ERL Blog

On January 25, 2012, in Docket No. RM12-6, NERC filed a petition for FERC Approval of a revised definition of “Bulk Electric System” in the NERC Glossary of Terms Used in Reliability Standards.  NERC also requested FERC approval in this proceeding of the proposed document entitled “Detailed Information to Support an Exception Request”, which will be used in the submittal, review, and approval or disapproval of requests for Exceptions from the application of the BES Definitions.  Finally, NERC requested FERC approval of its implementation plan for the revised BES Definition. To view NERC’s petition for the revised glossary term “Bulk Electric System”, click here.

In a separate but concurrent filing in Docket No. RM12-7, NERC filed for approval of revisions to its Rules of Procedure to Adopt a Bulk Electric System Exception Procedure, for the purposes of requesting and receiving requests for exceptions from the exclusions or inclusions created by the default application of the NERC definition of “Bulk Electric System”. To view NERC’s petition for revisions to its Rules of Procedure to create the “BES Exception Procedure”, click here.

On January 17, 2012, in Docket No. RD11-3, NERC submitted a compliance filing in response to FERC’s November 17, 2011 Order approving Reliability Standard FAC-013-2.  In the compliance filing, NERC submits proposed revisions to two VRFs and one VSL. To view NERC’s compliance filing, click here.

On January 17, 2011, in Docket No. RD11-10, NERC submitted a compliance filing in response to FERC’s November 17, 2011 order approving Reliability Standard FAC-008-3. In the compliance filing, NERC submits a revision to one VRF for Requirement R2 of FAC-008-3. To view NERC’s compliance filing, click here.

On January 11, 2012, in Docket No. RR12-1, FERC issued a letter order approving NERC’s proposed revisions to section 1.3 of Appendix 4D of the NERC  Rules of Procedure, which addressed the procedures for requesting and receiving Technical Feasibility Exceptions (TFEs).  On November 14, 2011, NERC submitted a petition requesting approval of a revision to Section 1.3.  The purpose was to correct an error in section 1.3, which contains the list of the Applicable Requirements for which a Responsible Entity may request a TFE.  Currently, section 1.3 of Appendix 4D lists the Interpretation in Appendix 3 to CIP-006-3c R1.1 as an Applicable Requirement, but the correct reference should be to “the Interpretation in Appendix 2” of CIP- 006-3c. To view the letter order, click here.

On January 11, 2012, in Docket Nos. RC11-1 and RC11-2, NERC filed answers in response to comments filed on December 23, 2011 regarding NERC’s December 2, 2011 compliance filing for Cedar Creek Wind Energy and Milford Wind Corridor Phase I.  In its comments, NERC states that it would be inappropriate to “disrupt the agreed upon resolution of two specific registration appeals which affect only the two registered entities named”, and states that FERC should disregard the comments and accept NERC’s compliance filing in its entirety. To view NERC’s filing, click here.

On January 6, 2012, in Docket Nos. RR09-7 and RR10-11, NERC submitted an informational filing, in response to paragraph 773 of Order No. 672, reporting that it had completed its initial Audit activities of the eight Regional Entities in 2011.  NERC also noted that it had concluded the first round of Key Reliability Standard Spot Checks (KRSSC) of the Regional Entities regarding PRC-005, and had posted a public report on September 14, 2011.  

NERC has also initiated the second round of KRSSC’s regarding EOP-005. In a previous informational filing submitted on December 23, 2010, NERC had targeted December 31, 2011 as the date to finalize the restructured Audit program.  However, NERC now has determined that such efforts should be finalized following the conclusion of FERC’s financial audit of NERC now underway in Docket No. FA11-21.  On December 23, 2010, NERC had submitted a previous informational filing in response to Paragraph 773 of Order No. 672, regarding the initial Three Year Regional Entity Audits and plans for Future Audits.  To view this informational filing, click here.

On December 23, 2011, in Docket No. RM11-20, NERC submitted comments in response to FERC’s October 20, 2011 Notice of Proposed Rulemaking regarding Automatic Underfrequency Load Shedding  (UFLS) and Load Shedding Plans Reliability Standards. To view NERC’s comments, click here.

