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Electric Reliability Update - March 12, 2015

March 12, 2015


FERC Approves Standard PRC-006-2 - March 4 - FERC issued a letter order approving Reliability Standard PRC-006-2 (Automatic Underfrequency Load Shedding), which establishes design and documentation requirements for automatic underfrequency load shedding (UFLS) programs.  The Standard revises PRC-006-1, which will be retired, to clarify that subject entities are required to implement corrective actions identified by the planning coordinator.

FERC Approves Two Regional Reliability Standards - March 3 - FERC approved revisions to two WECC regional reliability standards.  NERC and WECC submitted a joint petition for approval for revisions to two previously approved regional reliability standards - VAR-002-WECC-2 (Automatic Voltage Regulators) and VAR-501-WECC-2 (Power System Stabilizer).  The revisions arose out of NERC's "P 81 Project," which was a response to paragraph 81 of FERC's order conditionally accepting NERC's Find, Fix, Track, and Report program.  The revisions remove requirement R2 from each of these regional reliability standards.

NERC President Comments on FERC Clean Power Plan Technical Conference - February 19 - NERC President and CEO Gerry Cauley presented remarks on behalf of NERC at FERC’s Technical Conference on EPA’s Clean Power Plan.  Cauley presented an overview of NERC’s Initial Reliability Review of the Clean Power Plan and key findings, as well as an outline of NERC’s recommendations.


NERC Files Supplemental Comments on COM Standards NOPR - March 6 - NERC filed with FERC supplemental comments on a notice of proposed rulemaking addressing two communications capabilities (COM) standards.  The supplemental comments specifically focus on the relationship between the COM standards and newly-developed Transmission Operation (TOP) and Interconnection Reliability Operation (IRO) standards, certain aspects of which affect the previously-submitted COM standards. 

NERC Requests Revisions to its Working Capital and Operating Reserve Policy - March 6 - NERC filed a request for approval of Revisions to its Working Capital and Operating Reserve Policy with FERC.

NERC Releases Draft Regional Delegation Agreement - March 2 - NERC released for comment a draft pro forma regional delegation agreement ("RDA"), intended to replace existing agreements expiring in December 2015 between NERC and the eight Regional Entities.The proposed RDA provides numerous clarifications and updates, and comments are due to NERC by April 2.

NERC Submits Petition for Approval for Amendments to Bylaws of Texas Reliability Entity, Inc. - February 27 - NERC submitted a petition for approval of amendments to the bylaws of Texas Reliability Entity, Inc. ("TRE").  The proposed bylaw amendments address: (1) term limits, selection process, and stock restrictions for independent directors; (2) selection and approval of corporate officers; (3) term limits for members of the Member Representatives Committee; and (4) stylistic and grammatical issues in the previously approved bylaws.  Comments are due March 20, 2015.

NERC and WECC Reply to Dominion Comments on WECC VAR Standards Petition - February 26 - NERC and WECC filed a reply to Dominion Resources Services, Inc. (Dominion) comments on a NERC/WECC petition for approval of proposed regional reliability standards VAR-002-WECC-2 (Automatic Voltage Regulators) and VAR-501-WECC-2 (Power System Stabilizer).  Dominion's comments express concerns the proposed regional standards do not include a waiver or variance from the “equivalent” continent-wide standard or are not incorporated as specific requirements (applicable only within that region) into the continent-wide standard, and the proposed standards are not more stringent than the current continent-wide standard. The NERC/WECC reply disagrees with the Dominion comments, states that adhering to them would contradict FERC precedent, and provides examples of how the proposed regional standards are more stringent than the current continent-wide standard.

February Penalty Activity - February 26 - NERC filed with FERC two separately-docketed penalty proceedings totaling $130,000 in penalties, as well as a spreadsheet notice of penalty detailing 18 violations of 9 standards.

NERC Releases Updated 2015 Budget Timetable - February - NERC released an update to its 2015 Budget Timetable, which includes information on NERC, Regional Entities, and Related Stakeholder-NERC Committee Initiatives.  Key dates include the NERC and Regional Entity 2014 budget filing due date (May 29), Final Regional Entity 2016 budget submittal due date (July 6), and the posting date of all 2016 business plans, budgets, and assessments (August 4).


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