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Electric Reliability Update - March 17, 2017: FERC Approves Retirement of WECC Regional Standard on System Operating Limits; FERC Approves Amendments to FRCC Regional Reliability Manual

FERC

FERC Approves Retirement of WECC Regional Standard on System Operating Limits - March 10 - FERC approved a joint petition of NERC and the Western Electricity Coordination Council (WECC) to retire regional Reliability Standard TOP-007-WECC-1a (System Operating Limits).  The retirement would shift away from the path-centric model and allow entities in the Western Interconnection to align their operating practices with framework established in the continent-wide TOP/IRO Reliability Standards approved in Order No. 817.

FERC Requests Data in Response to Proposed Standard Revisions - March 7 - FERC issued a data request  to NERC relating to its petition for approval of revised Reliability Standards BAL-005-1 (Balancing Authority Control) and FAC-001-3 (Facility Interconnection Requirements), which FERC has proposed to approve.  The data request asks NERC about the current practices of a representative sample of entities potentially affected by the proposed revisions to the Reliability Standards.  Specifically, FERC is seeking the following additional information about balancing authorities, reliability coordinators, and transmission operators:

  1. “Does the identified entity have backup power supplies at its primary control center(s), its backup control center(s) and other critical locations? Briefly describe what types of backup power supplies are in each location, how long these supplies will provide power, what level of service the backup power supplies support, and how the entity has determined what locations warrant backup power supplies and the performance requirements for those supplies”.

  2. “For each location identified above, how often and when were backup power supplies tested, including testing of switchover (i.e., from primary power supply to backup power supply), during 2016? What are the procedures for testing, and how are the tests documented”?

FERC Approves Amendments to FRCC Regional Reliability Manual - March 3 - FERC issued a letter order approving amendments to the Florida Reliability Coordinating Council’s (FRCC) Regional Reliability Standard Development Process Manual (SDPM). The changes, filed by NERC on FRCC’s behalf, comprehensively revise the SDPM, clarifying the standards development process and making the SDPM consistent with those of NERC and other regional entities.

NERC

NERC and WECC Seek Approval of Proposed Regional Reliability Standard on Power System Stabilizers - March 10 - NERC and WECC submitted a joint petition to FERC seeking approval of proposed regional Reliability Standard VAR-501-WECC-3 (Power System Stabilizers).  The proposed Standard  will help ensure the Western Interconnection operates in a coordinated manor under normal and abnormal conditions by establishing performance criteria for power system stabilizers, and would require WECC Generator Owners and Operators to:  (1) provide Transmission Operators with procedures or other documents that inform the Transmission Operator of when a power system stabilizer will be out of service; (2) have the power system stabilizer in service at all times except during specific circumstances; (3) tune power system stabilizers to stated criteria; (4) install and complete start-up testing of a power system stabilizer; and (5) repair or replace a power system stabilizer within a specified time period.

NERC Signs Memorandum of Understanding With Mexican Reliability Regulators - March 8 - Mexico’s Comisión Reguladora de Energía (CRE) and the Centro Nacional de Control de Energía (CENACE) signed a memorandum of understanding (MOU) with NERC that establishes a  collaboration mechanism between the Parties to strengthen their respective regulatory and technical capacities.  The MOU identifies as initial topics of collaboration the identification and assessment of risks related to critical infrastructure protection and cyber and physical security; the assessment of reliability performance and risks; the development of practices, tools and techniques for analysis of system events and management of reliability risks identified as a result of system events; and strengthening technical and regulatory capacities. 

NERC Seeks Approval of Proposed Reliability Standards on Transmission Monitoring and Data Exchange - March 6 - NERC filed with FERC a petition for approval of proposed reliability standards IRO-002-5 (Reliability Coordination – Monitoring and Analysis) and TOP-001-4 (Transmission Operations)The proposed standards would require Transmission Operators to monitor non-Bulk Electric System facilities for potential System Operating Limit exceedances, would direct Transmission Operators and Balancing Authorities to have redundant and diversely routed real-time data exchange capabilities within the entity’s primary control center, and would require those data exchange capabilities to be tested on a regular basis.

NERC Files Amendments to Texas Reliability Entity Bylaws and Standard Development Process - March 6 - NERC filed with FERC a petition seeking to amend the Texas Reliability Entity Inc.’s (Texas RE) bylaws and Standard Development Process (SDP).  The proposed changes would restructure the Texas RE’s committee structure for administrative efficiency and to ensure balanced representation on the compensation committee, and would reflect these changes (as well as clarifications and updated language) in the SDP.

