, establishes consistent modeling data requirements and reporting procedures for development of planning horizon cases necessary to support analysis of the reliability of the interconnected transmission system.
  • PRC-0006-NPCC-1, for Automatic Underfrequency Load Shedding (UFLS), provides a regional reliability standard that ensures the development of an effective automatic UFLS program in order to preserve the security and integrity of the bulk power system during declining system frequency events.

NERC Files Comments on PRC NOPR – June 22 – NERC filed comments in support of FERC's Notice of Proposed Rulemaking proposing to approve Reliability Standard PRC-002-2 (Disturbance Monitoring and Reporting Requirements).  

NERC Submits Comments Supporting FERC PRC Proposed Rule – June 19 – NERC submitted comments supporting FERC’s proposal to approve proposed Reliability Standard PRC-005-4 (Protection System, Automatic Reclosing, and Sudden Pressure Relaying Maintenance), along with a new definition of Sudden Pressure Relaying and four revised definitions.  Proposed Reliability Standard PRC-005-4 aims to improve upon the existing protection system maintenance program developed in PRC-005-2 and PRC-005-3.

NERC Budget Requests Accepted – June 15 – FERC accepted NERC’s uncontested February 18 filing to remove or revise certain components of its annual business plan and budget filings, in addition to revising annual budgeted to actual costs true-up filings.  Requests for rehearing by FERC must be filed within 30 days of the acceptance order.

Cybersecurity and Grid Security

DOE Inspector General Issues NNSA Audit Report – June 3 – The Inspector General (IG) of the Department of Energy (DOE) issued an audit report on the cybersecurity controls in the National Nuclear Security Administration (NNSA), which is responsible for management and security of the Nation's nuclear weapons inventory.  In the audit report, which focused on NNSA's information system at a key facility, the IG found that the NNSA's cybersecurity controls had not been adequately developed, documented, or implemented, and identified weaknesses related to the implementation of access controls and the development and implementation of effective database change management, configuration management, and continuous monitoring processes. 


Vegetation Management Bill Advances in Congress – June 11 – The Electricity Reliability and Forest Protection Act (H.R. 2358) was approved by the House Committee on Natural Resources during a Full Committee markup by a 22-15 vote.  The bill, introduced by Rep. Ryan Zinke (R-MT), aims to reform right-of-way practices on federal lands to protect utilities and their ratepayers from damages in the event of forest fires caused by inadequate vegetation management near power lines.  The bill is also intended to speed up decision-making by the government, which the bill’s sponsors argue would eliminate potentially costly fire hazards and provide greater electric reliability.  

Regional Developments

WECC Releases State of the Interconnection Report – June 15 - WECC released its 2015 State of the Interconnection Report.  The report covers outages, developments in transmission, generation, and load, and compliance efforts across the Western Interconnection. 

Peak Reliability Membership Approves Alternative Funding Agreement – June 10 – At Peak Reliability's Annual Meeting, Peak Reliability members approved funding agreement under which Balancing Authorities and Transmission Operators will fund Peak Reliability according to a net energy for load cost allocation basis. Under the funding agreement, Peak Reliability will no longer be funded under Section 215 of the Federal Power Act as of January 1, 2016.


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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