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Electric Reliability Update - June 3, 2016

June 3, 2016


FERC Holds Reliability Technical Conference - June 1 - FERC held a technical conference to discuss policy issues related to the reliability of the Bulk-Power System.  The conference included discussion on NERC’s 2016 State of Reliability Report, international perspectives in dealing with renewable energy and their potential effects on reliability, and the ongoing effort to secure and maintain grid security.  The presentations from each conference panel have been posted for public interest.

FERC Accepts Aliso Canyon Proposal from CAISO; Sets Technical Conference - June 1 -  FERC issued an order accepting revisions to the California Independent System Operator’s (CAISO’s) tariff to address limitations in the natural gas delivery system in southern California. The revisions (which will expire on November 30, 2016) allow for better recognition of bids that reflect gas system limitations which could adversely impact the reliability of CAISO's electric grid and marketing options during summer 2016. FERC recognized the unique set of circumstances that CAISO will face this summer due to the limited operability of the Aliso Canyon natural gas storage facility following a gas leak that depleted the facility. The order also directs Commission staff to convene a technical conference to discuss the efficacy of the measures accepted in this order, and the need for additional longer-term measures. 

Peak Reliability Requests Clarification on Information Sharing - May 26 - Peak Reliability (Peak) submitted to FERC a request for clarification on Order No. 787 addressing communication of operational information between natural gas pipelines and electric transmission operators.  Peak seeks clarification to ensure that a Reliability Coordinator that is not a Transmission Operator is not prohibited from obtaining non-public information.  In its filing, Peak indicated that having access to the operational information would allow it to better evaluate options to ensure reliability.


NERC Submits 2015 Report of Budgeted to Actual Costs - May 31 - NERC submitted its Report of Comparisons of Budgeted to Actual Costs for 2015.  In 2015, NERC was $1.8 million (3%) over budget excluding expenses related to the Cyber Risk Information Sharing Program (CRISP).  The primary reasons for NERC going over budget included consulting support for assessment studies related to EPA's Clean Power Plan, contract costs for multiple reliability tools, leasehold improvements in the Atlanta, GA and Washington, D.C. offices, software costs, and executive and employee compensation studies.  The filing also includes budgeted to actual costs reports for NERC's Regional Entities and Peak Reliability. 

NERC Submits Petition for Approval of Proposed Reliability Standards - May 26 - NERC submitted to FERC a petition for approval of proposed Reliability Standards IRO-018-1 (Reliability Coordinator Real-time Reliability Monitoring and Analysis Capabilities) and TOP-010-1 (Real-time Reliability Monitoring and Analysis Capabilities).  The proposed standards address the need for improvement of real-time situational awareness capabilities requiring Reliability Coordinators, Transmission Operators, and Balancing Authorities to provide operators with monitoring and analysis capabilities.

Report Highlights Potential Reliability Risks Due to Increased Gas Dependence - May 24 - NERC released a report titled "Short-Term Special Assessment: Operational Risk Assessment with High Penetration of Natural Gas-Fired Generation."  The report addresses the increasing dependence on natural gas for electricity generation and the reliability risks that this dependence poses to the bulk system. Also included in the report are recommendations for managing the potential impacts of reliance on a single, just-in-time fuel source like natural gas, such as planning for extreme weather events, ensuring resource adequacy for generator outages, and maintaining coordination between electric and natural gas operators.

NERC Submits Comments on SGIA NOPR - May 23 - NERC submitted comments in response to a FERC Notice of Proposed Rulemaking to revise the pro forma Small Generator Interconnection Agreement (SGIA), which would require small generating facilities to ride through abnormal frequency and voltage events and not disconnect during such events.  NERC contends that technological developments now permit small generators to maintain ride through capability, and as such should be subject to the same ride through requirements that large generators are subject to under the Large Generator Interconnection Agreement (LGIA).  NERC also stated that the proposed revisions to the SGIA are consistent with NERC reliability assessments. 

Cybersecurity and Grid Security

NRC Rejects Plan to Require Power Plants to Install Programmable Logic Computers - May 25 - The Nuclear Regulatory Commission (NRC) denied a petition for rulemaking in which the petitioner had requested that the NRC require the petitioner's "new-design programmable logic computers" be installed in the control systems of nuclear power plants. The programmable logic computer is designed to block malware attacks on the industrial control systems of those facilities. The petitioner also requested that nuclear power plant staff be trained for use of these computers. The NRC denied the petition because the petitioner did not present any significant new information or arguments that would request the changes or demonstrate that a need for the change exists. 


The Van Ness Feldman Electric Reliability Update is published by Malcolm McLellan, Ilan Gutherz, Van Smith, Gabe Tabak, Darsh Singh, Tyler Elliott, and Michael WeinerVan Ness Feldman counsels, advises and trains a wide range of clients on reliability matters.  Please email us or call us at 206.829.1814 or 202.298.1800 for additional information.  Click here to sign up for the Reliability Update. 

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