NERC Submits Informational Filing on TRE's Primary Frequency Response Reference Document - March 6 - NERC submitted to FERC an informational filing providing revisions to Texas Reliability Entity, Inc.'s (TRE) Primary Frequency Response Reference Document (Document) included in regional Reliability Standard BAL-001-TRE-1 (Primary Frequency Response in the ERCOT Region).  The Document provides the methodology for determining the Primary Frequency Response performance for individual resources.  NERC's revisions reflect proposed amendments to the TRE Bylaws and the TRE Standards Development Process that eliminate the TRE Reliability Standards Committee and transfer its duties to the TRE Member Representatives Committee.

NERC Seeks Approval of Cybersecurity Management Controls Standard - March 3 - NERC filed with FERC a petition for approval of proposed reliability standard CIP-003-7 (Cybersecurity Management Controls).  The proposed standard would address certain FERC directives in Order No. 822, issued in 2016, by clarifying electronic access control requirements for low impact Bulk Electric System Cyber Systems, adding requirements for protection of transient electronic devices (such as flash drives) used on these systems, and requiring entities subject to the standard to maintain a documented cyber security policy for declaring and responding to CIP Exceptional Circumstances for these systems.

NERC Reliability Standards to become Effective April 1st  - The following standards become enforceable on April 1st, 2017, unless otherwise noted:

  • Emergency Preparedness and Operations (EOP): EOP-004-3 (Event Reporting); EOP-011-1 (Emergency Operations)

  • Facilities Design, Connections, and Maintenance (FAC): FAC-010-3 (System Operating Limits Methodology for the Planning Horizon);  FAC-011-3 (System Operating Limits Methodology for the Planning Horizon)

  • Interconnection Reliability Operations and Coordination (IRO): IRO-001-4 (Reliability Coordination - Responsibilities); IRO-002-4 (Reliability Coordination - Monitoring and Analysis); IRO-008-2 (Reliability Coordinator Operational Analyses and Real-Time Assessments); IRO-014-3 (Coordination Among Reliability Coordinators); IRO-017-1 (Outage Coordination)

  • Modeling, Data, and Analysis (MOD): MOD-029-2a (Rated System Path Methodology); MOD-030-3 (Flowgate Methodology)

  • Protection and Control (PRC): PRC-004-5(i) (Protection System Misoperation Identification and Correction)(April 2, 2017 effective date); PRC-004-WECC-2 (Protection System and Remedial Action Scheme Misoperation); PRC-010-1 (Undervoltage Load Shedding) and PRC-010-2 (April 2 effective date); PRC-015-1 (Remedial Action Scheme Data and Documentation); PRC-016-1 (Remedial Action Scheme Misoperations); PRC-017-1 (Remedial Action Scheme Maintenance and Testing); PRC-023-4 (Transmission Relay Loadability);

  • Transmission Operations (TOP): TOP-001-3 (Transmission Operations); TOP-002-4 (Operations Planning).

Cybersecurity and Grid Security

Cyber Resilient Energy Delivery Consortium to Hold Industry Workshop - February 27 - Funded by the Department of Energy’s Office of Electricity Delivery and Energy Reliability and the Department of Homeland Security's Science and Technology Directorate, the Cyber Resilient Energy Delivery Consortium (CREDC) is hosting its Industry Workshop focused on research on cybersecurity and cyber-resiliency for the electric power and oil and gas industries.  The Workshop, taking place in Tempe, AZ on March 27-29, 2017, will highlight current and future research opportunities and allow participants to engage with CREDC researchers.

Congress

House and Senate Introduce State Cyber Resiliency Act - March 2 - Senator Mark Warner (D-VA) and Representative Derek Kilmer (D-WA) introduced the State Cyber Resiliency Act in the United States Senate and House of Representatives respectively.  The Act would establish a State Cyber Resiliency Grant Program (Program) to assist State, local and tribal governments in preparing for and responding to cyber threats.  Under the Program, States would submit Cyber Resiliency Plans that meet certain criteria to enhance preparation, response, and communication against cybersecurity threats.  The Act has been referred to the Senate Committee on Homeland Security and Governmental Affairs and the House Committee on Transportation and Infrastructure. 

© 2017 Van Ness Feldman LLP

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Malcolm C. McLellan, Electric Energy and Regulated Business Attorney, Van Ness Feldman, Seattle Law Firm
Partner

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;...

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Suzanne McBride, Van Ness Feldman Law Firm, Energy and Gas Attorney
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Suzanne McBride 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.

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Darshana Singh, Energy Regulatory Law Clerk, Van Ness Feldman, D.C. Law firm
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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. 

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