On December 21, 2011, NERC submitted a petition for FERC approval of Reliability Standard FAC-003-2 (Transmission Vegetation Management) and the associated implementation plan, Violations Risk Factors (VRFs) and Violation Severity Levels (VSLs). In addition, NERC sought approval of proposed definitions for the following terms to be added to the NERC glossary: “Right-of-Way”, “Vegetation Inspection”, and “Minimum Vegetation Clearance Distance (‘MVCD’)”. Accordingly, NERC concurrently sought approval of the retirement of Reliability Standard FAC-003-1 and the currently effective definitions for “Right-of-Way” and Vegetation Inspection”.  To view NERC’s petition, click here.

On December 21, 2011, in Docket No. RM11-18, NERC submitted comments in response to FERC’s October 20 NOPR on Table 1, footnote b within four TPL Standards – TPl-001-1, TPL-002-1b, TPL-003-1a, and TPL-004-1 – regarding planned or controlled interruption of electric supply where a single contingency occurs on a transmission system . Although footnote b appears in all four of the aforementioned standards, NERC states that its relevance and practical applicability is limited to TPL-002-1b.  To view NERC’s comments, click here.

On December 15, 2011, in Docket No. RD11-12, FERC issued an order approving NERC’s September 9, 2011 petition for approval of an interpretation of Requirements R1 and R3.2 of Reliability Standards EOP-00-1-0 (Emergency Operations Planning).  Requirement R1 requires balancing authorities to have operating agreements with provisions for emergency assistance, including provisions to facilitate emergency assistance from remote balancing authorities, with adjacent balancing authorities.  Requirement R3.2 requires each transmission operator and balancing authority to develop, maintain, and implement a set of plans to mitigate operating emergencies on the transmission system. To view FERC's order, click here.

On December 13, 2011, in Docket Nos. RM05-17, RM05-25 and RM06-16, NERC filed its Reliability Standards Development Plan for 2012-2014 pursuant to Section 310 of the NERC Rules of Procedure.  To see the plan, click here.

On December 5, 2011, in Docket No. RM11-11 NERC filed reply comments on FERC's September 15, 2011 NOPR proposal for approving the CIP Version 4 Reliability Standards submitted by NERC on February 10, 2011.  To see the reply comments, click here.

On December 1, 2011, in Docket No. IN11-6, FERC approved a stipulation and consent agreement between FERC’s Office of Enforcement, NERC, and PacifiCorp as a result of a joint investigation by FERC and NERC into the possible violations of NERC reliability Stdnards by PacifiCorp related to its functions as a Balancing Authority and Transmission Operator surrounding a disturbance that originated in Utah on February 14, 2008. In addition to a set of Reliability Enhancement Measures and semi-annual compliance reports to FERC and NERC staff for up to two years, the agreement also stipulates to a penalty of $3,925,000, to be allocated equally between the U.S. Treasury and NERC. To view the order and attached agreement, click here.

On October 7, 2011, FERC issued a notice in Docket No. AD12-1-000 regarding the technical conference to be held on November 29 and 30, 2011, to discuss policy issues related to reliability of the BPS. The November Technical Conference will explore the progress made on the priorities for addressing reliability risks that were identified in earlier Commission technical conferences. The November Technical Conference also will discuss emerging issues, including processes used by planning authorities and other entities to identify reliability concerns that might arise in the course of compliance with EPA regulations and the tools and processes (including tariffs and market rules) available to address any identified reliability concerns. To read the Commission’s October 7 notice, click here.

On November 9, 2011, in Docket Nos. AD12-1, RC11-6, and EL11-62, FERC issued a second notice that detailed the agenda and panelists for the technical conference. To view the second notice, click here.  A revised agenda was issued on November 22, 2011.  To view the revised agenda, click here.

On November 14, 2011, in Docket Nos. AD12-1, RC11-6, EL11-62, Commissioner Moeller issued a Request for Evidence on EPA Issues for the technical conference, that set out 22 questions (or in some cases sets of questions) regarding the impact of EPA regulations on reliability. To view Commissioner Moeller's request for evidence, click here.

On November 17, 2011, in Docket No. AD12-1, Commissioner Moeller issued a Statement regarding his previous Request for Evidence, details his motivations behind issuing his previous request and circulating his thoughts on the topic in advance of the November 29-30 technical conference. To view Commissioner Moeller's statement, click here.

Written testimony and statements of the panelists, to the extent available, are listed below:

Panel I: Identifying Priorities for NERC Activities (Nov. 29, 1:25pm)

To view the statement of Gerry Cauley (NERC), click here.

