FERC Issues Letter Seeking Additional Information on Proposed Revisions to NERC ROP

On February 24, 2022, in Docket No. RR21-8-000, FERC issued a letter order seeking additional information regarding NERC’s August 18, 2021 proposal to revise Section 305.3.3 of the NERC Rules of Procedure (ROP). NERC proposes to revise sub-section 3.3 of section 305 (Registered Ballot Body), which governs the frequency in which NERC reviews the qualification guidelines and rules for industry members to join the 10 industry segments that vote on NERC Reliability Standards.  Instead of reviewing segment criteria at least every three years, NERC proposes to modify section 305.3.3 to require review of the guidelines and rules for joining segments “periodically.”  NERC states this revision was necessary to provide consistency with its guidelines in Appendix 3D of the NERC ROP. FERC’s letter states that the NERC’s filing is deficient and requests additional information, including information on why the change to “periodic” review is preferable, how NERC currently conducts its review, and the timeframe for review that NERC anticipates under its proposed ROP revisions.

To view FERC’s letter, click here.