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Electric Reliability Update - July 28, 2017: NERC Submits Remote Access Study Report; NERC Submits Information Filing on Light; NERC Penalty Activity


NERC Submits Remote Access Study Report - June 30 – NERC submitted to FERC a Remote Access Study Report, assessing three areas: (1) the effectiveness of the controls in the CIP Reliability Standards to mitigate known remote access vulnerabilities; (2) the risks posed by remote access-related threats and vulnerabilities; and (3) appropriate mitigating controls for any identified risks. In Order No. 882, issued by the FERC in 2016, the Commission had directed NERC to perform a study on the remote access protections required by the NERC’s Critical Infrastructure Protection (CIP) Reliability Standards.

NERC Submits Information Filing on Light-Load Case Study - June 30 - NERC submitted to FERC an informational filing, finding that the Eastern Interconnection is resilient to large losses of generation resources and that the Interconnection Frequency Response Obligation is adequate during light load conditions.  In the report, NERC recommends continuing to improve the data quality of models and creating a yearly light load dynamics case study with actual governor data.  The filing was in response to a FERC order approving Reliability Standard BAL-003-1 (Frequency Response and Frequency Bias Setting) and directing NERC to submit results of the Eastern Interconnection Reliability Assessment Group’s light-load case study, using actual turbine governor response data. 

NERC Penalty Activity - June 29 - NERC filed with FERC a spreadsheet notice of penalty resolving 3 violations of 3 Reliability Standards totaling $254,000 in penalties.

Other Developments

Draft of DOE Grid Study Finds Renewables not a Threat to Reliability - July 14 – A leaked draft of the Department of Energy’s Electric Power System, Markets and Reliability Study shows that the increase in renewable energy, such as wind and solar power, has not harmed the reliability of the US electricity grid.  The draft reports that, "Costly environmental regulations and subsidized renewable generation have exacerbated baseload power plant retirements.  However, those factors played minor roles compared to the longstanding drop in electricity demand relative to previous expectations and years of low electric prices driven by high natural gas availability."  The final report has yet to be released.

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About this Author

Malcolm C. McLellan, Van Ness Feldman Law Firm, Seattle, Cybersecurity and Energy Law Attorney

Malcolm’s practice focuses on the generation, transmission, and distribution of electric energy and regulated businesses. Malcolm has an intricate knowledge of the technical, legal, and business considerations facing electric utilities.  He regularly advises on Open Access Transmission Tariff and business practice compliance issues, reliability standards, standards of conduct, market behavior rules, interlocking director rules, electronic quarterly reporting, and accounting rules. He has significant experience with developing comprehensive energy compliance programs;...

Suzanne Keppeler, Van Ness Feldman Law Firm, Energy and Gas Attorney
Of Counsel

Suzanne Keppeler focuses her practice on the representation of electric and natural gas utilities and oil pipeline companies on a wide range of regulatory matters before the Federal Energy Regulatory Commission (FERC) and U.S. Courts of Appeal. She counsels various clients on rate development, contract and tariff provisions, regulatory compliance and investigation defense, administrative litigation, and transactional matters. She also advises on compliance with North American Electric Reliability Corporation (NERC) and regional reliability standards, including self-reports, spot checks, formal audits and enforcement actions involving NERC and FERC’s Office of Enforcement.

Darshana Singh, Van Ness Feldman Law Firm, Washington DC, Cybersecurity and Energy Law Attorney

Darsh Singh assists clients and firm professionals in the energy regulatory arena. Prior to joining Van Ness Feldman, Darsh served as a law clerk in the Office of Administrative Litigation at the Federal Energy Regulatory Commission (FERC) and interned at the Federal Trade Commission (FTC).   While at FERC, Darsh assisted Trial Staff in natural gas and oil pipeline rate proceedings and conducted research on market-based rates.   During her time at the FTC, Darsh focused on complex antitrust and consumer protection issues. 

While at The George...