To view the statement of Kevin Burke (Consolidated Edison and EEI), click here.

To view the statement of Mike Smith (Georgia Transmission Corp. and NRECA), click here.

To view the statement of John A. Anderson (ELCON), click here.

To view the statement of Allen Mosher (APPA and NERC Standards Committee), click here.

To view the supplemental statement of Allen Mosher, click here. 

To view the statement of Deborah Le Vine (CAISO), click here.

To view the statement of William J. Gallagher (Vermont Public Power Supply Authority and NERC MRC), click here.

To view the statement of Peter Fraser (Ontario Energy Board), click here.  

Panel II: Incorporating Lessons Learned into a More Reliable Grid (Nov. 29, 3:30pm) 

To view the statement of Gerry Cauley (NERC), click here.

To view the statement of Thomas J. Galloway (North American Transmission Forum), click here.

To view the statement of Tom Burgess (FirstEnergy and EEI), click here.

To view the statement of Scott Helyer (Tenaska and EPSA), click here.

To view the statement of Mary Kipp (El Paso Electric), click here.

 

Panel III: Presentations and Discussion on the Current State of Processes for Identifying Unit-Specific Local or Regional reliability Issues in Response to Final EPA Regulations (Nov. 30, 9:40am)

 

To view the preliminary statement of Regina McCarthy (EPA), click here.

To view the statement of Mark Lauby (NERC), click here.

To view the statement of Michael Kormos (PJM Interconnection), click here.

To view the statement of Carl Monroe (SPP), click here.

To view the statement of Thomas F. Farrell II (Dominion and EEI), click here.

To view the statement of Kathleen Barrón (Exelon), click here.

To view the statement of Anthony Topazi (Southern Company), click here.

To view the statement of David Wright (South Carolina Public Service Commission), click here.

To view the comments and supplemental materials of Joshua Epel (Colorado Public Utilities Commission), click here.

 

Panel IV: Discussion on Multi-Jurisdictional Processes (Nov. 30, 2:30pm)

To view the statement of Patricia A. Hoffman (DOE), click here.

To view the statement of Gerry Cauley (NERC), click here.

To view the statement of Nick Akins (AEP), click here.

To view the statement of Clair J. Moeller (MISO), click here.

To view the statement of Betty Ann Kane (DC Public Service Commission), click here.

To view the statement of Cheryl Roberto (Ohio Public Utilities Commission), click here.

To view the statement of Eric Baker (Wolverine Electric Power Cooperative), click here.

To view the statement of Debra Raggio (GenOn), click here.

On November 17, 2011, in Docket No. RD11-10, FERC issued an order approving Reliability Standard FAC-008-3 (Facility Ratings).  NERC had submitted FAC-008-3 for approval on June 15, 2011. FERC also requested comments on October 13, 2011, of a proposed collection of information that FERC was developing for submission to the Office of Management Budget (OMB) pursuant to the Paperwork Reduction Act of 1995. 

In this November 17 order, FERC also approved the associated Violation Risk Factors (VRFs) and Violation Severity Levels (VSLs), although FERC directed NERC to modify the VRF for FAC-008-3 Requirement R2 to “medium”.  This Reliability Standard replaces both FAC-008-1 (Facility Ratings Methodology) and FAC-009-1 (Establish and Communicate Facility Ratings) to combine them into a single standard, and therefore those standards will be retired.  To view FERC’s order, click here.

On November 17, 2011, in Docket No. RD11-3, FERC issued an Order approving NERC’s January 28, 2011 petition for approval of Reliability Standard FAC-013-2 (Assessment of Transfer Capability for the Near-term Transmission Planning Horizon). To view FERC’s Order, click here.

On October 27, 2011, in Docket No. PL10-4, FERC issued a second notice on its November 17, 2011 technical conference on the revised penalty guidelines and their impact on compliance and enforcement, thus supplementing the original notice issued on September 21, 2011. This second notice gives more detail as to the scheduled agenda and the topics addressed by the two panels of speakers.  FERC will accept comments related to the Penalty Guidelines and their application for thirty days after the conference. To view FERC’s second notice, click here.

On November 15, 2011, in Docket No. RR11-2, FERC issued a letter order accepting NERC’s May 25, 2011 petition requesting approval of: (1) an agreement between Northwest Power Coordinating Council (NPCC) and Western Electricity Coordinating Council (WECC) regarding compliance monitoring and enforcement (CMEP) of WECC registered functions; (2) an agreement between NERC and WECC regarding termination of NERC’s existing CMEP role regarding WECC registered functions; and (3) related amendments to delegation agreements between NERC and NPCC, and NERC and WECC.  The purpose of the petition, states the FERC letter order, is “to provide for NPCC to assume responsibility for performing Regional Entity [CMEP] functions for which WECC is the registered entity within the US portion of the WECC region.”  Currently, NERC acts as the Compliance Enforcement Authority for WECC registered functions in the US portion of the WECC region. The effective date is January 1, 2012.  To view FERC’s letter order, click here. 

On November 7, 2011, in Docket No. RR10-11, NERC made a compliance filing in response to FERC’s October 7, 2011 order conditionally accepting NERC’s proposal to amend the NERC Rules of Procedure but rejecting NERC’s proposed deletion of Section 402.1.3.2 from the Rules of Procedure.  To see the compliance filing, click here.

 

On Wednesday and Thursday, November 2-3, 2011, Board of Trustees (BOT), the NERC Member Representatives Committee (MRC), Standards Oversight and Technology Committee (SOTC), and Board of Trustees Compliance Committee (BOTCC) will meet in Atlanta, GA:

To view the BOT Agenda, click here.

To view the BOT Presentations, click here.

To view the BOT Policy Input, click here.

 

To view the MRC Agenda, click here.

To view the MRC Presentations, click here.

 

To view the SOTC Agenda, click here.

To view the SOTC Presentations, click here.

 

To view the BOTCC Agenda, click here.

To view the BOTCC Presentations, click here.

On October 31, 2011, NERC submitted its second spreadsheet of FFT violations (the first of which was submitted on September 30, 2011).  To view NERC’s October FFT Spreadsheet, click here.

On October 31, 2011, NERC submitted its second Spreadsheet NOP filing (the first of which was submitted on September 30, 2011, and accepted by FERC on October 28, 2011). 

On October 28, 2011, in Docket Nos. NP11-267 through NP11-270, FERC issued a notice of no further review of NERC's first Spreadsheet Notice of Penalty filing, which was submitted on September 30, 2011.  To see the notice, click here.

On October 20, 2011, in Docket No. RM11-20, FERC issued a NOPR proposing to approve Reliability Standards PRC-006-1 (Automatic Underfrequency Load Shedding) and EOP-003-2 (Load Shedding Plans). The proposed Reliability Standards establish design and documentation requirements for automatic underfrequency load shedding programs that arrest declining frequency and assist recovery of frequency following system events leading to frequency degradation. The Commission also proposes to approve the related VRFs and VSLs, implementation plan, and effective date proposed by NERC.  Comments on the NOPR are due 60 days after publication in the Federal Register.  To view a copy of the NOPR, click here. 

On June 29, 2011, FERC issued a letter order approving the complete sets of Violation Risk Factors (VRFs) and Violation Severity Levels (VSLs) to the Version 2 and Version 3 Critical Infrastructure Protection (CIP) Standards. To view the Commission’s letter order, click here.

On October 20, 2011, in Docket No. RD11-9, FERC issued an order approving NERC's interpretation of Requirement R10 of Reliability Standard TOP-002-2a (Normal Operations Planning) and changed the reference of the Reliability Standard including this interpretation to "TOP-002-2b."  Requirement R10 addresses the planning required to meet all System Operating Limits and Interconnection Reliability Operating Limits.  To view a copy of FERC's order, click here. 

On October 20, in Docket No. RD11-8, FERC issued an order approving the Northeast Power Coordinating Council's (NPCC) Protection and Control (PRC) regional Reliability Standard PRC-002-NPCC-01 (Disturbance Monitoring) and two associated new definitions submitted for approval by NERC on May 31, 2011.  The regional Reliability Standard requires transmission owners and generator owners to provide recording capability necessary to monitor the response of the Bulk-Power System to system disturbances, including scheduled and unscheduled outages; requires each reliability coordinator to establish requirements for its area’s dynamic disturbance recording needs; and establishes disturbance data reporting requirements.  To view a copy of this order, click here. 

On October 20, 2011, in Docket No. RM11-18, FERC issued a Notice of Proposed Rulemaking regarding Table 1, footnote b to four Reliability Standards – TPL-001-1, TPL-002-1b, TPL-003-1a, and TPL-004-1 -- regarding planned or controlled interruption of electric supply where a single contingency occurs on a transmission system.  To view FERC’s NOPR, click here.

On October 19, 2011, in Docket No. RM __-__-___, NERC submitted a petition for approval of a Revised TPL-001 Standard (Transmission System Planning Performance Requirements), as well as several definitions regarding load loss and transmission planning. Accordingly, it also sought FERC approval to retire standards TPL-001-1, TPL-002-1b, TPL-003-1a, and TPL-004-1, which address system performance under conditions ranging from Normal (Category A) to Following Extreme Events Resulting in the Loss of Two or More Bulk Electric System Elements (Category D).  Finally, NERC sought to withdraw pending standards TPL-005 (Regional and Interregional Self-Assessment Reliability Reports) and TPL-006-0.1 (Data From the Regional Reliability Organization Needed to Assess Reliability).  To view NERC’s petition, click here. 

On October 17, 2011, in Docket No. RR11-3, FERC issued a letter order approving proposed amendments to the NERC-NPCC Delegation Agreement, specifically to the NPCC Bylaws and to the Regional Reliability Standards Development Procedure.  The amendments to the NPCC Bylaws: (1) establish a hybrid Board of Directors comprised of stakeholder directors and independent directors; (2) reduce the total number of stakeholder directors; (3) combine two existing stakeholder membership sectors to reduce the number of sectors; (4) establish procedures for electing stakeholder directors and independent directors; and (5) revise the composition of the NPCC Hearing Body for compliance matters. The amendments to the Regional Reliability Standards Development Procedure are conforming changes due to the proposed amendments to the Bylaws.  To view FERC’s letter order, click here.

On October 13, 2011, in Docket No. RR11-4, FERC approved NERC’s May 31, 2011 filing that compared budgeted costs to actual costs for the 2010 fiscal year.  NERC’s filing had submitted comparisons between budgeted and actualized expenditures, audited financial statements, and metrics concerning administrative costs for itself and all of the Regional Entities.  To view the letter order, click here. 

On October 13, 2011, in Docket No. RD11-10, FERC issued a request for comment on a proposed collection of information that the Commission is developing for submission to the Office of Management and Budget pursuant to the Paperwork Reduction Act of 1995.  The proposed information collection in Docket No. RD11-10-000 relates to a proposed Reliability Standard, FAC-008-3 -- Facility Ratings, submitted by NERC for FERC approval.  Comments are invited on:

(a) whether the proposed information collection is necessary for the proper performance of FERC’s agency functions, including whether the information shall have practical utility

(b) the accuracy of FERC’s estimate of the burden of the proposed collection of information, including the validity of the methodology and assumptions used;

(c) ways to enhance the collected information’s quality, utility, and clarity; and

(d) ways to minimize the burden of collecting the information on respondents, including through the use of automated techniques or other forms of information technology To view the request for comment, click here. 

On October 7, 2011, in Docket No. RM10-6, FERC issued a Notice of a Staff meeting to be held on Monday, October 24th from 1-5pm EST and Tuesday, October 25th, from 8am-12noon EST.  The purpose of the staff meeting is to conduct a technical discussion to "discuss the reliability implications to the interconnected transmission system associated with a single point of failure on protection systems."

In Order No. 754, FERC approved NERC’s interpretation of Requirement R 1.3.10 of Reliability Standard TPL-002-0 (System Performance Following Loss of a Single Bulk Electric System Element).  In addition, FERC stated that it believes there is an issue concerning the study of a single point of failure on protection systems, and directed FERC staff to meet with NERC and appropriate subject matter experts to explore this concern, how it can best be addressed, and identify any additional actions necessary to address the matter. To view FERC’s Notice of Staff Meeting, click here.

On October 7, 2011, in Docket Nos. RR10-11, et al., FERC issued an order conditionally accepting  NERC’s Rules of Procedures, NERC’s Pro Forma Delegation Agreement, the Delegation Agreements between NERC and the eight Regional Entities, and the FRCC and MRO Bylaws. The Order conditionally accepted NERC’s February 18, 2011 compliance filing submitted in response to FERC’s October 21, 2010 order. To view FERC’s October 7 order, click here.

On October 7, 2011, FERC Chairman Jon Wellinghoff responded to questions posed in an October 4, 2011 letter from Senator Lisa Murkowski regarding the impacts of Environmental Protection Agency (EPA) regulations on electric reliability.  To view Chairman Wellinghoff’s response, click here.

On October 5, 2011, in Docket No. PA11-02, the FERC Division of Audits issued a letter order approving the final audit report of Southwest Power Pool’s (SPP) functions as a Regional Entity (RE).  FERC audit staff generally approved SPP’s implementation of its RE functions, but found five issues relating to SPP’s implementation of its Compliance Monitoring and Enforcement Program, and issued fourteen related recommendations.

To view the FERC Letter Order, click here.

To view the Final Audit Report, click here.

On October 4, 2011, NERC posted the proposed SERC Reliability Corporation (SERC) Regional Reliability Standards Development Procedure for a 45-day industry review.  The comment period ends November 18, 2011.  To see the posted SERC standards development procedures, click here.

On October 3, 2011, NERC submitted a Motion to Intervene and Comments in response to the September 2, 2011 appeal of NERC’s registration decision by the city of Holland, Michigan Board of Public Works. To view NERC’s Motion, click here. 

On September 30, 2011, in Docket No. NP11-270, NERC filed some NOPs in the new “spreadsheet NOP” format.  This was part of NERC’s concurrent filing of its streamlined compliance enforcement process, involving: (1) the traditional “full Notices of Penalty (NOPs)” for possible violations posing serious risk to reliability; (2) find, fix, track and report (“FFT”) spreadsheet filings for possible violations posing lesser risk to reliability; and (3) “spreadsheet NOPS” for violations whose moderate risk to reliability falls in between the risks posed for possible violations eligible for the previous two tracks. NERC requested that FERC take action on the Spreadsheet NOP format and the specific “spreadsheet NOP” violations themselves.  No further action has been taken.

To view NERC’s filing, click here.

To view NERC’s public spreadsheet NOP filing for non-CIP identified entities, click here.

To view NERC’s public spreadsheet NOP filing for Unidentified Registered Entities (UREs), click here.

On September 30, 2011, in Docket No. RC11-6, NERC requested approval of a new enforcement approach to differentiate possible violations according to the risks posed to the bulk power system (“BPS”).  Under NERC’s new compliance enforcement process, there are three “tracks” for dealing with possible violations: (1) the traditional “full Notices of Penalty (NOPs)” for possible violations posing serious risk to reliability; (2) find, fix, track and report (“FFT”) spreadsheet filings for possible violations posing lesser risk to reliability; and (3) “spreadsheet NOPS” for violations whose moderate risk to reliability falls in between the risks posed for possible violations eligible for the previous two tracks. NERC also filed its first spreadsheet of FFT violations.  NERC did not request that FERC act on the FFT informational spreadsheet filing itself, but rather only asked that FERC act on the overall approach being proposed.

To view NERC’s filing, click here.

To view NERC’s FFT spreadsheet filing, click here.

On September 28, 2011, in Docket No. RR10-1-001, NERC filed the first Annual Report on Wide-Area Analysis of Technical Feasibility Exceptions ("TFE") in compliance with paragraphs 220 and 221 of Order No. 706, FERC's January 21, 2010 Order Approving TFE Procedures and Ordering Compliance Filing, and Appendix 4D of the NERC Rules of Procedure.  In Order No. 706, NERC was directed to submit an annual report to FERC that provides a wide-area analysis regarding use of TFEs and the effect on Bulk-Power System reliability.  The first Annual Report covers the period from January 1, 2010 through June 30, 2011.  A copy of the report can be found here.

On September 26, 2011, in Docket No. RD11-5, FERC issued an order approving interpretations to Reliability Standards PRC-004-1 and PRC-005-1, which address maintenance, testing, and analysis of transmission and generation protection systems.  Specifically, NERC interprets “transmission Protection System,” as it appears in Requirements R1 and R3 of PRC-004-1 and Requirements R1 and R2 of PRC_005-1, to mean “any Protection system that is installed for the purpose of detecting faults on transmission elements (lines, buses, transformers, etc.). identified as being included in the Bulk Electric system and trips an interrupting device that interrupts current supplied directly from the BES.”

Therefore, regarding the question of whether a radially connected transformer would be considered part of a “transmission Protection System” NERC’s interpretation states that “[a] Protection System for a radially connected transformer energized from the BES would be considered a transmission Protection System and subject to these standards only if the protection trips an interrupting device that interrupts current supplied directly from the BES and the transformer is a BES element.” To view the Order approving NERC’s interpretation, click here.

On September 26, 2011, in Docket No. RD10-8, FERC issued a Notice of a Technical Conference on CIP-006-2, to take place on October 26, 2011, which will explore the risks of leaving dial-up intelligent electronic devices that are part of the Bulk-Power system and that use non-routable protocols physically unprotected.  FERC  is interested in: (1) information on the number of Bulk-Power System assets that are networked using non-routable protocols; (2) the proportion of those assets that are currently physically unprotected; (3) risks associated with leaving such assets physically unprotected; and (4) methods for mitigating such risks.  FERC states that the conference will also explore monitoring authorized personnel’s physical access both when entering and exiting a controlled access area.  To view the notice, click here. 

On September 21, 2011, FERC issued a notice in Docket No. PL10-4-000 stating that FERC Staff will hold a technical conference on November 17, 2011, to discuss the Commission’s Revised Penalty Guidelines issued on September 17, 2010.  The technical conference will be held from 1:00 p.m. to 4:30 p.m. (EST) in the Commission Meeting Room.  The purpose of the conference is to discuss the impact of the Revised Penalty Guidelines on compliance and enforcement matters.  The notice states that additional information regarding the topics to be explored and the number and composition of the panels will be provided in subsequent notices. To read the notice (as well as the errata notice correcting incorrect contact information contained in the first notice), click here.

On September 19, 2011, NERC released an analysis of how the electrical system performed during the Southwest cold-weather event during the first week of February, 2011, which resulted in rolling blackouts and natural-gas curtailments in the Southwest (Southwest Blackout Power-System Analysis). The Southwest Blackout Power-System Analysis follows on the August 16, 2011, report from the FERC and NERC joint task force assessing the electric and natural-gas impacts of the cold weather event on the Texas, Western and Eastern Interconnections. To view the Southwest Blackout Power-System Analysis, click here.

On September 19, 2011, in Docket No. NP11-238, NERC submitted additional comments in support of the Notice of Penalty filed on July 28, 2011 regarding Southwestern Power Administration. FERC initiated a review of NERC’s initial Notice of Penalty on August 29, 2011.  In its additional comments, NERC provides additional information in support of its argument that there are no policy reasons to treat federal entities any differently in terms of monetary penalties than other users, owners, and operators of the bulk power system.  To view NERC’s additional comments, click here.

On September 15, 2011, in Docket No. RD11-7, FERC issued an order granting NERC’s April 29, 2011 petition for approval of its proposed Personnel Performance, Training and Qualification Reliability Standard PER-003-1 (Operating Personnel Credentials), and retirement of PER-003-0.  To view FERC’s order, click here.

On September 15, 2011, in Docket No. RM11-11, FERC issued a Notice of Proposed Rulemaking (NOPR) which proposes to approve eight modified Critical Infrastructure Protection (CIP) Reliability Standards, CIP-002-4 through CIP-009-4.  FERC also proposed to approve the related Violation Risk Factors (VRFs) and Violation Severity Levels (VSLs) with modifications, the implementation plan, and proposed effective date. To view the NOPR, click here. 

 

On September 15, 2011, in Docket No. RM03-13-004, FERC issued Order No. 733-B, which denied reconsideration and granted clarification in part and denied clarification in part of Order No. 733-A (which addressed requests from rehearing and clarification of FERC's Final Rule on NERC's Relay Loadability Reliability Standard (PRC-023-1)).  On March 21, 2011, EEI and NRECA (jointly) and APPA and TAPS (jointly) filed motions requesting clarification or reconsideration of Order No. 733-A, asserting that FERC based its directives on a faulty understanding of the "Final Report on the August 14, 2003 Blackout in the United States and Canada: Causes and Recommendations" or an incorrect characterization of relay engineering.  In Order No. 733-B, FERC addressed (1) stable power swings, (2) due weight to the ERO, (3) scope of Commission directives, (4) expected relay performance, and (5) relays located at generators.  FERC rejected outright all arguments related to other topics.  To view Order No. 733-B, click here.